Memo – RFP: Evaluation Status 1 SC&A – July 10, 2015 

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

MEMO 

DATE: July 10, 2015

TO: Rocky Flats Plant Work Group 

FROM: Ron Buchanan, SC&A

SUBJECT: SC&A’s Current Status of Evaluating the RFP Potential Data Falsification, 

Handling Bioassays, and Document Destruction Issues 

1.0 Introduction 

SC&A was tasked by the Rocky Flats Plant (RFP) Work Group (WG) with reviewing documents 

and NIOSH white papers that might shed further light on the allegation of falsification of 

records, improper handling of bioassay samples, and document destruction in the 1989 

timeframe. SC&A provided the RFP WG a summary report on this issue in December 2013 

(SC&A 2013). Since that time, NIOSH and SC&A have conducted numerous interviews with 

former RFP employees and others that were associated with the RFP. NIOSH has recently 

issued a white paper titled, Evaluation of Petitioner Concerns about Data Falsification and Data 

Invalidation in RFP Building 123 Based on Worker Allegations and Issues Relating to the FBI 

Raid, Rev. 3 (NIOSH 2015). The white paper also addressed the potential destruction of 

documents when applicable. This present report is a summary of SC&A’s current status 

concerning the evaluation of this most recent NIOSH white paper (NIOSH 2015). 

The following is a brief summary of the events relevant to this review that took place concerning 

the raid at the RFP during 1989 (DOE 1989, PDF page 8): 

 June 6, 1989 – Call to FBI Hotline concerning environmental issues at the RFP. DOJ and 

EPA served warrant to search RFP. 

 June 6, 1989 – DOE initiated an internal environmental review at the RFP. 

 June 6–July 21, 1989 – The Special Assignment Team performed an evaluation of RFP 

environmental practices. 

 August 1989 – DOE issued the report, Assessment of Environmental Conditions at the 

Rocky Flats Plant (DOE 1989). 

 October 24, 1989 – EPA conducted an interview with an RFP employee concerning 

issues of concern at the RFP (EPA 1989). 

2.0 NIOSH’s 2015 Evaluation Report

After conducting numerous interviews, performing further document searches, and considering 

additional petitioners’ inputs, NIOSH issued a recent report (June 24, 2015) concerning alleged 

data falsification, improper bioassay processing, and potential document destruction (NIOSH 

2015). The report contained the following major sections: 
Memo – RFP: Evaluation Status 2 SC&A – July 10, 2015 

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

1.0 Additional Topics Requiring NIOSH Review and Response 

1.1 Interviews related to the FBI raid investigation 

1.2 Review of: an insider's view of Rocky Flats: Urban Myths Debunked 

1.3 Follow-up research: availability and accessibility of relevant documents 

2.0 Additional Issues Related to the Expanded Post-1983 Scope 

2.1 Additional Colorado visit for data capture and interviews 

2.2 Additional post-Colorado site visit/data capture interviews 

2.2.1 Data falsification interviewee 

2.2.2 FBI raid interview and follow-up information reviews 

2.3 Review of petitioner-identified RFP technical safety appraisal issues 

2.4 Review of petitioner-identified data falsification issues/report 

2.5 Additional information from RFP manager personal notebook/logbook 

3.0 Assessment of Available Personnel Radiological Monitoring Data 

4.0 General Summary and Conclusions 

3.0 SC&A’s Current Evaluation of NIOSH’s White Paper

Interviews 

SC&A participated in most of the RFP interviews and provided summary notes. The interviews 

provided some relevant information and identified some potential issues to be considered. There 

were approximately 13 interviews conducted during the last 11⁄2 years that concentrated on data 

falsification, bioassay data, and destruction of RFP documents. NIOSH analyzed the results of 

these interviews in their recent white paper (NIOSH 2015). In the white paper, NIOSH 

summarized each interview and responded to the issues raised. NIOSH referenced 

approximately 140 documents in the SRDB in their responses. The NIOSH white paper consists 

of 4 sections in 32 pages, with the various interviews, related documents, and articles interlaced 

within those sections. To facilitate evaluating the interviews, SC&A has summarized the most 

pertinent information in the following table. 

Table 1. Summary of Interviews in NIOSH’s White Paper

Interview No. RFP Association NIOSH Page # Main SRBD Ref #

1 Employee 4–6 122614

2 Employee 7–8 123339

3 Employee 8 123338

4 Employee 8 126995

5 Employee 8 127272

6 Employee 13–14 129514

7 Employee 15–16 131488

8 Employee 17–18 130943

9 Gov. agent 18–20 131006

10 Employee 21 133401

11 Employee 21 132826

12 Gov. panel 21–22 132825

13 Employee 24 133888
Memo – RFP: Evaluation Status 3 SC&A – July 10, 2015 

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

SC&A reviewed each of the interviews (and associated documentation) and analyzed NIOSH’s 

response and some of the referenced documents to determine if any of the issues that were raised 

would impact the ability of NIOSH to perform dose reconstruction with sufficient accuracy. 

Issues concerned with area surveys, operational procedures, use/calibration of instruments, 

pocket dosimeters, air monitor alarms, etc. (or altering the results and/or destruction of the 

records of these types of items), may indicate that best practices might not have been followed, 

but would not impact the adequacy/accuracy of the recorded external and bioassay results used in 

dose reconstruction, unless they involved the actual records of the external doses and internal 

intakes of an RFP worker for which there were no duplicate form(s) of the necessary data 

available. 

SC&A’s Conclusion Concerning the RFP Interviews 

Alteration of data, bioassay processing/data, and destruction of documents were discussed during 

the interviews. However, SC&A did not find any firm indications that essential individual 

personnel records needed for dose reconstruction were knowingly altered or destroyed, or that 

bioassay samples were improperly processed. SC&A found that, in general, the issues identified 

were not directly related to NIOSH’s ability to perform radiation dose reconstruction. While 

some of the issues may indicate that operational and health physics practices could have been 

improved, and that as low reasonably achievable (ALARA) standards may not have always been 

implemented, these issues would not have a direct impact on the data needed to reconstruct dose 

for individual workers. 

It should be clarified that SC&A did not have direct access to the examples of documents 

shredded by Interviewee #6 (listed in Table 1 above) and as discussed in SRDB Ref ID #132787 

(NIOSH 2014). SC&A based its evaluation of this interview on the examples and summaries 

provided in NIOSH 2014.

SC&A did find that the NIOSH white paper (NIOSH 2015), page 14, referenced the SRDB 

interview document NIOSH 2014 for Interviewee #6. In NIOSH 2014, there appears to be an 

instance on page 1, Item 1, f. iii, where NIOSH may have incorrectly stated that the higher of the 

Hand or Forearm handwritten doses from the form on PDF page 52 [not page 53] of the DOE file 

in the NIOSH/OCAS Claims Tracking System (NOCTS) were carried forward to the later 

version of the printed form on PDF page 77 of the DOE file in NOCTS. However, this statement 

appears to be in error, because the Hand doses do not appear in the later version of the form on 

PDF page 77 of the DOE file in NOCTS. This would not impact the dose reconstruction,

because the original handwritten record is also available to the dose reconstructor in the DOE file 

in NOCTS. 

Related Articles

SC&A reviewed articles related to data falsification, bioassay processing/data, and document 

destruction as discussed in NIOSH’s white paper. SC&A has summarized the most pertinent 

information in the following table. 
Memo – RFP: Evaluation Status 4 SC&A – July 10, 2015 

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

Table 2. Summary of Articles in NIOSH’s White Paper

Article Main Contents NIOSH Page # Main SRBD Ref #

A An insider's view of Rocky Flats: Urban myths debunked – 2010 9 104858

B DOE assessment of environmental conditions at the RFP – 1989 9–10 21359

C Are you prepared to survive an FBI raid at your facility – 1995 10 122696

D DOE initial agency decision case concerning reprisals – 1999 10 125051

E Grand jury report from the 1989 FBI raid at the RFP – 1994 11 126910

F RFP occupational radiological control program – Pre & Post-1989 11–13 126860

G RFP Technical safety appraisal – 1988 22–24 131058

H RFP manager notebook – mid 1980s 25 143317

SC&A’s Conclusion Concerning RFP-Related Articles 

SC&A reviewed each of these articles and found that, in general, the documents were concerned 

with other aspects of RFP operations or environmental issues, rather than data falsification, 

record destruction, or bioassay data, that would potentially impact the ability to perform 

adequate dose reconstructions. 

4.0 RFP Environmental TBD 

Although not addressed in NIOSH’s white paper, SC&A has found that the RFP Occupational 

Environmental Dose technical basis document (TBD) ORAUT-TKBS-0011-4 (ORAUT 2007) 

could contain dose reconstruction recommendations that relied on the collection and handling of 

environmental data. The 1989 FBI raid, and concurrent DOE investigations, did raise questions 

concerning the validity of environmental sample analyses; therefore, because in certain situations 

some of the claimants’ doses may be assigned using the data and recommendations in ORAUT 

2007, SC&A reviewed this TBD to determine if issues with environmental samples/data could 

potentially impact dose reconstruction. This was not a complete technical review of ORAUT 

2007, but only a review to determine if there are potential areas in this TBD that may rely on 

environmental data obtained during the timeframe in question; i.e., pre- and post-1989. The 

following is a brief summary of SC&A’s review of ORAUT 2007: 

 Pages 10–16 discuss the source terms for two periods, Operational (pre-1993) and 

post-operational (post-1992). In this section, Table 4-3 presents the site-wide 

maximum annual median inhalation intake of 239,240Pu and 241Am (1965 to 2005), 

based on monitoring data. 

 Attachment A, pages 33–54, discuss the estimation of plutonium air concentrations at 

the RFP for various time periods spanning 1964 through 2005. It contains the 

following relevant tables and figures: 

o Figure A-3, page 42 – Annual average 239,240Pu concentrations in air as a 

function of time for particles <30-μm AED in RFP industrial area (1953–

1990). 
Memo – RFP: Evaluation Status 5 SC&A – July 10, 2015 

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

o Figure A-4, page 43 – Annual average 239,240Pu concentrations in air as a 

function of time for particles <30-μm AED in the perimeter area surrounding 

RFP (1953–1990). 

o Table A-1, page 47 – Monthly average concentrations (fCi/m3) of total longlived alpha activity in onsite air samples, October 1964 to December 1971. 

o Table A-2, page 50 – Estimated annual average concentrations (fCi/m3) of 

239,240Pu in onsite air samples between 1965 and 1994, based on measurement 

data provided in Table A-1, RFP annual environmental reports, RFETS 

monthly and quarterly monitoring reports, and CDPHE quarterly 

environmental surveillance reports. 

o Table A-3, page 51 – Annual average concentrations (fCi-m3) of plutonium in 

air for three location groups, RFP contractor monitoring, (1971–1990). 

o Table A-6, page 54 – Corrected annual average concentrations of 239,240Pu in 

air at perimeter monitoring stations (1971–1990). 

There are indications in the TBD that some of the data in the above listed figures and tables were 

derived from RFP environmental data (e.g., as underlined in the above list), in addition to data 

from outside contractors (e.g., Rope et al. 1999). 

SC&A’s Conclusion Concerning the RFP TBD-4

SC&A is not aware of any evaluation that has been conducted to determine if the RFP and 

contractor data used to generate these radionuclide intakes were impacted by the environmental 

sampling/data issues that surfaced from the 1989 FBI raid or the 1989 DOE investigation and the 

evaluation that followed. Therefore, SC&A suggests that the RFP Environmental Dose TBD be 

evaluated in view of the environmental issues related to the 1989 raid to determine if any of the 

environmental issues impact the data contained in the ORAUT 2007 when used for dose 

reconstruction purposes. 
Memo – RFP: Evaluation Status 6 SC&A – July 10, 2015

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

REFERENCES

DOE 1989. Assessment of Environmental Conditions at the Rocky Flats Plant, United States 

Department of Energy, Golden, CO, August 1989. SRBD Ref ID: #21359.

EPA 1989. Report of Rocky Flats October 24, 1989 Interview. United States Environmental 

Protection Agency, Office of Criminal Investigations, October 26, 1989. SRBD Ref ID: 

#122614.

NIOSH 2014. Follow-up call with [interviewee] on Documents submitted for Rocky Flats Plant, 

National Institute for Occupational Safety and Health, Division of Compensation

Analysis and Support, Cincinnati, Ohio. May 14, 2014. SRBD Ref ID: #132787.

NIOSH 2015. Evaluation of Petitioner Concerns About Data Falsification and Data 

Invalidation in RFP Building 123 Based on Worker Allegations and Issues Relating to the FBI 

Raid, Rev. 3, National Institute for Occupational Safety and Health, Division of Compensation

Analysis and Support, Cincinnati, Ohio. June 24, 2015

ORAUT 2007. Technical Basis Document for the Rocky Flats Plant – Occupational 

Environmental Dose, ORAUT-TBKS-0011-4, Rev. 02, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. April 23, 2007.

Rope, S.K, K.R. Meyer, M.J. Case, H.A. Grogan, D.W. Schmidt, M. Dreicer, and T.F. Winsor, 

1999. Evaluation of Environmental Data for Historical Public Exposures Studies on Rocky 

Flats, Task 4: Evaluation of Environmental Data, Final Report, Revision 1, RAC Report 1-

CDPHE-RFP-1997-Final (Rev. 1), Radiological Assessments Corporation, Neeses, South 

Carolina, August.

SC&A 2013. SC&A’s Review of DOE’s RFP August 1989 Environmental Report Concerning 

potential data falsification or improper bioassay analyses. SC&A, Inc., Vienna, Virginia, and 

Saliant, Inc., Jefferson, Maryland. December 2013.

SRBD Ref ID: #104858. An Insider's View of Rocky Flats: Urban Myths Debunked” 2010. 

SRBD Ref ID: #122696. Are You Prepared To Survive An FBI Raid At Your Facility, KaiserHill Co., L.L.C. Nuclear Information and Records Management Association 19th Annual 

Symposium. Washington, DC. August 1995.

SRBD Ref ID: #125051. DOE Initial Agency Decision, United States Department of Energy, 

Washington D.C. August 6, 1999. 

SRBD Ref ID: #126860. Sample Handling in 771 Labs [RFP], United States Department of 

Energy, Golden, CO, February 16, 1996. 
Memo – RFP: Evaluation Status 7 SC&A – July 10, 2015

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

SRBD Ref ID: #126910. Colorado Federal District Court Report of the Federal District Special 

Grand Jury 89-2. Denver, Colorado. January 24, 1992. 

SRBD Ref ID: #131058. Technical Safety Appraisal: Buildings 776/777 Rocky Flats Plant, 

United States Department of Energy, Golden, CO, March 1988. 

SRBD Ref ID: #143317. RFP Manager’s Notebook, United States Department of Energy, 

Golden, CO, 1986.