S E, C.- o o a t-r i 

Special ·exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

U.S. Department of Healt.h and Human Services 

Centers for Disease Control and Prevention 

National Institute for OccupaUonal Safety §ind Health 

0MB Number: 0920-0639 

General Instructions on Completing this Form (complete instructions are available in a separate packet): 

Except for signatures, please PRINT all information clearly and neatly on the form. · 

Please read each of Parts A - G in this form and complete the sections appropriate to you. If there is more 

than one petitioner, then each petitioner should complete those sections of Parts A - C of the form that apply 

to them. Additional copies of the first two pages of this form are provided at the end of the form for this 

purpose. A maximum of three petitioners is allowed. 

If you need more space to provide additional information, use the continuation page provided at the end of 

the form and attach the completed continuation page(s) to Form B. 

For Further Information: If you.have questions about the use of this form, please call the following NIOSH 

toll-free phone number and request to speak to someone in the Division of Compensation Analysis and 

Support about an SEC petition: 1-877-222-8570. 

If you 

are: 

D A Labor Organization, 

D An Energy Employee (current or former), 

D A Survivor (of a former Energy Employee), 

CX A Representative (of a current or former Energy Employee); 

Start at D 

Start at C 

Start at B 

Start at A 

A. Representative Information Complete Part A if you are authorized by an Energy Employee or 

Survivor(s) to petition on behalf of a class. 

A.1 Are you a contact person for an organization? D Yes (Go to A.2) 129 No (Go to A.3) 

A.2 Organization Information: 

Name of Organization 

Position of Contact Person 

A.3 Name of Petition Representative: 

Mr./Mrs./Ms. First Name 

A.4 Address of Petition Representative: 

Street 

City State 

Middle Initial Last Name 

Apt# P.O. Box 

A.5 Telephone Number of Petition Representative: ( 

Zip Code 

A.6 Email Address of Petition Representative: 
Special Exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

U.S. Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health -

0MB Number: 0920-0639 Expires: 10/31/2019 

Pa e2of7 

I 

R 1 Name of Survivor: 

Mr./Mrs./Ms. First Name Middle Initial 

B.2 Address of Survivor: 

Street 

City State 

B.3 Telephone Number of Survivor: 

B.4 Email Address of Survivor: 

B.5 Relationship to Energy Employee: D Spouse 

OGrandparent 

Goto Partc. 

Last Name 

Apt# 

Zip Code 

D Son/Daughter 

DGrandchild 

P.O. Box 

OParent 

C. Energy Employee Information Complete Part C UNLESS you are a labor organization. 

C.1 Name of Energy Employee: 

Mr./Mrs./Ms. First Name Middle Initial Last Name 

C.2 Former Name of Energy Employee (e.g., maiden name/legal name change/other): 

Mr./Mrs./Ms. First Name Middle Initial Last Name 

C.3 Address of Energy Employee (if living): 

Street Apt# P.O. Box 

City State Zip Code 

C.4 Telephone Number of Energy Employee: (.~ ____ _ 

C.5 Email Address of Energy Employee: 

C.6 Employment Information Related to Petition: 

C.6a Energy Employee Number (if known): _1 _______________ _ 

C.6b Dates of Employment: Start __ 19_7_5 _____ _ End 1996 

C.6c Employer Name: ROCKWELL INTERNATIONAL 

C.6d Work Site Location: DESOTO FACILITY 

LOS ANGELES COUNTY, CALIFORNIA 

C.6e Supervisor's Name: _________________ _ 

Go to Part E. 
Special Exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

- . D.1 Labor Organization Information: 

Name of Organization 

Position of Contact Person 

D.2 Name of Petition Representative: 

Mr./Mrs./Ms. First Name 

D.3 Address of Petition Representative: 

Street 

City State 

U.S. Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health 

0MB Number: 0920-0639 

Middle Initial Last Name 

Apt# P.O. Box 

Zip Code 

D.4 Telephone Number of Petition Representative: ( ___ _, _____________ _ 

D.5 Email Address of Petition Representative: 

D.6 Period during which labor organization represented energy employees covered by this petition 

(please attach documentation): 

Start End 

D.7 Identity of other labor organizations that may represent or have represented this class 

of energy employees (if known): 

. , ' .Go to Part'E . .. .. ':,' 
Special Exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

U.S. Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health 

0MB Number: 0920-0639 

E.1 Name of DOE or AWE Facility: _D_E_S_O_T_O_F_A_C_I_LI_T_Y ______________ _ 

E.2. Locations at the Facility relevant to this petition: 

DESOTO FACILITY - LOS ANGELES COUNTY, CA 

E.3 List job titles and/or job duties of energy employees included in the class. In addition, you can 

list by name any individuals other than petitioners identified on this form who you believe 

should be included in this class: 

ALL JOB TITLES - ALL LOCATIONS 

E.4 Employment Dates relevant to this petition: 

Start 

Start 

Start 

JAN. 1, 1965 End 

End 

End 

DEC. 31, 1995 

E.5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or 

recorded exposure incidents?: ~ Yes D No 

If yes, provide the date(s) of the incident(s) and a complete description (attach additional pages as 

necessary): 

NIOSH has determined it cannot reconstruct radiation dose for americium, thorium, or associated progeny at SSFL Area IV, 

1965-1988. Based on shared contractor and operational history, shared data limitations between SSFL Area 

IV/ DeSoto Facility, and the established presence of americium, thorium and associated progeny at DeSoto Facility until at 

least 1995, the following petition is submitted. Supplemental documentation is attached, in support of this petition . 

. Go· to Part F. 
Special Exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

U.S. Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health 

Special Exposure Cohort Petition - Form B 

0MB Number: 0920-0639 Expires: 10/31/2019 

P 5 . f 7 

F. Basis for Proposing that Records and Information are Inadequate for Individual Dose 

Reconstruction Complete Part F. 

Complete at least one of the following entries in this section by checking the appropriate box and providing 

the required information related to the selection. You are not required to complete more than one entry. 

F.1 []I I/We have attached either documents or statements provided by affidavit that indicate that 

radiation exposures and radiation doses potentially incurred by members of the proposed class, 

that relate to this petition, were not monitored, either through personal monitoring or through area 

monitoring. 

(Attach documents and/or affidavits to the back of the petition form.) 

Describe as completely as possible, to the extent it might be unclear, how the attached 

documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored. 

Historical Facility Records and Other Documentation 

F.2 Q9 I/ We have attached either documents or statements provided by affidavit that indicate that 

radiation monitoring records for members of the proposed class have been lost, falsified, or 

destroyed; or that there is no information regarding monitoring, source, source term, or process 

from the site where the energy employees worked. 

(Attach documents and/or affidavits to the back of the petition form.) 

Describe as completely as possible, to the extent it might be unclear, how the attached 

documentation and/or affidavit(s) indicate that radiation monitoring records for members of the 

proposed class have been lost, altered illegally, or destroyed. 

Historical Facility Records and Other Documentation 

· Part F is ·continued on the followin 
Special Exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

U.S. Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health 

Special Exposure Cohort Petition - Form B 0MB Number: 0920-0639 Expires: 10/31/2019 

Pa e6of7 

F.3 l!l IM/e have attached a report from a health physicist or other individual with expertise in 

radiation dose reconstruction documenting the limitations of existing DOE or AWE records on 

radiation exposures at the facility, as relevant to the petition. The report specifies the basis for 

believing these documented limitations might prevent the completion of dose reconstructions for 

members of the class under 42 CFR Part 82 and related NIOSH technical implementation 

guidelines. 

(Attach report to the back of the petition form.) 

F.4 lxl IM/e have attached a scientific or technical report, issued by a government agency of the 

Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory 

Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed 

journal, that identifies dosimetry and related information that are unavailable (due to either a lack 

of monitoring or the destruction or loss of records) for estimating the radiation doses of energy 

employees covered by the petition. 

(Attach report to the back of the petition form.) 

d date the petition. A maximum of three persons may sign the petition. 

,~ -13-1 ± 

Date 

Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of 

fact or any other act of fraud to obtain compensation as provided under EEOICPA or who 

knowingly accepts compensation to which that person is not entitled is subject to civil or 

administrative remedies as well as felony criminal prosecution and may, under appropriate 

criminal provisions, be punished by a fine or imprisonment or both. I affirm that the information 

provided on this form is accurate and true. 

Send this form to: SEC Petition 

Division of Compensation Analysis and Support 

NIOSH 

1090 Tusculum Ave, MS-C-47 

Cincinnati, OH 45226 

If there are additional petitioners,.they mu,s_t complete the Appendix Foims for additional petit!oners .. 

, ·_. ' The Appendix for~s·are locatecl'atthe end of this document. , . ·. ·, . ," 
Special Exposure Cohort Petition 

under the Energy Employees Occupational 

Illness Compensation Program Act 

U.S. Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health 

0MB Number: 0920-0639 

Special Exposure Cohort Petition - Form B Expires: 10/31/2019 

Paae 7 of 7 

Public Burden Statement 

Public reporting burden for this collection of information is estimated to average 5 hours per response, 

including time for reviewing instructions, gathering the information needed, and completing the form. If you 

have any comments regarding the burden estimate or any other aspect of this collection of information, 

including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton 

Road, MS-E-11, Atlanta GA, 30333; ATTN: PAA 0920-0639. Do not send the completed petition form to this 

address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions. 

Persons are not required to respond to the information collected on this form unless it displays a currently 

valid 0MB number. 

Privacy Act Advisement 

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the 

following: 

The Energy Employees Occupational Illness Compensation Program Act (42 U.S.C. §§ 7384-7385) 

(EEOICPA) authorizes the President to designate additional classes of employees to be included in the 

Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the 

assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease 

Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional 

classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory 

Board on Radiation and Worker Health and HHS. 

Records containing identifiable information become part of an existing NIOSH system of records under the 

Privacy Act, 09-20-147 "Occupational Health Epidemiological Studies and EEOICPA Program Records and 

WTC Health Program Records, HHS/CDC/NIOSH." These records are treated in a confidential manner, 

unless otherwise compelled by law. Disclosures that NIOSH may need to make for the processing of your 

petition or other purposes are listed below. 

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal 

agencies, other government or private entities and to private sector employers to permit these entities to 

retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these 

individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting 

NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations; 

(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a 

Congressional staff member in response to a verified inquiry. 

This notice applies to all forms and informational requests that you may receive from NIOSH in connection 

with the evaluation of an SEC petition. 

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these 

forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to 

provide required information may not be considered by HHS. 
File Number: 

AUTHORIZATION FOR REPRESENTATION & PRIVACY ACTWAIVER 

to serve as my representative in all matters pertaining to the adjudication of my claim under the Energy Employee 

Occupational Illness Compensation Program Act of 2000 (EEOICPA), and to receive copies of all factual and medical 

evidence contained in my claim filed under the Energy Employee Occupational Illness Compensation Program Act of 

2000 (EEOICPA) -(rom the Office ofWorkers' Compensation Programs. U.S. Department of labor: 

I declare that the foregoing is true and correct. This authorization is effective on the date it is signed, and is effective 

until specifically revoked by me in writing. 

Pagel of I 
Special Exposure Cohort (SEC) Petition 

DeSoto Facility 

1965-1995 

For Review by: 

National Institute for Occupational Safety and Health (NIOSH) 

Presidential Advisory Board on Radiation and Worker Health (ABRWH) 

Presented to NIOSH / ABRWH December 13, 2017 

SEC Petition: D~Soto 1965-1995 
Introduction to the SEC Petition for DeSoto Facility: 1965-1995 

I respectfully submit a Special Exposure Cohort (SEC) Petition for DeSoto Facility (1965-1995). 

Based on the circumstances described herein, I respectfully ask that the National Institute for Occupational 

Safety and Health (NIOSH) and the Presidential Advisory Board on Radiation and Worker Health (ABRWH) 

engage in an expeditious evaluation of the petition. 

This petition honors the contributions of one of the pioneering of the nuclear 

industry during the Cold War, and a claimant under the Energy Employee Occupational Illness Compensation 

Program Act (EEOICPA, or "the Act").1 

In addition, this petition is submitted on behalf of all employees of North American Aviation Atomics 

International / Rocketdyne, its corporate successors and its subcontractors, whose efforts during the Cold 

War and Race to Space often came at great personal sacrifice. 

It is a privilege to represent the workers of Santa Susana Field Laboratory (SSFL) and its associated sites 

under EEOICPA. I thank you for the opportunity to provide the following information. 

Sincerely, 

SEC Petition: DeSoto 1965-1995 2 
The Proposed Class Definition 

The proposed class includes all employees of the Department of Energy (DOE), its predecessor 

agencies, their contractors and subcontractors who worked at the DeSoto Facility in Los Angeles County, 

California from January 1, 1965 through December 31, 1995 tor a number of work days aggregating at 

least 250 work days, occurring either solely under this employment or in combination with work days 

within the parameters established tor one or more other classes of employees included in the Special 

Exposure Cohort (SEC). 

Basis for the Class 

Between January 1, 1965 and December 31, 1995 DeSoto Facility and Santa Susana Field Laboratory 

(SSFL) were involved in operations with shared contractors and subcontractors, including nuclear 

research and development, fuel fabrication, gamma irradiation, mass spectroscopy of neutron-irradiated 

samples, various radiochemistry operations, decontamination and decommissioning (D&D), Site 

Remediation, and other operations conducted in concert with and in support of DOE programs at SSFL 

Area IV. DeSoto Facility routinely used and handled americium, thorium and its associated progeny, tor 

which NIOSH determined cannot reconstruct radiation dose with sufficient accuracy at SSFLArea IV. 

In 2017, NIOSH acknowledged that SSFL and DeSoto Facility "really represent a single entity, when it 

comes to operating contractor and employment." NIOSH stated that, since both sites are related and 

operated under the same Health Physics oversight program, NIOSH uses a single Technical Basis 

Document (TBD) tor both sites. 

In addition, NIOSH stated that SEC-00156 and SEC-00168 were initiated to cover the same time period, 

at both sites, because the same data limitations that affected SSFL Area IV also affected DeSoto Facility. 

Further, all data used tor dose reconstruction tor employees at SSFL Area IV / DeSoto Facility comes 

from the same place; The Boeing Company ("Boeing'').2 

NIOSH acknowledged that when it initiated SEC-00156 (SSFL Area IV, 1959-1964), it recognized the 

need to initiate SEC-00168 (DeSoto Facility, 1959-1964) based on shared contractor operations, joint 

participation in DOE programs, shared work processes and rotating personnel, shared materials and 

practices between the sites, the same radiological record-keeping programs, and the same data 

limitations in dose reconstruction. Through the course of ongoing dose reconstruction, data capture 

efforts and investigations associated with SEC-00156 / SEC-00168, NIOSH found the following issues at 

SSFL Area IV and DeSoto Facility, tor the time period 1959-1964: 

- Insufficient controls employed at both sites, resulting in some employees who should have been 

monitored but were not, and who could have received unmonitored intakes of radioactive materials. 

- Inability to track worker movements throughout either site, or between the sites. 

- Inability to identity a specific workgroup that was not potentially exposed to radioactive materials, 

releases or possible subsequent contamination resulting from DOE operations at SSFL Area IV or 

DeSoto Facility. 

- Insufficient information available tor NIOSH to associate job titles / job assignments with specific 

radiological operations or conditions. 

I 

SEC Petition: DeSoto 1965-1995 3 
- Insufficient site-specific and claimant-specific data to define potential radiation exposure conditions 

based on worker job descriptions. 

- A lack of access to sufficient personnel monitoring, workplace monitoring, or source term data to bound 

potential unmonitored internal exposures that may have occurred for workers at SSFL Area IV or 

DeSoto Facility, between the years 1959-1964. 

On August 2, 2016 NIOSH initiated SEC-00234 (SSFL Area IV, 1965-1988) based on the inability to 

reconstruct dose for americium and thorium with sufficient accuracy. NIOSH stated that it decided not to 

initiate an SEC class for DeSoto Facility for the same time period because DeSoto Facility "did not work 

with" americium or thorium. 

The following documentation clearly shows the presence and use of americium and thorium at DeSoto 

Facility. Current TBD's considered to be part of the SSFL Site Profile and used by NIOSH in dose 

reconstruction for SSFL Area IV and DeSoto Facility workers reference americium, thorium and 

associated progeny at DeSoto Facility. 

ORAUT-TKBS-0038-4: "Energy Technology Engineering Center (ETEC) Occupational 

Environmental Dose" (2006) verifies that Th-228, Th-230, Th-232 and Am-241 were present in stack 

effluent at DeSoto Facility and SSFLArea IV between 1959-1999.3 

"A Review of ORAUT-OTIB-0800, Rev. 00: Internal Coworker Dosimetry Data for Area IV of the 

Santa Susana Field Laboratory and the DeSoto Avenue Facility" (2014) describes work processes 

that involved the grinding of thorium at DeSoto Facility Building 001 in 1979, supported by a citation to 

historical facility documentation.4 s 

The U.S. Environmental Protection Agency (EPA) listed americium, thorium and associated progeny as 

"Radionuclides of Concern" at over 60 SSFL Area IV locations during the Area IV Historical Site 

Assessment and Radiological Characterization Study. The majority of the locations were excluded from 

the SSFL Site Profile. Many were directly involved in processes and operations that required the 

participation of DeSoto Facility.s 

NIOSH has not demonstrated that it can reconstruct dose for americium or thorium after 1988, although it 

is reasonable to assume that Site Remediation workers (many of whom rotated between DeSoto and 

SSFL on an as-needed and undocumented basis) would encounter the materials during the course of 

D&D. As NIOSH has acknowledged the presence of americium, thorium and its associated progeny at 

both SSFL Area IV and DeSoto Facility until at least 1999, it raises questions about NIOSH's decisions to 

end SEC-00234 at 1988 and not to initiate a similar SEC class for DeSoto Facility. 

The Boeing Incident Report Database, which is in the possession of NIOSH, contains numerous incident 

reports that document the use of americium, thorium and associated progeny at DeSoto Facility well into 

a Oak Ridge Associated Universities (ORAU), "ETEC - Occupational Environmental Dose," 2006. 

Document No. ORAUT-TKBS-0038-4. 

4 S. Cohen & Associates (SC&A), "A Review of ORAUT-OTIB-0080, Rev. 00: Internal Coworker Dosimetry Data for 

Area IV of the Santa Susana Field Laboratory and the DeSoto Avenue Facility," SCA-TR-OTIB2014-0080, Revision 0, 

11/2014. sca-ortib80r0-r0.pdf 

s Begley, F.E., 1979b. Internal letter from F.E. Begley to R.J. Tuttle, "Thorium Grinding Operation Use Authorization 

120,"March 20, 1979. 

s U.S. Environmental Protection Agency (EPA), Draft Final Historical Site Assessment (HSA), Santa Susana Field 

Laboratory (SSFL) Area IV Radiological Characterization Study, Ventura County, CA. 2012. 

SEC Petition: DeSoto 1965-1995 4 
the Site Remediation period. In addition, supportive documents referenced in this petition show that 

DeSoto Facility: 

• Participated in the fabrication, examination, reprocessing, and storage of spent nuclear fuel including 

uranium-thorium (U-Th) Fuel associated with the Sodium Reactor Experiment (SAE), fabrication and 

analysis of Systems for Nuclear Auxiliary Power (SNAP) fuel, and transuranic materials containing 

americium (Am-241) under the Transuranic Management Pyropartitioning (TRUMP-S) program. 

• Routinely accepted waste generated by all DOE Atomics International programs at SSFL Area IV 

• Rotated waste and radioactive materials between the DeSoto Facility Building 001 SS Vault and various 

Area IV locations, where americium and thorium are among the established "Radionuclides of 

Concern." 

• Was licensed to store and to use special nuclear materials including americium and thorium 

• Routinely handled and shipped americium and thorium. 

Based on the documented presence of americium, thorium and its associated progeny at DeSoto Facility 

and NIOSH's acknowledgment that it cannot conduct dose reconstruction for americium or thorium with 

sufficient accuracy, the basis for the SEC class at DeSoto Facility is firmly established. 

Supportive Documentation 

Facility records show that DeSoto Facility engaged in processes including the acceptance and analysis of 

spent uranium-thorium (U-Th) fuel from the Sodium Reactor Experiment (SAE), and that it was stored at 

the DeSoto Facility Building 001 SS Vault.7 a 9 10 

DeSoto Facility maintained a dedicated area to fabricate fuel associated with the Systems for Nuclear 

Auxiliary Propulsion (SNAP) program at Buildings 001 and 004. Based on the characteristics of 

Americium-241 (Am-241 ), its relationship to plutonium, its use in conjunction with beryllium, its presence 

in relation to SNAP operations at DeSoto Facility should be closely examined. All SSFL Area IV locations 

affiliated with SNAP operations are sites where americium and thorium were identified as "Radionuclides 

of Concern" by EPA.11 

The DeSoto Facility Log Book details acceptance and routine rotation of radioactive and contaminated 

materials from the SSFL Area IV Special Nuclear Materials Handling Facility (Building 4064) to and from 

the DeSoto Facility Building 001 SS Vault. SSFL Area IV Building 4064 was built to house fissionable 

material and to store special nuclear materials and source radioactive material (enriched uranium, 

plutonium, thorium, and U-233) in various forms and configurations. It also housed spent fuel casks and 

radioactive wastes generated by all DOE Area IV programs. Building 4064 processes included the 

7 Atomics International, Atomic Energy Commission (AEC) Research and Development Report, • SRE Fuel Element 

Damage, Final Report," 1961. NAA-SR-4488_Suppl.pdf 

8 Atomics International, "Design Modifications to the SRE During FY 1960," NAA-SR-5348. NAA-SR-5348.pdf 

9 Rockwell International to Atomic Energy Division, Re: Letter J.F. Proctor to W.F. Heine, 7/2/75. 

HDMSE00024566.pdf 

10Atomics International- Log Book, DeSoto Facility. 1964-1965. HDMSP01640471.pdf 

11 Atomics International, "Feasibility Report for Fabrication of SNAP Fuel Elements," 12/11/1963. 4078934.pdf 

SEC Petition: DeSoto 1965-1995 5 
opening, splitting, and repackaging of radioactive materials, and the storage of 55-gallon drums of lowlevel enriched recoverable scrap. 12 

It is reasonable to review the documented materials and working conditions at SSFL Area IV and to 

consider the likelihood of potential exposure and cross-contamination between the worksites. In 1988, 

Rockwell International conducted a radiological survey of Building 4064 and found it to be contaminated 

with normal and depleted uranium and thorium, thought to be the result of dust associated with the 

handling of bare metallic pieces. 13 

The DeSoto Facility and SNAP Building 4012 Log Books show materials transfer between SSFL Area IV / 

DeSoto Facility routinely relied on the reuse of containers known as "birdcages," which were used to 

transport radioactive materials and frequently found to be severely contaminated with various 

radionuclides as they circulated among and between all SSFL Area IV / DeSoto radiological locations. 14 

Atomics International and its corporate successors maintained current Special Nuclear Materials Licenses 

(SNM-21 / 1059-59), issued by the Nuclear Regulatory Commission (NRC). The licenses specified 

nuclear materials, including americium and thorium, that would be stored and used across a broad 

application of nuclear research and development, handling and processes. The licenses also specified 

the locations of materials use and storage: DeSoto Facility and SSFL Area IV. In 1995, Rockwell 

International renewed and modified the licenses to include activities related to D&D activities / Site 

Remediation at both facilities. 1s 

A 1999 radiological survey of the Mass-Spectroscopy Laboratory at DeSoto Facility Building 104 

confirmed the presence of Th-232 and Th-238. The document also confirms that waste generated by 

D&D efforts at DeSoto Facility Building 104 was sent to SSFL Area IV, further supporting the established 

longevity and continuity of shared operations and processes at both sites through the Site Remediation 

period. 16 

DeSoto Facility Log Books 

In 2016, the DeSoto Facility Log Book was provided to NIOSH as part of a larger compilation submitted to 

correct the SSFL Site Profile. The document, "2016 SSFL: Proposed Corrections to Technical Basis 

Documents 1 & 2 (ORAUT-TKBS-0038-1 /ORAUT-TKBS-0038-2)"was uploaded to the NIOSH docket. 

A section on DeSoto Facility contains select Log Book entries. A complete copy of the DeSoto Facility Log 

Book is respectfully provided again, in support of this petition.17 

12 Montgomery Watson Harza, DOE Leach Fields (Area IV AOC) RCRA Facility Investigation Report, SSFL, Ventura 

County, CA, Draft, October 2003. 

13 Chapman, J.A., Radiological Survey of the Source and Special Nuclear Material Storage Vault- Building 4064, 

8/19/88. GEN-ZR-0005. HDMSP00023980.pdf 

14 Log Book, SSFLArea IV Building 4012 (SNAP), 1962-1966. HDMSP001852993.pdf 

1s State of California Department of Public Health, Applications for License Renewal. M.E. Remley, 117/1969. 

HDMSP001812995.pdf 

Rockwell International I Department of Health Services, Updated Application for Broad Scope "A" License 0015-70, 

Reference to 95RC-04277. 8/10/95. HDMSP001865866pdf 

1s Lupo, R.K., "Confirmatory Survey of Mass Spectroscopy Laboratory, Building 104 DeSoto Facility, BoeingRocketdyne, n7 /30/99. DHS_ Verification_Survey _MSL.pclf 

11 Atomics International - Log Book, DeSoto Facility. 1964-1965. HDMSP01640471.pdf 

SEC Petition: DeSoto 1965-1995 6 
The DeSoto Facility Log Book contains daily entries describing routine work processes and materials 

used at the worksite during the mid-1960's. There are several references to americium and thorium, SAE 

U-Th fuel processes, and materials transport between SSFLArea IV Building 4064 / DeSoto SS Vault. In 

addition, the Log Book contains entries that describe lapses in the control of radiological materials, 

inconsistent monitoring practices, and inconsistent training of new employees in radiation safety. 

Although some of the Log Book entries were made prior to 1965, they still validate the presence of 

americium and/or thorium at the worksite. Entries made after 1965 further confirm that processes 

remained routine and continuous; there is no evidence to suggest that the operational relationship 

between SSFL Area IV and DeSoto Facility changed after January 1, 1965. 

Select Entries - DeSoto Facility Log Book 

November 12, 1964: Thorium contamination resulted from thorium oxide sifting with sieves that did not fit 

tightly. An airborne release of thorium caused the room to become contaminated. The description of the 

work process suggests that the sifting of thorium oxide was a routine procedure at DeSoto Facility. 

March 30, 1965: Contaminated "cans" from the SAE, containing U-Th fuel elements, were removed from 

the DeSoto Facility SS Vault and transported to the DeSoto Facility Machine Shop, for cutting and 

removal of the elements. After 1964, activities involving the reprocessing of irradiated SAE fuel 

assemblies were assumed to have been confined to SSFL Area IV Building 4003 (ETB, Hot Cave). 

April 13, 1965: A container of Am-241 crystals logged for transfer, DeSoto Bldg. 001 to DeSoto Bldg. 004. 

May 20, 1965: A shipment of thorium oxide logged at DeSoto Facility SS Vault. 

May 21, 1965: A box of thorium oxide logged for transport to an outside contractor. 

May 28, 1965: Four shipments, SAE U-Th fuel elements, surveyed prior to DeSoto SS Vault storage. 

May 28, 1965: Milling depleted uranium in the "cold" machine shop occurred. 

June 4, 1965: "Cans" of enriched-U fuel taken to DeSoto Building 005 for weighing in clean area. 

August 23, 1965: 55-gallon drum, SAE radioactive material, shipped from DeSoto Vault to SSFL Area IV. 

Boeing Incident Report Database 

NIOSH is in possession of the Boeing Incident Report Database. Several incident reports reference the 

use of americium and thorium at DeSoto Facility. Some of the incident reports are referenced below, and 

copies of the reports have been provided to support this petition. 

1959 Incidents at Headquarters: A "can" containing 10 U-Th fuel slugs was removed from the DeSoto 

Facility SS Vault without notifying Health Physics (HP). The employee took the container of U-Th into the 

SNAP II area of DeSoto Facility. According to the HP, such an amount of fuel in the SNAP II area was, 

"bordering a definite possibility of criticality." Although the event occurred during the SEC period at 

DeSoto Facility, it verifies the storage of U-Th fuel at the DeSoto Facility SS Vau1t. 1a 

,a Boeing Incident Report Database, Incident Reports at HQ 1959. NIOSH is in possession of the Boeing Incident 

Report Database. 

SEC Petition: DeSoto 1965-1995 7 
1970 - Incident Report #A0328 - DeSoto Facility Building 001: Cutting of wires contaminated with 

UAlx, indicating work with spent nuclear fuel. 19 

1986 - Incident Report #A0154 - DeSoto Facility Building 106: Radioactive source of Am-241 taken 

offsite without authorization or license.20 

1989 - Incident Report #A0200 - DeSoto Facility Building 106: A shipment of radioactive materials 

containing plutonium and Am-241, used for the Transuranic Management Pyropartitioning Program 

(TRUMP-S) was delivered to the address listed on SNM-21: The DeSoto Facility "Receiving Area," 

Building 106. It was subsequently transferred to SSFL Area IV Building 4064. The incident report 

identifies poor management of special nuclear materials due to inadequate training, new employees, and 

a lack of apprenticeship programs. It confirms that radioactive and transuranic materials were received at 

DeSoto Facility ("Headquarters") prior to shipment to SSFL Area 1v.21 

Historical Facility Documents 

1971: Internal Letter Re: Inspection of SNM Vault Rooms & Vault Pad 

An internal letter verifies storage of thorium and several "birdcages" containing SNAP fuel at the DeSoto 

SS Vault and various other locations at DeSoto Building 001. The document describes the inventory of 

the vault, involvement of the Security Department (Protective Services) in transport of materials to SSFL's 

Radioactive Materials Disposal Facility (RMDF) and/or vault located at SSFLArea IV Building 4064.22 

1972: Annual Fuels Committee Inspection of DeSoto Facility and SSFL 

The NAA Atomics International Fuels Committee conducted an annual review and inspection of DeSoto 

Facility and SSFL Area IV during which the presence of SNAP fuel stored in ''birdcages" in the mezzanine 

area of DeSoto's SNAP Fuels Fabrication Area at the DeSoto Building 001 Storage Vault is documented. 

The document references various DeSoto Facility locations where SNAP fuel was fabricated and stored, 

and the [then] current inventory of enriched SNAP fuel at each location:23 

Vault Pad 

Vault 

SNAP Vault 

SNAP Fuel Fabrication 

QC Lab 

Analytical Chem Lab 

Building 001 

Building 001 

Building 001 

Building 001 

Building 001 

Building 004 

19 Boeing Incident Report Database, Report #A0328: Exposure of Individual During Cut-Off Operation. May 6, 1970. 

a-0328_pii-redacted.pdf 

20 Boeing Incident Report Database, Report #A-0154: Radiological Safety Incident Report. DeSoto Building 106 -

Americium-241. March 7, 1986. a-0154.pdf 

21 Boeing Incident Report Database, Report #A-0200: Delay in Performing Required Radiological Survey of a R/A 

Materials Package. TRUMP-S. July 20, 1989. a-0200.pdf 

22 Atomics International Internal Letter, H.E. Clow, Criticality & Nuclear Materials Controls, NAA-AI. 11/11/1971. 

HDMSP001839892.pdf 

23 North American Aviation Atomics International, "Safeguards Annual Facilities Review: Fuels Committee Annual 

Review and Inspection of Facilities at Headquarters and Nuclear Field Laboratory," M.E. Remley, 9/20/72. 

HDMSP001807625.pdf 

SEC Petition: DeSoto 1965-1995 8 
1973: Internal Letter Re: SNAP Program Close-Out 

The document describes actions that would be taken involving the close-out of the SNAP program at 

DeSoto Facility / SSFL Area IV. At DeSoto Facility Building 001, general actions included the removal of 

all SNAP building improvements; walls, ceiling and utilities to point of connection (POC) to restore the 

area to original condition. The processes described are consistent with SNAP D&D / Site Remediation. In 

potentially contaminated areas, surveyed were ordered with decontamination as recommended.24 

1973: Internal Letter Re: Weekly Highlights - Criticality & Nuclear Materials Controls 

During the SNAP close-out, un-irradiated enriched archive samples of U-235 at the SSFL Area IV Hot 

Laboratory (Building 4020) were transferred to DeSoto Facility Building 001 SS Vault MBA 01 for later 

shipment to scrap recovery, or to be reprocessed. The consolidation of SNAP natural uranium (U) had 

begun. Some had been transferred to the DeSoto Building 001 SS Vault. The document describes the 

preparation of general criteria for the storage of SNAP fuel in "birdcages," drums and on shelves at the 

SS Vaults at DeSoto and SSFLArea 1v.2s 

1973: Criteria for the DeSoto Facility SS Vault Storage/ SNAP "Birdcages" 

Thorium was stored at DeSoto Facility during the close-out of the SNAP program. NAA Atomics 

International studied the combined storage of fuels in their storage containers on vault shelves, as well as 

in SNAP "birdcages" and in approved shipping containers using the reduced safety factors allowable for 

storage at a facility. The document, "Criteria for the SS Vault Storage (SNAP and Other Fuels)" 

establishes the storage criteria for SNAP and other types of fuel during SNAP's close-out phase. It was 

recommended that the central shelf section (in the middle of the DeSoto Vault, MBA-01) be used to store 

thorium, natural and depleted uranium, only. An earlier document, entitled, "DeSoto SS Vault Criticality 

Operating Criteria," NAA-001-140-003 (11/13/1970) is also referenced.2s 

1983: Worker Rotation Between SSFL and DeSoto Facility 

It has been established that employees routinely rotated between SSFL and DeSoto Facility without 

appropriate identifiers, documentation, or even adequate monitoring. Documentation continues to surface 

that details the inability to reliably track worker movements between SSFL and DeSoto Facility. 

1983: Rockwell Internal Letter, Re: Listing of Personnel Assigned to Nuclear Facilities 

An internal letter authored by indicates that a list of 

personnel assigned as "radiation workers" was discovered, for a project that "does not exist." According to 

the author of the correspondence: 

" ... Such a list is easy to generate at the beginning of a program, but falls into disuse 

even more easily with time. While managers generally inform RNS of assignments of 

personnel to a nuclear facility, this information often does not get recorded. To correct 

this, please make a list of radiation workers at your facility and periodically (or as people 

come and go) update it. This should not be a problem, except for RMDF [Area IV 

24 North American Rockwell Internal Letter, "SNAP Program Close-Out," M.E. Remley, 1/9/1973. 

HDMSP001841591.pdf 

2s North American Rockwell Internal Letter, Weekly Highlights - Criticality and Nuclear Materials Controls - SNAP 

Close-Out,"M.E. Remley, 2/9/1973. HDMSP001856250.pdf 

26 Atomics International Supporting Document# Tl-652-240-019, "5 Kwe I TE Unmanned System Test, Criteria for the 

SS Vault Storage (SNAP and Other Fuels)," M.E. Remley. 3/15n3. H DMSP001856058.pdf 

SEC Petition: DeSoto 1965-1995 9 
Radioactive Materials Disposal Facility], NMDF [Area IV Nuclear Materials Development 

Facility] and RIHL [Area ·1v Rockwell International Hot Laboratory] where people shift a lot." 

The document includes a list of DeSoto Decommissioning Radiation Workers. Several of these individuals 

are also listed on SSFL Area IV documents, and shown to have performed job duties at Area IV 

radiological facilities during the same time period; further supporting poorly documented worker rotation 

between SSFLArea IV and DeSoto Facility well into the Site Remediation period.21 

Boeing Employment Verification Confirms Inability to Determine Worker locations 

Boeing states that after 1999, employee work locations "were the same for Canoga Facility as they were 

for DeSoto Facility," indicating that it is unable to verify work locations, and cannot determine which 

employees rotated between Canoga and DeSoto Facilities. 

In a growing number of cases, workers who clearly meet established eligibility criteria (and even qualify 

for an existing SEC) are disqualified from EEOICPA in error. Boeing routinely provides misleading and 

inaccurate information in lieu of authentic employment records. Boeing's information misrepresents the 

employee as affiliated with a non-covered location or facility; however when authentic records are 

obtained they routinely verify covered employment (and even radiation monitoring). The inability to obtain 

authentic employment records, or to rely on Boeing's information to be accurate, compromises dose 

reconstruction. I can provide multiple examples where this has occurred, upon request.2a 

. DOE - SSFL Former Worker Interviews, Final Report 

In 2009, as part of the Historical Site Assessment and Area IV Radiological Characterization Study, DOE 

and EPA conducted formal interviews with former employees of SSFL, Canoga and DeSoto Facility. The 

employees provided consistent testimony describing joint projects, undocumented worker rotation 

between SSFL areas and associated facilities, and their recollection of working conditions at the sites. 

The DOE SSFL Former Worker Interview Final Report has been provided to NIOSH on two occasions, 

since 2014. I respectfully provide another copy in support of this petition.29 

DOE Interviewee #106 

A former NAA states that he began working for NAA in 1954, and routinely worked back-andforth between SSFL, DeSoto and VanOwen facilities. He stated that many times, workers weren't even 

clocked in; they used "the honor system" and many times, he worked "off the clock." The employee stated 

that workers were not exclusive to one department, as NAA would move employees around based on skill 

set and phase of project I program development. In addition, the employee states that work was done at 

both SSFL and DeSoto because, "it was easier to move the piece that needed tooling, rather than the 

tooling to the work." 

It appears that the employee is referencing the transport of certain components, assemblies, or other 

equipment / materials in need of machining or other processes, between SSFL / DeSoto, as required. 

21 Rockwell International, Internal Letter Re: Listing of Personnel Assigned to Nuclear Facilities," R.J. Tuttle, 1983. 

HDMSP001815173.pdf 

28 Redacted, The Boeing Company ''lime Clock Location Summary." DAR2.pdf 

29 U.S. Department of Energy (DOE), Santa Susana Field Laboratory (SSFL) Former Worker Interviews, November 

2011. Interviewee #106. 

SEC Petition: DeSoto 1965-1995 10