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SEC Petition Evaluation Report 

Petition SEC-00192 

Report Rev #:0 Report Submittal Date: September 5, 2012 

Subject Expert(s): Daniel Stempfley, James Bogard, Elizabeth Brackett, Paul Ruhter, Tosh Ushino, 

Brant Ulsh

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition

Receipt Date

Qualification 

Date

DOE/AWE Facility Name

SEC-00192 83.13 August 23, 2011 February 9, 2012 Rocky Flats Plant

Petitioner-Requested Class Definition 

All workers employed at Rocky Flats from April 1, 1952 to December 31, 2005.

Class Evaluated by NIOSH

All employees of the Department of Energy, its predecessor agencies, and their contractors and subcontractors 

with the potential for tritium exposures while working at the Rocky Flats Plant in Golden, Colorado, during the 

period from April 1, 1952 to December 31, 2005.

NIOSH-Proposed Class(es) to be Added to the SEC

None

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE Facility Name Petition Status

SEC-00030 83.13 Rocky Flats Plant Two classes added to the SEC:

- Apr. 1, 1952 through Dec. 31, 1958 

- Jan. 1, 1959 through Dec. 31, 1966

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name

SEC Petition Evaluation Report for Petition SEC-00030 Rocky Flats Plant

ORAU Lead Technical Evaluator: Daniel Stempfley ORAU Peer Review Completed By: Michael Kubiak

Peer Review Completed By: [Signature on File] 9/5/2012

LaVon B. Rutherford Date

[Signature on File] 9/5/2012 SEC Petition Evaluation Reviewed By:

J. W. Neton Date

[Signature on File] 9/5/2012 SEC Evaluation Approved By:

Stuart Hinnefeld Date
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Evaluation Report Summary: SEC-00192, Rocky Flats Plant 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C.

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000.

Petitioner-Requested Class Definition 

Petition SEC-00192 was received on August 23, 2011, and qualified on February 9, 2012. The 

petitioner requested that NIOSH consider the following class: All workers employed at Rocky Flats 

from April 1, 1952 to December 31, 2005. 

Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH accepted the petitioner-requested class. NIOSH evaluated 

the following class: All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors with the potential for tritium exposures while working at the Rocky 

Flats Plant in Golden, Colorado, during the period from April 1, 1952 to December 31, 2005. 

NIOSH-Proposed Class(es) to be Added to the SEC 

Based on its full research of the class under evaluation, NIOSH has obtained documentation and data 

for the worst-case tritium exposure scenario at RFP for any worker, working in any area, over the 

applicable time period under evaluation. Based on its analysis of these available resources, NIOSH 

found no part of the class under evaluation for which it cannot estimate radiation doses with sufficient 

accuracy. 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient 

information to: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred in plausible circumstances by any member of 

the class; or (2) estimate radiation doses of members of the class more precisely than an estimate of 

maximum dose. Information available from the site profile and additional resources is sufficient to 

document or estimate the maximum internal and external potential exposure to members of the 

evaluated class under plausible circumstances during the specified period. 

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is not required 

because NIOSH has determined that it has sufficient information to estimate dose for the members of 

the evaluated class. 
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Table of Contents 

1.0 Purpose and Scope .......................................................................................................................... 7

2.0 Introduction .................................................................................................................................... 7

3.0 SEC-00192 Rocky Flats Plant Class Definitions ........................................................................... 8

3.1 Petitioner-Requested Class Definition and Basis .................................................................. 8

3.2 Class Evaluated by NIOSH ................................................................................................... 9

3.3 NIOSH-Proposed Class(es) to be Added to the SEC ............................................................ 9

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ............................................................. 9

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 10

4.2 Technical Information Bulletins and Procedures ................................................................ 11

4.3 Facility Employees and Experts .......................................................................................... 11

4.4 Previous Dose Reconstructions ........................................................................................... 13

4.5 NIOSH Site Research Database .......................................................................................... 13

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 13

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 14

5.1 Rocky Flats Plant and Process Descriptions ....................................................................... 14

5.2 Radiological Exposure Sources from Rocky Flats Operations ........................................... 20

5.2.1 Tritium Exposure Sources from Rocky Flats Operations ........................................ 20

5.2.2 Plant Operations and Radiological Programs .......................................................... 21

5.2.2.1 Tritium Operations ................................................................................... 21

5.2.2.2 Radiological Programs ............................................................................. 23

5.2.3 Incidents .................................................................................................................. 24

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 26

6.1 Available Rocky Flats Plant Tritium Monitoring Data ....................................................... 26

6.2 Available Rocky Flats Plant External Monitoring Data ...................................................... 29

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 29

7.1 Pedigree of Rocky Flats Plant Data ..................................................................................... 30

7.1.1 Tritium Monitoring Data Pedigree Review ............................................................. 30

7.2 Evaluation of Bounding Tritium Radiation Doses at Rocky Flats ...................................... 31

7.2.1 Evaluation of Bounding Process-Related Tritium Doses ........................................ 31

7.2.1.1 Tritium Urinalysis Information and Available Data ................................ 31

7.2.1.2 Tritium Airborne Survey Data .................................................................. 31

7.2.2 Evaluation of Bounding Ambient Environmental Internal Tritium Doses ............. 32

7.2.3 Methods for Bounding Tritium Dose at Rocky Flats .............................................. 32

7.2.3.1 Excerpts from the 1973 RFP Tritium Release Investigation .................... 32

7.2.3.2 NIOSH Conclusion on the RFP Bounding Approach .............................. 35

7.2.4 Internal Tritium Dose Reconstruction Feasibility Conclusion ................................ 36

7.3 Evaluation of Bounding External Radiation Doses at Rocky Flats ..................................... 36

7.4 Evaluation of Petition Basis for SEC-00192 ....................................................................... 36
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7.4.1 Incidents .................................................................................................................. 36

7.4.2 Building 460 Plutonium .......................................................................................... 37

7.4.3 Tritium Exposures ................................................................................................... 37

7.4.4 Previous Issues – RFP Site Profile .......................................................................... 38

7.4.5 Information Not Provided in the Previous SEC Evaluation .................................... 39

7.4.6 Adequacy of Co-worker Models ............................................................................. 39

7.4.7 Analysis Laboratories .............................................................................................. 40

7.4.8 Analysis Laboratories .............................................................................................. 40

7.4.9 Site and Process Information ................................................................................... 41

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation ...... 41

7.6 Summary of Feasibility Findings for Petition SEC-00192 .................................................. 49

8.0 Evaluation of Health Endangerment for Petition SEC-00192 ...................................................... 49

9.0 Class Conclusion for Petition SEC-00192 ................................................................................... 50

10.0 References .................................................................................................................................... 51

Attachment 1: Data Capture Synopsis ................................................................................................... 59

Tables 

4-1: No. of Rocky Flats Claims Submitted Under the Dose Reconstruction Rule ................................ 13

5-1: Rocky Flats Plant Development Chronology and Population Over Time ..................................... 15

5-2: RFP Key Facilities with Potential Tritium Exposures ................................................................... 17

6-1: Available RFP Tritium Data from 122 NOCTS Claims ................................................................ 28

7-1: Summary of RFP Tritium Dose Estimates (mrem) ........................................................................ 35

7-2: Summary of Feasibility Findings for SEC-00192 .......................................................................... 49
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SEC Petition Evaluation Report for SEC-00030

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: 

Daniel Stempfley, Dade Moeller. The rationales for all conclusions in this document are explained in 

the associated text.

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for Rocky Flats Plant workers from 

exposures to tritium during the period from April 1, 1952 through December 31, 2005. It provides 

information and analyses germane to considering a petition for adding a class of employees to the 

congressionally-created SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83,

and the guidance contained in the Division of Compensation Analysis and Support’s (DCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, DCAS-PR-004.1

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

 

1

 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS). 

2

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 
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radiation doses may have endangered the health of members of the class. The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for one or more other SEC 

classes. 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.3

3.0 SEC-00192 Rocky Flats Plant Class Definitions 

The following subsections address the evolution of the class definition for SEC-00192, Rocky Flats 

Plant. When a petition is submitted, the requested class definition is reviewed as submitted. Based on 

its review of the available site information and data, NIOSH will make a determination whether to 

qualify for full evaluation all, some, or no part of the petitioner-requested class. If some portion of the 

petitioner-requested class is qualified, NIOSH will specify that class along with a justification for any 

modification of the petitioner’s class. After a full evaluation of the qualified class, NIOSH will 

determine whether to propose a class for addition to the SEC and will specify that proposed class 

definition. 

3.1 Petitioner-Requested Class Definition and Basis 

Petition SEC-00192 was received on August 23, 2011, and qualified on February 9, 2012. The 

petitioner requested that NIOSH consider the following class: All workers employed at Rocky Flats 

from April 1, 1952 to December 31, 2005. 

The petitioner provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the Rocky Flats workers in question. NIOSH 

deemed the following information and affidavit statements sufficient to qualify SEC-00192 for 

evaluation. 

 

3

 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 
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The petitioner affidavit states: 

I attest that there were occasions when I was not monitored. When I worked in the 700 

complex, one of my duties was to work on site returns. I clearly remember one incident at 

a down draft table. I was given the incorrect measurements and when the machine tool 

reached the given measurement the shell was breached. I remember that I had a nasal 

smear taken after the breach. I have requested a copy of this nasal smear report numerous 

times but have not received it. I was later told that I was probably exposed to tritium gas. 

I have no bioassay for tritium exposure. (Affidavit, 2011) 

Based on its review of Rocky Flats Plant past research and data capture efforts, specifically as it 

relates to the SEC-00030 RFP evaluation, NIOSH determined that it has access to personnel or area 

monitoring data for Rocky Flats workers specifically applicable to tritium starting from the time of the 

tritium incident that occurred in 1973. However, NIOSH also determined that a review of tritium 

records and data was necessary for all time periods. NIOSH concluded that there is sufficient 

documentation to support, for at least part of the requested time period, the petition basis that tritium 

radiation exposures and radiation doses were not adequately monitored at Rocky Flats Plant, either 

through personal monitoring or area monitoring. The information and statements provided by the 

petitioner qualified the petition for further consideration by NIOSH, the Board, and HHS. The details 

of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH accepted the petitioner-requested class because NIOSH has 

determined there is evidence of possible tritium exposures warranting evaluation beyond that 

performed for SEC-00030. Therefore, NIOSH defined the following class for further evaluation: All 

employees of the Department of Energy, its predecessor agencies, and their contractors and 

subcontractors with the potential for tritium exposures while working at the Rocky Flats Plant in 

Golden, Colorado, during the period from April 1, 1952 to December 31, 2005.

3.3 NIOSH-Proposed Class(es) to be Added to the SEC 

Based on its research, NIOSH has obtained monitoring data and bioassay data for the worst-case 

tritium exposure scenario that support its ability to bound the tritium dose at the Rocky Flats Plant 

over the site’s entire covered operational period. Based on its analysis of these available resources, 

NIOSH found no part of the class under evaluation for which it cannot estimate tritium radiation doses 

with sufficient accuracy. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

As is standard practice, NIOSH completed an extensive database and Internet search for information 

regarding Rocky Flats Plant. The database search included the DOE Legacy Management Considered 

Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, the Energy 

Citations database, and the Hanford Declassified Document Retrieval System. In addition to general 

Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, OSTI 
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Information Bridge Fielded searches, Nuclear Regulatory Commission (NRC) Agency-wide 

Documents Access and Management (ADAMS) web searches, the DOE Office of Human Radiation 

Experiments website, and the DOE-National Nuclear Security Administration-Nevada Site Officesearch. Attachment 1 contains a summary of Rocky Flats Plant documents. The summary 

specifically identifies data capture details and general descriptions of the documents retrieved. 

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source

materials. The following subsections summarize the data sources identified and reviewed by NIOSH.

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into 

Rocky Flats Plant operations or related topics/operations at other sites: 

Rocky Flats Plant– Introduction, ORAUT-TKBS-0011-1; Rev. 01; November 30, 2006; SRDB 

Ref ID: 30012 

Rocky Flats Plant – Site Description, ORAUT-TKBS-0011-2; Rev. 01; February 1, 2007; SRDB 

Ref ID: 30013 

Rocky Flats Plant – Occupational Medical Dose, ORAUT-TKBS-0011-3; Rev. 01; April 23, 

2007; SRDB Ref ID: 31376 

Rocky Flats Plant – Occupational Environmental Dose, ORAUT-TKBS-0011-4; Rev. 02; April 

23, 2007; SRDB Ref ID: 31377

Rocky Flats Plant – Occupational Internal Dose, ORAUT-TKBS-0011-5; Rev. 02; August 17, 

2007; SRDB Ref ID: 34365 

Rocky Flats Plant – Occupational External Dose, ORAUT-TKBS-0011-6; Rev. 02 PC-1; October 

20, 2010; SRDB Ref ID: 89284
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4.2 Technical Information Bulletins and Procedures 

A Technical Information Bulletin is a general working document that provides guidance for preparing 

dose reconstructions at particular sites or categories of sites. A Procedure provides specific 

requirements and guidance regarding EEOICPA project-level activities, including preparation of dose 

reconstructions at particular sites or categories of sites. NIOSH reviewed the following Technical 

Information Bulletins as part of its evaluation: 

OTIB: Tritium Calculated and Missed Dose Estimates, ORAUT-OTIB-0011; Rev. 00; Oak Ridge 

Associated Universities; June 29, 2004; SRDB Ref ID: 19430

TIB: Tritium Calculations with IMBA, OCAS-TIB-002; Rev. 00; April 22, 2003; National Institute 

for Occupational Safety and Health (NIOSH); SRDB Ref ID: 22407

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH interviewed 12 former RFP employees. NIOSH performed 

individual telephone interviews as well as worker outreach meetings in Colorado to obtain additional 

information regarding tritium exposures and monitoring at RFP. 

Personal Communication, 2012a, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 12, 2012; SRDB Ref ID: 116217

Personal Communication, 2012b, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 12, 2012; SRDB Ref ID: 116218

Personal Communication, 2012c, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 13, 2012; SRDB Ref ID: 116008

Personal Communication, 2012d, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 13, 2012; SRDB Ref ID: 116009

Personal Communication, 2012e, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 21, 2012; SRDB Ref ID: 116210

Personal Communication, 2012f, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 21, 2012; SRDB Ref ID: 116211

Personal Communication, 2012g, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 22, 2012; SRDB Ref ID: 116666

Personal Communication, 2012h, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; June 26, 2012; SRDB Ref ID: 117164

Personal Communication, 2012i, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; July 9, 2012; SRDB Ref ID: 116671
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Personal Communication, 2012j, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; July 9, 2012; SRDB Ref ID: 116672

Personal Communication, 2012k, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; July 18, 2012; SRDB Ref ID: 116677

Personal Communication, 2012l, Personal Communication with [redacted]; In-person Classified 

Interview by ORAU staff; August 10, 2012; SRDB Ref ID: 117245

Worker Outreach Meeting, 2012a, Colorado Worker Outreach Meeting with former RFP Workers 

10:00 AM session; Public outreach meeting by ORAU and NIOSH staff; May 24, 2012; SRDB 

Ref ID: 117357

Worker Outreach Meeting, 2012b, Colorado Worker Outreach Meeting with former RFP Workers 

1:15 PM session; Public outreach meeting by ORAU and NIOSH staff; May 24, 2012; SRDB Ref 

ID: 117358

The interviews and meetings performed in support of this evaluation were focused on collecting 

information specific to tritium at RFP, and more specifically, collecting tritium information for the 

period prior to the 1973 incident. Of the 12 interviews performed, six were with former employees 

who worked at RFP prior to 1973. The collective summary of the information from the interviews 

and meetings indicate the following: 

- As a normal practice, RFP did not handle or process tritium and did not expect to have tritiumcontaminated materials on site (other than tritium targets for neutron generators). 

- Although they may not have been as effective, instruments for monitoring for tritium existed from 

the very early years at the site, including sniffers, vibrating reed instruments, and air bubblers. 

- The site performed environmental monitoring for tritium, including the periods prior to the 1973 

incident, with no positive results that personnel could recall. 

- There were limited tritium bioassay samples performed at RFP prior to the 1973 incident; there 

were no known positive bioassays other than those associated with the 1973 incident. 

- Radiological surveys were performed at the site that included periodic tritium smears. 

- The 1973 incident involved tritium-contaminated materials from Livermore (described as pits and 

scrap materials) and resulted in personnel exposures, which resulted in a program change 

regarding tritium at the site. 

The interviews listed above are referenced, as applicable, within the text of this evaluation report. 
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4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH DCAS Claims Tracking System (referred to as NOCTS) to locate 

EEOICPA-related dose reconstructions that might provide information relevant to the petition 

evaluation. Table 4-1 summarizes the results of this review. (NOCTS data available as of July 9, 

2012) 

Table 4-1: No. of Rocky Flats Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 1695

Number of dose reconstructions completed for energy employees who worked during the period 

under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 1524

Number of additional claims identified as SEC Pulled (i.e., pulled from NIOSH by the Department of 

Labor for final approval). 81

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 1442

Number of claims for which tritium bioassay records were obtained for the identified years in the 

evaluated class definition 122

1 Table 4-1 totals comprise all RFP claims listed in NOCTS, including those that may be covered by other 

 existing SECs. 

4.5 NIOSH Site Research Database 

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. 3399 documents in this database were identified as pertaining to 

Rocky Flats. These documents were evaluated for their relevance to this petition. The documents 

include historical background on air monitoring, urinalysis data, the radiological control program, 

process materials, and process description. 

4.6 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed the following document submitted by the 

petitioners: 

Affidavit from [redacted]; October 31, 2011; DSA Ref ID: 115186, pdf p. 7 (Affidavit, 2011)
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5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

NOTE: This SEC-00192 Evaluation Report (ER) focuses on RFP worker exposures to tritium. 

However, during the feasibility evaluation for SEC-00192, NIOSH concluded that a review of 

SEC-00030 issues and their subsequent resolutions and closures should be documented in this report. 

This review is provided in Section 7.5. For discussions about all other non-tritium aspects of RFP 

work and their related exposures, refer to the SEC-00030 Evaluation Report. Discussion of 

non-tritium topics beyond those discussed in Section 7.5 will not be included in this ER. 

The following subsections summarize both tritium operations at the Rocky Flats Plant (RFP) from 

April 1, 1952 to December 31, 2005, and the information available to NIOSH to characterize 

particular tritium processes and radioactive source quantities. From available sources NIOSH has 

gathered process and source descriptions, information regarding the identity and quantities of each 

radionuclide of concern, and information describing processes through which radiation exposures may 

have occurred and the physical environment in which they may have occurred. The information 

included within this evaluation report is intended only to be a summary of the available information. 

5.1 Rocky Flats Plant and Process Descriptions 

The Rocky Flats Plant was located in Golden, Colorado on a 384-acre site, surrounded by a 

~6000-acre buffer zone (RFP Overview, 2001; RFP Overview, 2011). The workforce grew from a 

little over 100 people at the beginning of the site’s covered period to just over 6000 in 1990. After the 

site ended operations and entered its remediation phase, the workforce began to decrease from the 

1990 employment levels until site closure in 2005. The previous Rocky Flats Plant SEC evaluation, 

SEC-00030, assessed all potential exposure issues with the exception of tritium (see Section 7.5 of 

this report). Consequently, this SEC-00192 evaluation focuses on those operations/activities with the 

potential for tritium exposures; therefore, only those locations and operations with the potential for 

tritium exposure will be discussed in this report. 

As previously discussed in the SEC-00030 ER, RFP site construction began in 1951 and initial 

radiological operations began in April 1952. The primary missions and general activities at the plant 

remained essentially the same from the time the plant opened until 1989, when the U.S. Department of 

Energy (DOE) suspended plutonium operations. From the beginning, the plant was a manufacturing 

facility making and recycling nuclear and non-nuclear components for a portion of the U.S. nuclear 

weapons arsenal. 

In 1989, DOE suspended plutonium processing to review and upgrade the plant’s safety systems. 

Although the site continued to prepare for restart after the 1989 shutdown, the Rocky Flats production 

mission ended permanently in 1992 and entered a site clean-up and remediation phase. In 1993, the 

Secretary of Energy formally announced the end of nuclear production at Rocky Flats. In 1994, the 

last defense production-related shipment left the site. The RFP site remediation was completed and 

the site officially closed in October 2005. 
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Table 5-1 summarizes the site’s development. 

Table 5-1: Rocky Flats Plant Development Chronology and Population Over Time

Years Buildings Comments Plant Population

1951-

1954

991, 771, 444, 881 By April 1952, production operations reportedly 

had begun, but no production or shipment details 

are available for 1952 or the first part of 1953. By 

1954, the plant was fully operational with about 

700,000 square feet of building space.

Employment grew steadily during 

this time. In 1951, there were 133 

people.

1955 A major facility expansion began, referred to as 

Part IV construction.

Approximately 1200 (ChemRisk 

3&4, 1992, Figure 3-4, p. 50)

1956-

1957

447, 776, 777, 

883, 997, 998, 

999, and the 

expansion of 

Bldgs. 444, 881, 

771

These additions were directly related to the change 

of the weapon concept to a hollow unit and the

anticipated production increases. A few years later, 

roughly coincident with the onset of the Cold War, 

RFP became the primary manufacturer of pits under 

the single-mission concept. 

Approximately 1500 (ChemRisk 

3&4, 1992, Figure 3-4, p. 50)

Mid1960s559, 779, 865 These additions were research and development 

facilities focusing on effects of time and field 

conditions on weapons.

By 1964, the workforce reached a 

level of about 3,000 people that 

remained stable for about 15 years.

Early 

1980s1990

371, 460 By 1990, total building space had grown to about 

2.5 million square feet.

Significant upturn in employment, 

with a peak of 5,990 in 1984.

1990s2006Pu processing ceased in 1990.

The announcement of the curtailment of nuclear 

weapons components for submarine-based missiles 

ended nuclear production.

Decontamination and Decommissioning phase. Site 

closed in 2005.

Announcement in workforce 

reduction to ~4,000 by October, 

1995. As of 1999, there were 280 

DOE employees and 3410 

contractors at the RFP site (RFP 

Overview, 2001).

Tritium Related Operations 

Rocky Flats dealt with pits or primary triggers for three different weapons types/pits over its history. 

The first two, which are the designs associated with pure fission devices (like those used in the “Fat 

Man” and “Little Boy” weapons), were handled through 1957 until those designs were phased out for 

improved, boosted fission or thermonuclear designs. The latter designs may have incorporated 

materials like tritium; however, operations involving coupling tritium with pits were performed at 

other sites (ChemRisk 3&4, 1992, p. 45.). Since 1958, pit designs at RFP remained relatively the 

same (ChemRisk 3&4, 1992, p. 47). Around the time of this change at RFP, the AEC began revising 

the weapons program so that each site focused on specific operations instead of maintaining the same 

production operations at multiple sites. RFP dropped most of its uranium operations as a part of this 

program change and became primarily focused on the plutonium pit operations (in the late 1950s and 

early 1960s). The program changes included construction and transformation of facilities to handle 

returned plutonium pits (including methods to remove Am-241 from the weapons-grade plutonium). 

Although it appears that the main focus of site operations shifted at the end of 1957 (ChemRisk 3&4, 

1992, pp. 45-61; RFP Operations Overview, 1996, pdf pp. 11-12), NIOSH’s follow-up research 

findings indicate that tritium-contaminated material in a form similar to the Lawrence Livermore 
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Laboratory (LLL, now LLNL)4 materials associated with the 1973 incident, as well as pits in the form 

of returns contaminated with tritium, were in existence in the MED/AEC complex in the early 1950s,

although there is no documented indication that those materials existed at RFP prior to 1957, and most 

likely, not until the late 1960s. As discussed in the 1994 ChemRisk report for Rocky Flats, a 

conservative assumption would be that the release of tritium from similar operations could have 

occurred since the time that RFP plutonium operations commenced in 1953 (LLNL Parts, 2012; 

Review, 2012b; ChemRisk 5, 1994, Page 119). 

The main plutonium sources at RFP during the late 1950s included plutonium from Hanford and 

Savannah River Site (SRS), and pits from retired nuclear weapons from the Pantex Plant (ChemRisk 

3&4, 1992, pp. 45-61; RFP Operations Overview, 1996, pdf pp. 11-12). Although the transuranic 

radioactive materials on site could have been responsible for the generation of tritium as a result of 

neutron interactions (mentioned below), the site deemed that the most significant source of personnel 

exposure was tritium-contaminated materials associated with plutonium returns. 

RFP also took over the AEC’s manufacture of stainless-steel tritium reservoirs in 1964. This occurred 

when the AEC shifted the contract from the American Car and Foundry Corporation in Albuquerque 

to RFP because of contract and economic reasons (ChemRisk 3&4, 1992, p. 54). It should be noted 

that although RFP manufactured these highly-technical components, they sent the tritium reservoirs to 

other locations for final assembly; therefore, although it was related, this work did not constitute a 

tritium activity at RFP (Tritium Reservoirs, 2012).5

The nature of the weapons work at Rocky Flats, and the specific weapons materials involved, resulted 

in the handling of tritium sources and the potential cross-contamination of materials, such as the 

materials associated with the 1968, 1973, and 1974 incidents discussed in the following section. The 

site’s assessment indicates that these potential sources existed from the beginning of plutonium 

operations at the site through the end of site operations (ChemRisk 3&4, 1992; ChemRisk 5, 1994, p. 

119; RFP Overview, 2001, pdf p 5). This tritium was associated with, and the result of, the receipt 

and reprocessing of contaminated weapons components and related waste or return products/materials 

sent to the site from other AEC/DOE facilities. The disassembly and reprocessing of these 

components had the potential to introduce tritium into air and wastewater streams, and in several 

documented cases, resulted in site environmental releases (Worker Outreach Meeting, 2012b). 

Other Potential Tritium Sources 

Another known tritium-related operation was associated with neutron generator targets, which 

incorporated the use of the tritium targets starting in 1963 (Tritium Release, 1973, pdf p. 68). As 

reported in a 1973 incident follow-up report, the site had two types of Cockcroft-Walton neutron 

generators, one incorporating a sealed-tube target and one incorporating a drift-tube target. Neutron 

generators were located in five different locations on site (Neutron Generators, 1973): Building 886 

(1963-1987) (Critical Mass Lab, 2011; Tritium Release, 1973); Building 991 (1969-1976) (Building 

991, 2011; Tritium Release, 1973); Building 881 (1969-the late 1980s) (Analytical Reports, 1985-86; 

 

4

 Lawrence Livermore Laboratory is now called Lawrence Livermore National Laboratory (LLNL). The historical source 

documents used for this evaluation refer to LLL; this report will refer to LLNL from here on. 

5

 Classified references at OSTI supporting the conclusions of this document include: (1) P.L. Sturgill, “SP-949SL Fill 

Fitting Weld. (U)”, LMfg-85-008, Rockwell International , 1985, and (2) R.W. Nokes, “Characterization of the SP830. 

(U)”, CD71-101, Dow Chemical Company , Jan 05, 1971. 
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Building 881, 2011; Tritium Release, 1973); Building 444 (1969-1971) (Building 444, 2011; Tritium 

Release, 1973); and Building 123 (1964-1980s/1990s) (Building 123, 2011; Decommissioning, 1997; 

Tritium Release, 1973). As of the 1973 incident assessment, the site had purchased 241 Ci of tritium 

containing targets. Based on documentation from the site (Target Changes, 1971) regarding sealedtube type neutron generators, maintenance could only be performed by a factory-authorized 

maintenance person in order to keep the warranty on the equipment valid. This was specific to 

maintenance on the head where the tritium target was installed (in a glass tube at a vacuum). 

Users/operators did, however, handle and replace the tritium targets in the drift-tube type units. 

Tritium contamination was also a concern in the neutron generator support systems, specifically the 

vacuum-pump system and the cooling-water system (Tritium Release, 1973).

There was also the potential to produce tritium at the site under normal conditions considering the 

various radioactive materials present (Tritium Release, 1973). Other sources discussed in the RFP 

Tritium release document (Tritium Release, 1973) were assessed but determined not to be a 

significant source or contributor to the overall tritium source term at Rocky Flats (Tritium Release, 

1973).

Table 5-2 summarizes the key processes with the potential for tritium exposures. All processing 

buildings were demolished as of October 2005. 

Table 5-2: RFP Key Facilities with Potential Tritium Exposures

(This table spans four pages)

Buildings Facilities

Date of 

Start-up of 

Operations

Comments

122 Medical Services Facility: This facility included a 

radiological decontamination facility with the potential for 

tritium contamination.

1953 Tritium Release, 1973, Fig VI-1, 

indicates Bldg 122 and 123 were in 

the waste transfer stream that had a 

potential for tritium exposures. Also 

see reference: Building 122, 2011, 

Facility Description.

123 Analytical Health Physics Laboratory: This facility 

contained a neutron generator with tritiated targets.

1953 Tritium Release, 1973, Fig VI-1, 

indicates Bldg 122 and 123 were in 

the waste transfer stream that had a 

potential for tritium exposures. 

Tritium Release, 1973, pdf p. 75,

indicates Bldg 123 neutron generator 

tritium source exposures for 

dosimetry studies. Reference: 

Building 123, 2011has a facility 

description.

374 Waste Water Facility: Waste waters contaminated with 

tritium were evaporated in this facility.

1970s ChemRisk 3&4, 1992, p. 130,

indicates tritium exposure.

440 Modification Center Receiving: Received tritiumcontaminated scrap.1960s Tritium Release, 1973, Fig 1-1 p. 98, 

indicates Bldg 440 received scrap. 

ChemRisk 3&4, 1992, pp. 55-57 

shows Bldg 440.
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Table 5-2: RFP Key Facilities with Potential Tritium Exposures

(This table spans four pages)

Buildings Facilities

Date of 

Start-up of 

Operations

Comments

444 DU and Beryllium Metallurgy: This facility contained a 

neutron generator with tritiated targets. Tritium stripping 

began in 1987; the U foundry shut down in 1989. 

1953 Tritium Release, 1973, Fig 1-1, 

indicates Bldg 444 as a potential 

location with tritium exposures. 

Tritium Release, 1973, Fig VI-1, 

indicates Bldg 444 was in the waste 

transfer stream that had a potential for 

tritium exposures. Reference Tritium 

Release, 1973, pdf p. 75, indicates 

Bldg 444 neutron generator tritium 

source exposures.

559/561 Plutonium Analytical Lab: Pu analytical laboratory 

operations are a possible source of tritium emissions from 

processing product. Building 561 contained the exhaust 

plenums for Building 559.

1968 Tritium Release, 1973, Fig VI-1, 

indicates Bldg 559 was in the waste 

transfer stream that had potential for 

tritium exposures. ChemRisk 3&4, 

1992, p. 130.

707/707A Plutonium Fabrication Operations: Bldg. 707 was originally 

a manufacturing facility for casting, fabricating, and 

assembling finished plutonium parts (as well as parts made of 

other materials) into nuclear weapons components. These 

operations had the potential for tritium contamination. Bldg. 

707A was added as part of a 1972 modification. 

1972 Tritium Release, 1973, Fig VI-1 

indicates Bldg 707 was in the waste 

transfer stream that had potential for 

tritium exposures. ChemRisk 3&4, 

1992, p. 130

771/774 Pu Recovery and Liquid Waste Treatment Building: Bldg. 

771 was designed for Pu recovery from scrap/residue materials. 

Bldg. 774 was used for low-level liquid waste treatment 

operations. Both had the potential for tritium contamination.

1953 Tritium Release, 1973, Fig 1-1 

indicates Bldg 771 was where oxide 

residue was sent. Indicates 774 was 

location of Storage Tank 207. 

Tritium Release, 1973, Fig VI-1, 

indicates Bldg 771 and 774 were in 

the waste transfer stream that had

potential for tritium exposures. 

ChemRisk 3&4, 1992, p. 130.

776/777 Pu Manufacturing and Assembly Complex: This complex 

was the major Pu fabrication and assembly facility. Waste 

operations (initiated in 1969 to support disposition of 

equipment damaged by the fire as well as waste generated in 

the clean-up efforts) were on-going. The Supercompactor and 

size-reduction facilities were used to minimize the total volume 

of radioactive waste at the complex. Bldg. 776 housed drums 

containing Pu residue and supported drum-venting activities to 

prevent the build-up of hydrogen gas and had the potential for 

tritium contamination. Bldg. 777 was a foundry operations and 

coatings facility and also operated as a disassembly and scrapweighing location with the potential to be the source of the 

most significant tritium releases at the site (i.e., the highest 

percentage of the site’s overall tritium releases).

1957 Tritium Release, 1973, Fig 1-1 

indicates Bldg 777 weighed scrap. 

Tritium Release, 1973, Fig VI-1, 

indicates Bldg 776 was in the waste 

transfer stream that had potential for 

tritium exposures. ChemRisk 3&4, 

1992, p. 130.
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Table 5-2: RFP Key Facilities with Potential Tritium Exposures

(This table spans four pages)

Buildings Facilities

Date of 

Start-up of 

Operations

Comments

778 Building 778 was a support building for the Pu processing 

buildings (776, 777, and 707). It was located directly south of 

Buildings 776 / 777 and was connected to these buildings, as 

well as Building 707, by enclosed walkways. Over its history, 

Bldg. 778 was used mainly as a protective clothing (Anti-C) 

laundry for all the Pu process buildings, a locker room and 

shower area, and maintenance shops. It had the potential for 

tritium contamination. 

1957 Tritium Release, 1973, Fig VI-1 

indicates Bldg 778 was in the waste 

transfer stream that had potential for 

tritium exposures. See also reference 

Building 778, 2011.

779 Pu Development Building: This building was constructed for 

Pu research activities involving process chemistry technology, 

physical metallurgy, machining and gauging, joining 

technology, and hydrating operations. Glovebox activities in 

support of Pu storage included inspection, metal brushing, and 

repackaging. Hydriding operations performed at the facility to 

recover plutonium also resulted in tritium releases. 

1965 Tritium Release, 1973, Fig 1-1 

indicates Bldg 779 was location of 

Hydriding Lab and waste tank dump 

to offsite. Tritium Release, 1973, Fig 

VI-1, indicates Bldg 779 was in the 

waste transfer stream that had 

potential for tritium exposures. 

ChemRisk 3&4, 1992, p. 130.

865, 867, 

868

Research and Development of Uranium and Beryllium: 

Material and process development and metallurgy laboratory. 

High Bay area of Building 865 supported production through 

research and development with a potential tritium waste 

stream. Buildings 867 and 868 contained filter plenums for 

process exhaust routed from Building 865.

1970 Tritium Release, 1973, Fig VI-1, 

indicates Bldg 865 was in the waste 

transfer stream that had potential for 

tritium exposures.

881 Laboratories, maintenance shops, and plant support 

facilities: The original building was designed and built for 

processing enriched U. Small quantities of other radioactive 

materials such as U-233 and Pu were also handled. The 

facility contained a neutron generator with tritiated targets.

1953 Tritium Release, 1973, Fig 1-1, 

indicates Bldg 881 as a potential 

location with tritium exposures. 

Tritium Release, 1973, Fig VI-1, 

indicates Bldg 881 was in the waste 

transfer stream that had potential for 

tritium exposures. Tritium Release, 

1973, pdf p. 75, indicates Bldg 881 

neutron generator tritium source 

exposures.

883 Beryllium and Uranium Machining Facility: Machining 

facility for both enriched and depleted U. The building was 

divided into an A side and B side. The A side rolled enriched 

U while the B side rolled depleted U. In 1966, the A side of 

Building 883 was converted to Be rolling. Depleted U rolling 

continued on the B side. Some indication of work with tritium 

shells (breaking up shells).

1957 Tritium Release, 1973, Fig 1-1, 

indicates Bldg 883 as a potential 

location with tritium exposures. 

Tritium Release, 1973, Fig VI-1, 

indicates Bldg 883 was in the waste 

transfer stream that had potential for 

tritium exposures.

886 Critical Mass Laboratory/Nuclear Safety Facility: This 

building contained a critical mass laboratory that had been used 

to conduct criticality experiments in support of process 

operations. More than 1,600 criticality experiments were 

performed. Short-lived fission products were produced and 

none were indicated as having been released to the work or 

outdoor environment. The isotopes decayed rapidly and were 

contained until stable. The facility contained a neutron 

generator with tritiated targets.

1965 Tritium Release, 1973, Fig VI-1, 

indicates Bldg 886 was in the waste 

transfer stream that had potential for 

tritium exposures. Tritium Release, 

1973, pdf p. 75 indicates Bldg 886 

neutron generator tritium source 

exposures
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Table 5-2: RFP Key Facilities with Potential Tritium Exposures

(This table spans four pages)

Buildings Facilities

Date of 

Start-up of 

Operations

Comments

889 Equipment Repackaging and Decontamination Facility:

Potential for tritium contamination.

Late 1960s Tritium Release, 1973, Fig VI-1, 

indicates Bldg 889 was in the waste 

transfer stream that had potential for 

tritium exposures. See also reference 

Decontamination, 1997.

Solar 

Ponds, 

207A, B, 

and C

Reverse Osmosis Facility: Bldg 910 was constructed in 1977. 

Solar Pond 207A constructed and put into use in 1957. It was 

used to store and evaporate low-level contaminated waste 

containing nitrates and radioactive substances (laundry 

wastewater containing Pu and U). Solar Ponds 207B and 207C 

were put into service in 1960. There was the potential for 

tritium contamination at these locations as the collection point 

for other facility discharges.

1957 Tritium Release, 1973, Fig 1-1, 

indicates Pond 207A as a potential 

location with tritium exposures. 

Tritium Release, 1973, Fig VI-1 

indicates the 207 ponds were in the 

waste transfer stream that had 

potential for tritium exposures.

991 Building 991 was used for weapon assembly, and later, storage 

and shipment of waste. Emissions data include: 238Pu, 238/239Pu, 

241Am, 233/234U, and 238U. Building 991 also provided access to 

underground storage vaults 996, 997, and 999. The facility 

contained a neutron generator with tritiated targets.

1952 Tritium Release, 1973, pdf p. 75, 

indicates Bldg 991 neutron generator 

tritium source exposures.

995 Sanitary Sewage Treatment Facility: There was the potential 

for tritium contamination at this location as the collection point 

for other facility discharges.

unknown Tritium Release, 1973, Fig VI-1, 

indicates Bldg 995 was in the waste 

transfer stream that had potential for 

tritium exposures.

5.2 Radiological Exposure Sources from Rocky Flats Operations 

NOTE: This SEC-00192 Evaluation Report (ER) focuses on RFP worker exposures to tritium. 

However, during the feasibility evaluation for SEC-00192, NIOSH concluded that a review of 

SEC-00030 issues and their subsequent resolutions and closures should be documented in this report. 

This review is provided in Section 7.5. For discussions about all other non-tritium aspects of RFP 

work and their related exposures, refer to the SEC-00030 Evaluation Report. Discussion of 

non-tritium topics beyond those discussed in Section 7.5 will not be included in this ER. 

The following subsections provide an overview of the exposure sources for the Rocky Flats class 

under evaluation in this report. 

5.2.1 Tritium Exposure Sources from Rocky Flats Operations 

Tritium is a radioactive isotope of hydrogen with a mass number of 3. It has a half-life of 12.262 

years and emits an 18 keV Emax (~6 keV Eavg) beta particle, with no other emissions. In the form of 

tritiated water (HTO), it will distribute uniformly throughout water-based body fluids. Because of the 

low energy of the beta particle, the dose is primarily an internal exposure concern where the dose to 

the whole body is equivalent to any particular organ dose. 
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The potential for tritium exposures from RFP operations involving tritium-contaminated materials 

(e.g., materials associated with the 1968, 1973, and 1974 incidents) existed from the beginning of 

operations to the end of operations in 1989 (ChemRisk 3&4, 1992; ChemRisk 5, 1994, p. 119; RFP 

Overview, 2001, pdf p 5). This tritium was associated with, and the result of, the receipt and 

reprocessing of tritium-contaminated weapons components returned to the site. For the most part, in 

cases prior to 1973, the site did not consider tritium a potential source of exposure as an

equipment/material contaminant; therefore, there was not a significant monitoring program prior to 

the 1973 incident. 

Other known tritium sources, associated with neutron generator targets, were brought on site 

beginning in 1963 (Tritium Release, 1973, pdf p. 68). As of the 1973 incident assessment, the site had 

purchased 241 Ci of tritium-containing targets. The site’s assessment concluded that the release of the 

entire amount of tritium from all of the targets would be necessary to produce a significant exposure 

from the targets (a scenario that is not evident from the available information) (Release Investigation, 

1973). The site concluded, and NIOSH concurs, that this source is not a significant tritium source 

from the perspective of a bounding exposure at RFP.

As part of its evaluation of tritium sources, the site also reviewed operations with the potential to 

produce tritium as a result of radiation interactions. The site concluded that the most likely and 

significant source of this tritium was associated with radiation interactions involving materials such as 

plutonium, boron, beryllium, and nitrogen. Two estimates were provided based on two evaluations 

performed in the early 1970s. The first estimate based on this source term determined that 

approximately 0.2 Ci/yr could have been produced with a worst-case production rate of 3.2 Ci/yr 

(although the worst-case conditions were considered unrealistic) (Tritium Release, 1973, pdf p. 70). 

A follow-up estimate was based on the assessment of six possible sources with a result of 5.4E-12 

Ci/day (approximately 2.0E-9 Ci/yr), which was much closer to the site’s measured background levels 

at the time (Tritium Release, 1973, pdf p. 70). The site’s conclusion was that this was not a 

significant tritium production/emissions source at RFP from the perspective of personnel chronic 

exposures (Tritium Monitoring History, 1973). NIOSH evaluated this issue and concurred with the 

site’s conclusion. 

5.2.2 Plant Operations and Radiological Programs 

This section reviews the engineering controls and plant configurations for RFP tritium-related 

operations. It also compares the radiological monitoring programs over the years as they relate to 

tritium exposures and monitoring. 

5.2.2.1 Tritium Operations 

Based on its assessment of RFP operations, NIOSH has concluded that the operations that could have 

resulted in the most significant personnel exposures to tritium were associated with the receipt and 

processing of scrap plutonium and returned/retired plutonium pits from other sites. The site received 

this scrap material and other “special materials” from other sites for the purpose of recovering and 

recycling usable plutonium. This is the type of material that resulted in the 1973 incident that 

produced the highest recorded tritium contamination levels at the site. The 1973 tritiumcontaminated scrap was received from LLNL and processed over a period of time from April through 

September of 1973. As a result of the tritium contamination incident, RFP reviewed and revised its 
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material receipt process. RFP records from 1970-1974 indicated that approximately 290 shipments 

were delivered to RFP (Review, 2012a). Of these shipments, RFP considered the four from LLNL the 

most likely to have been contaminated with tritium. The estimated levels of tritium contamination in 

each of the four shipments was: April 1969, 57 Ci; March 1971, 50Ci; December 1971, 29 Ci (Tritium 

Release, 1973, pdf pp. 68-71); March 1973, 500-2000 Ci. Other potential sources of tritium at RFP 

were also evaluated and determined to be very small in comparison to the 1973 incident levels 

(Tritium Release, 1973). This is exemplified in the tritium incidents that resulted in the most 

significant personnel tritium exposures at the site. The plutonium operations were performed in 

specific buildings, including Buildings 771 and 776/777. As indicated in the available documentation, 

the operations associated with the receipt and processing of returns and scrap did not change 

significantly over the early years until after the tritium incidents of 1973 and 1974.

Evaluation of 1,700 LANL ‘site return’ pits, retrieved from stockpile for Stockpile Laboratory Test 

(SLT) Evaluation, normal retirement, or with possible defective or unusual conditions, showed little 

or no tritium gas in the 18-month period in 1979 and 1980. Tritium gas concentrations in these pits 

ranged from <15 μCi/m3 to 468 mCi/m3, with most in the 150 mCi/m3- 350 mCi/m3range.6

Plutonium from site returns was reclaimed by acid dissolution, but parts involved in boost testing 

were reclaimed by a hydriding process in the Building 779A Hydriding Laboratory. Tritium levels 

monitored for a 40-day period in 1974 in a glovebox used for hydriding ranged from 50 μCi/m3

to 300 

μCi/m3. All other gloveboxes and the glovebox exhaust showed background (10 μCi/m3) levels.7

Radiography to determine the structural integrity of internal components was a routine part of 

Stockpile Laboratory Testing and was sufficient to determine that tritium contamination was likely in 

a pit returned for SLT evaluation in 1984. This pit was returned to LANL for disassembly.8

Building 771 was the initial and primary RFP facility constructed for plutonium operations from 1953 

through 1957 (when Buildings 776/777 were placed in operation to handle the increased workload). 

In 1957, RFP installed an americium line in Building 771 to remove Am-241 that had grown into 

weapons-grade plutonium due to plutonium decay; the americium operation was most likely to 

involve scrap materials and returns. The americium was considered a significant contaminant in the 

plutonium from a weapons perspective. The americium product was a major money-maker at the site 

for some time based on its commercial use in items like smoke detectors. Both buildings (771 and 

776/777) experienced fires that resulted in the shift of some operations to other locations. A Building 

771 fire in 1957 resulted in the shift of some work to 776/777 (ChemRisk 3&4, 1992), and a Building 

776/777 fire in 1969 resulted in the shift of some work to 707 (ChemRisk 3&4, 1992, p. 73). 

Although changes in the individual plutonium purification process at RFP occurred over the years, the 

overall process remained unchanged until 1975, specifically as it related to engineering or plant 

configuration changes that would affect or control associated tritium exposures (Building 771, 1994). 

The primary airborne control implemented at the site was the use of HEPA filtration, which was 

 

6

 W.G. Scherer, “Summary Report of LANL Site-Return Pits for July 1979 through December 1980. (U)” CD81-2164, 

Rockwell International. (Classified Document, OSTI); cited in RefID_117274, J.S. Bogard, “Review of Classified 

Documents in OSTI (deleted version)(U). 

7

 R.P. DeGrazio, “Tritium Information from August 1 – September 9, 1974. (U)”, CD74-3726. (Classified Document, 

OSTI); cited in RefID_117274, J.S. Bogard, “Review of Classified Documents in OSTI (deleted version)(U). 

8

 A.E. Hodges, III, Report no. CD84-1298, Rocky Flats Plant , March 5, 1984. (Title and document are classified, OSTI); 

cited in RefID_117274, J.S. Bogard, “Review of Classified Documents in OSTI (deleted version)(U). 
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implemented from the beginning of operations in 1953 (ChemRisk 3&4, 1992, p. 66). RFP 

implemented administrative controls for tritium after the 1973 incident until engineering controls 

could be implemented in the processes to control potential exposures to tritium-contaminated scrap 

and materials; the engineering controls were completed in 1975. 

Since the beginning of plutonium operations in 1953, RFP continuously upgraded its plant and 

systems to address the recycling of on-site and off-site scrap materials and returns as well as to align 

its operations with the different pit designs that RFP handled over the years. These upgrades included 

installation of the americium line in Building 771 that was associated with the weapons-recycling 

process. The most significant known source of tritium at RFP was the contaminated scrap materials 

received from LLNL from 1969-1973 (ChemRisk 3&4, 1992, p. 241; ChemRisk 5, 1994, p. 116). It 

is assumed that unmonitored levels of tritium are consistent with the 1973 incident levels, which 

involved the processing of tritium-contaminated materials at RFP over the period from April –

September 1973 (i.e., the current maximum basis for tritium at RFP during any period). Therefore, 

the 1973 levels represent the maximum chronic exposure scenario for the period 1953-1973. 

5.2.2.2 Radiological Programs 

Based on the available information reviewed by NIOSH for this evaluation, there were no reported 

detectable personnel exposures to tritium at RFP prior to the 1973 incident (Neutron Generators, 

1973; Personal Communication, 2012a; Personal Communication, 2012f; Personal Communication, 

2012g; Worker Outreach Meeting, 2012a). The 1973 incident introduced significant levels of tritium 

to the RFP that resulted in detectable personnel exposures. Although tritium was present at RFP prior 

to 1973, it was contained in sealed sources or was believed to be present at levels that did not 

constitute an exposure concern. Following the 1973 incident, a more rigorous bioassay program was 

implemented to monitor for potential tritium exposures (Urine Sampling, 1973).

A routine monitoring program was implemented that required that one-tenth of the urine samples 

taken as part of the Pu and Am monitoring program would be analyzed for tritium (Tritium 

Monitoring, 1974); however, in September 1975 this program was discontinued “... since not a single 

sample has measurable tritium during this testing period (1973-1975)”. Consequently, the tritium 

monitoring program was changed to a job-specific program. The program basis document stated that 

RFP “... does not routinely handle tritium containing materials” (Sampling Program, 1981). The 

document identified the operations that would be involved in tritium sampling program, which 

included: 

Operations of neutron generators Building 887 (tritium/tritide targets) 

Operations of Gas Chromatograph Building 881 (tritiated foils) 

Operations of Special Disassembly Systems Building 777 (sealed sources containing tritium)

Operations in Tritium Surveillance Laboratory Building 777 (incoming shipments) 

As a result of these new criteria, workers were identified for participation in a tritium bioassay 

program typified in RFP memos available to NIOSH (Special Tritium Samples, 1983; Tritium 

Bioassay Results, 1982). As shown in Table 6-1, NIOSH also has access to RFP sample results for 

the post-1973 incident period (Tritium Bioassay Results, 1979; Tritium Bioassay Results, 1980; 

Tritium Bioassay Results, 1981; Tritium Bioassay Results, 1982).
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The criteria for job-specific monitoring were subsequently reiterated in RFP procedures and technical 

basis documents (EG&G, 1991; Routine Bioassay, 1992; Tritium Procedure, 1986). The RFP 

requirement was that jobs that involved <1 mCi of tritium would not require any tritium bioassay. 

Jobs that involved >1 mCi of tritium would require a pre-job urinalysis, a weekly urinalysis if the job 

lasted longer than one week, and a post-job urinalysis, all to be analyzed for tritium. The program 

also included air sampling and smear surveys of ongoing operations (Tritium Procedures, 1979; 

Tritium Reports, 1979-1985; Tritium Reports, 1983-1984; Tritium Reports, 1984-1986; Tritium 

Results, 1974-1982; Tritium Results, 1976-1983; Tritium Smears, 1979; Tritium Smears, 1980; 

Tritium Smears, 1981).

5.2.3 Incidents 

The most significant tritium exposure incidents being assessed in this evaluation were associated with 

events from 1968, 19739, and 1974, with the 1973 incident being the most significant from the 

perspective of the amount of tritium involved/released. No documented tritium incidents have been 

identified relating to the neutron generator targets, but none of those sources were capable of 

producing the levels associated with the 1968, 1973, and 1974 incidents. 

A 500-600 Ci tritium release occurred from a Rocky Flats special project in 1968 (details cannot be 

relayed due to the classified nature of the work) (Incident Summary, 1976; ChemRisk 3&4, 1992, p. 

243). The site’s report indicated that there was no significant off-site impact as a result of this 

incident. Based on NIOSH’s review of the information associated with the 1968 incident, as 

compared to the 1973 incident where releases and personnel exposures did occur, there was no 

detectable environmental or workplace impact in 1968 because of differences in the chemical form 

(H3 versus HTO). These differences were the result of the two plutonium-recovery operations at 

RFP. Normal site returns (the bulk of RFP’s reprocessing effort) were processed by acid dissolution 

in Buildings 776/777. Special returns like the ones from LLNL were processed by hydriding the 

plutonium in the Building 779A Hydriding Laboratory. The hydriding process for recovering 

plutonium (presumably having no tritium) involved burning the resulting gases before filtering and 

release to the atmosphere. Release of any tritium from this process is almost certainly as tritiated 

water from the final combustion of these gases. So when tritium was present in boost-tested parts, as 

in the case of the material processed at RFP10 in 1973, it went up the stack as tritiated water, which 

very quickly got into the groundwater around RFP and was subsequently detected. The processing of 

normal site returns by acid dissolution of the plutonium involved no combustion stage so any existing 

tritium would have been vented out the building exhaust stack without a chemical change. The other 

evaluated incidents (i.e., the 1968 and 1974 incidents), resulted principally from the failure of tritium 

reservoirs during disassembly leading to the release of elemental tritium which, in turn, takes much 

longer to become incorporated into environmental water (Tritium Release (1968), 2012; LLNL Parts, 

 

9

 Also in 1981: “Investigation Report of Tritium Release Incident, January 6, 7, 1981,” Internal letter from K.G. Tallman 

to R. E. Yoder, CD89-2188, January 16, 1981. (.CRF00079052$, Denver Federal Center) 

10 Classified documents supporting this conclusion include the following: (1) “Extracts from Classified Section of Draft 

Report to Committee Investigating Rocky Flats Tritium Release (U),” Extracts from CD73-4775, pp 6-7, October 9, 1973 

(Extracted from Rocky Flats Classified Document .CRF00041936%); and (2) “Investigation of the Tritium Release 

Occurrence at The Rocky Flats Plant – Extract,” pp. 18-19, October 29, 1973 (Extracted from Rocky Flats Classified 

Document .CRF00536785R). 
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2012)11. Based on NIOSH’s review of the available documentation, there is no other evidence that 

tritiated plutonium in any significant quantity was ever found in the normal site returns which were 

recovered by the acid-dissolution method.

In the 1973 incident, tritium-contaminated scrap from LLNL was sent to Rocky Flats for processing 

(Release Investigation, 1973; Release Investigation, 1974; ChemRisk 3&4, 1992). The material was 

processed in Building 779A at the site. As a result of the processing, tritium was released to on-site 

basins and ponds, to the Great Western Reservoir, and to the atmosphere (as a result of hydriding and 

oxidizing operations). The recovery products were also routed through other locations at the site 

resulting in the spread of tritium contamination to other worker areas on site. Based on the 

assessment of the incident, it was estimated that between 500-2,000 curies of tritium-contaminated 

materials were shipped from LLNL to Rocky Flats for processing. 

There were varying levels of tritium exposures based on the site’s assessment (Exposure Data, 1973). 

This incident was initially detected by the Colorado State Department of Health as a result of 

environmental monitoring around the site. The site had the capability to perform personnel and area 

monitoring for tritium; however, because it did not handle or process tritium, there was no belief that 

routine monitoring was needed. Although the site had developed a method of detecting tritium in 

urine in 1961, the method was maintained on standby and not routinely used to monitor personnel. 

The site commenced liquid scintillation tritium bioassay monitoring techniques in 1972. 

Coincidentally, the site had shifted to a more job-specific sampling program in 1972-1973 because of 

the lack of positive results and the need to analyze plutonium samples at the site (Tritium Sampling 

History, 1973). In conducting its environmental monitoring around the site, the Colorado State 

Department of Health (CDH) identified significantly-elevated tritium levels in waterways surrounding 

the site. Records indicate that CDH had been conducting environmental monitoring since 1969 

(Incident Summary, 1976). The site disputed that it was the source of the tritium until it was finally 

confirmed later in the year. Since the 1973 incident, the RFP implemented significant improvements 

in the amount and types of personnel and area monitoring for tritium. NIOSH has reviewed the 

available CDH environmental monitoring data (which it has found only for 1970-1974) to assess the 

sequence of events the data represent (Surveillance, 1970-1974). NIOSH determined that the data are 

representative of an incident occurring in the mid-1973 period with no other indication of a release 

(such as that in 1973) during the period that CHD was performing environmental monitoring. 

The 1974 incident (ChemRisk 3&4, 1992, p. 247) involved the release of approximately 1.5 Ci of 

tritium from the exhaust system of Building 777. The source of the tritium contamination in the 

incident was identified to be the opening of an un-surveyed shipping container (called a “pressure 

cooker”) received from Battelle that was found to be contaminated (Building 777 Investigation, 1974). 

No significant environmental or personnel impact from this incident was identified by the Colorado 

State Department of Health or RFP as a result of this incident (Building 777 Investigation, 1974).

 

11 Classified documents supporting this conclusion include the following: (1) “Investigation Report of Tritium Release 

Incident, January 6, 7, 1981,” Internal letter from K.G. Tallman to R. E. Yoder, CD89-2188, January 16, 1981 

(.CRF00079052$, Denver Federal Center); and (2) “Classified Section of Draft Report to Committee Investigating Rocky 

Flats Tritium Release. (U)”, CD73-4775, October 9, 1973 (.CRF-00041936%, Denver Federal Center). 
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6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the Rocky Flats Plant class under evaluation. The previous RFP evaluation 

(SEC-00030) that was assessed by the Board Working Group in multiple meetings and reviews 

assessed many facets of the RFP personnel monitoring program but it did not conclusively address 

issues with tritium. The extensive assessment identified no significant RFP internal monitoring 

program deficiencies or SEC-related issues that resulted in a recommendation for an SEC class at RFP 

(current SEC classes are based on external monitoring issues for neutrons). The result of the SEC00030 assessment as it relates to internal monitoring complements the findings and recommendations 

in this SEC-00192 evaluation, which is exclusive to the tritium exposure issue at RFP. This section 

focuses solely on the available tritium data at RFP. 

6.1 Available Rocky Flats Plant Tritium Monitoring Data 

As discussed in the operations portion of this report, because tritium was not handled as part of RFP 

operations, it was not considered to be a significant source of personnel exposure prior to the 1973 

tritium chronic exposure incident. Other than the known sources on site relating to neutron generator 

targets, the site did not expect tritium-contaminated materials to be on site or a source of exposure, 

which has been corroborated by interviews performed by NIOSH as part of this evaluation. The site 

acknowledged the presence of sealed tritium sources, such as those associated with the neutron 

generators, but concluded that those sources presented very little potential for exposure. 

Consequently, monitoring for tritium exposure prior to 1973 was not performed on a routine basis or 

as a part of the routine radiological monitoring program. After the 1973 incident, the site assessed the 

tritium sources on site, and the potential for personnel exposures associated with those sources. Based 

on the potential personnel exposure and environmental release issues, the site implemented a routine 

tritium monitoring program in 1973 (Tritium Monitoring History, 1973; Release Investigation, 1973). 

As a result of the 1973 incident, tritium monitoring was performed on 148 individuals who were 

judged to have had a potential for tritium exposure. The results of that monitoring are well 

documented (Case Studies, 1973; Personnel, 1973; Tritium Release, 1973; Urine Sampling, 1973). Of 

the personnel who were monitored, five were identified as having potentially-significant exposures. 

The bioassay data for these individuals are provided in the documents above. One of the individuals 

who had positive exposures is included in the NOCTS database; the tritium bioassay results were 

included in the dosimetry data provided by RFP. Dose histories that include tritium monitoring 

results are included in the SRDB for all five of these individuals. 

The 1974 incident is discussed in the Investigation of Tritium Releases, Building 777 (Building 777 

Investigation, 1974). This was primarily a release to the environment with no significant exposure to 

personnel. 
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“Special Analysis Logbooks” (Special Analyses Logbook, 1965-1969) contain sample analysis data; 

there are results for tritium bioassays taken in 1966. This document includes names and associated 

results, all of which were “0”. A notation indicates these samples were related to an “incident @ Box 

A-5”. There is another set of samples processed in the January 1969 period. 

Air sampling and smear sampling were performed routinely where the site deemed it appropriate. The 

document, Tritium Contamination, describes the precautions to be taken to determine the presence of 

tritium on parts being returned for retirement and describes some of the results (Tritium 

Contamination, 1981). Several documents provide air sampling results for this location in late 1977, 

with the conclusion that it was left over from the 1973 incident (Investigation, 1977; Tritium Reports, 

1983). There are also listings of smear results for the period from 1979-1980 (Tritium Smears, 1979).

Because tritium was normally present in only trace quantities in the production lines and was 

considered to be an insignificant source of personnel exposures, routine bioassay for tritium was not 

implemented. Room air samples were typically less than the limit of detection to 0.02% of Radiation 

Control Guides (RCG) established by AEC (Tritium Status, 1975).

As previously mentioned, a “routine” bioassay program was implemented after the 1973 incident to 

evaluate the potential for tritium exposures by sampling for tritium in 10% of the urine intended for 

Pu analysis. In 1975, this routine monitoring program was discontinued because not a single positive 

tritium sample was found (Bioassay Procedure, 1979). This evaluation further supports the contention 

that the possibility of exposure to the workers from tritium was extremely low if not non-existent. 

However, procedures were implemented that specified that personnel working a job involving more 

than 1 mCi of tritium would be sampled. This policy is supported by letters from the site that identify 

the personnel who should provide tritium samples (Routine Bioassay, 1992). One document contains 

letters covering 1980-1983 that identify the personnel who should be sampled for tritium (Special 

Tritium Samples, 1983). [Sentence redacted]. Tritium bioassay results were found for 13 of the 16 

individuals in NIOSH’s Site Research Database (Tritium Bioassay Results, 1979; Tritium Bioassay 

Results, 1980; Tritium Bioassay Results, 1982). 

The post-1973 radiation protection program was aware of the presence of tritium and monitored for it 

in both the workplace and the workers. Based on the available RFP operational information as it 

relates to tritium, NIOSH believes that these available tritium data sufficiently represent the worstcase exposure scenario for any RFP operational period where tritium existed, or could have existed. 

As part of its tritium assessment for this evaluation, NIOSH reviewed all available RFP health 

physics, industrial hygiene, and environmental monitoring reports which exist for all operational years 

at the site. For the years prior to the 1973 incident, there are limited results identified specifically for 

tritium (as expected, because the site did not handle or process tritium other than tritium targets for 

neutron generators). The available documentation discusses the use of tritium monitors such as 

tritium sniffers (used to periodically monitor incoming materials/shipments), area air monitoring 

systems capable of monitoring for tritium (triton portable and fixed air monitors), swipe and smear 

surveys (counted with instruments including, but not limited to, gas-flow proportional counters), and 

the use of vibrating reed and liquid scintillation monitoring/detection systems/instruments. These 

methods/surveys are periodically discussed in the pre-1973 documentation as it related to 
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environmental soil, water, and air monitoring in the areas surrounding the site, as well as RFP work 

area radiological monitoring. 

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in the Technical Basis Document for the Rocky Flats-Occupational Internal Dose (ORAUTKBS-0011-5). 

Table 6-1 provides the available RFP tritium data for the 122 claims noted in Table 4-1 of this report 

that are currently in NOCTS (as of August 20, 2012). 

Table 6-1: Available RFP Tritium Data from 122 NOCTS Claims

Year Tritium Bioassays in NOCTS No. of Tritium Bioassays in

SRDB - (SRDB Ref IDs)

1960 None 7 - (24699; 26652)

1965 None 6 - (24630; 24691; 27048)

1966 None 13 - (24691; 26259)

1968 None 2 - (26259; 24680)

1969 None 5 - (26259; 24680; 24693)

1973 150 180 - (24388)

1974 44 11 - (8790)

1975 46 None

1976 6 None

1977 13 None

1978 10 None

1979 11 23 - (111276)

1980 30 95 - (111278)

1981 19 87 - (111153)

1982 1 24 - (111077)

1983 No info 2 - (110932)

1991 2 None

1993 7 None

1995 2 None

1996 2 None
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6.2 Available Rocky Flats Plant External Monitoring Data 

The claimant files and other documents available to NIOSH in the SRDB contain external radiological 

exposure data for all years under evaluation. The principal source of external radiation doses for 

members of the evaluated class was as evaluated in the SEC-00030 Rocky Flats Plant Evaluation 

Report. Because tritium is the sole focus of this current evaluation, and tritium is strictly an internal 

dose reconstruction issue, NIOSH has determined that there is no need to assess external exposures 

and the ability to reconstruct dose at RFP beyond what has already been presented and assessed in 

SEC-00030. NIOSH defers to the SEC-00030 RFP ER for all external and medical X-ray decisions 

regarding bounding of dose at RFP as well as the definition of dose reconstruction methods. Details 

regarding the various dosimeters used and the associated minimum detectable doses are presented in 

the Technical Basis Document for the Rocky Flats Plant-Occupational External Dose (ORAU-TKBS0011-6). 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH 

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class as summarized in Section 7.6. 

This approach is discussed in DCAS’s SEC Petition Evaluation Internal Procedures which are 

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine: 

The sufficiency and reliability of the available data. (Section 7.1) 

The feasibility of reconstructing internal radiation doses. (Section 7.2) 

The feasibility of reconstructing external radiation doses. (Section 7.3) 

The bases for petition SEC-00192 as submitted by the petitioner. (Section 7.4) 
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7.1 Pedigree of Rocky Flats Plant Data 

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

7.1.1 Tritium Monitoring Data Pedigree Review 

As discussed above in Section 6.1, RFP personnel were aware of the potential for tritium exposures 

from known sources of tritium, and methods existed to perform the corresponding personnel and area 

monitoring. Based on the site’s 1973 assessment, the trace quantities of tritium that may have been 

present at any time in the production lines, and from other known sources, were small relative to the 

levels and corresponding exposure potential during routine operations with tritium-contaminated scrap 

and returns. Based on its review of the available information leading up to and following the 1973 

tritium incident, NIOSH believes that there is sufficient information associated with site returns and 

scrap processing (most of which is classified) that (when coupled with the available air monitoring, 

radiological survey, and bioassay data) can be used to corroborate this position. Based on NIOSH’s 

review of the available information in the SRDB and other sources, the monitoring results and data as 

well as other operational, source/source term, and radiological program information are available in 

original form and can be used to support the assessment performed for the RFP class under evaluation. 

Although there were several incidents during RFP’s history that involved significant quantities of 

tritium, only one in particular resulted in exposures to personnel. The personnel involved in this 1973 

incident were carefully monitored as part of the investigation conducted after this incident. The 

results of the personnel and area monitoring were also included in the reports conducted for this 

incident. The results are numerous over a period of time after the incident. The monitoring results 

from this incident are available in both claimants’ files and the SRDB. The information is also 

available in original form and can be used to support the assessment performed for the RFP evaluated 

class in this evaluation.

In summary, a program was in place at RFP to sample workers who had potential for exposure to 

tritium, especially as it applied to the site’s follow-up to the 1973 tritium incident. The workers were 

identified and sampled. The bioassay results are available and have been provided to NIOSH as a part 

of the claims process. Based on its assessment of the documentation and data, NIOSH finds that RFP 

workers for whom tritium monitoring data was not provided had very little potential for exposure. 
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7.2 Evaluation of Bounding Tritium Radiation Doses at Rocky Flats 

As discussed in the previous sections of this evaluation, the principal source of internal tritium 

radiation doses for members of the class under evaluation was tritium-contaminated materials returned 

to RFP from other sites in the form of scrap and retired weapons returns. The following subsections 

address the ability to bound tritium doses, methods for bounding doses, and the feasibility of tritium 

dose reconstruction. 

7.2.1 Evaluation of Bounding Process-Related Tritium Doses 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal tritium doses of members of the class under evaluation. 

7.2.1.1 Tritium Urinalysis Information and Available Data 

There are limited tritium bioassay data for years other than 1973 at RFP. Table 6-1 indicates the 

number of RFP tritium bioassay samples currently available to NIOSH. The most significant RFP 

tritium exposures occurred in 1973, which is also the year with the highest number of bioassay sample 

analyses. Based on the available information, the incident occurred between April and September of 

1973. Dow (the site contractor at the time) commenced a sampling protocol that included any 

employee who was thought to have had the best chance of being exposed to tritium. These data are 

available and support NIOSH’s ability to develop a bounding approach to reconstructing RFP tritium 

exposures for the class under evaluation. Based on the information available to NIOSH, RFP 

identified the capability of monitoring personnel for tritium exposures over the majority of the 

operational period under evaluation. Very limited bioassay results are available prior to the 1973 

incident. It is expected that these available data correspond to work assignments that constituted 

maximum-exposure scenarios or include workers with the highest tritium exposure potential (of 

known RFP tritium sources); no radiologically-significant personnel exposure results are indicated in 

the available pre-1973 monitoring data. NIOSH has discovered no evidence of an ongoing exposure 

potential outside of the 1973 incident discussed in this evaluation report. Based on its reviews and the 

analysis performed below, NIOSH concludes that the available bioassay data are sufficient to support 

bounding the tritium exposures at the site. 

7.2.1.2 Tritium Airborne Survey Data 

Environmental and operational air sample data are available for the majority of the years under 

evaluation in this report. There is limited information and documentation relating to tritium 

radiological surveys and air sampling prior to 1973. The most significant quantity of radiological 

survey data specific to tritium sampling are primarily available for the years after the 1973 incident. 

Although limited, the existence of these data over the RFP operational period, coupled with the 

information associated with the existence of tritium on site, does support the position that the site 

maintained the ability to assess tritium emissions and personnel exposures to determine if there were 

radiological issues or releases occurring as a result of known operations. In addition, the data 

corroborate the position presented in this evaluation regarding the ability to bound tritium dose based 

on the available bioassay data for the 1973 incident. 
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7.2.2 Evaluation of Bounding Ambient Environmental Internal Tritium Doses 

The proposed bounding method for tritium defined in this evaluation accounts for, and includes the 

potential contribution of, doses associated with environmental tritium exposures at the site. 

Therefore, further assessment of the doses from environmental tritium exposure sources is not 

necessary for the RFP class under evaluation. 

7.2.3 Methods for Bounding Tritium Dose at Rocky Flats 

Based on NIOSH’s evaluation in this report, it has been determined that the 1973 data serve as the 

bounding exposure scenario for tritium exposures at RFP. Therefore, these data will be used to 

develop a bounding approach for the purpose of reconstructing dose for unmonitored workers who 

may have been exposed to tritium as a result of RFP plutonium-recycling operations with tritiumcontaminated materials. 

7.2.3.1 Excerpts from the 1973 RFP Tritium Release Investigation 

The following series of excerpts is from the document titled, Investigation of the Tritium Release 

Occurrence at the Rocky Flats Plant, (Release Investigation, 1973; Dosimetry Records, name1; 

Dosimetry Records, name2; Dosimetry Records, name3; NOCTS, 2012).

SAMPLING PROTOCOL 

Dow began by sampling urines from all employees who were thought to have had the best chance 

of being exposed to tritium. As of October 15, 1973, about 250 employees have been tested. Dow 

is continuing to trace leads to other possible exposure and will sample them as they are found. 

Dow intends to sample many employees who have had only a remote chance of coming in contact 

with tritium. Dow also tests the urine of any employee who requests this whether or not they are 

candidates for exposure. 

ACTION LEVELS 

An "action level" of 10,000 pCi/l was tentatively chosen for resampling. This level was chosen for 

several reasons such as: 

1. An article by Fitzsimmons indicated that people wearing tritiated watches could excrete levels 

of 10,000 pCi/l. 

2. A calculation of worst possible circumstances indicate that an employee would have to exceed 

levels of 23,000 pCi/l before any permissible yearly levels of whole body radiation would be 

exceeded. 

3. The sample load was such that Dow could handle resampling only a limited number of 

employees on a frequent basis. It turned out that a relatively small number were over 10,000 

pCi/l but a large fraction were in the 5,000 and 10,000 pCi/l range. 
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4. Without predistilling the urine samples the counting efficiency drops to about 3% and the 

corrections made for spectral shift can lead to abnormally high reading. 

5. With a large sample load, counting time devoted to each sample must be restricted so that 

10,000 pCi/l might be considered lowest detection limit available under the present 

circumstances. 

All samples above 10,000 pCi/l are redone by counting the distillate of the original sample. 

Rocky Flats identified five workers with tritium urinalysis results exceeding the action level of 10,000 

pCi/L. Results from these five workers are reviewed here. Fourteen other workers initially exceeded 

10,000 pCi/L but fell below this level upon recount (as noted above, the distillates of the original 

samples were counted, offering better counting statistics during recount). 

The document contains information, including tritium bioassay results and brief work histories about 

the five workers with the largest tritium sample results. This information was used to assess the doses 

to the affected workers and is displayed in italics in the sections below. All five cases had initial 

samples that were not distilled, with one to five later samples that were distilled. In general, the 

non-distilled and distilled sample results tended to not match up, with the distilled samples yielding 

lower values. This is to be expected, given the site discussion above (see Item 4).

Case A 

Case A worked in Room [location redacted] from [date range redacted].

He was involved in the hydrating and processing of the parts in question from [date range 

redacted], along with Cases [case identifiers redacted]. He was not involved in any of the following 

special projects: 

a. [date, special project name redacted]

b. [date, special project name redacted]

c. [date, special project name redacted]

He was involved in taking samples from a tritium-contaminated [device redacted] on [dates 

redacted]. On [date redacted], this was done without a [item redacted].

From this history, it would appear the most likely exposure occurred on [dates redacted]. If an 

exposure had occurred between [date range redacted], it is likely that both Cases [case identifiers 

redacted] would have been exposed to the same source, and subsequently, excreted the same 

quantities of tritium. 

The RFP document also states: 

In Case A, a history of his work assignment and his urine results for the first two weeks indicate 

that he sustained a recent exposure. At the present time he is excreting tritium with an elimination 

half life of less than 10 days. According to Sanders and Snyder, this is the pattern of elimination 

from an exposure up to 90-days post exposure. 
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The statement that Case A’s intake appears to be recent agrees with current models for HTO intakes. 

If an intake on [date redacted] is assumed, a very poor fit to the data is achieved when the standard 

model is applied to all of the data. If only the distilled sample results are used, an intake date of [date 

redacted] provides a somewhat reasonable fit, yielding an intake of 11,000 μCi, resulting in a dose of 

753 mrem. This coincides with the assessment document which states: 

Case A would have a total dose of [dose value redacted] from the present levels of excretion, 

assuming the exposure occurred 90 days ago.

If an intake on September 1 is assumed, the fit to Case A’s early data (non-distilled) is excellent; the 

total intake is 132 μCi with a dose of 9 mrem. If just the later (distilled) data are used, the intake 

drops to 115 μCi. The site indicated that Case A’s intake might have occurred on [date redacted]; in 

that case, the intake would be 36 μCi. 

Case B 

He has worked in [location redacted] since [date redacted]. He was in the room when [action 

redacted].

Assuming an intake on [date redacted] (Case B’s first date in the area), the worst-case scenario, and 

the use of only non-distilled sample results, Case B’s intake is 690 μCi, which results in a dose of 47 

mrem. 

If all sample results are used, the intake is reduced to 430 μCi if the reported errors are applied; if all 

results are weighted equally, the intake is 660 μCi (the same as using just the non-distilled samples). 

A later intake date of September 1 provides a somewhat better fit but the dose drops by an order of 

magnitude to 1.6 mrem. 

Case C 

He worked in [location redacted] since [date redacted]. He was not in the room when [action 

redacted].

Given that Case C did not start in the area until [date redacted], this was the assumed intake date. 

Using only the non-distilled sample results, Case C’s intake is 22 μCi, which results in a dose of 1.5 

mrem. All other combinations of data yield a lower dose. 

Case D 

He worked in [location redacted], between [date range redacted]. He has not been exposed to 

tritium since [date redacted].

Case D submitted samples on only [number redacted] days, although there are [number redacted] 

results on [number redacted] of those days. In one instance, one of the results was distilled; on the 

other day, there is a note that states “repeated with sample channel ratio.” On the latter day, the 

results differ by a factor of almost two. An assumed intake date of [date redacted] (last date of the 
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1973 incident) yields a reasonable fit. The resulting intake is 900 μCi with a corresponding dose of 61 

mrem. 

Case H 

He came in contact with the possible source of tritium on [date redacted].

Results are not consistent with an acute intake on [date redacted]. Case H’s last [number redacted] 

results show an increasing trend and appear more representative of a chronic exposure. If an intake on 

[date redacted] is assumed and only the largest result is used for the calculation, the intake is 1400 

μCi, which results in a dose of 94 mrem. This fit overestimates all of the other results, some 

significantly. Using all of the data and an intake date of [date redacted] yields an intake of 116 μCi, 

but this significantly underestimates the largest result. 

The assumption of a chronic intake beginning [date redacted] and running until the last urine sample 

yields an intake rate of 0.005 μCi/day for a total intake of 10 μCi and a corresponding dose of 0.65 

mrem. 

7.2.3.2 NIOSH Conclusion on the RFP Bounding Approach 

The doses associated with the worst-case scenarios discussed in the site documents are based on the 

assumption of an elimination half-time of 10 days for intakes that occurred less than 90 days prior to 

the bioassay result. This is not representative of the current ICRP biological model, which includes an 

additional longer-term compartment. Because the bioassay results were collected well after the 

assumed intake dates for most of these cases, the intakes and doses calculated with the current model 

are less, sometimes significantly, than those calculated with the older model, even in the worst-case 

situations. Table 7-1 summarizes the RFP tritium dose estimates calculated with the current ICRP 

model.

Table 7-1: Summary of RFP Tritium Dose Estimates (mrem)

Case Worst Case Best Fit

A 753 9

B 47 1.6

C 1.5 1.5

D 61 61

H 94 0.65

Based on this assessment, the most conservative and bounding dose value for this class would be the 

753 mrem value that represents the worst-case chronic individual exposure over a year. NIOSH 

believes this to be representative of the maximally-exposed operations worker and could be used to 

bound doses for unmonitored RFP workers for the period under evaluation. Therefore, NIOSH 

concludes that the bounding approach for unmonitored personnel would be to assign the Case A 

Worst Case tritium dose estimate for each year from the beginning of plutonium operations at RFP 

through 1973 (the year of the most significant incident and when tritium monitoring began at RFP in 
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earnest). For the period from 1973 through 1989 (when operations ceased at the plant), NIOSH 

intends to evaluate the available monitoring data and establish a method to assign an appropriate 

bounding dose for that portion of the evaluated class (i.e., this will require the development of a coworker study, or alternative dose reconstruction method, for the post-1973 period). 

7.2.4 Internal Tritium Dose Reconstruction Feasibility Conclusion 

Based on the assessment presented in the preceding sections of this evaluation, NIOSH concludes that 

there are sufficient data and knowledge of processes and operations to support bounding the 

associated tritium dose using the methods and information presented in this evaluation. Based on the 

assessment of operations, the 1973 incident associated with the processing of LLNL special return 

materials contaminated with significant levels of tritium represented a chronic exposure event that 

occurred from April through September 1973. As compared to the other known sources and previous 

incidents at RFP, the 1973 incident involved by far the largest tritium source term, and resulted in the 

most significant personnel tritium exposures recorded at RFP. Therefore, based on NIOSH’s 

assessment, the values as discussed in Section 7.2.3 can be used to bound unmonitored doses for 

personnel for the period from 1953 through 1989. NIOSH does not believe there is a basis for 

assigning additional unmonitored tritium dose for the period before 1953 or after 1989 because of the 

lack of tritium-related operations outside that date range. 

7.3 Evaluation of Bounding External Radiation Doses at Rocky Flats 

The principal source of external radiation doses for members of the evaluated class was as evaluated 

in the SEC-00030 Rocky Flats Plant Evaluation Report. Because tritium is the sole focus of this 

current evaluation, and tritium is strictly an internal dose reconstruction issue, NIOSH has determined 

that there is no need to assess external exposures and the ability to reconstruct dose at RFP beyond 

what has already been presented and assessed in SEC-00030. Therefore, NIOSH will not assess 

external or medical X-ray dose reconstruction methods further in this evaluation. NIOSH defers to the 

SEC-00030 RFP report for all external and medical X-ray decisions regarding bounding of dose at 

RFP as well as the definition of dose reconstruction methods. 

7.4 Evaluation of Petition Basis for SEC-00192 

The following subsections evaluate the assertions made on behalf of petition SEC-00192 for the 

Rocky Flats Plant site.

7.4.1 Incidents 

SEC-00192: The petitioner asserted during the consultation telephone calls on this petition that there 

were one or more unmonitored, unrecorded, or inadequately monitored or recorded exposure incidents 

at the Rocky Flats Plant site, specifically claiming an Item E.5 basis.

NIOSH’s initial interpretation was that the information provided by the petitioner in one affidavit 

seemed to indicate a description of a radiological incident, for which additional detail was requested 

from the petitioner. In subsequent phone conversations and emails (DSA Ref ID: 115629), the 

petitioner later clarified the intent and indicated that the situation was given as an example of a worker 
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who should have been monitored but was not (applicable to Petition basis F.1). Based on its review, 

NIOSH concluded that there was no intent to include or support an Item E.5 basis.

7.4.2 Building 460 Plutonium 

SEC-00192: Originally, the DOL Site Exposure Matrix showed that plutonium was present in 

Building 460. NIOSH was advised of this in the attached email dated December 8, 2009. According 

to the statement submitted in that email, a former [job title redacted] related that waste drums from 

the 700 complex were stored in Building 460 in 1988 when the governor of Idaho refused to allow 

shipments of radioactive waste from Rocky Flats into the state. Building 460 was a “cold” building 

and workers were not monitored for exposure to radiation. [This was specific to an Item F.1 basis.]

As stated in the Site Profile and the SEC-00030 Evaluation Report, the majority of workers at Rocky 

Flats were monitored for radiation exposure, and NIOSH has exposure records for most workers. 

Some workers may not have been monitored if it was determined that their exposure potential was 

below the threshold for dose monitoring to be required. Building 460 was considered a “cold” 

building, so dose monitoring may not have been required for workers assigned there. The affidavit 

regarding the stored drums describes the performance of radiological monitoring of those drums and 

states that there were radiological postings due to the exposure rates from the drums. This indicates to 

NIOSH that radiological controls were being exercised to prevent unmonitored workers outside the 

posted areas from receiving exposures above appropriate limits. NIOSH does not see indication that 

the movement and storage of these drums was controlled differently than the general waste storage 

activities on site. The doses associated with general waste-handling and storage activities are 

represented in the dose monitoring records of the RFP worker population. The adequacy of RFP 

worker population dose records for the development of co-worker distributions for the assignment of 

unmonitored internal and external does has already been evaluated by NIOSH and the ABRWH for 

SEC-00030. 

In addition, records available to NIOSH indicate that the [job title redacted] had plutonium bioassay 

during the period of concern, although [redacted] stated normal work areas, including the 400 area 

(depleted U) and 800 area (enriched U), would likely require only uranium bioassay. The plutonium 

bioassay indicates to NIOSH that the site was aware of the added plutonium concern, and serves as an 

example that the site was monitoring individuals. 

Relative to the requirements of 42 C.F.R § 83.9 (a)(5), NIOSH has determined that this information 

provides no substantially new information regarding unmonitored plutonium or uranium exposures 

beyond what NIOSH has previously addressed in its evaluation for SEC-00030. 

7.4.3 Tritium Exposures 

SEC-00192: Affidavit states - I attest that there were occasions when I was not monitored. When I 

worked in the 700 complex, one of my duties was to work on site returns. I clearly remember one 

incident at a down draft table. I was given the incorrect measurements and when the machine tool 

reached the given measurement the shell was breached. I remember that I had a nasal smear taken 

after the breach. I have requested a copy of this nasal smear report numerous times but have not 

received it. I was later told that I was probably exposed to tritium gas. I have no bioassay for tritium 

exposure. [This was specific to an Item F.1 basis.]
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NIOSH has available personal or area monitoring data applicable to a tritium incident that occurred in 

1973, which was evaluated as part of SEC-00030. The affiant states that he was employed from [date 

range redacted]. NIOSH does not have this individual’s data readily available, and as of the time of 

the qualification review of the SEC-00192 petition, did not have a clear time period when the incident 

occurred. Since there was an apparent lack of personal monitoring for tritium prior to the 1973 

incident and possibly during the affiant’s employment period ([date range redacted]), NIOSH has 

determined there was evidence of possible tritium exposures warranting evaluation beyond that 

performed for SEC-00030. The additional evaluation is presented in this SEC-00192 evaluation 

report. 

7.4.4 Previous Issues – RFP Site Profile 

SEC-00192: NIOSH has failed to reconcile outstanding site profile issues [These issues were specific 

to an Item F.1 basis]: 

a. Accepted unsworn statement from the supervisor for the thorium strikes, which contradicts 

RFP-5331, which was reviewed by NIOSH and rejected. 

b. Only 5 individuals interviewed about thorium at RFP. 

c. ER’s subsequent to RFP have been reversed after reviewing classified docs. RFP not afforded the 

same level of investigation. 

d. Sworn affidavits dismissed because they weren’t backed up by documentation. Yet, as noted 

above, NIOSH readily accepted an unsworn testimony over a document. 

e. RFP SEC class definition is inconsistent with other SECs and difficult for DOL to administer. The 

class is building specific. But, it is not possible to determine all occupants.

Issue a was extensively discussed by the ABRWH under SEC-00030. The number of individuals 

interviewed in previous efforts, as presented in Issue b, does not provide evidence of lost, falsified, or 

destroyed records; or that there is no information regarding monitoring, source term, or processes. 

Relative to Issue c, classified documents were available to NIOSH, SC&A, and the Advisory Board 

and were reviewed as necessary under SEC-00030; SEC-00030 was afforded an extensive level of 

investigation. Relative to Issue d, NIOSH believes this statement is inaccurate. Affidavits were not 

dismissed. They were extensively investigated and compared to documentary evidence and discussed 

with the Rocky Flats Working Group associated with SEC-00030. The statement presented in Issue e 

is inaccurate in that the SEC-00030 class definition is based on potential neutron exposure. Work 

location is one issue that is considered, but there are others (such as neutron dosimetry). The class 

definition is an administrative issue associated with the previously-evaluated SEC-00030. 

Regarding thorium exposure reconstructions in general, extensive attention has been given to this 

issue during evaluation of SEC-00030, which included classified document reviews. NIOSH has 

determined that it is feasible to accurately bound thorium doses to RFP workers. Methodologies are 

discussed in detail both in the RFP Site Profile and a peer-reviewed paper, Establishing Bounding 

Internal Dose Estimates for Thorium Activities at Rocky Flats, published by the Health Physics 

Society in 2008 (Health Physics, 2008).
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Relative to the requirements of 42 C.F.R § 83.9 (a)(5), NIOSH has determined that this information 

provides no substantially new information beyond what NIOSH has previously addressed in its 

evaluation for SEC-00030, nor does this information provide evidence of lost, falsified, or destroyed 

records; or that there is no information regarding monitoring, source term, or processes. 

7.4.5 Information Not Provided in the Previous SEC Evaluation 

SEC-00192: Information the Board did not have when deciding the RFP SEC petition. [These were 

specific to an Item F.1 basis]:

a. Presence of plutonium in Building 460 (waste drums stored in the building). 

b. Contaminated equipment present in Buildings 440, 444, & 447 (a contaminated Empire lift-a-loft 

was shipped from Building 371 to these buildings, which were considered “cold”). 

The issue regarding drums stored in Building 460 was previously determined to be a non-issue during 

the assessment of the SEC-00030 evaluation report. The contaminated equipment report states the 

levels of contamination found on the equipment as well as the timeframe involved; therefore, NIOSH 

has area monitoring data. NIOSH has developed methods to estimate intakes to unmonitored workers 

at the Rocky Flats. The adequacy of the RFP monitoring programs, and ability to assess unmonitored 

dose, was the primary focus of the evaluation of SEC-00030. 

Relative to the requirements of 42 C.F.R § 83.9 (a)(5), NIOSH has determined that this information 

provides no substantially new information regarding plutonium or other exposures beyond what 

NIOSH has previously addressed in its evaluation for SEC-00030.

7.4.6 Adequacy of Co-worker Models 

SEC-00192: Co-worker models are inaccurate for some buildings [These were specific to an Item F.1 

basis]: 

a. Site profile does not include the 1980 fire in Building 771’s incinerator; in 1980 53% of badges 

had zero. If there was a release from the fire, then the coworker badge readings may not be 

accurate or reflect this incident. 

b. The site profile does not include the plutonium recovery system in Building 440 post 1996. 

c. The site profile does not consider high exposures at the stacker retriever. (Attached email states 

potential exposure rate of a “couple hundred” millirem per hour. Criticality engineers had to 

make sure spacing was maintained). 

d. The highest number of zero readings occurred during the D&D period (2004). 

As presented in the NIOSH responses above, extensive personnel monitoring data are available to 

assess internal and external doses. NIOSH has stated that it will estimate incident-related dose based 

on individuals’ personal data since most workers were routinely monitored. For unmonitored 

workers, NIOSH contends that exposures from incidents would be covered by the co-worker approach 
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because incident doses are represented in the worker population dose. Specific to Issues a and d, the 

zero-dose issue was previously evaluated as a part of the SEC-00030 Evaluation. 

Relative to the requirements of 42 C.F.R § 83.9 (a)(5), NIOSH has determined that this information 

provides no substantially new information beyond what NIOSH has previously addressed in its 

evaluation for SEC-00030. 

7.4.7 Analysis Laboratories 

SEC-00192: Documents show evidence that the laboratories responsible for radiation readings were 

not in compliance with DOE criteria for radiation monitoring. It is likely they were also deficient 

when analyzing personnel dosimeters and breathing zone samples. [This was specific to an Item F.3 

basis]

The referenced compliance audits were performed specifically to evaluate the RFP environmental 

programs. Records do not indicate any correlations between the environmental and personnel 

dosimetry programs. 

7.4.8 Analysis Laboratories 

SEC-00192: An Assessment of Criticality Safety at RFP document, dated June-Sept 1989, shows 

[These were specific to an Item F.3 basis]:

a. Additional incidents from 1983 that are not reflected in the site profile.

b. Deficient or outdated safety practices. 

c. Contamination in the ducts in Building 881 (Issue raised by plant mgrs out of concern for 

employee health.). 

d. Building 881 issue indicated significant amounts of radioactive materials, including one instance 

of 288 grams of U-235 in an old laundry line.

As presented in the NIOSH responses above, extensive personnel monitoring data are available to 

assess internal and external doses. As part of the SEC-00030 evaluation, NIOSH has stated that it will 

estimate incident-related dose based on individuals’ personal data since most workers were routinely 

monitored. For unmonitored workers, NIOSH contends that exposures from incidents would be 

covered by the co-worker approach because incident doses are represented in the worker population 

dose. This would also apply to the situations described. Issues c and d were discussed by the Board 

in a previous meeting in Westminster. In addition, the current SEC as implemented by DOL includes 

Building 881 workers. Therefore, further assessment of the Building 881 issues in regard to bounding 

dose is not productive from a SEC evaluation perspective. 
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7.4.9 Site and Process Information 

SEC-00192: RFP Site-wide Process Descriptions, Material Mass Balances, and Operational 

Emissions Support Document, dated Apr 12, 1994 not represented in the site profile, indicates that 

“radiography occurs in Buildings 122, 444, 460, 707, 777, and T371J”. The site profile does not 

indicate that X-rays were present in Building 460. Workers in Building 460 were not monitored for 

radiation exposure. [This was specific to an Item F.3 basis] 

Where radiography is performed, regulations require specific protocols to prevent inadvertent 

exposure to unmonitored personnel, such as: radiological posting at area boundaries, constant 

radiation monitoring during the activities, and personnel monitoring for individuals performing the 

work. The Rocky Flats Plant had a standard operating procedure, Radiation Safety for Field 

Radiography, for performing radiographic testing, which states that “the personnel access boundary 

location shall not exceed 2 mR/hr”. Therefore, the dose reconstruction methodologies for 

unmonitored workers described in the Site Profile would be adequate for this circumstance. 

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the 

Evaluation 

During the feasibility evaluation for SEC-00192, NIOSH concluded that a review of the SEC-00030 

issues and subsequent resolutions and closures should be documented in this evaluation. Only the 

primary issue title and associated resolution/response are provided here – specific details of the 

sub-tasks of the issue can be found in the Board Working Group’s Rocky Flats Site Profile Review: 

Matrix of Priority Issues Potentially Relevant to SEC Petition Review (available on the NIOSH 

website at: http://www.cdc.gov/niosh/ocas/pdfs/dps/rockymatrix010807.pdf). The issues and their 

status are as follows: 

ISSUE: The approaches regarding solubility need to be reviewed, particularly for Type “S” or 

“Super-S” plutonium compounds whose high insolubility may lead to more exposure to 

gastrointestinal and respiratory tract organs. The sensitivity of the bioassay methods was not 

adequate to detect incidental intakes of insoluble compounds, and also the bioassay methods 

applied at that time were not appropriate. 

RESPONSE: ORAUT-OTIB-0049 addresses Super-S and RFP fire particle size in Section 4.2. 

The concurrence that this issue was closed is presented in the March 7, 2007 RFP working group 

meeting transcript (http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, page 193 of 269). 

ISSUE: Uncertainties are not addressed in the TBD regarding the Am-241 assay of plutonium 

processed at RFP and how lung counting was calibrated to these values, especially in view of 

different Am-241 proportions at different processing steps and different plutonium ages. 
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RESPONSE: See ORAUT-TKBS-0011-5, Rocky Flats Plant – Occupational Internal Dose, 

Section 5.3, Bioassay Data; and Attachment B, Section 5.3.2, Lung Count Data, which states: 

In vivo lung counts have been performed at RFP since 1964 to determine the activity of 

plutonium in the lungs of workers who were exposed, or had the potential to be exposed, to 

airborne plutonium. The method of in vivo lung counts was to place one or more detectors 

over the chest of the subject and count the photons emitted from the plutonium mixture, if any, 

in the chest. Plutonium was not detected directly because of the low abundance of gamma 

photons and the severe attenuation of the more abundant L X-rays. Instead, the 59.5-keV 

gamma photon from 241Am was used to detect 241Am, which is present to some extent in all 

WG plutonium at RFP. The activity of plutonium was then calculated from the detected 241Am 

by measuring, calculating, or assuming the fraction of the 241Am in the plutonium mixture on 

the date of the lung count (see Section B.11 in Attachment B). At RFP, the fraction of the 

241Am in the plutonium mixture has historically been characterized in terms of parts per 

million by weight. Direct in vivo measurement of plutonium in the lungs, although 

investigated, was never implemented at RFP. 

ORAUT-TKBS-0011-5, Attachment B, Table B-11 summarizes the americium MDAs for RFP in 

vivo lung counts. 

ISSUE: Interpretation of NTA film data and correction of recorded dose for workers who were not 

included in the Neutron Dose Reconstruction Project (NDRP) is not evident. 

RESPONSE: Neutron information and approaches were incorporated into ORAUT-TKBS-0011-6, 

Rocky Flats Plant - Occupational External Dose. In addition, it has been discussed in past 

working group meetings that the NDRP documentation indicates that workers who wore NTA film 

were part of the NDRP (NDRP, 2005, pdf p. 9). Possible sources of errors are addressed in the 

TBD. However, a result of the SEC-00030 evaluation was the recommendation of an SEC class 

based on neutron exposures for the period from April 1, 1952 through December 31, 1966. 

ISSUE: There is a need to use neutron-to-photon ratios and/or film/TLD comparisons to correctly 

determine past neutron doses. Workers were exposed to neutrons in the NTA film period at lower 

energy levels than the dosimeter is capable of measuring. It is important to generate correction 

factors for under-monitored workers or for monitored-worker missed dose. This is especially 

important for non-Pu workers covered by the NDRP, and for workers involved with the Pu 

tetrafluoride and Pu-machining operations during the early period. 

RESPONSE: A default neutron-to-gamma ratio is provided in Tables 6-21 and 6-22 in Section 

6.7.3.4 of ORAUT-TKBS-0011-6, Rocky Flats Plant – Occupational External Dose. However, a 

result of the SEC-00030 evaluation was the recommendation of an SEC class based on neutron 

exposures for the period from April 1, 1952 through December 31, 1966. 
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ISSUE: The RFP Site Profile, while incorporating methodologies for assignment of missed dose, 

has not adequately bounded exposure conditions, compensated for calibration errors and technical 

deficiencies, and addressed possible data integrity issues, including possible zero entries in the 

dose records when badges were not returned, all of which may contribute to missed dose. 

RESPONSE: There were eight subtopics assessed as part of this issue. The results of those 

subtopic assessments were: 

1. Provide NDRP data (ORAUT-OTIB-0050): Completed and closed as indicated in the May 30, 

2006 RFP working group meeting transcript 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/tr053006.pdf, page 73 of 276). 

2. Ruttenberg job exposure matrix: Not an SEC issue, as indicated in the March 28, 2006 RFP 

working group meeting transcript (http://www.cdc.gov/niosh/ocas/pdfs/abrwh/tr032806.pdf, 

page 101 of 259). 

3. Completeness of external exposure monitoring data was explicitly discussed over several 

working group meetings. 

4. Co-worker model provided and agreed upon, as indicated in the April 30, 2007 RFP working 

group meeting transcript (http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr043007.pdf, page 

113 of 153); incorporated into the RFP TBD, ORAUT-TKBS-0011 in August 2007. 

5. Zeros in badge readings were listed separately as two different issues (#12 and #28). 

6. Correction factor from DNFSB report: Completed and closed, as indicated in the July 26, 2006 

RFP working group meeting transcript 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr072606.pdf, page 168 of 381). 

7. Criminal and security investigations: No supporting evidence of this based on NIOSH’s 

reviews. Completed and closed, as indicated in the July 26, 2006 RFP working group meeting 

transcript (http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr072606.pdf, page 173 of 381). 

8. Demonstration of the reliability of the bioassay and external database was explicitly discussed 

over several working group meetings. 

ISSUE: Only “roll-up” penetrating doses exist for individuals prior to 1976. It is not clear how the 

neutron and photon doses will be determined from the roll-up dose.

RESPONSE: Neutron information and approaches were incorporated into ORAUT-TKBS-0011-6, 

Rocky Flats Plant – Occupational External Dose. For pre-1971, the approach proposes the use of 

the method defined in the NDRP; for 1971-1976, the method incorporates a neutron-to-photon 

ratio approach. As a result of the SEC-00030 evaluation was the recommendation of an SEC class 

based on neutron exposures for the period from April 1, 1952 through December 31, 1966. 
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ISSUE: Zero entries in dose record when badges were not returned. This issue is divided into two 

periods: 1) Pre-1964, when badges were not issued to all workers; 2) 1964 and after when badges 

were issued to all workers. The dose record may also contain blanks or “no data available.” 

Methods to separate these kinds of entries or blanks from zeros that denote a value below the LoD 

are needed. 

RESPONSE: See False Entries response below. This issue was also addressed in ORAUT-TKBS0011-6, Rocky Flats Plant – Occupational External Dose, Section 6.5, Table 6-2, Interpretation of 

Reported Data. 

ISSUE: Chips fell out of TLDs and readings were not included in worker records. Allegation in 

SEC petition. 

RESPONSE: See False Entries response below. This issue was also addressed in ORAUT-TKBS0011-6, Rocky Flats Plant – Occupational External Dose, Section 6.6.5.2.1, Loose-Chip 

Thermoluminescent Dosimeters; and Section 6.8.5.2.1, Loose-Chip Thermoluminescent 

Dosimeter. 

ISSUE: Hair and body oils on TLD chips cause inaccurate readings (SEC-00030 Petition, Part a, 

p. 45) 

RESPONSE: See False Entries response below. 

ISSUE: Deliberately false entries were made into dose record: there is a charge of deliberate 

falsification of data. For instance, a worker alleges that his supervisor “would advise the 

dosimeter worker that the dose shown was too high to be possibly correct,” and the worker was 

advised to change or delete the reading. (SEC-00030 Petition, Part a, p. 57.). Further in Part b, p. 

501, a worker alleges that zeros were entered into dose records when the TLD reader failed. 

RESPONSE: False entries, along with other issues such as zero dose entries, chips falling out of 

TLDs, and other data reliability issues constitute the “Rocky Flats Data Integrity Issues. The 

working group’s discussion over several meetings culminated in a discussion that addressed 

and/or resolved the issue, as indicated in the March 7, 2007 RFP working group meeting transcript 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, page 154 of 269). 

ISSUE: Unauthorized work practices: the petition provides examples of unauthorized work 

practices (e.g., SEC-00030 Petition, Part a, p. 54) 

RESPONSE: The associated issues were addressed in the SEC-00030 evaluation report and were 

completed and closed, as indicated in the April 12, 2006 RFP working group meeting transcript 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wg041206.pdf , pages 233-239 of 347). 

ISSUE: Workers frequently did not wear badges in production areas and did not report non-use of 

badge (SEC-00030 Petition, Part a, p. 53). This raises a question of how missed dose is to be 

interpreted. 
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RESPONSE: This issue is addressed in ORAUT-TKBS-0011-6, Rocky Flats Plant – Occupational 

External Dose, Section 6.6.3, Missed Dose (photon); Section 6.7.3, Missed Dose (neutron); 

Section 6.8.3, Missed Dose (electron); and Appendix C.4, Adjustment for Missed Dose. 

ISSUE: Badge did not properly record organ dose due to organ being closer to the source than the 

badge or due to workers wearing the badge under their lead aprons. Petition provides examples 

where dose to head and other areas would be much greater than badge reading (SEC-00030 

Petition, Part a, p. 53,). Some workers wore their badge under their lead aprons leading to underrecording of doses to some organs, such as the head, arms, and face. (SEC-00030 Petition, Part a, 

p. 53; Part b, p. 23). Note that these examples are also part of the suggestion that co-worker 

models for Rocky Flats worker external dose would not be valid. 

RESPONSE: This issue is addressed in ORAUT-TKBS-0011-6, Rocky Flats Plant – Occupational 

External Dose, Section 6.5.4, Exposure Geometry; and Section 6.5.5, Lead Aprons. 

ISSUE: Missing dose record in areas of high exposure: one worker has provided an affidavit 

saying that an entire year’s dose record is missing from a time he worked in an area with radiation 

dose rates that ranged up to 8 R/hour. He was an [redacted] in the Stacker Receiver area of 

Building 371, and [redacted], he was not rotated out of the area since he was an [redacted] 

(SEC-00030 Petition, Part b, p. 32). A worker affidavit including this problem is provided on p. 

539 of SEC-00030 Petition, Part b.

RESPONSE: See False Entries response above. 

ISSUE: Bioassays redone when they indicated high exposure. There are two examples cited that 

claim that bioassays were redone or individuals were recounted when the readings were high and 

subsequent results were declared as having no exposure or false positives (SEC-00030 Petition, 

Part a, p. 47; Part b, p. 32).

RESPONSE: Missed dose is addressed in ORAUT-TKBS-0011-5, Rocky Flats Plant –

Occupational Internal Dose, Attachment D, Internal Coworker Dosimetry Data For Rocky Flats 

Plant.

ISSUE: Most exposed workers were not monitored for neutrons. The petition cites [redacted] as 

saying that until July 1958, the most exposed workers were not monitored for neutrons 

(SEC-00030 Petition, Part a, p. 71), raising a question about how the neutron data in the NDRP 

study are to be used, even if the re-reading of the badges is accepted as sound. 

RESPONSE: These methods are now part of ORAUT-TKBS-0011-6, Rocky Flats Plant –

Occupational External Dose. See Section 6.3.5.2, Neutron Dose Reconstruction Project File; 

Section 6.5, Common Issues; Section 6.7.3, Missed Doses; Section 6.7.3.3, Neutron Dose 

Reconstruction Project; and Section 6.7.3.4, Default Neutron-to-Gamma Ratio. 
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The neutron-to-photon ratio for the period prior to 1970 is not included. In Section 6.1.2, the 

Scope states: 

Only a limited assessment of neutron doses can be performed prior to 1970. Unmonitored and 

notional neutron doses from 1952 through 1966 cannot be reconstructed under the Energy 

Employees Occupational Illness Compensation Program Act. Between 1967 and 1970, 

unmonitored and notional neutron doses should be replaced with external coworker doses. 

Reported NDRP and non-affected original neutron dose can be used during all years. 

Section 6.7.3.3, Neutron Dose Reconstruction Project, Page 49: 

Only a limited portion of the NDRP neutron dose components can be used in dose 

reconstructions – 1952 through 1966: Only reported non-affected original neutron dose and 

NDRP neutron dose should be used in the reconstruction. Original and notional doses should 

not be used in the reconstruction of neutron doses. During periods where only original and 

notional doses are reported, the worker should be treated as an unmonitored worker. 

Unmonitored neutron dose cannot be reconstructed during this period. 

However, a result of the SEC-00030 evaluation was the recommendation of an SEC class based on 

neutron exposures for the period from April 1, 1952 through December 31, 1966. 

ISSUE: Many incidents were not reported or recorded. The petition claims, “Throughout the 

history of the site it was common practice for incidents in the workplace to be handled at the floor 

or building level and not reported” (SEC-00030 Petition, Part a, p. 19). This goes to whether 

missed internal dose due to unreported and unrecorded incidents causes a problem in regard to 

adequacy of data for dose reconstruction. Tab E.5 has a detailed example of this and refers to 

others. Also, SEC-00030 Petition, Part a, p. 139 cites an unreported incident discovered during a 

routine bioassay. There are other examples of undocumented exposures in the pages that follow p. 

179; Part a is an example of a worker who was in an explosion involving Pu but there is no film 

badge. 

RESPONSE: The information responding to this issue has been incorporated into ORAUT-TKBS0011-5, Rocky Flats Plant – Occupational Internal Dose, Attachment D, Internal Coworker 

Dosimetry Data For Rocky Flats Plant. 

ISSUE: Concern over potential exposures to other radionuclides. There were potentials for 

occupational exposure to tritium (gas, HTO and others), 233U, 241Am, 237Np, 244Cm and 

210Po. Purification of 241Am began in 1962 and continued to 1979. 233U processing at RFP 

was conducted from 1965-1982. Operations involving 233U included metal processing, 

component manufacturing, material recovery, and waste handling. Curium, neptunium, and 

polonium were used as tracer for the purpose of testing components and were handled in small 

quantities. 
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RESPONSE: The issues associated with this topic were addressed and closed, or otherwise 

determined to be other than a SEC issue, at the April, 12, 2006 working group meeting, January 

26, 2007 working group meeting, and the March 3, 2007 working group meeting 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wg041206.pdf, starting at page 307 of 347; 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/tr012607.pdf, page 149-192 of 274; 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, pages 157-177 of 269). 

ISSUE: Safety Concern Reports indicate concerns with dosimetry results. 

RESPONSE: The issues were discussed at multiple working group meetings and NIOSH 

addressed the issues and closed, or otherwise determined them to be other than SEC issues, at the 

March 3, 2007 working group meeting. No further transcript discussions have been identified. 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, pages 177-192 of 269). 

ISSUE: Concerns were expressed over discrepancies between log books and personnel dosimetry 

records. 

RESPONSE: The issues were discussed at multiple working group meetings and NIOSH address 

the issues and closed, or otherwise determined to be other than a SEC issue, at the March 3, 2007 

working group meeting – no further transcript discussions have been identified 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, pages 177-192 of 269). 

ISSUE: Concern that secondary dosimetry logs, contamination control logs, or foreman logs 

include exposure information (possibly individual specific data) which is inconsistent with 

individual personnel dosimetry records. 

RESPONSE: The issues were discussed at multiple working group meetings and NIOSH address 

the issues and closed, or otherwise determined to be other than a SEC issue, at the March 3, 2007 

working group meeting – no further transcript discussions have been identified 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, pages 177-192 of 269). 

ISSUE: Concern was raised as to whether adequate information was available for reconstructing 

internal doses for D&D workers (including all subcontractors). 

RESPONSE: OCAS-TIB-014, Rocky Flats Internal Dosimetry Coworker Extension, extends 

ORAUT-OTIB-0038, Internal Dosimetry Coworker Data for Rocky Flats Environmental 

Technology Site. In order to extend the analysis beyond 1988, data were obtained from RFP’s

HIS-20 database. The purpose of OCAS-TIB-014 is to extend the previous ORAUT-OTIB-0038 

using the same methodology. 

ISSUE: ORAUT-TKBS-0011-5, Rocky Flats Plant – Occupational Internal Dose, indicates that 

urinalysis log books are available for purposes of assessing MDAs. These log books may be 

useful in assessing the reliability of the electronic data. 
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RESPONSE: Log books were scanned and entered. The draft SC&A Logbook Analysis, Section 

1.1.4, Field and Urinalysis Logbook Data Comparison, has a discussion of the analysis. The 

issues were discussed at multiple working group meetings and NIOSH addressed the issues and 

closed, or otherwise determined them to be other than SEC issues, at the March 3, 2007 working 

group meeting. No further transcript discussions have been identified 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, pages 177-192 of 269). 

ISSUE: Concerns raised about whether other radionuclides which were not specifically monitored 

for were an exposure concern. Radionuclides include: Th-232, U-233, Cm-244, Np-237, Am-241, 

Pu-238, and Po-210.

RESPONSE: ORAUT-TKBS-0011-5, Rocky Flats Plant – Occupational Internal Dose, Section 

5.2.5.2.4, Mold-Coating and Analytical Procedures, states: 

The uses of thorium in analytical procedures have been described as numerous but involving 

small (gram or less) quantities. Accounts of several small, laboratory procedures have been 

found in progress reports about research and development. Therefore, using the NUREG-1400 

approach, with a release fraction R of 0.01, including a confinement factor C of 1, a 

dispersibility factor D of 10 and a quantity Q of <100 g (4 × 105 Bq), a quantity <100 g 

would result in potential intake of <0.04 Bq and is considered inconsequential. 

The issues associated with this topic were addressed and closed, or otherwise determined to be 

other than an SEC issue, at the April, 12, 2006 working group meeting, January 26, 2007 working 

group meeting, and the March 3, 2007 working group meeting 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wg041206.pdf, starting at page 307 of 347; 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/tr012607.pdf, page 149-192 of 274; 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr030707.pdf, pages 157-177 of 269).

ISSUE: An allegation was made that records related to occupational exposure were brought to the 

T-690 trailer and then removed and put in a landfill. 

RESPONSE: The issues associated with this topic were addressed in a document presented by 

NIOSH and closed, or otherwise determined to be other than an SEC issue, at the August 31, 2006 

working group meeting. No further transcript discussions have been identified 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/tr083106.pdf, starting at page 317 of 367). 

ISSUE: Other Specific data integrity concerns (not detailed in above actions), including: 

[Redacted] case; neutron film blackening. 

RESPONSE: The issues associated with this topic were addressed in a document presented by 

NIOSH and closed, or otherwise determined to be other than an SEC issue, at the August 31, 2006 

working group meeting. No further transcript discussions have been identified 

(http://www.cdc.gov/niosh/ocas/pdfs/abrwh/tr083106.pdf, starting at page 317 of 367). 
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7.6 Summary of Feasibility Findings for Petition SEC-00192 

This report evaluates the feasibility for completing dose reconstructions for employees with the 

potential for tritium exposures while working at the Rocky Flats Plant from April 1, 1952 to 

December 31, 2005. NIOSH found that the available monitoring records, process descriptions and 

source term data available are sufficient to complete dose reconstructions for the evaluated class of 

employees. 

Table 7-2 summarizes the results of the feasibility findings at Rocky Flats for each exposure source 

during the time period April 1, 1952 to December 31, 2005.

Table 7-2: Summary of Feasibility Findings for SEC-00192

April 1, 1952 to December 31, 2005

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible

Internal1 X

 - Tritium X

(For relevant years,

as discussed in Section 7.2.4)

 - Other radionuclides Refer to SEC-00030

RFP Evaluation Report

External Refer to SEC-00030

RFP Evaluation Report

Refer to SEC-00030

RFP Evaluation Report

1

 Internal includes an evaluation of bioassay data. 

As of August 20, 2012, a total of 1695 claims have been submitted to NIOSH for individuals who 

worked at Rocky Flats during the period under evaluation in this report. Dose reconstructions have 

been completed, or otherwise addressed via the SEC process, for 1605 individuals (~95%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00192

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 
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required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH’s evaluation determined that it is feasible to estimate radiation dose for members of the 

NIOSH-evaluated class with sufficient accuracy based on the sum of information available from 

available resources. Therefore, a health endangerment determination is not required. 

9.0 Class Conclusion for Petition SEC-00192 

Based on its full research of the class under evaluation, NIOSH found no part of said class for which it 

cannot estimate tritium radiation doses with sufficient accuracy. This class includes all employees of 

the Department of Energy, its predecessor agencies, and their contractors and subcontractors with the 

potential for tritium exposures while working at the Rocky Flats Plant in Golden, Colorado, during the 

period from April 1, 1952 to December 31, 2005. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00192. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation. 
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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22,296; May 2, 2002; SRDB Ref ID: 19391

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended 

Affidavit, 2011, Affidavit from [redacted]; affidavit submitted by SEC-00192 petitioners; October 31, 

2011; DSA Ref ID: 115186, pdf p. 7 

Analytical Reports, 1985-86, Analytical Reports for Rocky Flats General Laboratory, Building 881; 

Rockwell International; various dates in 1985 and 1986; SRDB Ref ID: 111252 

Bioassay Procedure, 1979, Procedure for Bioassay Sampling for Body Counter and Wound Counter 

Exposure Cases, Rocky Flats Plant; January 25, 1979; SRDB Ref ID: 24664 

Building 122, 2011, Rocky Flats Plant, Emergency Medical Services Facility, HAER No. CO-83-S 

(Rocky Flats Plant, Building 122), U.S. Department of Energy Legacy Management, Historic 

American Engineering Record; accessed November 7, 2011 from 

http://lm.doe.gov/land/sites/co/rocky_flats/ haer/base/Buildings/122.htm; SRDB Ref ID: 104842 

Building 123, 2011, Rocky Flats Plant, Analytical Health Physics Laboratory, HAER No. CO-83-B 

(Rocky Flats Plant, Building 123), U.S. Department of Energy Legacy Management, Historic 

American Engineering Record; accessed November 2, 2011 from 

http://lm.doe.gov/land/sites/co/rocky_flats/ haer/base/Buildings/123.htm; SRDB Ref ID: 104329 

Building 444, 2011, Rocky Flats Plant, Nonnuclear Production Facility, HAER No. CO-83-L (Rocky 

Flats Plant, Building 444 and Plant A), U.S. Department of Energy Legacy Management, Historic 

American Engineering Record; accessed November 2, 2011 from 

http://lm.doe.gov/land/sites/co/rocky_flats/ haer/base/Buildings/444.htm; SRDB Ref ID: 104453 

Building 771, 1994, Operational History of Building 771, Historical Release Report, Building 

Historics; November 1994; November 1994; SRDB Ref ID: 105185 
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Building 777 Investigation, 1974, Investigation of a Tritium Release Occurring in Building 777 on 

September 3-4, 1974, U.S. Department of Energy, Rocky Flats Area Office (RFAO); undated; SRDB 

Ref ID: 8790 

Building 778, 2011, Rocky Flats Plant, Laundry Facility, HAER No. CO-83-AB (Rocky Flats Plant, 

Building 778), U.S. Department of Energy Legacy Management, Historic American Engineering 

Record; accessed November 1, 2011 from http://lm.doe.gov/land/sites/co/rocky_flats/ 

haer/base/Buildings/778.htm; SRDB Ref ID: 104334 

Building 881, 2011, Rocky Flats Plant, Manufacturing and General Support, HAER No. CO-83-Q 

(Rocky Flats Plant, Building 881 and Plant B), U.S. Department of Energy Legacy Management, 

Historic American Engineering Record; accessed November 1, 2011 from 

http://lm.doe.gov/land/sites/co/rocky_flats/ haer/base/Buildings/881.htm; SRDB Ref ID: 103887 

Building 886, 2011, Rocky Flats Plant, Critical Mass Laboratory, HAER No. CO-83-A (Rocky Flats 

Plant, Building 886), U.S. Department of Energy Legacy Management, Historic American 

Engineering Record; accessed November 3, 2011 from http://lm.doe.gov/land/sites/co/rocky_flats/ 

haer/base/Buildings/886.htm; SRDB Ref ID: 104452 

Building 991, 2011, Rocky Flats Plant, Final Assembly and Shipping Facility, HAER No. CO-83-U 

(Rocky Flats Plant, Building 991), U.S. Department of Energy Legacy Management, Historic 

American Engineering Record; accessed November 29, 2011 from 

http://lm.doe.gov/land/sites/co/rocky_flats/ haer/base/Buildings/991.htm; SRDB Ref ID: 105196 

Case Studies, 1973, Tritium Actions Levels and Case Studies of Individuals Involved in the 1973 

Tritium Release Incident, Rocky Flats Plant; October 5, 1973; SRDB Ref ID: 111303 

ChemRisk 3&4, 1992, Project Tasks 3 & 4, Final Draft Report, Reconstruction of Historical Rocky 

Flats Operations & Identification of Release Points; ChemRisk, a Division of McLaren/Hart; August 

1992; http://www.lahdra.org/pubs/RockyFlats/ROCKY34.pdf; SRDB Ref ID: 8016 

ChemRisk 5, 1994, Project Tasks 5 Report, Estimating Historical Emissions from Rocky Flats; 

ChemRisk, a Division of McLaren/Hart; March 1994; 

http://www.lahdra.org/pubs/RockyFlats/ROCKY5.pdf; SRDB Ref ID: 8017 

Decommissioning, 1997, Proposed Action Memorandum for the Decommissioning of Building 123, 

Rocky Mountain Remediation Services, LLC; RF/RMRS-97-012; Rev. 5; November 12, 1997; SRDB 

Ref ID: 104888 

Decontamination, 1997, Decontamination and Decommissioning of Building 889 at Rocky Flats 

Environmental Technology Site; K. A. Dorr, et al; Rocky Flats Environmental Technology Site; 1997; 

SRDB Ref ID: 104694 

DCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 1, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; April 15, 2011; 

SRDB Ref ID: 94768 
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Dosimetry Records, name1, Dosimetry Records, Contamination Results, Sample Results, and 

Analytical Reports for Rocky Flats Personnel [name1 redacted]; Rocky Flats Plant; various dates; 

SRDB Ref ID: 113622 

Dosimetry Records, name2, Dosimetry Records, Contamination Results, Sample Results, and 

Analytical Reports for Rocky Flats Personnel [name2 redacted]; Rocky Flats Plant; various dates; 

SRDB Ref ID: 113623 

Dosimetry Records, name3, Dosimetry Records, Contamination Results, Sample Results, and 

Analytical Reports for Rocky Flats Personnel [name3 redacted]; Rocky Flats Plant; various dates; 

SRDB Ref ID: 113624 

EG&G, 1991, EG&G Rocky Flats, Inc., Internal Dosimetry Technical Basis Manual, Version 1.0; 

EG&G Rocky Flats, Inc.; December 16, 1991; SRDB Ref ID: 24399 

Exposure Data, 1973, Exposure Data for Tritium Incident, Cases A to D, Rocky Flats Plant; October 

4, 1973; SRDB Ref ID: 111081 

Health Physics, 2008, Establishing Bounding Internal Dose Estimates for Thorium Activities at Rocky 

Flats, Health Physics Society, 2008; publicly available: 

http://www.ncbi.nlm.nih.gov/pubmed/18545032 

Incident Summary, 1976, Factual Development Outline of 1973 Tritium Release, memorandum by 

Dawson, Nagel, Sherman & Howard; February 27, 1976; SRDB Ref ID: 111269 

Investigation, 1977, Investigation of Elevated Tritium Levels in Building 779A, Room 154, Glovebox 

1363, internal letter from R. T. Scott to R. E. Yoder; Rockwell International; December 19, 1977; 

SRDB Ref ID: 110903 

LLNL Parts, 2012, Nature of the Parts Returned from LLL (now LLNL) from which Tritium Was 

Released, Leading to the 1973 Incident, research notes from Denver FRC visit by J. S. Bogard; Oak 

Ridge Associated Universities (ORAU) Team; August 9, 2012; SRDB Ref ID: 117207 

Monthly Reports, 1965-1967, Monthly Status Reports – Industrial Hygiene and Bioassay, 1/65 –

12/67, The Dow Chemical Company, Rocky Flats Division; various dates in 1965-1967; SRDB Ref 

ID: 24691 

NDRP, 2005, Neutron Dose Reconstruction Protocol, R. B. Falk, et al; Oak Ridge Institute of Science 

and Education, and the Department of Statistics of Colorado State University; ORISE 05-0199; 

February 7, 2005; SRDB Ref ID: 17126 

Neutron Generators, 1973, Status of Neutron Generators at Rocky Flats, author unknown; Rocky 

Flats Plant; accompanying document dated September 20, 1973; SRDB Ref ID: 110885 

NOCTS, 2012, Rocky Flats Plant NIOSH Claim [claim number, name redacted]; NIOSH OCAS 

Claim Tracking System: Online; accessed August 22, 2012 
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OCAS-TIB-002, Tritium Calculations with IMBA, Rev. 00, National Institute for Occupational Safety 

and Health (NIOSH), April 22, 2003; SRDB Ref ID: 22407

ORAUT-OTIB-0011, Tritium Calculated and Missed Dose Estimates, Rev. 00, Oak Ridge Associated 

Universities; June 29, 2004; SRDB Ref ID: 19430

ORAUT-TKBS-0011-1, Rocky Flats Plant– Introduction, Rev. 01; November 30, 2006; SRDB Ref 

ID: 30012 

ORAUT-TKBS-0011-2, Rocky Flats Plant – Site Description, Rev. 01; February 1, 2007; SRDB Ref 

ID: 30013 

ORAUT-TKBS-0011-3, Rocky Flats Plant – Occupational Medical Dose, Rev. 01; April 23, 2007; 

SRDB Ref ID: 31376 

ORAUT-TKBS-0011-4, Rocky Flats Plant – Occupational Environmental Dose, Rev. 02; April 23, 

2007; SRDB Ref ID: 31377 

ORAUT-TKBS-0011-5, Rocky Flats Plant – Occupational Internal Dose, Rev. 02; August 17, 2007; 

SRDB Ref ID: 34365 

ORAUT-TKBS-0011-6, Rocky Flats Plant – Occupational External Dose, Rev. 02 PC-1; October 20, 

2010; SRDB Ref ID: 89284 

Personal Communication, 2012a, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 12, 2012; SRDB Ref ID: 116217

Personal Communication, 2012b, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 12, 2012; SRDB Ref ID: 116218

Personal Communication, 2012c, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 13, 2012; SRDB Ref ID: 116008

Personal Communication, 2012d, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 13, 2012; SRDB Ref ID: 116009

Personal Communication, 2012e, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 21, 2012; SRDB Ref ID: 116210

Personal Communication, 2012f, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 21, 2012; SRDB Ref ID: 116211

Personal Communication, 2012g, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 22, 2012; SRDB Ref ID: 116666

Personal Communication, 2012h, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; June 26, 2012; SRDB Ref ID: 117164
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Personal Communication, 2012i, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; July 9, 2012; SRDB Ref ID: 116671

Personal Communication, 2012j, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; July 9, 2012; SRDB Ref ID: 116672

Personal Communication, 2012k, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; July 18, 2012; SRDB Ref ID: 116677 

Personal Communication, 2012l, Personal Communication with [redacted]; In-person Classified 

Interview by ORAU staff; August 10, 2012; SRDB Ref ID: 117245

Personnel, 1973, Personnel, Major Work Performed, and Work Locations for Individuals Receiving 

Tritium Exposures, Rocky Flats Plant; 1973; SRDB Ref ID: 111084 

Release Investigation, 1973, Investigation of the Tritium Release Occurrence at the Rocky Flats Plant, 

author unknown; Rocky Flats Plant; November 26, 1973; SRDB Ref ID: 110941, 111284, and 24165, 

pdf p. 123 onward 

Release Investigation, 1974, Investigative Report of the 1973 Tritium Release at the Rocky Flats Plant 

in Golden, Colorado; Radiation/Noise Control Branch, Hazardous Materials Control Division, U.S. 

Environmental Protection Agency, Region VIII; July 1974; SRDB Ref ID: 110897 

Review, 2012a, Review of CD71-00360 Prod Rsch & Dev Svc Rpt.pdf; Review of D73-4775.pdf; 

Notes from a review of two classified documents; J. Bogard; May 29, 2012; SRDB Ref ID: 114085 

Review, 2012b, Review of Classified Documents – OSTI (Deleted Version) (U); J. S. Bogard; Oak 

Ridge Associated Universities (ORAU) Team; July 31, 2012; SRDB Ref ID: 117274 

RFP Operations Overview, 1996, Overview of Rocky Flats Operations, T. B. Cochran, Ph.D.; 

November 21, 1996; SRDB Ref ID: 103823 

RFP Overview, 2001, Rocky Flats Site, overview of Rocky Flats Plant and its history; Alliance for 

Nuclear Accountability; http://www.ananuclear.org; undated report excerpt, but from context, after 

January 2001; SRDB Ref ID: 103891 

RFP Overview, 2011, Rocky Flats Plant, overview of Rocky Flats Plant and its history; Wikipedia; 

http://www.wikipedia.com; accessed November 1, 2011; SRDB Ref ID: 103884 

Routine Bioassay, 1992, Routine Bioassay Monitoring Program, Procedure 1-16200-HSP-18.20, Rev. 

0, Rocky Flats Plant Radiological Health; February 8, 1992; SRDB Ref ID: 24275 

Sampling Program, 1981, Rocky Flats Health Physics Tritium Urinalysis Sampling Program, internal 

letter from R. A. Link to C. R. Lagerquist; Rockwell International; September 1, 1981; SRDB Ref ID: 

111174 
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Special Analyses Logbook, 1965-1969, Special Analyses Logbook (Sr-90, Po-210, Np-237, H-3, Th), 

samples, names, and results for various dates in 1965-1969; Rocky Flats Plant; SRDB Ref ID: 26259 

Special Analyses Logbook, 1960, Special Analyses Logbook, samples, names, and results for various 

dates in 1960; Rocky Flats Plant; SRDB Ref ID: 26652 

Special Tritium Samples, 1983, Urinalysis Sampling for Tritium, internal letter from R. A. Link to M. 

A. Wickland; also assorted sampling memos from 1981; Rockwell International; February 22, 1983; 

SRDB Ref ID: 111072 

Status Report, 1968, Status Report – Industrial Hygiene – February, 1968, The Dow Chemical 

Company, Rocky Flats Division; March 8, 1968; SRDB Ref ID: 24680 

Surveillance, 1970-1974, Rocky Flats Plant Surveillance 7/70 – 12/74, environmental monitoring data 

collected by the Colorado Department of Health; various dates in 1970-1974; SRDB Ref ID: 1226 

Target Changes, 1971, Target Changes in P&HPR Neutron Generator, Rocky Flats Plant; from 

context, around September 17, 1971; SRDB Ref ID: 111295 

Tritium Bioassay Results, 1979, Analysis Report Forms with Tritium Bioassay Results, author 

unknown; Rocky Flats Plant; various dates in 1979; SRDB Ref ID: 111276 

Tritium Bioassay Results, 1980, Analysis Report Forms with Tritium Bioassay Results, author 

unknown; Rocky Flats Plant; various dates in 1980; SRDB Ref ID: 111278 

Tritium Bioassay Results, 1981, Analysis Report Forms with Tritium Bioassay Results, author 

unknown; Rocky Flats Plant; various dates in 1981; SRDB Ref ID: 111153 

Tritium Bioassay Results, 1982, Analysis Report Forms with Tritium Bioassay Results, author 

unknown; Rocky Flats Plant; various dates in 1982; SRDB Ref ID: 111077 

Tritium Contamination, 1981, Tritium Contamination, Site Return Pits, internal letter from R. A. Link 

to R. E. Yoder; Rockwell International; September 25, 1981; SRDB Ref ID: 109245 

Tritium Monitoring, 1974, Tritium Monitoring, letter from H. E. Bowman to W. M. Lamb; The Dow 

Chemical Company; September 12, 1974; SRDB Ref ID: 111267 

Tritium Monitoring History, 1973, Tritium Monitoring History, C. W. Piltingsrud; Rocky Flats Plant; 

September 20, 1973; SRDB Ref ID: 110885 

Tritium Procedure, 1986, Tritium Contamination Control, Rocky Flats Plant Radiation Protection 

Group; July 28, 1986; SRDB Ref ID: 24306, pdf p. 12 

Tritium Release (1968), 2012, Nature of the 1968 Tritium Release (~600 Ci) from Rocky Flats, notes 

from Denver FRC visit by J. S. Bogard; Oak Ridge Associated Universities (ORAU) Team; August 9, 

2012; SRDB Ref ID: 117206 
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Tritium Reports, 1979-1985, Tritium Analytical Reports, 1979-1985, Rockwell International; various 

dates in 1979-85; SRDB Ref ID: 110898 

Tritium Reports, 1983, Tritium Analysis Reports, 1983, Rocky Flats Plant; various dates in 1983; 

SRDB Ref ID: 110886 

Tritium Reports, 1983-1984, Tritium Analytical Reports, 1983-1984, Rockwell International; various 

dates in 1983-84; SRDB Ref ID: 110892 

Tritium Reports, 1984-1986, Tritium Analytical Reports, January 1984 – February 1986, Rockwell 

International; various dates in 1984-86; SRDB Ref ID: 111224 

Tritium Reservoirs, 2012, Filling of Tritium Reservoirs, notes from Denver FRC visit by J. S. Bogard; 

Oak Ridge Associated Universities (ORAU) Team; August 9, 2012; SRDB Ref ID: 117204 

Tritium Procedures, 1979, Multiple Procedures Related to Tritium Monitoring; including Air 

Sampling for Tritium, Radiation Monitoring Procedure for Qualitative Respirator Testing, Effluent 

and Room Air Sampling for Tritium; Rocky Flats Plant Radiation Monitoring Group; November 14, 

1979; SRDB Ref ID: 24238 

Tritium Release, 1973, Draft Report to the Committee Investigating the Rocky Flats Tritium Release, 

Rocky Flats Plant; October 9, 1973; SRDB Ref ID: 24167 

Tritium Results, 1974-1982, Tritium Air Sample and Smear Results, 1974-1982; Rockwell 

International; various dates from 1974-1982; SRDB Ref ID: 111157 

Tritium Results, 1976-1983, Tritium Air Sample and Smear Results, 1976-1983; Rockwell 

International; various dates from 1979-1983; SRDB Ref ID: 111212 

Tritium Sampling History, 1973, Tritium Sampling History, Dow Chemical U.S.A., Rocky Flats 

Division; September 19, 1973; SRDB Ref ID: 111306 

Tritium Smears, 1979, Monthly Tritium Smear Surveys, 1979, various buildings and dates in 1979; 

Rocky Flats Plant; SRDB Ref ID: 110908 

Tritium Smears, 1980, Monthly Tritium Smear Surveys, 1980, various buildings and dates in 1980; 

Rocky Flats Plant; SRDB Ref ID: 111105

Tritium Smears, 1981, Monthly Tritium Smear Surveys, 1981, various buildings and dates in 1981; 

Rocky Flats Plant; SRDB Ref ID: 111102 

Tritium Status, 1975, Tritium at Rocky Flats, summary of current status of tritium and tritium 

surveillance and control at RFP; Rockwell International; November 12, 1975; SRDB Ref ID: 8789

Urine Sampling, 1973, Urine Sampling for Tritium, memo with assorted documents and results from 

C. R. Lagerquist to E. Jianetti; Rocky Flats Plant; November 7, 1973; SRDB Ref ID: 24388 
SEC-00192 09-05-12 Rocky Flats Plant 

58 of 70

Worker Outreach Meeting, 2012a, Colorado Worker Outreach Meeting with former RFP Workers 

10:00 AM session; Public outreach meeting by ORAU and NIOSH staff; May 24, 2012; SRDB Ref 

ID: 117357

Worker Outreach Meeting, 2012b, Colorado Worker Outreach Meeting with former RFP Workers 

1:15 PM session; Public outreach meeting by ORAU and NIOSH staff; May 24, 2012; SRDB Ref ID: 

117358
SEC-00192 09-05-12 Rocky Flats Plant 

Page 59 of 70 

Attachment 1: Data Capture Synopsis 

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Primary Site/Company Name: Rocky Flats Plant; DOE 

1951-2006

Alternate Site Names: 

Rocky Flats Environmental Technology Site

Operating Contractor Names: 

Dow Chemical 1951-1975

Rockwell International 1975-1989

EG&G Rocky Flats, Inc. 1989-1995

Kaiser-Hill Company 1995-2006 

Physical Size of the Site: 6,500 acres. Operations were 

conducted in the 300 acre Industrial Area, which contained 

over 800 structures, at the center of the site. The 

surrounding 6,200 acres were known as the Buffer Zone.

Site Population: In 1973 the average site population was 

3192. In 1993, at the time of the workforce reduction, there 

were approximately 6,800 employees on site.

Dosimetry databases, neutron dosimetry, site external dosimetry 

technical basis documents, dosimetry data, dosimetry software 

validations, radiological control procedures, training, tritium releases, 

tritium investigations, incident investigations, internal dosimetry 

manuals, radiological surveys, tritium monitor instruction manuals, air 

monitoring records, dosimetry audits and surveillances, corrective 

action plans, DOELAP testing results, TLD system descriptions, TLD 

response studies, plutonium bioassay studies, in vivo system studies, 

decommissioning closeout reports, log books, safety concerns, progress 

reports, epidemiologic reports, slide presentations, individual employee 

records, explanation of the HIS-20 database, Company/Union Safety 

Committee concerns, urinalysis records, and curium research. 

03/22/2011 635

State Contacted: NA The state was not contacted as its holdings either duplicate DOE 

holdings or concentrate on off-site contamination issues.

05/22/2012 0

Argonne National Laboratory - East (ANL-E) Decontamination and disposal of plutonium gloveboxes and a 1961 

weekly radiation safety summary.

03/26/2008 3

Brookhaven National Laboratory (BNL) Ambient air monitoring at DOE sites and a draft preliminary hazard 

analysis.

10/24/2008 2

Cincinnati Public Library Volume 3 of "A History of the U.S. Atomic Energy Commission". 02/18/2009 1

Claimant Provided Environmental monitoring data, links between occupational exposures 

and workforce illnesses, a New York State worker's compensation 

hearing, nuclear material codes, a claimant's job descriptions and 

dosimetry results, and a safety concern regarding neutron dosimetry 

results.

10/30/2007 6

College Hill Library, Westminster, CO Investigation of the 1969 fire in Building 776-777. 08/09/2006 4

Colorado Mesa University Tomlinson Library The Health and Safety Laboratory quarterly fallout report from January 

1972. 

04/18/2011 1
SEC-00192 09-05-12 Rocky Flats Plant 

60 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Colorado State University Library Am-241 in soils around the site and a report on characterizing 

environmental plutonium by nuclear track techniques.

01/05/2007 2

Curtiss-Wright, Cheswick, PA Reference to the 1969 Rocky Flats fire and a trip report to Rocky Flats. 05/01/2009 2

Department of Labor / Paragon A 1971 announcement of construction to take place at Rocky Flats, 

waste inventory, and treatment reports.

01/23/2012 3

DOE / SC&A Tritium removable contamination limit at Rocky Flats. 02/22/2012 1

DOE Albuquerque Operations Office The use of data from the 1969 fire to develop plutonium release factors 

and nonreactor hazard level classifications.

04/15/2010 2

DOE Environmental Information Center A Paducah Gaseous Diffusion Plant metals recovery report including 

the recovery of silver from Rocky Flats film.

07/20/2011 1

DOE Environmental Measurements Laboratory Beryllium reports. 02/10/2009 3

DOE Germantown Beryllium reports and the 1965 weapons plant specific missions policy. 08/08/2012 2

DOE Hanford Public Reading Room A 1991 assessment of Building 559. 02/15/2006 1

DOELAP Office Idaho National Laboratory 1988 Albuquerque Operations Office applications for Department of 

Energy Laboratory Accreditation Program. 

06/11/2009 1

DOE Legacy Management - Grand Junction Office Progress reports, performance evaluations, long range planning, 

uranium scrap processing, plutonium in soil, accountability station 

symbols, a waste disposal report, and a Neutron Dose Reconstruction 

Project spreadsheet.

01/24/2012 15

DOE Legacy Management - Morgantown Fernald progress reports, material transfer reports, recycle uranium 

reports, all of which reference Rocky Flats, health and mortality studies 

of DOE employees, and Grand Junction Office employee exposure 

histories including Rocky Flats exposures. 

09/19/2011 69

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

Review of the environmental program, incineration of radioactive 

wastes, summaries of unusual occurrences, long range plans, bioassay 

and analytical chemistry meeting reports, plutonium internal 

depositions, material transfers from Fernald, a brief description of 

criticality dosimetry at Rocky Flats, and Mound incident reports 

referencing Rocky Flats.

04/22/2010 46

DOE Legacy Management - RFP Mountain View Office Logbooks and logbook excerpts, internal dosimetry description and 

assessments, internal and external dosimetry reports, radiological 

surveys, dosimetry procedures, dosimetry progress and status reports, 

health physics progress and status reports, material transfers, terminated 

employee records, and thorium reports.

11/16/2006 127
SEC-00192 09-05-12 Rocky Flats Plant 

61 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

DOE Legacy Management - Westminster Office Tritium procedures, tritium monitoring, tritium analysis reports, thorium 

reports, the 1973 tritium release, processing of Los Alamos and 

Lawrence Livermore plutonium scrap, tritium surveys and air 

monitoring, tritium in water, effluent monitoring programs, 

environmental reports, urinalysis reports, tritium bioassay results and 

exposure data, Hot Man Books, packaging of tritium wastes, and 

individual dosimetry records. An additional 21 documents which 

required classification review have been received and are in the process 

of uploading to the Site Research Database.

OPEN 175

DOE Oak Ridge Operations Office Former radiation worker medical surveillance files and radiation 

exposure history requests for workers starting at Rocky Flats.

11/18/2011 26

DOE Oak Ridge Operations Records Holding Task Group 1953 and 1954 production division progress reports. 04/05/2011 2

DOE Office of Scientific and Technical Information 

(OSTI)

Technical papers from the 1968 Metallographic Group meeting, Pacific 

Northwest National Laboratory's description of source term data sources 

for contaminated buildings and sites, and the method by which the 

Rocky Flats site was selected.

09/05/2008 3

DOE Rocky Flats Reading Room - Front Range 

Community College

Occurrence reports, 1994 Radiological Control Manual, health 

monitoring, beryllium surveillance, medical monitoring reports, neutron 

dose reconstruction project reports, contamination incident reports, high 

bioassay results, environmental surveillance reports, minutes of 

meetings with the Colorado Department of Health, and remedial action 

closeout reports.

04/07/2006 256

Dr. Henry Spitz The Pacific Northwest National Laboratory dosimetry system 

performance comparison for several DOE sites.

08/13/2003 1

Energy Technology Engineering Center Rockwell International's annual reviews of the Energy Systems Group's 

radiological controls. 

11/03/2005 4

Federal Records Center (FRC) - Chicago A radioactive waste management working group meeting and a 

reference to Rocky Flats decontamination efforts as a learning tool for 

the termination of Mound's Special Metallurgical Building.

09/27/2006 2

Federal Records Center (FRC) - Denver Dosimetry procedures, health physics procedures, health and mortality 

studies, chronological log of the Building 771 fire, and site problem 

areas.

02/01/2012 20

Federal Records Center (FRC) - Fort Worth Exposure report for Pantex personnel while at Rocky Flats. 07/27/2006 1

Federal Records Center (FRC) - Kansas City/Bannister ANL-E's consideration of Rocky Flats as a transuranic waste 

consolidation center.

08/15/2008 1

Federal Records Center (FRC) - San Bruno Shielding design for a shipment of Na-24 to Rocky Flats. 01/10/2006 1
SEC-00192 09-05-12 Rocky Flats Plant 

62 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

General Atomics Material transfer reports. 11/02/2005 1

Hagley Museum and Library Trip reports regarding transuranic waste incineration and exposures 

exceeding the DOE standard.

09/30/2010 5

Hanford Hanford monthly reports referencing Rocky Flats, material transfers, 

plutonium feed and fuel specifications and incident reports. 

01/25/2012 39

Hanford / SC&A Volume III of the investigation of the 1969 Building 776-777 fire. 08/09/2006 1

Interlibrary Loan Proceedings of a criticality safety short course, survey of DOE mixed 

waste HEPA filters, proceedings of a conference on incinerating wastes, 

and environmental reports.

05/29/2012 14

Interlibrary Loan / SC&A The December 1971 report of environmental levels of radioactivity at 

Rocky Flats.

01/21/2010 1

Internet A history of the site by a former worker. 06/20/2012 1

Internet - Defense Technical Information Center (DTIC) Defense Nuclear Facility Safety Board reports, Los Alamos actinide 

research reports, plutonium machining and handling reports, and 

plutonium stabilization and disposition reports.

01/09/2012 37

Internet - Defense Technical Information Center (DTIC) / 

SC&A

The 1995 Idaho National Laboratory environmental report, which 

discusses Rocky Flats waste at INL.

01/09/2012 1

Internet - DOE The review of solutions stabilization at Rocky Flats, a DOE guide of 

good radiological protection practices at plutonium facilities, and the 

data analysis from the DOE's handbook of airborne release fractions.

12/04/2008 3

Internet - DOE Comprehensive Epidemiologic Data 

Resource (CEDR)

No relevant documents identified. 05/22/2012 0

Internet - DOE Environmental Management Chapter 3 of Linking Legacies. 10/28/2007 1

Internet - DOE Hanford Declassified Document Retrieval 

System (DDRS)

Hanford monthly reports referencing Rocky Flats and a reference to 

Rocky Flat's use of a shrouded probe stack sampler.

09/01/2010 11

Internet - DOE Legacy Management Considered Sites No relevant documents identified. 04/03/2012 0

Internet - DOE National Nuclear Security Administration 

(NNSA) - Nevada Site Office

No relevant documents identified. 04/03/2012 0

Internet - DOE OpenNet A plutonium uptake incident description, U.S. Transuranium Registry 

summary reports, a summary history of the nuclear weapons program, 

and Appendix B of Linking Legacies.

12/11/2011 10

Internet - DOE OSTI Energy Citations Proceedings of the ERDA D&D conference, an inventory of 

contaminated concrete in the DOE complex, an assessment of Rocky 

Flats criticality safety, plutonium processing experimental reports, and 

the decontamination and decommissioning waste estimate validation.

03/27/2012 17
SEC-00192 09-05-12 Rocky Flats Plant 

63 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - DOE OSTI Information Bridge Environmental reports, U.S. radioactive waste inventories, Hanford 

reports referencing Rocky Flats, material transfers, AEC and DOE 

radioisotope customers, Health and Safety Laboratory environmental 

reports, transuranic waste disposition, evaluations of beryllium 

exposures, assessment of airborne plutonium, waste stabilization 

reports, remediation of plutonium contaminated components, Savannah 

River Site reports referencing Rocky Flats plutonium waste, and 

meteorological reports.

05/04/2012 125

Internet - Google Environmental reports and plans, air monitoring program and reports, 

offsite dose assessment, DOE complex histories and descriptions, DOE 

occupational radiation exposure reports, transuranic inventories, 

management, and disposition, DOE 5 year plans, building histories and 

descriptions, groundwater monitoring, EPA records of decision, an EPA 

report on radioactive emissions from DOE facilities, component closure 

plans, public hearings and meetings, radiological surveys, 

environmental remediation of transuranics, site remediation plan 

assessments, preparing and transporting radioactive waste, air emissions 

reports, the toxicology of uranium, radium disposition options, an 

ALARA analysis for hazardous waste disposal, improving tritium 

exposure reconstructions, the finding aid for the K.Z. Morgan papers at 

the University of Tennessee Hodges Library, and decommissioning 

gloveboxes. 

07/23/2012 493

Internet - Health Physics Journal No relevant tritium-related articles identified. Other relevant articles not 

already in the SRDB will be downloaded. 

OPEN 0

Internet - Journal of Occupational and Environmental 

Hygiene

No relevant tritium-related articles identified. Other relevant articles not 

already in the SRDB will be downloaded. 

OPEN 0

Internet - National Academies Press (NAP) An analysis of cancer risks in populations near nuclear facilities 

including Rocky Flats.

03/27/2012 1

Internet - NRC Agencywide Document Access and 

Management (ADAMS) 

U.S. spent fuel and radioactive waste inventories, long-term 

surveillance and maintenance program reports, disposition of plutonium 

environmental impact statement, disposition of highly enriched uranium 

environmental impact statement, Hanford waste disposition 

environmental impact statements referencing Rocky Flats, an intervener 

petition referencing Rocky Flats, and stockpile stewardship documents.

03/27/2012 35

Internet - Oak Ridge National Laboratory (ORNL) Library ORNL progress reports and an air filtration report referencing Rocky 

Flats. 

03/09/2012 5
SEC-00192 09-05-12 Rocky Flats Plant 

64 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - Rocky Flats Environmental Technology Site 

(RFETS)

Air monitoring reports, radiological surveys, decommissioning closeout 

reports, project closeout reports, and site newsletters from closure 

period.

07/05/2006 70

Internet - US Transuranium and Uranium Registries No relevant documents identified. 04/03/2012 0

Kansas City Plant Mention of Rocky Flats closure during testimony on pits production. 10/01/2004 1

Lawrence Livermore National Laboratory (LLNL) Individual exposure files and a summary of LLNL employee internal 

doses at Rocky Flats.

06/10/2009 4

Los Alamos National Laboratory (LANL) Trip reports, analysis of Rocky Flats environmental samples, support of 

FBI/EPA investigation at Rocky Flats, report of the 1969 fire, storage

and disposition of plutonium, and plutonium body burdens.

09/06/2007 21

Lovelace Respiratory Research Institute (LRRI) LRRI annual reports referencing Rocky Flats and the analyses of cancer 

patterns around Rocky Flats.

05/22/2007 3

Mesa County Libraries, Grand Junction, CO A newspaper article about rocky Flats waste inventories. 01/06/2011 1

Missouri Department of Natural Resources The Plutonium Working Group report on plutonium storage 

environmental, safety, and health vulnerabilities.

10/01/2008 1

Mound Museum Material transfers, plutonium accountability and shipments, the Mound 

Laboratory index which mentions Rocky Flats, and newsletters 

mentioning Rocky Flats.

02/01/2012 21

National Archives and Records Administration (NARA) -

Atlanta

The DOE indoor radon study, summaries of AEC accidents and high 

exposures, and a directory of AEC consultants to contractors. 

06/07/2004 5

National Archives and Records Administration (NARA) -

College Park

A 1974 summary report from the U.S. Transuranium and Uranium 

Registry, environmental plutonium contamination, and a report of the 

1973 tritium release.

04/16/2010 6

National Institute for Occupational Safety and Health 

(NIOSH)

Plutonium excretion study, the investigation of thorium handling at 

Rocky Flats, a logbook, interviews, affidavits from former workers, 

radiological surveys, worker outreach meeting minutes, SEC focus 

group meeting sign-in sheets, the protocol for the site epidemiological 

study, an amended NIOSH referral summary showing a visit to Rocky 

Flats, a claimant's public testimony to NIOSH, soil and leachate 

monitoring, a cost-saving plan for decontamination and demolition of 

tritium contaminated facilities, a NIOSH researcher's notes from 

document reviews at DOE headquarters, and responses to union 

requests for data. 

07/26/2012 47
SEC-00192 09-05-12 Rocky Flats Plant 

65 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

National Institute for Occupational Safety and Health 

(NIOSH) / SC&A

The Ohio Field Office Recycled Uranium Project report, highly 

enriched uranium working group reports, the former worker medical 

surveillance program, radiation protection program reviews, disposition 

of plutonium and U-233, a summary of Rocky Flats problems, and 

personnel protection requirements.

02/16/2006 25

Nevada Test Site (NTS) The NTS Environmental Impact Statement, and an area closure report 

detailing waste shipments from Rocky Flats.

04/14/2008 4

Nuclear Regulatory Commission Public Document Room Rocky Flats records at the Public Document Room have not been 

reviewed at this time.

OPEN 0

Oak Ridge A Freedom of Information Act request and responses. 11/09/2007 4

Oak Ridge Institute for Science and Education (ORISE) Chelation DTPA data for DOE including Rocky Flats employees. 08/06/2009 115

Oak Ridge Library for Dose Reconstruction Identification of radionuclides used at Rocky Flats, the Rocky Flats

exposure pathway study, and Oak Ridge Gaseous Diffusion and 

National Laboratory reports referencing Rocky Flats.

05/23/2011 5

ORAU Library A nuclear weapons databook showing shipments from Fernald to Rocky 

Flats.

10/12/2006 1

ORAU Team ORAU Team technical basis documents and information bulletins, 

Rocky Flats' approaches to dose reconstruction, bioassay 

documentation, documented communications, analyses of cancer risks, 

annual DOE radiation exposure reports, external dosimeter 

characteristics, instrument descriptions and instructions, reviews of 

releases, Rocky Flats technical basis documents and procedures, 

reference to the 1985 completion of the Rocky Flats Custom Campaign 

at the INL Chemical Processing Plant Hot Chemistry Lab, and ORAU 

Team researchers' notes from reviews of classified documents at the 

Office of Scientific and Technical Information and the Denver office of 

the DOE Environmental Management Consolidated Business Center.

08/15/2012 430

Paducah Gaseous Diffusion Plant Paducah radiological reports referencing Rocky Flats. 09/18/2006 1

Pantex Plant Confirmation that Rocky Flats was the back-up dosimetry processor for 

Pantex, the results of lead apron studies, and the development of 

diagnostic x-ray dose estimates.

11/01/2005 7

Pantex Plant / SC&A A discussion of tritium contamination of returned pits. 06/23/2011 1

Sandia National Laboratories, New Mexico The Rocky Flats exposure histories for Sandia employees and material 

transfers handled by Ross Aviation.

02/17/2012 4
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66 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Savannah River Site (SRS) Material transfers, FOIA responses, SRS progress reports referencing 

Rocky Flats, a discussion of plutonium in soil around Rocky Flats, the 

record of a californium shipment to Rocky Flats, and the flow of 

materials to and from Rocky Flats.

02/07/2012 45

S. Cohen & Associates (SC&A) Confirmation that Rocky Flats personnel attended dosimetry training at 

Hanford, a Lawrence Livermore National Laboratory paper on dose 

reconstruction, discussions of neutron dosimetry, the analyses of Rocky 

Flats material returned to Y-12 and Mound, interactions between 

Sandia-Livermore and Rocky Flats, and the vulnerabilities of plutonium 

storage. 

02/16/2009 14

SC&A / Idaho National Laboratory (INL) Discussions of Rocky Flats transuranic waste treated and stored at INL, 

reports of Rocky Flats waste incidents, and Rocky Flats waste data.

06/24/2010 34

SC&A / Nevada Test Site (NTS) A 1950-1954 Santa Fe Operations report which summarizes Rocky 

Flats operations.

06/24/2010 1

SC&A / NIOSH Highly enriched uranium and plutonium working group reports. 02/16/2006 2

SC&A / Y-12 Inclusion of the Rocky Flats 1969 fire report in the investigation of the 

1969 Y-12 thorium fire.

07/28/2010 1

Science Applications International Corp (SAIC) Radiation exposure summaries. 09/02/2004 5

Southern Illinois University, Edwardsville, IL Material transfers, a U.S. Transuranium and Uranium Registries report 

of a Rocky Flats whole body donation, Advisory Board on Radiation 

and Worker Health (ABRWH) meeting minutes, and a review of the 

Rocky Flats Special Exposure Cohort petition. 

11/08/2008 9

University of Colorado Norlin Library Air monitoring data, environmental reports, site cleanup activities, 

plutonium releases, release points, trends in plutonium environmental 

monitoring, draft tritium release investigation report, waste disposal 

reports, public doses from the 1969 fire, Rocky Flats 1998 internal 

dosimetry technical basis document, environmental surveys, thorium 

and U-233 handling reports, a 1992 subpoena, and historical 

radionuclide inventories.

11/16/2006 129

University of Tennessee Hodges Library U.S. Transuranium and Uranium Registries reports, the distribution of 

transuranics in food chains, and a fact sheet on DTPA.

03/18/2010 5
SEC-00192 09-05-12 Rocky Flats Plant 

67 of 70

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Unknown Environmental reports, internal deposition of plutonium, site histories, a 

guide to Rocky Flats records series, air emissions annual reports, the 

angular dependence of NTA film, a dose control procedure, studies of 

plutonium particle size distribution, recycle uranium transfers, 

employee statements on exposure reporting and radiation controls, a 

history of Dayton Project and Mound dosimetry which mentions Rocky 

Flats dosimetry, mention of Rocky Flats as a weapons production site, 

DOE occupational exposure reports, and x-ray machine records. 

04/26/2005 151

U.S. Transuranium and Uranium Registries A review of a Rocky Flats whole body donor case. 08/22/2005 1

Westinghouse Site (United Nuclear Corporation), Hematite, 

MO

A trip report to Rocky Flats. 03/13/2009 1

Y-12 A 1983 description of Y-12 extremity monitoring provided to Rocky 

Flats.

06/30/2006 1

Y-12 / SC&A Y-12's transuranics sampling frequency for castings from Rocky Flats 

returns.

07/28/2010 1

TOTAL 3397

Table A1-2: Databases Searched for Rocky Flats Plant

Database/Source Keywords / Phrases Hits Selected

NOTE: Database search terms employed for each of the databases listed below are 

available in the Excel file called “Rocky Flats Plant Rev 01, (83.13) 08-22-12”

Defense Technical Information Center (DTIC)

https://www.dtic.mil/

COMPLETED 12/23/2011

See Note above 1,319 62

DOE CEDR

https://www.orau.gov/cedr

COMPLETED 05/22/2012

See Note above 9 0
SEC-00192 09-05-12 Rocky Flats Plant 

68 of 70

Table A1-2: Databases Searched for Rocky Flats Plant

Database/Source Keywords / Phrases Hits Selected

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 04/03/2012

See Note above 0 0

DOE Legacy Management Considered Sites

http://www.lm.doe.gov/considered_Sites/

COMPLETED 04/03/2012

See Note above 38 0

DOE NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 04/03/2012

See Note above 0 0

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 04/03/2012

See Note above 160 0

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 04/03/2012

See Note above 7,811 5

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 04/03/2012

See Note above 5,038 19

Google

http://www.google.com

COMPLETED 04/03/2012

See Note above 4,141,787 399

HP Journal

http://journals.lww.com/health-physics/pages/default.aspx

COMPLETED 05/31/2012

See Note above 158 0

Journal of Occupational and Environmental Health 

http://www.ijoeh.com/index.php/ijoeh

COMPLETED 05/22/2012

See Note above 82 0

National Academies Press

http://www.nap.edu/

COMPLETED 04/03/2012

See Note above 12,974 0

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/web-based.html

COMPLETED 04/03/2012

See Note above 90 0

USACE/FUSRAP

http://www.lrb.usace.army.mil/fusrap/

COMPLETED 04/03/2012

See Note above 10 1
SEC-00192 09-05-12 Rocky Flats Plant 

69 of 70

Table A1-2: Databases Searched for Rocky Flats Plant

Database/Source Keywords / Phrases Hits Selected

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 04/03/2012

See Note above 8 0

Table A1-3: DTIC Documents Requested for Rocky Flats Plant

Document Number Document Title Requested

Date

Received

Date

ARCCD-CR-87011 Roll Forming Process For Cannon Caliber Depleted Uranium 

Penetrators

01/10/2012

NA Indoor Air Modeling Dated January 1998, Author Kogan, Vladimir; 

Odasso, James

01/10/2012 05/21/2012

NA

Ref ID: 107537

Swaging The Xm774 Depleted Uranium-0.75 Titanium Penetrator 01/10/2012 01/19/2012

Table A1-4: Interlibrary Loan Documents Requested for Rocky Flats Plant

Document Number Document Title Requested

Date

Received

Date

SA-93-010 Statistical Applications: Statistical Methodology for Determining 

Contaminants of Concern by Comparison of Background and Site Data 

with Applications to Operable Unit 2

06/02/2011
SEC-00192 09-05-12 Rocky Flats Plant 

70 of 70

Table A1-5: OSTI Documents Requested for Rocky Flats Plant

Document Number Document Title Requested

Date

Received

Date

RFP-4317; CONF-8905122-4

Ref ID: 106431

Pilot-Scale Production of Dicesium Hexachloroplutonate (Cs2/PuCl6) 

and Filtrate Recovery Dated 3/15/1989

01/11/2012 01/17/2012

RFP-4203

Ref ID: 106432

Preliminary Molten Salt Extraction Experiments with Dicesium 

Hexachloroplutonate (Cs2/PuCl6) Dated 1/30/1989

01/11/2012 01/17/2012

RFP-2134

Ref ID: 107471

An Evaluation of the Cryofit Tube Joining System in Selected 

Plutonium Chemical Processing Solutions

01/10/2012 01/13/2012

RFP-3780

Ref ID: 107472

Measurement Control For Plutonium Isotopic Measurements Using 

Gamma-ray Spectrometry

01/10/2012 01/13/2012