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SEC Petition Evaluation Report

Petition SEC-00192

 

Report Rev #:1 Report Submittal Date: September 30, 2013

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

Mutty Sharfi, Chris Miles

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, thorium, uranium-233 and associated progeny, and/or neptunium-237 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

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

at the Rocky Flats Plant in Golden, Colorado, from April 1, 1952 through December 31, 1983, for 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 for one or more other classes of employees included in the Special Exposure Cohort.

Related Petition Summary Information 

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

SEC-00030

SEC00192, Rev. 0

83.13

83.13

Rocky Flats Plant

Rocky Flats Plant

Two classes added to the SEC:

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

Jan. 1, 1959 through Dec. 31, 1966

Evaluation specific to tritium:

No class added to the SEC

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: James Bogard ORAU Peer Review Completed By: Daniel Stempfley

Peer Review Completed By: [Signature on File] 9/30/2013

LaVon B. Rutherford Date

[Signature on File] 9/30/2013 SEC Petition Evaluation Reviewed By:

J. W. Neton Date

[Signature on File] 9/30/2013 SEC Evaluation Approved By:

Stuart L. Hinnefeld Date
SEC-00192 09-30-13 Rocky Flats Plant

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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. As a result of the 

initial qualification of petition SEC-00192, and the identification of issues associated with the 

incomplete analysis of tritium during the original evaluation for Rocky Flats petition SEC-00030, 

NIOSH evaluated the following class for Rev. 0 of this SEC-00192 evaluation report: 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 through December 31, 2005. 

As a result of the presentation of Rev. 0 of this SEC-00192 evaluation report to the Advisory Board, 

and the subsequent review by the Board working group, the petitioner and NIOSH, additional issues 

were identified that required further evaluation. Therefore, the class evaluated by NIOSH in Rev. 1 of 

this report has been expanded to include: All employees of the Department of Energy, its predecessor 

agencies, and their contractors and subcontractors with the potential for tritium, thorium, uranium-233 

and associated progeny, and/or neptunium-237 exposures while working at the Rocky Flats Plant in 

Golden, Colorado, during the period from April 1, 1952 through 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 tritium radiation doses with 

sufficient accuracy. However, in the process of subsequent classified and unclassified document 

reviews and interviews (after initial presentation of Rev. 0 of this evaluation report to the Advisory 

Board), NIOSH identified issues that prevent estimation with sufficient accuracy exposures to 

thorium, uranium-233 and associated progeny, and neptunium-237. Therefore, NIOSH is proposing 

the following class be added to the SEC: All employees of the Department of Energy, its predecessor 

agencies, and their contractors and subcontractors who worked at the Rocky Flats Plant in Golden, 
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Colorado, from April 1, 1952 through December 31, 1983, for 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 for one or more other classes of employees included in the Special 

Exposure Cohort.

Feasibility of Dose Reconstruction

NIOSH finds it is not feasible to estimate internal exposures with sufficient accuracy for all workers at 

the site from April 1, 1952 through December 31, 1983 due to insufficient data. With the exception of 

this class, 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 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 (January 1, 1984 through December 31, 

2005). 

The NIOSH dose reconstruction feasibility findings are based on the following:

• NIOSH finds that it is likely feasible to reconstruct occupational medical dose for Rocky Flats 

workers with sufficient accuracy.

• Principal sources of internal radiation for members of the proposed class included exposures to 

tritium, thorium, uranium-233 and associated progeny, and/or neptunium-237. The modes of exposure 

for all four radionuclides of concern were ingestion and inhalation.

• The potential for tritium exposures existed from the beginning to the end of RFP operations, and 

was associated with, and the result of, the receipt and reprocessing of tritium-contaminated 

weapons components returned to the site. Based on the assessment presented in 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.

• Thorium exposure was related to fabrication of metal parts from natural thorium or thorium alloys, 

use of oxide (“thoria”) as a mold coating compound, use in compounds in analytical procedures 

and research and development, and use as a substitute for U or Pu components in research and 

development. NIOSH has evaluated the available personnel and workplace monitoring data and 

has determined that these data are insufficient for estimating internal thorium exposures. In the 

absence of adequate in vitro or in vivo bioassay, NIOSH would employ source term data. 

However, NIOSH lacks sufficient source term data that are inclusive of the throughput amounts of 

thorium (i.e., they only represent a snapshot in time in regards to quantities); these data do not 

support estimating potential internal exposures to thorium during the period of RFP thorium 

operations from April 1, 1952 through December 31, 1966.
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• Uranium-233 and associated progeny exposure was related to receipt and processing of U-233 

residues. Processing involved thorium strikes to extract Th-228, which was containerized and 

shipped to Idaho National Laboratory. The uranium was then converted to a peroxide and 

ultimately reduced to U-233 metal. In its review of available bioassay records for individuals 

identified as having worked in U-233 processing areas, NIOSH has determined that uranium 

bioassay data may not be available for all potentially-affected individuals. In additional, these 

same workers were also potentially exposed to Th-228. NIOSH lacks thorium bioassay data for 

Rocky Flats personnel. Furthermore, NIOSH has determined that workplace air monitoring and 

contamination surveys for U-233 processes are insufficient for dose reconstruction purposes.

Without uranium and thorium bioassay results, NIOSH has concluded that it cannot estimate with 

sufficient accuracy the potential internal exposures to U-233, U-232, and Th-228 which the 

proposed class may have received from 1964 through 1983.

• Neptunium-237 exposure was associated with, and the result of, preparation of pure neptunium 

oxide, metal and metal alloys, and the recovery of Np-237 from a variety of residues, including 

sand, slag, crucibles, casting skulls, and alloys. Processes included dissolution, anion exchange, 

precipitation, filtration, calcination, conversion to fluoride, and reduction to metal. Fabrication 

steps such as casting and rolling were also sometimes performed for the production of high-purity 

metal shapes and foils. Evidence points to a number of specific tasks performed at the request of 

other DOE laboratories from 1962 until around 1983, involving a few grams to a few hundred 

grams of neptunium. NIOSH has evaluated the available personnel and workplace monitoring 

data and has determined that these data are insufficient for estimating internal neptunium 

exposures. In the absence of adequate in vitro or in vivo bioassay, NIOSH would employ source 

term data. However, NIOSH lacks sufficient source term data that are inclusive of the throughput 

amounts of neptunium (i.e., they only represent a snapshot in time in regards to quantities). These 

data do not support estimating potential internal exposures to neptunium during the period of RFP 

neptunium operations from January 1, 1962 through December 31, 1983.

• The principal sources of external radiation doses for members of the proposed class were 

evaluated in the SEC-00030 Rocky Flats Plant Evaluation Report. SEC-00030 concluded that all 

external dose except neutrons could be estimated with sufficient accuracy. This revision of SEC 

Evaluation Report SEC-00192 was initiated based on NIOSH’s subsequent research and 

determination that internal radiation exposures to U-233, thorium, and Np-237 could not be 

reconstructed; consequently, 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.

• Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient information to 

either: (1) 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 (2) estimate the radiation doses of members of the class more precisely 

than a maximum dose estimate.
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• Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed 

Rocky Flats during the period from April 1, 1952 through December 31, 1983, but who do not 

qualify for inclusion in the SEC, may be performed using these data as appropriate.

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate dose for the members 

of the proposed class from April 1, 1952 through December 31, 1983.

NIOSH did not identify any evidence supplied by the petitioners or from other resources that would 

establish that the proposed class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high-level exposures. However, evidence indicates that some workers in the 

proposed class may have accumulated substantial exposures through chronic and/or episodic intakes 

of thorium, uranium-233 and associated progeny, and neptunium-237. Consequently, NIOSH has 

determined that health was endangered for those workers covered by this evaluation who were 

employed for at least 250 aggregated work days either solely under their employment or in 

combination with work days within the parameters established for other SEC classes.

For the period January 1, 1984 through December 31, 2005, 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........................................................................................................................ 11

2.0 Introduction .................................................................................................................................. 11

3.0 SEC-00192 Rocky Flats Plant Class Definitions ......................................................................... 12

3.1 Petitioner-Requested Class Definition and Basis................................................................ 13

3.2 Class Evaluated by NIOSH ................................................................................................. 13

3.3 NIOSH-Proposed Class(es) to be Added to the SEC.......................................................... 14

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class........................................................... 14

4.1 Site Profile Technical Basis Documents (TBDs)................................................................ 15

4.2 Technical Information Bulletins and Procedures................................................................ 15

4.3 Facility Employees and Experts.......................................................................................... 16

4.4 Previous Dose Reconstructions........................................................................................... 21

4.5 NIOSH Site Research Database .......................................................................................... 22

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 22

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH......................................... 22

5.1 Rocky Flats Plant and Process Descriptions ....................................................................... 23

5.1.1 Tritium Related Operations..................................................................................... 24

5.1.2 Thorium Related Operations ................................................................................... 30

5.1.3 U-233 Related Operations....................................................................................... 31

5.1.4 Np-237 Related Operations..................................................................................... 32

5.2 Tritium Exposure Sources, Radiological Programs, and Incidents..................................... 33

5.2.1 Exposure Sources from Tritium Operations............................................................ 34

5.2.2 Tritium Radiological Programs............................................................................... 36

5.2.3 Tritium Incidents..................................................................................................... 37

5.3 Thorium Exposure Sources, Radiological Programs, and Incidents................................... 40

5.3.1 Exposure Sources from Thorium Operations.......................................................... 40

5.3.2 Thorium Radiological Programs ............................................................................. 41

5.3.3 Thorium Incidents ................................................................................................... 41

5.4 U-233 Exposure Sources, Radiological Programs, and Incidents....................................... 41

5.4.1 Exposure Sources from U-233 Operations.............................................................. 41

5.4.2 U-233 Radiological Programs................................................................................. 45

5.4.3 U-233 Incidents....................................................................................................... 45

5.5 Np-237 Exposure Sources, Radiological Programs, and Incidents..................................... 46

5.5.1 Exposure Sources from Np-237 Operations............................................................ 46

5.5.2 Np-237 Radiological Programs............................................................................... 48

5.5.3 Np-237 Incidents..................................................................................................... 48
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6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 50

6.1 Available Rocky Flats Plant Internal Monitoring Data....................................................... 50

6.1.1 Available RFP Internal Monitoring Data for Tritium ............................................. 50

6.1.1.1 SEC-00192, Rev. 0 Tritium Data Follow-up............................................ 53

6.1.2 Available RFP Internal Monitoring Data for Thorium............................................ 57

6.1.3 Available RFP Internal Monitoring Data for U-233 ............................................... 57

6.1.4 Available RFP Internal Monitoring Data for Np-237 ............................................. 57

6.2 Available Rocky Flats Plant External Monitoring Data...................................................... 59

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH...................................... 59

7.1 Pedigree of Rocky Flats Plant Data..................................................................................... 60

7.1.1 Tritium Monitoring Data Pedigree Review............................................................. 60

7.1.2 Thorium Monitoring Data Pedigree Review ........................................................... 61

7.1.3 U-233 Monitoring Data Pedigree Review............................................................... 61

7.1.4 Np-237 Monitoring Data Pedigree Review............................................................. 61

7.2 Evaluation of Bounding Internal Radiation Doses at Rocky Flats...................................... 61

7.2.1 Evaluation of Bounding Process-Related Tritium Doses........................................ 61

7.2.1.1 SEC-00192, Rev. 0 Tritium Dose Feasibility Follow-up......................... 62

7.2.1.2 Internal Tritium Dose Reconstruction Feasibility Conclusion................. 80

7.2.2 Evaluation of Bounding Process-Related Thorium Doses...................................... 80

7.2.2.1 Methods for Bounding Thorium Dose at Rocky Flats ............................. 81

7.2.2.2 Internal Thorium Dose Reconstruction Feasibility Conclusion ............... 81

7.2.3 Evaluation of Bounding Process-Related U-233 Doses.......................................... 82

7.2.3.1 U-233 Urinalysis Information and Available Data .................................. 82

7.2.3.2 U-233 Airborne Survey Data.................................................................... 82

7.2.3.3 Evaluation: Bounding Ambient Environmental Internal U-233 Doses.... 83

7.2.3.4 Methods for Bounding U-233 Dose at Rocky Flats................................. 83

7.2.3.5 Internal U-233 Dose Reconstruction Feasibility Conclusion................... 84

7.2.4 Evaluation of Bounding Process-Related Np-237 Doses........................................ 84

7.2.4.1 Np-237 Urinalysis Information and Available Data ................................ 84

7.2.4.2 Np-237 Airborne Survey Data.................................................................. 84

7.2.4.3 Internal Np-237 Dose Reconstruction Feasibility Conclusion................. 85

7.3 Evaluation of Bounding External Radiation Doses at Rocky Flats..................................... 86

7.4 Evaluation of Petition Basis for SEC-00192....................................................................... 87

7.4.1 Incidents .................................................................................................................. 87

7.4.2 Building 460 Plutonium .......................................................................................... 87

7.4.3 Tritium Exposures................................................................................................... 88

7.4.4 Previous Issues – RFP Site Profile .......................................................................... 88

7.4.5 Information Not Provided in the Previous SEC Evaluation.................................... 89

7.4.6 Adequacy of Co-worker Models............................................................................. 89

7.4.7 Analysis Laboratories.............................................................................................. 90

7.4.8 Analysis Laboratories.............................................................................................. 91

7.4.9 Site and Process Information................................................................................... 91
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7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation...... 92

7.5.1 Post-SEC-00192, Rev. 0 SEC Issues Follow-up ..................................................... 99

7.6 Summary of Feasibility Findings for Petition SEC-00192................................................ 101

8.0 Evaluation of Health Endangerment for Petition SEC-00192.................................................... 102

9.0 Class Conclusion for Petition SEC-00192 ................................................................................. 102

10.0 References .................................................................................................................................. 105

Attachment 1: Data Capture Synopsis................................................................................................. 121

Figures

5-1: Total Rocky Flats Neptunium Inventory by Quarter .................................................................... 49

7-1: Case A Chronic Intake of HTO from April 11 through April 25, 1973 ...................................... 73

7-2: Case A Acute Intake of HTO on September 19, 1973................................................................. 74

7-3: Case B Chronic Intake of HTO from July 1 through September 25, 1973.................................. 74

7-4: Case B Acute Intake of HTO on September 19, 1973 ................................................................. 75

7-5: Case B Acute Intake of HTO on July 1, 1973 ............................................................................. 75

7-6: Case C Acute Intake of HTO on August 27, 1973....................................................................... 76

7-7: Case C Chronic Intake of HTO from August 27 through Sept. 25, 1973.................................... 76

7-8: Case D Chronic Intake of HTO from April 10 through April 25, 1973 ...................................... 77

7-9: Case D Chronic Intake of HTO from April 10 through June 15, 1973........................................ 78

7-10: Case H Acute Intake of HTO on April 6, 1973 ........................................................................... 78
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Tables

4-1: No. of Rocky Flats Claims Submitted Under the Dose Reconstruction Rule................................ 21

5-1: Rocky Flats Plant Development Chronology and Population Over Time ..................................... 24

5-2: RFP Key Facilities with Potential Tritium Exposures................................................................... 26

5-3: RFP Key Facilities with Potential Thorium Exposures................................................................. 31

5-4: Location of Rocky Flats U-233 Activities..................................................................................... 43

5-5: Summary of RFP U-233 Quantity Estimated To Be Present at Any One Time............................ 44

5-6: Characteristics of U-233 Material Processed at RFP..................................................................... 45

5-7: RFP Neptunium-237 Fiscal-Year-End Inventories........................................................................ 47

6-1: Available RFP Tritium Data from 128 NOCTS Claims................................................................ 52

6-2: Rocky Flats Tritium Bubbler Information in the SRDB................................................................ 54

7-1: Reported Tritium Air Concentrations (μCi/m3

) from the August 30, 1974 Release ..................... 66

7-2: Tritium Activity Concentrations in Room Air: Rm. 452 - Special Assembly - Bldg. 777............ 67

7-3: Tritium Urinalysis Results - Exposed Workers and Others, August 30, 1974 .............................. 68

7-4: Tritium Smear Surveys - Work Areas in Buildings 776-777......................................................... 69

7-5: Summary of Intake Assessments for the RFP 1973 Incident......................................................... 79

7-6: April 1965 Air Sample Results from Building 771, Room 114..................................................... 82

7-6: Summary of Feasibility Findings for SEC-00192........................................................................ 101
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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: James 

Bogard, 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 all employees of the Department of 

Energy, its predecessor agencies, and their contractors and subcontractors with the potential for 

tritium, thorium, uranium-233 (and associated progeny), and neptunium-237 exposures while working 

at the Rocky Flats Plant in Golden, Colorado, 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.

 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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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 

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 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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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.

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. Subsequent to the presentation of Rev. 0 of this SEC-00192 evaluation 

report to the Advisory Board, the Board-assigned working group and petitioner identified other issues 

beyond tritium requiring additional response. NIOSH’s follow-up research identified further issues as 

well. Therefore, the class evaluated by NIOSH in this report was expanded to include: All employees 

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

the potential for tritium, thorium, uranium-233 and associated progeny, and/or neptunium-237 

exposures while working at the Rocky Flats Plant in Golden, Colorado, during the period from April 

1, 1952 to December 31, 2005.
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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. However, in the process of responding to issues raised during the review and 

evaluation of Rev. 0 of this SEC-00192 evaluation report, NIOSH’s research confirmed issues that 

prevent estimating with sufficient accuracy exposures to thorium, uranium-233 and associated 

progeny, and/or neptunium-237. Therefore, NIOSH is proposing the following class be added to the 

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

subcontractors who worked at the Rocky Flats Plant in Golden, Colorado, from April 1, 1952 through 

December 31, 1983, for 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 for 

one or more other classes of employees included in the Special Exposure Cohort.

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 effort included searches of the OSTI OpenNet Advanced

system, OSTI Information Bridge Fielded system, Nuclear Regulatory Commission (NRC) Agencywide Documents Access and Management (ADAMS) system, the DOE Office of Human Radiation 

Experiments website, the DOE-National Nuclear Security Administration-Nevada Site Office system, 

the Defense Technical Information Center (DTIC), the DOE Comprehensive Epidemiologic Data 

Resource (CEDR), the DOE Hanford Declassified Document Retrieval System (DDRS), National 

Archives and Records Administration sites (NARA), the Nuclear Information and Records 

Management Association (NIRMA) database, the Oak Ridge Institute for Science and Education 

(ORISE) database, and the University of Colorado Norlin Library. Attachment 1 contains a complete 

list of databases/libraries searched as well as 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.
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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

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 and procedure as part of its evaluation:

• OTIB: Tritium Calculated and Missed Dose Estimates, ORAUT-OTIB-0011; Rev. 00; June 29, 

2004; Oak Ridge Associated Universities; 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
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• Procedure: Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUT-PROC0060; Rev. 01; June 28, 2006; Oak Ridge Associated Universities (ORAU); SRDB Ref ID: 20213

4.3 Facility Employees and Experts

To obtain additional information, NIOSH interviewed 48 former RFP employees and subject experts. 

NIOSH performed individual in-person interviews, telephone interviews, email interchanges, and 

worker outreach meetings in Colorado to obtain additional information regarding tritium, plutonium 

and neptunium exposures and monitoring at RFP.

• Personal Communication, 2003, Personal Communication with [redacted]; Email interchange; 

July 30, 2003; SRDB Ref ID: 25014

• Personal Communication, 2007, Personal Communication with [redacted]; In-person Interview by 

ORAU staff; May 15, 2007; SRDB Ref ID: 92798

• Personal Communication, 2008, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; May 14, 2008; SRDB Ref ID: 44428

• Personal Communication, 2009, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; February 2, 2009; SRDB Ref ID: 59674

• 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

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122515

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122516

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122517

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122550

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122551

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122553

• Personal Communication, 2012s, Personal Communication with [redacted]; In-person Interview 

by ORAU staff; November 6, 2012; SRDB Ref ID: 122666

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122667

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122668

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122669

• Personal Communication, 2013a, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 15, 2013; SRDB Ref ID: 122627
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• Personal Communication, 2013b, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 15, 2013; SRDB Ref ID: 122628

• Personal Communication, 2013c, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 16, 2013; SRDB Ref ID: 122624

• Personal Communication, 2013d, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 18, 2013; SRDB Ref ID: 122625

• Personal Communication, 2013e, Personal Communication with [redacted]; In-person Interview 

by ORAU staff; January 22, 2013; SRDB Ref ID: 122623

• Personal Communication, 2013f, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 22, 2013; SRDB Ref ID: 122629

• Personal Communication, 2013g, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 23, 2013; SRDB Ref ID: 122626

• Personal Communication, 2013h, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 31, 2013; SRDB Ref ID: 122670

• Personal Communication, 2013i, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; January 31, 2013; SRDB Ref ID: 122671

• Personal Communication, 2013j, Personal Communication with [redacted]; In-person Interview 

by ORAU staff; February 5, 2013; SRDB Ref ID: 122466 

• Personal Communication, 2013k, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 4, 2013; SRDB Ref ID: 122805

• Personal Communication, 2013l, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 4, 2013; SRDB Ref ID: 122806

• Personal Communication, 2013m, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 4, 2013; SRDB Ref ID: 122807

• Personal Communication, 2013n, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 5, 2013; SRDB Ref ID: 122808

• Personal Communication, 2013o, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 14, 2013; SRDB Ref ID: 122907

• Personal Communication, 2013p, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 7, 2013; SRDB Ref ID: 123337
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• Personal Communication, 2013q, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; March 11, 2013; SRDB Ref ID: 123762

• Personal Communication, 2013r, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; July 18, 2013; SRDB Ref ID: 126995

• Personal Communication, 2013s, Personal Communication with [redacted]; Telephone Interview 

by ORAU staff; August 20, 2013; SRDB Ref ID: 127272

• Personal Communication, 2013t, Personal Communication with [redacted]; email to ORAU staff; 

September 18, 2013; SRDB Ref ID: 127751

• 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

• Worker Outreach Meeting email follow-up interchange, 2012c, Colorado Worker Outreach 

Meeting with former RFP Workers 10:00 AM session; Email follow-up with a participant at the 

public outreach meeting by ORAU and NIOSH staff; Meeting: May 24, 2012, email follow-up 

interchange: May 25 and 29, 2012; SRDB Ref ID: 118770

Collective Summary of Information Gathered from RFP Interviews

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

collective summary of the information from the interviews and meetings indicate the following:

Tritium Related Information

Six of the interviews were with former employees who worked at RFP prior to the 1973 tritium 

incident.

- 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.
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- 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.

Thorium Related Information

- Interviews related to thorium were focused on thorium strikes, which were directly related to 

U-233.

U-233 Related Information

- Interviews related to thorium were focused on thorium strikes, which were directly related to 

U-233.

- Some interviewees said that multiple thorium strikes may have occurred before U-233 processing; 

- Other interviewees had heard about the presence of thorium on site, but did not know what a 

thorium strike was.

Np-237 Related Information

- Neptunium bioassay may have been performed in the Building 771 (operations area) laboratory 

prior to the early 1980s.

- There were written manuals for the Building 123 HS&E laboratory that were published and 

exchanged between the laboratories located in different buildings; however, outdated procedures 

were not archived prior to the early 1980s.

- Gross alpha analysis was used for early assessments of uranium and plutonium exposures and was 

not intended as a screening analysis for workers exposed to other radionuclides.
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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 September 

12, 2013)

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

Description Totals

Total number of claims submitted for dose reconstruction1 1963

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

under evaluation (April 1, 1952 to December 31, 2005) (i.e., the number of such claims completed 

by NIOSH and submitted to the Department of Labor for final approval). 1519

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

Labor for final approval). 82

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

evaluated class definition 1507

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

evaluated class definition 128

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

evaluated class definition 2

Number of claims for which uranium2 bioassay records were obtained for the identified years in the 

evaluated class definition 1028

Number of claims for which Np-237 bioassay records were obtained for the identified years in the 

evaluated class definition 1

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

evaluated class definition 1638

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

 existing SECs. 2 Although one focus of this evaluation is U-233, it is unlikely there will be U-233 bioassay identified; it is

 more likely that bioassay would be identified as uranium. 
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4.5 NIOSH Site Research Database

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

assessment of the evaluated class. 4106 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)

• Email from [redacted]; September 29, 2012 and October 1, 2012; Subject: Rocky Flats worker 

interviews; DSA Ref ID: 119323

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, 

thorium, U-233 and associated progeny, and neptunium. However, during the feasibility evaluation 

for SEC-00192 Rev. 0, 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. 

This report is specific to the assessment of tritium, thorium, U-233 and associated progeny, and 

neptunium. For discussions and assessments that cover RFP exposures above and beyond those 

exposures, refer to the SEC-00030 Evaluation Report. Discussion of topics beyond those discussed in 

Section 7.5 will not be included in this ER.

The following subsections summarize tritium, thorium, U-233, and neptunium operations at the Rocky 

Flats Plant (RFP) from April 1, 1952 to December 31, 2005, and the information available to NIOSH 

to characterize those particular processes and radioactive source quantities. From available sources 

NIOSH has attempted to gather 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.
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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. While the previous Rocky Flats Plant SEC 

evaluation, SEC-00030, assessed potential exposure issues (see Section 7.5 of this report), other issues 

have been brought up during discussions with the Board working group and petitioner requiring 

additional research and evaluation. Consequently, this SEC-00192 evaluation focuses on those 

operations/activities with the potential for tritium, thorium, U-233, and neptunium exposures;

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

initially began with uranium production and shifted in the 1960s to plutonium production, which 

continued through 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.

1990s2006--- Pu 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.

Plant population had grown to over 10,000 

(including contractors and subcontractors) by 

the very early 1990s (Personal 

Communication, 2013t). 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).

5.1.1 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 
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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 

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).

 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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Other Potential Tritium Sources

Another known tritium-related operation was associated with neutron generator 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; 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 sealed-tube 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.
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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

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.

444 DU and Beryllium Metallurgy: This facility contained a 

neutron generator with tritiated targets. Titanium 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.
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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

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.

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. In the 1950s and 1960s, 

778 had a cafeteria in the west end and offices in the east end 

of the building (Personal Communication, 2013t). 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.
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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

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

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.
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5.1.2 Thorium Related Operations

Thorium was present at Rocky Flats Plant facilities starting from the beginning of operations in 1952, 

at least through 1975, with quantities varying from 0 or gram quantities to 238 kilograms in any one 

month at the site (ChemRisk 3&4, 1992, pdf p. 136; Thorium Bounding, 2008; RFP, 1976). The site 

used thorium in various ways including:

- Fabrication of metal parts from natural thorium or thorium alloys

- Use of oxide (“thoria”) as a mold-coating compound

- In compounds used in numerous analytical procedures and research and development programs.

- As a substitute for U or Pu components in various research and development activities and 

programs.

- The removal of Th-228 (referred to as a thorium strike performed during U-233 processing – to be 

discussed in that section of this report).

- Mg-Th alloy work is being assessed and addressed as part of a follow-up being performed outside 

the scope of this evaluation; therefore, further discussion of that operation is not included in this 

report.

While the consensus of the contributors and authors of the thorium reference documents was that the 

quantities and concentrations of thorium on site over the years at RFP were minimal, there was the 

potential for thorium exposures to certain populations on site. The available documentation supports 

the existence of thorium on site in the early 1950s through the development of internal and external 

thorium-monitoring processes (Monthly Reports, 1956-1957; Monthly Progress Reports, 1953-1963; 

Monthly Progress Reports, 1958).
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Table 5-3 summarizes the key processes with the potential for thorium exposures. All processing 

buildings were demolished as of October 2005.

Table 5-3: RFP Key Facilities with Potential Thorium Exposures

Buildings Facilities1 Date of Start-up 

of Operations Comments

331 Plant Garage: Building 331 was the location of 

shearing small quantities of thorium. Handled ~240 

kg (3 80 kg ingots).

1960 Thorium Bounding, 2008, 

indicates thorium exposure.

334 Maintenance Shop: Building 334 was the location 

of shearing small quantities of thorium.

unknown ChemRisk 3&4, 1992, p. 136, 

indicates thorium exposure.

771 Special Recovery Laboratory: Bldg. 771 was used 

for some small scale thorium work of an unspecified 

nature, using a few kilograms of thorium.

unknown ChemRisk 3&4, 1992, p. 136, 

indicates thorium exposure.

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 U233 and Pu were also handled. The facility 

contained a neutron generator with tritiated targets.

1950s and 1960s ChemRisk 3&4, 1992, p. 136; 

RFP, 1994b, pg 164, indicates 

thorium exposure.

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. Handled ~240 kg (3 80 kg 

ingots).

1960 Thorium Bounding, 2008, 

indicates thorium exposure.

1 Inventory numbers are included in Table 5-3; however, these numbers are not reflective of RFP throughput for 

 any particular time period or year at the site. Inventory numbers for U-233 are provided in Table 5-5.

5.1.3 U-233 Related Operations

The U.S. government evaluated materials that could serve as alternative sources of nuclear fuels for 

weapons and reactors. One of the alternative sources identified was uranium-233. U-233 was 

produced as a transmutation of thorium when thorium is placed in a reactor neutron flux. It was also 

concluded that U-233 could be more easily separated from thorium than U-235 could be separated 

from U-238. While there were many advantages to the thorium fuel cycle, a major disadvantage was 

the generation of U-232, which was a contaminant in the production of U-233. U-232 has decay 

products that emit highly-energetic gammas, which pose a significant personnel external radiation 

hazard (Buildings 9205 and 9212, 1964; Building, 9202, 1974; ORNL, 1998, pdf pp. 17-20; RFP, 

1965b; Thorium U-233 Symposium, 1958). One solution for removing the source of the highlyenergetic gammas was to remove the Th-228, which occurs at a point in the decay scheme before the 

primary sources of the highly-energetic gammas. This Th-228 removal process was called a “thorium 

strike” (Dow, 1965, pdf p. 13).
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Shipments of U-233 residues were sent from Oak Ridge to RFP for processing. Based on the 

available documentation, U-233 operations and refining also took place at Hanford, SRS, INEEL, 

ANL-W, LANL, and LLNL (which also used fuel from several commercial nuclear power plants). 

Several other national laboratories had small research quantities of U-233 (SRDB 117226). Available 

data indicate that RFP activities involving U-233 residue processing occurred between 1964 and 1983 

(Dow, 1972; RFP, 1999). 

5.1.4 Np-237 Related Operations

Neptunium processing at Rocky Flats included preparation of pure neptunium oxide, metal and metal 

alloys, and the recovery of Np-237 from a variety of residues (Conner, 1981, pdf p. 6). Processes 

employed included dissolution, anion exchange, precipitation, filtration, calcination, conversion to 

fluoride, and reduction to metal. Fabrication steps such as casting and rolling were also sometimes 

performed for the production of high-purity metal shapes and foils. Neptunium was recovered from 

residual materials including sand, slag, crucibles, casting skulls, and alloys (Np-Sn, Np-U, and 

Np-Zr).

The first special-order request for neptunium processing at Rocky Flats came from Lawrence 

Radiation Laboratory (now Lawrence Livermore National Laboratory, LLNL), which required 

high-purity neptunium with gamma-emitting impurities removed. Techniques for purifying 

neptunium (including the removal of other actinides) were developed as a result of this project. The 

project also called for preparation of Np-Pu alloys, which were prepared by co-reducing Np and PuF4

mixtures with calcium metal. This technique led to a capability for producing pure Np metal that 

could be cast with Pu or U to form alloys. The first Np-Pu alloy was produced in 1964, and several 

kilograms of Np metal were produced in subsequent years for preparing U and Pu alloys. Other 

specific projects that involved Np processing included the preparation of high-purity neptunium oxide 

for the Oak Ridge National Laboratory isotope pool, neptunium metal foils for the Savannah River 

Plant, and neptunium metal disks for use in the liquid-metal, fast-breeder-reactor, neutron dosimeter 

program (Conner, 1981, pdf pp. 6-7).

Some early neptunium work was conducted in open hoods, but most was performed in “alpha 

containment” glove boxes in general-purpose research facilities. The first hydrofluorination 

equipment used for neptunium consisted of a glove box used to load NpO2 into reaction “boats,” and 

several open hoods enclosing the front portion of the hydrofluorination furnaces. A second system 

used for this purpose was smaller and enclosed in a glove box, limiting batch sizes to 110 g of NpO2. 

These first hydrofluorination systems (which were originally designed for applications other than 

neptunium processing) were subsequently replaced with a glove-box-enclosed system specifically 

designed for converting small batches (≤100 g) of NpO2 to NpF4 (Conner, 1981, pdf pp. 20-23).

A typical glove box for aqueous Np processing consisted of a “wet” section (for aqueous processes) 

and a “dry” section (for calcining precipitates and weighing powders) separated by an air lock. Each 

section had separate air inlet and exhaust filters. A door in the air lock was used to pass equipment 

and material between the wet and dry sections. A 1⁄8-inch-thick lead sheet was bonded to the stainless 

steel portion of the glove box and 1⁄4-inch leaded glass was placed over the glove box windows as a 

shield against gamma radiation from the neptunium and its impurities (Conner, 1981, pdf pp. 7-8). 

Radiological impurities in neptunium included other actinides, primarily Pu isotopes. Occasionally, 
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neptunium contaminated with thorium (typically 200 ppm – 2,000 ppm) was processed. One 343-g 

batch of NpO2 with 3% thorium by weight was processed (Conner, 1981, pdf p. 18). 

Neptunium metal was produced by reduction of NpF4 with calcium metal and iodine in a sealed 

reaction vessel (Conner, 1981, pdf pp. 24-26). This thermite process, used to produce 10 g - 400 g 

batches of Np, was initially performed in the same area as the first hydrofluorination runs using the 

same glove box and hoods employed for loading the hydrofluorination “boats.” The operation was 

later moved to reduction furnaces enclosed in glove boxes. Vessels for four charge sizes were used: 

15 g scale (for charge sizes containing 10 g – 15 g of Np), 50 g scale (16 g – 50 g of Np), 100 g scale 

(50 g – 110 g of Np), and 500 g scale (125 g – 400 g of Np).

Neptunium metal-casting techniques were similar to those for plutonium because of the similar 

melting points of the two elements. A tilt-pour casting technique was used for metal shapes with 

thicknesses exceeding 0.040 inch. Injection casting was used for thicknesses of 0.010 inch (Conner, 

1981, pdf p. 29). Hot-rolling of Np ingots heated to 310 0C was initially used to produce foil 

thicknesses <0.010 inch; however, once process development was completed, injection casting proved 

superior and replaced rolling for Np foil production. Hot rolling required care to avoid problems such 

as edge-cracking of the ingots, and the high temperature required for pre-heating and rolling the ingot 

resulted in vaporization of the silicon oil, which condensed on the glove box walls, windows, and 

equipment inside the box (Conner, 1981, pdf pp. 33-34).

5.2 Tritium Exposure Sources, Radiological Programs, and Incidents

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

thorium, U-233 (and associated progeny), and neptunium. However, during the feasibility evaluation 

for SEC-00192 Rev. 0, 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. 

This report is specific to the assessment of tritium, thorium, U-233 (and associated progeny), and 

neptunium. For discussions and assessments that cover RFP exposures above and beyond those 

exposures, refer to the SEC-00030 Evaluation Report. Discussion of topics beyond those discussed in 

Section 7.5 will not be included in this ER.

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.

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
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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.

In response to the Board review of Rev. 0 of this SEC-00192 evaluation report, NIOSH conducted a 

follow-up research and evaluation effort to respond to issues identified during the Board’s review. As 

part of the follow-up, additional document data captures and personnel interviews were performed 

(classified and unclassified). In addition to follow-up on the existence of tritium on site and 

associated personnel exposures, the effort also focused on the specific areas of tritium bubbler 

sampling, shipping container tritium surveys, and sampling analysis performed in Building 123. 

These follow-up efforts were performed to validate the tritium bounding method for the SEC-00192 

RFP ER (which uses information from the 1973 tritium incident as the maximum exposure scenario), 

and to provide more precise estimates of doses due to tritium.

5.2.1 Exposure Sources from 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 

material receipt process. RFP records from 1970-1974 indicated that approximately 290 shipments 
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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/m3 range.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 Review, 2012b, 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 Review, 2012b, 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 Review, 2012b, 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). 

5.2.2 Tritium 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 Tritium 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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5.2.4 SEC-00192, Rev. 0 Tritium Follow-up

A review of all RFP-related SRDB documents was performed to determine if any documents existed 

in that dataset that could expand on any of the issues raised by the Board regarding tritium. The 

documents relating to tritium monitoring at RFP were identified, including some tritium bubbler 

results, and some indication of tritium contamination surveys. There are multiple documents 

regarding four significant incident-related tritium releases that occurred in 1968, 1973, 1974, and 1977 

(Building 777 Investigation, 1974; Investigation, 1977; Release Investigation, 1973c; Tritium 

Releases, 1968; Tritium Release, 1973; Tritium Releases, 1976-1983; Tritium Releases, 1987; Tritium 

Report, 1973). There are also post-1977 documents that confirm continued monitoring of tritium 

releases and residual tritium as a result of these four earlier releases. There is also an SRDB 

document that provides information on post-1977 stack releases occurring in 1981 and 1986; both 

releases were considered small with no impact to site personnel or the immediate surrounding area 

(Tritium Releases, 1987). While some of the documents corroborated the classified interview issues 

addressed later in this report (i.e., bubblers and tritium contamination surveys), it does not appear that 

any of the new information supports the notion that there were any tritium levels that exceeded the 

1973 incident. 

As stated in Revision 0 of the SEC-00192 ER, RFP operations that were related to, or had potential 

exposure impacts associated with tritium included neutron generator operations (i.e., the use of 

tritiated targets), and returned pit operations. Subsequent classified interviews identified shipping 

container handling as a potential exposure source. The following was learned:

• The follow-up effort corroborated in at least one interview (Personal Communication, 2013o) and 

in two documents (RFP, 1994a; Review, 2012b) the point made in Revision 0 of the SEC-00192 

ER that the stainless steel reservoir operation was a construction operation before the introduction 

of tritium, which occurred at other sites. RFP was responsible constructing the reservoirs and 

shipping them to other locations where they were filled/used. 

 

• The follow-up effort corroborated that the neutron generator tritium target sources did not 

represent a source larger than the one represented in the 1973 tritium incident. 

• The tritium-contaminated pits and shipping containers are considered directly related because the 

shipping container tritium was a result of tritium from the pits loaded in the containers. Because 

of potential classification issues the assessment of this issue will be addressed later in this report 

under the more general term Shipping Containers rather than the term Pits.

• A follow-up effort was directed to determine if there are any other scenarios with the potential to 

exceed the SEC-00192 RFP ER, Rev. 0 bounding approach. These scenarios are assessed as part 

of the pre-1973 tritium shipping container exposure evaluation in this report.

The indications found in the available documentation, and provided by the majority of interviewees, 

were that RFP did not work with tritium as a normal or usual process, and therefore, did not expect it 

on site. The RFP radiological program did very little monitoring for tritium prior to the 1973 incident 

because they felt they had limited tritium exposure potential. Changes to the program related to 
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tritium monitoring were implemented as a result of the 1973 incident. It has been corroborated that 

tritium bubbler monitoring did exist on site as part of the usual RFP air monitoring program before 

and after the 1973 tritium incident (Personal Communication, 2013o); however, the current 

information does not indicate how long before the 1973 incident bubblers existed on site.

As indicated in Rev. 0 of the SEC-00192 ER, the site implemented a routine tritium bioassay program 

after the 1973 tritium incident, but discontinued the routine program in 1975 due to lack of positive 

bioassay results. The program was subsequently implemented on an as-needed or as-identified basis. 

This implementation process was corroborated in at least one personnel interview performed during 

this follow-up effort (Personal Communication, 2013o).

5.3 Thorium Exposure Sources, Radiological Programs, and Incidents

Thorium is a soft ductile metal that is also radioactive. It is a long-lived radionuclide that emits alpha 

particles as part of its radioactive decay. It is found in nature and is commercially used in welding 

rods, lantern mantles, alloys, and optical glass. When inhaled, the radionuclide delivers dose to a 

person’s lungs before it is assimilated and deposited in the bone.

The potential for thorium exposures from RFP operations existed from the beginning of RFP 

operations, through the mid-1960s with most thorium inventories off-site by the mid-1970s 

(ChemRisk 3&4, 1992, pdf p. 136; RFP, 1976; Thorium Bounding, 2008). The Thorium operations 

were related to special projects, of which limited information and documentation is available because 

of classification issues associated with the operations and materials.

LL

5.3.1 Exposure Sources from Thorium Operations

Based on the research and review of related thorium operations at RFP, NIOSH has identified that 

there were thorium related operations with personnel exposure potentials (ChemRisk 3&4, 1992, pdf 

p. 136; RFP, 1976; Thorium Bounding, 2008). These operations included:

- Fabrication of metal parts from natural thorium or thorium alloys – 3 thorium metal ingots sent to 

RFP from W.R. Grace for experiments on forming and shaping thorium metal as well as canning 

the resulting products.

- Use of oxide (“thoria”) as a mold coating compound – for a brief period at RFP, experiments 

involving the use of thoria as a mold coating compound for weapons-grade uranium and 

plutonium.

- Compounds used in numerous analytical procedures and research and development programs –

RFP coordinated with Oak Ridge in several thorium laboratory experiments including use of 

thorium as a titrating agent, in separation studies, in impurity analyses, and in the conversion of 

thorium oxide to thorium metal.

- Used as a substitute for U or Pu components in various research and development activities and 

programs – RFP received pre-shaped/formed thorium parts from Y-12 for use in experiments 

because of the rarity and higher cost of the Pu and U parts.
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- The removal of Th-228 (referred to as a thorium strike performed during U-233 processing –

Th-228 at RFP was related to the U-233 operations and existed in the U-233 as the progeny of the 

U-232 contaminant in the U-233. This operation is discussed further in the U-233 section of this 

report.

5.3.2 Thorium Radiological Programs

There are some indications that RFP acknowledged the potential for personnel thorium exposures 

associated with operations and the need to develop personnel internal/external monitoring for the 

work as early as 1954 (SRDB 24631, page 165). The development of the thorium analysis methods 

continued through the 1950’s and into the 1960’s (Monthly Reports, 1956-1957; Monthly Progress 

Reports, 1958; Monthly Reports, 1960-1961). While some sporadic personnel monitoring results 

exist for some RFP personnel, no known routine thorium monitoring programs existed at RFP 

(Thorium Bounding, 2008, pdf p. 4). NIOSH has collected some thorium specific personnel and area 

monitoring data in the process of its research for the development of this evaluation report (Dosimetry 

History, date unknown, pdf p. 11; ChemRisk 3&4, 1992, pdf p. 136; Monthly Reports, 1956-1957, pdf 

p. 116-125); Monthly Progress Reports, 1958 pdf p. 50; Monthly Reports, 1960-1961, pdf p. 8, 72, 

96-112); Logbook, 1966-1969, pdf p. 6; Special Analyses Logbook, 1960 [starting pdf p. 20 for 

1960, including urine samples starting p. 25]). While some data were available, it was determined that 

at least some of the results contained in the data were inconclusive (SRDB 25698). It was also 

determined that gross alpha would not necessarily be representative of the personnel thorium 

exposures (ChemRisk 3&4, 1992, pdf p. 136).

5.3.3 Thorium Incidents

There are no known thorium incidents in the documentation available to NIOSH.

5.4 U-233 Exposure Sources, Radiological Programs, and Incidents

Uranium-233 is a fissile radioactive isotope of uranium that is part of the thorium fuel cycle. U-233 is 

produced by neutron irradiation of Th-232. U-233 has a half life of 159,200 years. It is part of the 

neptunium decay series, decaying via alpha emission to Th-229. U-233 and its progeny are primarily 

considered internal dose hazards, similar to the naturally-occurring uranium isotopes, U-234, U-235, 

and U-238.

Production of U-233 also results in the unavoidable production of uranium-232, a problematic 

contaminant with a half life of 72 years. U-232 decays via alpha emission to thorium-228, a member 

of the thorium decays series, which subsequently decays to produce several strong gamma-emitting 

radionuclides. In addition to being an internal dose hazard, U-232 and its gamma-emitting progeny 

represent a significant external radiation hazard. The purpose of the “thorium strike” operation was to 

remove Th-228 from U-233, thus reducing the gamma radiation levels. 

5.4.1 Exposure Sources from U-233 Operations
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Locations of U-233-related operations at RFP are summarized in Table 5-4. Note that the information 

on 1964 activities, although inconsistent with published reports from the same era (Investigation 

Summary, 1965), is included because it was based on logbook entries that appear to be factual in 

terms of early testing operations (Logbook, 1965-1967).

U-233 residues were received and initially processed in Building 771, Room 114. Room 114 is where 

the thorium strike process took place (Investigation Summary, 1965, pdf pp. 8-9, 17, 44; Incident 

Reports 2/64 – 5/65, pdf p. 30). Based on information from personnel interviews, the U-233 material 

at RFP may have gone through several thorium strikes before it was processed to produce U-233, as 

some material was not immediately processed (Personal Communication, 2013n). The extracted Th228 was containerized for disposal and shipped to Idaho National Laboratory in Arco, Idaho 

(Investigation Summary, 1965, pdf p. 81). The uranium was converted to peroxide and then shipped 

to Building 881 where it was ultimately reduced to U-233 metal. Casting and machining of parts also 

took place in Building 881, while other fabrication steps were handled in Building 883. By the mid1970s, work previously performed in Building 881 shifted to the R&D areas of Building 771. It is 

likely that machining steps also took place in Building 779A. Final component assembly took place 

in Building 777/777A. Uranium oxides and green salt residues were converted to uranyl nitrate in 

Building 771 and then shipped back to Oak Ridge or to Lawrence Livermore Laboratory. Wastes 

from casting and machining were burned in Building 881 and the waste oxides from this and other 

processes were then converted to a nitrate solution for shipping back to Oak Ridge. The liquid wastes 

were handled in Building 774 with all low-level wastes being drummed and sent to Idaho for burial 

(Investigation Summary, 1965; RFP, 1999). 

The U-233 process included the following steps (Investigation Summary, 1965):

1. Material received as nitrate solution

2. Thorium strike (thorium fluoride precipitation > peroxide precipitation > UO4 cake)

3. Conversion (UO4 > UO3 > UO2 > UF4)

4. Reduction to metal and casting into an ingot

5. Rolling ingot into a sheet and producing part blanks from the sheet

6. Machining

7. Sampling
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Table 5-4: Location of Rocky Flats U-233 Activities

Year RFP Building Number

559 771 774 777 777A 779A 881 883

1964* X X

1965 X X X X X X

1966 X X X X X X

1967 X X X X X X

1968 X X X X X X

1969 X X

1970 X X X

1971 X X X

1972 X X X

1973 X X X X

1974 X X

1975 X

1976 X X X

1977 X X X X X X

1978 X X X X X X

1979 X X X X X X

1980 X X X X X X

1981 X X X X X X

1982 X X X X X X

1983 X X

* Information on 1964 based on logbook entries (Logbook, 1964-1967); all other data from RFP, 1999, Table 3.

559: Analytical Laboratories

771: Chemical processing, analytical laboratories, waste processing

774: Waste disposal 

777: Non-destructive testing, inspection, manufacturing processing

777A: Assembly

779A: Machining

881: Chemical processing, casting, machining

883: Fabrication

Rocky Flats U-233 operations continued through 1982, with the majority of the remaining U-233 

being shipped off site in 1983 (RFP, 1999). The U-233 remaining on site at the end of RFP operations 

was in the form of contaminated waste materials, which were expected to be disposed of as waste 

(ORNL, 1998).
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Based on the available information, the quantities of U-233 processed at RFP are summarized in Table 

5-5. 

Table 5-5: Summary of RFP U-233 Quantity Estimated To Be Present at Any One Time

Time Period Quantity (amount/year)* Basis and SRDB Ref ID

1964 47 g Documented in RFP, 1965b, pdf p. 9.

1965 20 kg Data contained in Investigation Summary, 1965 indicate the 

button size to be approximately 2 kg (pdf p. 62), and that nine 

such buttons were produced (pdf pp. 57, 62), coupled with the 

presence of four ‘boats’ of leftover material, each weighing 

approximately 400-700 g (pdf pp. 7, 26, 72).

1966 – 1968 150 kg RFP, 1999 states that kilogram quantities of U-233 were 

received, processed, and shipped between 1966 and 1968. The 

quantity is based on one-third of the estimated total quantity 

produced through 1968 in the entire AEC complex, assuming 

the equal distribution of U-233 between ORNL/RFP, SRS, and 

Hanford (Building 3019, pdf p. 24).

1969 – 1973 1 kg RFP, 1999, pdf p. 10 and Dow, 1972 (for 1972) indicate 

quantities < 1 kg during this period.

1974 – 1977 10 kg RFP, 1999 states that during 1974 – 1977, kg quantities of 

U-233 arrived and were processed at RFP. RFP, 1978a indicates 

that 530 g of 233UF4 were used for each of 8 castings performed 

for a total of ~5 kg.

1978 – 1983 1 kg RFP, 1999 indicates quantities < 1 kg during this period.

* The presented values are based upon review of readily available unclassified documents. The quantities presented,

 therefore, may not be bounding or reflect actual throughput. Exact quantities are not provided due to classification

 issues.
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Material characteristics based on the available data are summarized in Table 5-6.

Table 5-6: Characteristics of U-233 Material Processed at RFP

Applicability Summary Basis and SRDB Ref ID

1964 2.5 years old, 42 ppm U-232 Documented in RFP, 1965b.

1965 90 days old, 50 ppm U-232 RFP, 1999 states that U-233 processed in 1965 contained 

approximately 50 ppm U-232. Documentation from the 

period indicates that material would be processed for thorium 

recovery if not shipped in 90 days (Thorium U-233 Shipping, 

pdf pp. 10-11). During interviews with many former RFP 

workers, several of them indicated that thorium strikes were 

periodically performed to clean up material (Investigation 

Summary, 1965; Personal Communication, 2012m; Personal 

Communication, 2012n; Personal Communication, 2012o; 

Personal Communication, 2012s; Personal Communication, 

2013n).

1966 – 1982 90 days old, 8 ppm U-232 RFP, 1999 states that U-233 operations subsequent to the 

1965 operations contained only 7-8 ppm U-232. RFP, 1977a 

indicates that U-233 processed in a 1976 operation contained 

8 ppm U-232. RFP, 1979 indicates that U-233 processed in a 

1977 operation contained 7 ppm U-232 and had undergone a 

thorium strike two months prior to shipment.

5.4.2 U-233 Radiological Programs

RFP activities involving U-233 were of limited scope and, while being performed, accommodations 

were made to account for the high specific activity of the U-232 material in an attempt to preclude 

cross-contamination of Pu-239 and U-235 materials with U-233, which was also fissile. However, a 

cross-contamination event occurred in 1965 involving U-233 and U-235 (Investigation Summary, 

1965). The quantities of U-233 that were available for use across the entire weapons complex were 

also limited. The total quantity of U-233 produced is not readily available for any one site due to 

classification issues, but overall quantities produced in the complex can be estimated based on the 

available documentation (Building 3019, 1994).

5.4.3 U-233 Incidents

NIOSH is unaware of any specific incidents or accidents involving U-233 at RFP that increased the 

potential for radiation exposure. A cross-contamination event occurred in 1965 when 447 grams of 

other uranium isotopes, including U-235, were mistakenly added to U-233 residues (Investigation 

Summary, 1965). An unspecified financial loss due to contamination by U-235 of otherwise-purified 

U-233 residues is mentioned in the above-referenced document; however, there are no suggestions 

that this event resulted in an increase in personnel exposure or increased the potential for exposure.
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5.5 Np-237 Exposure Sources, Radiological Programs, and Incidents

Neptunium was processed at Rocky Flats as early as 1962 (Conner, 1981, pdf p. 6). The potential for 

radiological exposures from handling and processing neptunium existed in the Material Balance Areas 

(MBAs) where it was stored and processed. These MBAs were located in Buildings 371, 559, 707, 

771, 776, 777, 779, 779A and 991 from 1963 forward (Vejvoda, 2005, pdf pp. 75-76). 

Captured documents indicate that the potential for exposure to neptunium existed from 1962 to 1988, 

the period during which neptunium is known to have been present at RFP (Conner, 1981, pdf p. 6; 

Vejvoda, 2005, pdf pp. 75-79). The potential for exposure to neptunium present as residual 

contamination during plant decommissioning after 1988 is also assumed.

Source term data for neptunium available to NIOSH for Rocky Flats is limited to the reported 

quantities from Material Balance Area accounts (Vejvoda, 2005, pdf pp. 75-79; Inventory, 1966-

1988). Only totals for the plant are available by year, and in some cases, by quarter. Individual 

Material Balance Areas having accountable quantities of neptunium are indicated for the annual totals, 

but not the amounts located in specific work areas.

NIOSH is unable to assess whether an energy employee, or class of employees, did or did not 

potentially enter specific areas of the Rocky Flats Plant having the potential for neptunium exposures 

during defined periods of time; therefore, NIOSH cannot define individual worker exposure scenarios 

based on specific Rocky Flats areas or work locations during the period from April 1, 1952 to 

December 31, 1983.

NIOSH is also unable to eliminate any specific worker from potential neptunium exposure scenarios 

based on job titles or job assignments.

5.5.1 Exposure Sources from Np-237 Operations

NIOSH has captured documents indicating that neptunium was processed at Rocky Flats as early as 

1962 (Conner, 1981, pdf p. 6). Nuclear Material Control and Accountability (NMC&A) records show 

that neptunium inventories at Rocky Flats from 1963 to 1988 varied between 29 g and 1,318 g 

(Vejvoda, 2005, pdf pp. 75-76). Table 5-7 below shows reported fiscal-year-end inventories for this 

period. NIOSH believes at this time that activities associated with neptunium virtually ceased after 

1983, even though neptunium inventories existed until the end of 1988. Whether neptunium was 

handled or processed from 1984-1988 at Rocky Flats is still being evaluated.
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Table 5-7: RFP Neptunium-237 Fiscal-Year-End Inventories

Fiscal Year Np-237 (g) Fiscal 

Year Np-237 (g) Fiscal Year

Np-237 

(g)

1963 29 1972 788 1980 744

1964 601 1973 768 1981 486

1965 1,292 1974 470 1982 699

1966 740 1975 485 1983 869

1967 1,215 1976* 485 1984 1,040

1968 972 1976A* 468 1985 931

1969 1,190 1977 458 1986 985

1970 1,105 1978 567 1987 995

1971 1,318 1979 492 1988 970

Source: Conner, 1981, pdf p. 76

* The source document does not explain why they are two inventories for 1976. However, 

the values correspond to those for the June 30, 1976 and September 30, 1976 inventory 

values from the reference (Inventory, 1966-1988) from which Figure 5-1 was generated.

Quarterly inventory values from December 31, 1967 were also captured (Inventory, 1966-1988) and 

are presented graphically in Figure 5-1 below along with the year-end values listed for 1963 

through1966 in Table 1 above.

Buildings having neptunium inventories included Buildings 371, 559, 707, 771, 776, 777, 779, 779A, 

and 991 (Vejvoda, 2005, pdf pp. 76-77). Refined neptunium for special projects undertaken at the 

request of other DOE laboratories was often recovered as metal or oxide from scrap and waste 

(Conner, 1981, pdf pp. 6-8; ChemRisk, 1992, pdf pp. 77, 100; Wittenberg, 1970, pdf p. 8). Typical 

special projects included the preparation of Np Pu alloys (Vejvoda, 2005, pdf p. 77) and specific 

configurations of neptunium, such as thin foils (Conner, 1969, pdf p. 10). Evidence points to a 

number of specific tasks performed at the request of other DOE laboratories from 1962 until around 

1983, involving a few grams to a few hundred grams of neptunium. Information from reports in the 

SRDB, and from reviews of classified documents, do not suggest that any special orders or other 

projects at Rocky Flats involved more than about 300 g of neptunium (Conner, 1967).

Neptunium processing at Rocky Flats included preparation of pure neptunium oxide, metal and metal 

alloys, and the recovery of Np-237 from a variety of residues (Conner, 1981, pdf p. 6). Processes 

employed included dissolution, anion exchange, precipitation, filtration, calcination, conversion to 

fluoride, and reduction to metal. Fabrication steps such as casting and rolling were also sometimes 

performed for the production of high-purity metal shapes and foils. Neptunium was recovered from 

residual materials including sand, slag, crucibles, casting skulls, and alloys (Np-Sn, Np-U, and NpZr).
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Some early neptunium work was conducted in open hoods, but most was performed in “alpha 

containment” glove boxes in general-purpose research facilities. The first hydrofluorination 

equipment used for neptunium consisted of a glove box used to load NpO2 into reaction “boats,” and 

several open hoods enclosing the front portion of the hydrofluorination furnaces. A second system 

used for this purpose was smaller and enclosed in a glove box, limiting batch sizes to 110 g of NpO2. 

These first hydrofluorination systems (which were originally designed for applications other than 

neptunium processing) were subsequently replaced with a glove- box-enclosed system specifically 

designed for converting small batches (≤100 g) of NpO2 to NpF4 (Conner, 1981, pdf pp. 20-23).

A typical glove box for aqueous Np processing consisted of a “wet” section (for aqueous processes) 

and a “dry” section (for calcining precipitates and weighing powders) separated by an air lock. Each 

section had separate air inlet and exhaust filters. A door in the air lock was used to pass equipment 

and material between the wet and dry sections. A 1⁄8-inch-thick lead sheet was bonded to the stainless 

steel portion of the glove box and 1⁄4-inch leaded glass was placed over the glove box windows as a 

shield against gamma radiation from the neptunium and its impurities (Conner, 1981, pdf pp. 7-8). 

Radiological impurities in neptunium included other actinides, primarily Pu isotopes. Occasionally, 

neptunium contaminated with thorium (typically 200 ppm – 2,000 ppm) was processed. One 343-g 

batch of NpO2 with 3% thorium by weight was processed (Conner, 1981, pdf p. 18). 

5.5.2 Np-237 Radiological Programs

NIOSH has found no workplace monitoring records (e.g., surface contamination samples, air samples) 

specific to neptunium.

5.5.3 Np-237 Incidents

No radiological incidents involving neptunium at Rocky Flats have been identified by NIOSH.
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Source: Inventory, 1966-1988; Vejvoda, 2005, pdf p. 76

Figure 5-1: Total Rocky Flats Neptunium Inventory by Quarter
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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 Internal Monitoring Data

The following subsections discuss the availability of Rocky Flats internal monitoring data for tritium, 

thorium, U-233 and associated progeny, and neptunium-237.

6.1.1 Available RFP Internal Monitoring Data for Tritium

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. 
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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.

“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 
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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 

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 128 claims noted in Table 4-1 of this report that 

are currently in NOCTS (as of September 12, 2013).

Table 6-1: Available RFP Tritium Data from 128 NOCTS Claims

Year Tritium Bioassays 

in NOCTS

No. of Tritium Bioassays in SRDB (source documents)

1960 None 7 (Monthly Reports, 1960-1961; Special Analyses 

Logbook, 1960)

1965 None 6 (Monthly Reports, 1963-1965; Monthly Reports, 1965-

1967; Logbook 1965)

1966 None 13 (Monthly Reports, 1965-1967; Logbook, 1966-1969)

1968 None 2 (Logbook, 1966-1969; Status Report, 1968)

1969 None 5 (Logbook, 1966-1969; Status Report, 1968; Monthly 

Reports, 1968-1971)

1973 156 180 (Urine Sampling, 1973)

1974 49 11 (Building 777 Investigation, 1974)

1975 48 None

1976 6 None

1977 13 None

1978 10 None

1979 11 23 (Tritium Bioassay Results, 1979)

1980 30 95 (Tritium Bioassay Results, 1980)

1981 19 87 (Tritium Bioassay Results, 1981)

1982 1 24 (Tritium Bioassay Results, 1982)

1983 No info 2 (Tritium Bioassay Results, 1993)

1991 2 None

1993 7 None

1995 2 None

1996 2 None
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6.1.1.1 SEC-00192, Rev. 0 Tritium Data Follow-up

As part of the follow-up to the Board review of Rev. 0 of the SEC-00192 evaluation report, NIOSH 

performed additional focused data capture efforts and assessments/reviews of the data to determine 

the applicability of the bounding approach defined in the ER. The documentation and data reviewed 

as part of this research were specific to Board working group issues regarding tritium bubblers, 

contamination surveys on shipping containers, and Building 123 radiological surveys/operations; 

these documentation and data are presented in the following subsections. The additional documents 

and interviews obtained during the post-ER follow-up efforts provide additional evidence of the 

potential for tritium exposures. However, the information also supports the case that estimates of 

potential tritium exposure that could have occurred prior to 1973 are bounded by the exposure 

estimate for the 1973 event, and that more precise estimates are feasible.

Follow-up on Tritium Bubblers

Significant information on the bubbler monitors was discovered during the additional follow-up data 

capture efforts. There is some documentation in the SRDB that discusses the use of tritium bubblers. 

Based on the available data, including the most recent information (schematics and pictures of the 

tritium air sampling and monitoring equipment and processes [RFP, 1974a through RFP, 1978d]), 

there was a program that included the use of tritium bubblers to monitor enclosed and exhaust systems 

for tritium (Personal Communication, 2013j). As previously discussed, the exact start date for the use 

of bubblers has not been confirmed, but they did exist on site before the 1973 incident (Personal 

Communication, 2013o). Most individuals interviewed were not well-informed on bubbler use or 

operation.

The SRDB contains some tritium bubbler results (Tritium Bubbler Results, 1992; Tritium Bubbler 

Results, 1998) as well as detailed schematics and pictures of the units (Dow, 1973; RFP, 1977b; RFP, 

1978f; RFP, 1978e; RFP, 1978b; RFP, 1978c; RFP, 1983). Based on these results, the information 

discovered during the follow-up research and in the interviews, there is nothing to support the 

occurrence of a release event more significant than the 1973 incident. Table 6-2 presents a summary 

of the Rocky Flats tritium bubbler information contained in the SRDB.
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Table 6-2: Rocky Flats Tritium Bubbler Information in the SRDB

(This table spans two pages)

SRDB Ref ID Year File Description Comments

Category: Tritium Monitoring Results, Procedures, and Occurrences

17824

(RFP, 1990a)

1990-

1991 Occurrence reports

Contains two occurrence reports involving 

inoperable bubblers, and one report of a Triton 

tritium air monitor that was shut off. None of the 

occurrences involved tritium releases.

24164

(Tritium 

Releases, 1976-

1983)

1976-

1983 Tritium inventories and effluents

Contains: an evaluation of tritium-release 

potential from a proposed neutron crate counter 

(1983); elevated tritium effluents from Bldg 

776/777 (January 1981); estimated inventory of 

tritium as surface contamination in glove boxes,

ducts, and exhaust plenums in Bldg 776/777 

(1980); evaluation of ethylene glycol in place of 

water in tritium bubblers (1978); special study of 

tritium in ambient air (1976); a report, Estimates 

of Maximum Tritium Releases to the Atmosphere 

from Operations at the Rocky Flats Plant (1976); 

and a Call Report indicating that 0.058 μCi of 

tritium would probably be vented to the 

atmosphere for an experiment on May 20, 1974.

24307

(RFP, 1990b) 1986 Procedure for effluent and room air tritium sampling Operating procedure

111095

(Tritium 

Bubbler Results, 

1992)

1977-

1981 Tritium bubbler sampling results

Log of analytical results for bubblers in operating 

areas, including room air and near downdraft 

tables. Most results are <100 pCi/m3

, but results 

exceed 1,000 pCi/m3 on several occasions in 

Bldg. 559 – Rm. 102, and in Bldg. 881- Rm. 283. 

Highest result appears to be 89,230 pCi/m3 in 

Bldg 771 for the period May 11-18, 1978.

122466

(Personal 

Communication, 

2013j)

2013 Documented interview with [Name 

redacted]

Includes a discussion of the different laboratories 

at Rocky Flats for analyzing tritium and other 

radionuclides in samples.

122712

(Tritium 

Bubbler Results, 

1998)

1998 Lab report - tritium activity in 

bubblers

Detailed analytical report from Thermo NUtech, 

including sample activity, counting uncertainty, 

detection limit, and total propagated uncertainty.

122907;

24167

(Personal 

Communication, 

2013o; Tritium 

Release, 1973)

2013 Documented interview with [Name 

redacted]; 1973 incident report

Includes a discussion of the tritiated targets for 

laser fusion experiments and corroboration that 

bubblers were in use at several Rocky Flats 

locations prior to the 1973 tritium release 

incident.
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Table 6-2: Rocky Flats Tritium Bubbler Information in the SRDB

(This table spans two pages)

SRDB Ref ID Year File Description Comments

Category: Tritium Sampler Photos and Design Documents

122691

(Dow, 1973) 1973 Photos – tritium operations at Dow

Relevance of photos to tritium monitoring or 

tritium operations is not apparent, except for one 

photo of a Triton tritium monitor.

122692

(RFP, 1977b) 1977 Photos - tritium monitoring

Good photos of sampling fixture for sealed cans 

and drums, Triton Model 955B tritium monitor, 

and bubblers mounted outside a glove box for 

sampling glove box air.

122693

(RFP, 1983) 1983 Photos – tritium air sampling station

Labeled tritium sampling assembly showing 

building number, air flow rates, and water 

volume.

122779

(RFP, 1974a) 1974 Drawing 1 of 8 - Tritium and iodine sampler assembly Engineering drawing

122780

(RFP, 1974d) 1974 Drawing 2 of 8 - Tritium and iodine sampler assembly Engineering drawing

122781

(RFP, 1974b) 1974 Drawing - Environmental tritium and radioiodine sampler details Engineering drawing

122782

(RFP, 1975) 1974 Drawing - Environmental tritium and radioiodine sampler wiring diagram Engineering drawing

122783

(RFP, 1974c) 1974 Drawing - Environmental tritium and radioiodine sampler mounting detail Engineering drawing

122784

(RFP, 1974f) 1974

Drawing - Environmental tritium and 

radioiodine sampler onsite electrical 

hookup

Engineering drawing

122785

(RFP, 1974g) 1974

Drawing - Environmental tritium and 

radioiodine sampler offsite electrical 

hookup

Engineering drawing

122786

(RFP, 1974e) 1974

Drawing - Environmental tritium and 

radioiodine sampler onsite and offsite 

electrical hookup

Engineering drawing

122787

(RFP, 1978f) 1978 Drawing – Tritium detector assembly Engineering drawing

122788

(RFP, 1978e) 1978 Drawing – Tritium detector details (1) Engineering drawing

122789

(RFP, 1978b) 1978 Drawing – Tritium detector details (2) Engineering drawing

122790

(RFP, 1978c) 1978 Drawing – Tritium detector details (3) Engineering drawing

122791

(RFP, 1978d) 1978 Drawing - Tritium detector flow diagram Engineering drawing
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Follow-up on Shipping Containers

Additional research was performed regarding the issue of tritium contamination in shipping 

containers. This issue arose from one of the classified interviews (Personal Communication, 2012n). 

Tritium contamination in shipping containers was corroborated in an SRDB document (Dow, 1974); 

however, no actual contamination surveys have been found. The follow-up survey requirements and 

processes were corroborated in a follow-up interview in which the interviewee discussed 

implementing the shipping container tritium survey program in response to the 1973 incident 

(Personal Communication, 2013o). During that interview, the interviewee said that no tritium 

contamination was ever found. Other classified interviewees indicated that they had heard about 

shipping-container contamination, but they had no direct experience of it.

Follow-up on Building 123

Analytical capability existed in both the production areas and in Building 123 (Personal 

Communication, 2013d), which housed the laboratories supporting worker health and safety 

(Industrial Hygiene and Health Physics) as well as the environmental programs (Personal 

Communication, 2013a). Samples collected in the production areas may have been analyzed either in 

the production laboratories or in Building 123, depending on the anticipated level of analytes and the 

potential for contamination with plutonium or uranium, for which strong contamination-control 

practices were in place. Tritium samples from stack exhausts, which were filtered several times 

before sampling and release to the environment, were typically analyzed in Building 123. Samples 

collected in the work areas were analyzed in a production area laboratory to eliminate the possibility 

of introducing plutonium contamination into the Building 123 lab (Personal Communication, 2013a). 

Samples with a high likelihood of elevated tritium content might also be analyzed in a production lab 

to prevent tritium contamination in the low-level Building 123 laboratories (Personal Communication, 

2013c). 

Some effort was made prior to 1973 to use commercially-available tritium monitoring equipment 

(e.g., the vibrating reed spectrometer and tritium sniffers) (Neutron Generators, 1973; Personal 

Communication, 2013e; Personal Communication, 2013h; Personal Communication, 2013i) or to 

develop an in-house capability (through development of specialized ion chambers or tritium 

concentration techniques, such as silica gel traps [Logbook, 1969-1972; Status Report, 1968]). Liquid 

scintillation counting was reportedly used for quantitative analysis of a variety of radioactive materials 

in the production areas; it quickly became the technique of choice for tritium sample analysis after the 

1973 environmental tritium release. Tritium sniffers continued to be used to indicate elevated tritium 

in the workplace, but they did not provide quantitative data of record.

No results for tritium samples analyzed in the production areas have been captured, and only limited 

data are available from the Building 123 laboratories. The information regarding the criteria for 

determining where tritium samples were analyzed comes solely from interviews with former Rocky 

Flats Plant employees.
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6.1.2 Available RFP Internal Monitoring Data for Thorium

While no major thorium campaigns were performed as part of the RFP operations, there were 

operations that could have contributed to personnel exposures to thorium. In addition to issues 

associated with limited information and monitoring data for thorium at RFP, classification issues (as 

discussed in Section 5) compound the difficulties and issues relating to the development of a bounding 

dose reconstruction methodology for thorium. While there were limited thorium operations at RFP, 

and no established routine thorium monitoring program or documented protocol for personnel, there 

are some limited thorium-monitoring data available for operations in the 1960s.

NIOSH has access to monitoring data contained in RFP special monitoring logbooks. One logbook 

contains two monitoring points, for one individual, in mid-1966 (Logbook, 1966-1969, pdf p. 6). The 

second logbook contains data from 1960 and provides an indication of some personnel (urine 

samples) and area (swab/swipe samples). However, the results appear to be in terms of volumes or 

quantities of material, with no clear indication of an activity result in the documentation (Special 

Analyses Logbook, 1960, starting pdf p. 20). As previously discussed, NIOSH has collected some 

thorium-specific personnel and area monitoring data during its research for development of this 

revised evaluation report; these data are contained in the Site Research Database (Dosimetry History, 

date unknown, pdf p. 11; ChemRisk 3&4, 1992, pdf p. 136; Monthly Reports, 1956-1957, pdf p. 116-

125; Monthly Progress Reports, 1958, pdf p. 50; Monthly Reports, 1960-196, pdf p. 8, 72, 96-112); 

Logbook, 1966-1969, pdf p. 6 [8/16/66, 9/1/66]; Special Analyses Logbook, 1960 [starting pdf p. 20 

for 1960, including urine samples starting p. 25]).

6.1.3 Available RFP Internal Monitoring Data for U-233

The uranium internal dose monitoring program at RFP is described in the Site Profile, ORAUTTKBS-0011-5. The uranium bioassay program was also discussed in SEC-00030. NIOSH is unaware 

of any internal monitoring at RFP that was specific to U-233, U-232, or the associated Th-228 for the 

period of U-233 operations at the site.

6.1.4 Available RFP Internal Monitoring Data for Np-237

NIOSH has found no workplace air or contamination measurements specific to neptunium. Air and 

contamination measurement results are typically expressed in units of activity per unit volume (e.g., 

dpm/m3

) or unit area (e.g., dpm/100 cm2). No results were captured that specify neptunium as the 

contaminant, nor any that provide locations or dates of neptunium processing/handling that can be 

correlated with air results.

NIOSH has captured documents with only two reported bioassays for neptunium. A urinalysis result 

in July 1966 was “Below Significant Level” (Progress, Jun1966, pdf p. 74; Logbook, 1966-1969, pdf 

p. 3), and a urinalysis result of 0.9 dpm/24h was reported for a worker in August, 1966, followed by a 

body count that showed no detectable uptake (Progress, Jul1966, pdf p. 78; Logbook, 1966-1969, pdf 

p. 5).

Urinary excretion of “gross alpha” was used to monitor workers for exposure to plutonium/americium 

and uranium prior to its being discontinued in the early 1970s. Results were reported as dpm/24 h of 
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enriched uranium (through 1963) or plutonium (after 1963). Results were non-specific, so that 

neptunium exposures might not have been identified as such for workers on routine bioassay sampling 

schedules and who might have worked with a variety of actinides, including neptunium, curium, 

plutonium, and uranium (ORAUT-TKBS-0011-5, pdf p. 27; Personal Communication, 2013s, pdf pp. 

3-5). 

NIOSH has been unable to capture early RFP bioassay procedures for either gross alpha or 

neptunium. Old procedures were not archived, but rather, were destroyed prior to the late 1980s 

(Personal Communication, 2013r). Ambiguity exists in NIOSH’s understanding of the procedures 

used. According to one source, the entire urine sample prior to 1962 was ‘ashed’ (taken to dryness), 

which was time-consuming and resulted in significant self-attenuation of radiations due to the 

resulting solids containing the radioactive materials (Personal Communication, 2013s, pdf p. 4). 

According to this same source, a co-precipitation process involving chemical separation and 

extraction using TTA (thenoyltrifluoracetone) replaced the total sample ashing in 1962, and was 

supplemented by a TOPO (trioctylphosphine oxide) extraction process in 1964. These methods 

reduced both the volume of liquid to be ashed and the mass of salts (and self-attenuation) in the 

sample to be counted.

According to a second source, two methods were used to analyze urine samples for gross alpha counts 

from either plutonium or uranium. The ether extraction method was used from 1952 to December 12, 

1962, and the TBP (tri-butyl-phosphate) extraction method was used from December 12, 1962 to 

1964. The TBP method was replaced by the TOPO (tri-octyl-phosphine-oxide) method (ORAUTTKBS-0011-5, pdf p. 64; MDA, 2003, pdf p. 10).

Total sample ashing without treatment retains all actinides in the residue, but counting the residue 

without spectroscopic analysis does not provide nuclide-specific information; thus, the presence or 

absence of neptunium could not be determined by this method alone. The effectiveness of bioassay 

procedures for neptunium using solvent separation cannot be determined without the detailed 

procedures themselves because chemical recoveries of specific elements in extractions using solvents 

such as TTA, TBP, and TOPO vary considerably with the conditions established by the particular 

procedure (Procedures Review, 1957, pdf p. 21; Internal Dosimetry, 2002, pdf p. 7; Enriched Uranium 

Urinalysis, 1959). Knowledgeable sources interviewed about bioassay procedures at Rocky Flats 

were uncertain whether neptunium would be recovered effectively using these methods (Personal 

Communication, 2013r, pdf p. 4; Personal Communication, 2013r, pdf p. 4).

Ion exchange, followed by electroplating and analysis by proportional counters, and later, PHA 

(pulse-height analysis), was specific for U and Pu and replaced chemical separation and extraction 

techniques. These newer techniques provided “cleaner” samples (i.e., with fewer interferences) that 

were almost ‘massless’ (greatly reducing or eliminating self-attenuation) (Personal Communication, 

2013s, pdf p. 4); however, these techniques were not designed to detect neptunium.

In vivo counters of the 1960s and 1970s would have had difficulty distinguishing between the 59.6-

keV gamma emission from Am-241 and the 86-keV photon from Np-237 (Personal Communication, 

2013r, pdf p. 5).
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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 doses for members of 

the evaluated class was evaluated in the SEC-00030 Rocky Flats Plant Evaluation Report. 

SEC-00030 concluded that all external dose, except neutrons, could be estimated with sufficient 

accuracy and nothing performed as part of this evaluation has been discovered to dispute that finding. 

Therefore, additional analysis or evaluation of external monitoring data for the purpose of bounding 

external dose at RFP will not be performed in this evaluation report.

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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7.1.2 Thorium Monitoring Data Pedigree Review

In this evaluation, NIOSH has determined that it lacks sufficient monitoring data relating to worker 

internal doses from work performed at RFP during the operational period from April 1, 1952 through 

December 31, 1983, which includes the thorium processing/operating period from 1952-1966. As 

discussed in Sections 5 and 6, NIOSH has located limited routine air sampling or area monitoring data 

for thorium during RFP operations, although most of the data contains references to the source or 

original information or documentation. Lacking the original documentation or source information, a 

data sufficiency and pedigree evaluation is not possible for the thorium data type for this period at 

RFP.

7.1.3 U-233 Monitoring Data Pedigree Review

A data pedigree review is not possible for U-233 because there are no available internal monitoring 

data for U-233 (or U-232). Pedigree of the available internal dosimetry data for other radionuclides at 

RFP, including other isotopes of uranium, were evaluated and addressed in the SEC-00030 RFP 

Evaluation Report. That report reached the following conclusion:

No evidence of censoring or data manipulation that would cast doubt on the integrity of the data 

for use in dose reconstruction or in the generation of co-worker dose distributions was found.

7.1.4 Np-237 Monitoring Data Pedigree Review

Only two neptunium bioassay results have been identified by NIOSH. Both were recorded in 1966 

Industrial Hygiene and Bioassay Monthly Progress Reports (Monthly Reports, 1965-1967, pdf pp. 74, 

78) and in a Special Analysis Logbook (Logbook, 1966-1969, pdf pp. 3, 5). There is no 

corresponding record of reasons for the bioassays, the analytical procedure(s) used, where the 

analyses were performed, or by whom. Therefore, no conclusions can be drawn regarding the Np-237 

data pedigree for this evaluation report.

7.2 Evaluation of Bounding Internal Radiation Doses at Rocky Flats

The following subsections evaluate the bounding of internal radiation doses for tritium, thorium, 

U-333 and associated progeny, and neptunium-237.

7.2.1 Evaluation of Bounding Process-Related Tritium Doses

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. The following subsections also summarize the extent and limitations of 

information available for reconstructing the process-related internal tritium doses of members of the 

class under evaluation.
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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.

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.

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. 

7.2.1.1 SEC-00192, Rev. 0 Tritium Dose Feasibility Follow-up 

The potential for tritium exposure to Rocky Flats personnel was not considered significant by the site 

until an unexpected release occurred in April 1973. NIOSH conducted a follow-up effort to validate 

the tritium bounding method for Rev. 0 of the SEC-00192 RFP ER, which uses information from the 

1973 tritium incident as the maximum exposure scenario. Additional document data captures and 
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personnel interviews were conducted regarding the existence of tritium on site and associated 

personnel exposures as well as follow-up on tritium bubbler sampling, shipping container tritium 

surveys, and sampling analysis performed in Building 123. 

In light of the additional information and data gathered during this follow-up effort, this revised 

SEC-00192 evaluation report presents a refined dose reconstruction approach. This approach 

provides specific analyses and recommended dose reconstruction methodologies for three periods at 

RFP: (1) pre-1973 [1959-1972]; (2) 1973; and (3) post-1973. 

Follow-up on the Pre-1973 Tritium Exposure Period and Methods for Bounding Dose 

Although tritium was used as a boost gas in weapons and as target material in neutron generators, it 

was not processed or handled in any significant quantities at Rocky Flats. Tritium was monitored in 

the environment around the site for a time, but that monitoring ceased and was left to the State of 

Colorado for a brief period preceding an environmental release that occurred in April 1973. No 

analytical records have been captured by NIOSH that might help establish the Rocky Flats workplace 

tritium environment prior to that time.

The management of Rocky Flats woke abruptly to the potential for tritium workplace and 

environmental contamination when a tritium release occurred in April 1973 associated with 500 Ci - 

2,000 Ci of tritium-contaminated scrap. This release was primarily from Building 779A, and its 

eventual detection in waters draining into a reservoir serving as a municipal drinking water supply 

(Incident Summary, 1976; Release Investigation, 1973a; Release Investigation, 1973b). The release 

also resulted in tritium exposure to a small number of Rocky Flats personnel. Subsequent workplace 

monitoring and personnel bioassay was implemented, in part to establish the baseline tritium 

environment against which future incidents could be evaluated. A smaller and less-impactful tritium 

release occurred in September 1974 from Building 777; the subsequent investigation report (Building 

777 Investigation, 1974) includes release details along with summaries of tritium workplace 

monitoring results prior to the incident for comparison. These data provide the basis for a model for 

bounding chronic tritium exposures to workers and of smaller, less-notable tritium releases that might 

have occurred prior to 1973. 

Several factors single out the 1973 tritium release as bounding for the entire history of Rocky Flats 

operations. These factors include the large quantity of tritium involved, the chemical form of the 

released tritium, and the meteorological conditions at the time of the release. Other documented 

releases involved smaller quantities of elemental tritium, having a much smaller dose conversion 

factor than the tritium oxide released in 1973. Bounds for personnel tritium exposures after the 1973 

release can be developed based on measurement results, since personnel bioassay, air sampling, and 

workplace contamination monitoring for tritium became more common after that release. There are 

only very limited tritium measurement results prior to 1973 because tritium was not perceived as a 

radionuclide of occupational or environmental interest at Rocky Flats. Bounding tritium exposures 

for the pre-1973 period are more difficult to develop as a result of this lack of measurement data. 

According to the ChemRisk report (ChemRisk 5, 1994), there was no environmental monitoring for 

tritium prior to 1970, and little in the way of workplace monitoring until after the 1973 tritium release; 

therefore, evidence of tritium releases prior to 1973 is primarily anecdotal. A 600-Ci release of 

elemental tritium (from a different source than the 1973 release) occurred in 1968. 
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The ChemRisk report said the following with regard to possible releases from tritiated Pu shipments 

(ChemRisk 5, 1994, pdf p. 285):

The 1973 findings associated with the tritiated plutonium initiated an investigation of other 

possible similar shipments and processing of tritiated plutonium. The investigation discovered 

three other shipments with maximum estimated tritium releases of 57 Ci (April 1969), 40 Ci 

(March 1971), and 29 Ci (November 1971).

The reported investigation and the documented 1968 release of elemental tritium are the only sources 

of information about other possible releases. The 1968 release was elemental tritium with no 

significant environmental or personnel exposure. None of the three identified potential releases from 

tritiated Pu was near the magnitude of the 1973 release. There is no evidence of a tritium release 

comparable to the magnitude and impact of the 1973 release prior to that year.

Despite the lack of measurement data, it is possible to develop pre-1973 tritium exposure bounds 

based on measurement results provided in a Rocky Flats Area Office (RFAO) report issued 

subsequent to a tritium release in one of the Rocky Flats production buildings on August 30, 1974 

(Building 777 Investigation, 1974). The information contained in this report includes measurement 

data (i.e., results from air samples, surface contamination surveys, and bioassay) from the production 

area where the release occurred as well as comparison data from other areas prior to, during, and after 

the release. Several factors support the use of these data as surrogates for bounding the tritium 

environment at Rocky Flats prior to 1973:

1. Background tritium levels immediately prior to the incident described in the RFAO report, 

although undoubtedly elevated since the more-significant 1973 release, were well below 

dosimetrically-significant values and can be considered fairly representative of typical background 

levels for this analysis. The background tritium levels monitored in the months prior to the 1974 

incident are consistent with internal radiation doses from tritium of well under 1 mrem annually. 

They are dosimetrically insignificant in this sense.

2. The quantity of tritium released (1.5 Ci) was significantly less than that released in 1973, and is 

probably more typical of potential undocumented releases in work areas – particularly those 

resulting from opening contaminated shipping containers.

The 1974 1.5-Ci tritium release is the only documented release from a shipping container in the 

Rocky Flats workplace. It is taken to be typical since there are no other such documented releases 

to use in forming the model. There is documented concern about tritium releases, as shown in the 

following quote from the ChemRisk report (ChemRisk 5, 1994, pdf p. 38):

As early as 1962, Rocky Flats maintained instruments for detection of tritium gas in particular 

work areas of the plant because operations have sometimes resulted in the storage of tritium 

containers.

The instruments available to Rocky Flats at that time were only semi-quantitative for indicating 

the presence of tritium; NIOSH has captured no records of these results.
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Because NIOSH has only identified six documented releases from 1968-1974 (an average of 1 per 

year), the application of a daily release would be a significant/bounding overestimate of the 

number of RFP tritium releases.

3. Tritium was released to the workplace environment, and not in a glovebox.

4. The release involved elemental tritium (HT, T2), and not tritium oxide (HTO)12.

5. The tritium was released from a contaminated shipping container which was procured by Rocky 

Flats in 1970 and can be taken as representative of shipping containers in use prior to 1973.

As stated in the discussion of Item 2, the 1974 1.5-Ci tritium release is the only documented

release from a shipping container in the Rocky Flats workplace. It is taken to be typical since 

there are no other such documented releases to use in forming the model. There is documented 

concern about such releases, as shown in the following quote from the ChemRisk report (SDRB 

8017, pdf p. 38):

As early as 1962, Rocky Flats maintained instruments for detection of tritium gas in particular 

work areas of the plant because operations have sometimes resulted in the storage of tritium 

containers.

The instruments available to Rocky Flats at that time were only semi-quantitative for indicating 

the presence of tritium; NIOSH has captured no records of these results.

Because NIOSH has only identified six documented releases from 1968-1974 (an average of 1 per 

year), the application of a daily release would be a significant/bounding overestimate of the 

number of RFP tritium releases.

6. The incident occurred close enough in time to the 1973 tritium release that work practices and 

controls were likely more similar to those prior to 1973 than to those even a year or two later, as 

procedures and controls evolved with greater sensitivity to the potential for tritium contamination.

The RFAO report provides the best source of monitoring data for use in bounding both chronic and 

accidental tritium exposures to Rocky Flats personnel prior to the unique circumstances of the 1973 

release.

The RFAO report states that elevated tritium concentrations were detected in air samples from 

Room 452 (Special Assembly Area) in Building 777 and from the Building 205 exhaust plenum 

servicing Building 776/777 over the period of August 29 – September 4, 1974 (Building 777 

 12 The impact of the 1973 tritium release was largely due both to the quantity (500 Ci – 2,000 Ci) and the chemical form 

(HTO) of the material. The presence of tritium oxide in the 1973 release resulted from peculiarities of the plutonium 

recovery operation from which it was generated. There is no indication that any other tritium release at Rocky Flats

involved the oxide. Tritium in its elemental form (HT, T2) is far more likely to have been a contaminant at Rocky Flats 

because of the nature of its possible source terms – tritiated accelerator targets (neutron generators), plutonium hydride in 

recovery operations, and boost gas in returned reservoirs or pits.
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Investigation, 1974, pdf p. 9). Subsequent sampling and investigation of the elevated sample results 

concluded that about 1.5 Ci of tritium was released from the exhaust system of Room 452, 

Building 777, when a shipping container (referred to as a “pressure cooker”) received in July 1974 

from Battelle Pacific Northwest Laboratory (BNW) was opened on a downdraft table in Room 452 on 

August 30 (Building 777 Investigation, 1974, pdf pp. 36-39). No elevated environmental tritium levels 

were detected as a result of the incident, but workplace tritium levels seven times the applicable 

Radiological Control Guide were detected in air samples collected on August 30 in Room 452 

adjacent to the downdraft table, with average concentrations for the work week about 1.5 times the 

guidelines. Table 7-1 shows the reported values. 

Table 7-1: Reported Tritium Air Concentrations (μCi/m3) from the August 30, 1974 Release

Sampling Reference Plenum 205, Bldg. 776/777a Room 452, Bldg. 777

Normal Concentrations <1×10-2 <1×10-2

August 29-30, 1974 0.148 37.7

September 3-4, 1974 2.51 1.1

Source: Building 777 Investigation, 1974, pdf pp. 93-96

a

The Special Assembly Glovebox Line in Room 452, Building 777, was normally served by Plenum 206, but exhaust 

air from this area was vented through Plenum 205 from February 11 – August 7, 1974 while a new Plenum 206 was 

constructed. A tritium air sampler for Plenum 206 was installed on August 30, 1974, but showed no elevated results. 

However, both Plenums 205 and Plenum 206 showed elevated tritium removable contamination (Building 777 

Investigation, 1974, pdf pp. 74-82).

An air sampler located near the downdraft table in Room 452 indicated a tritium air concentration of 

4.9×10-3 μCi/m3 on August 29 and 37.7 μCi/m3 on August 30. The applicable Radioactive 

Concentration Guideline at the time was 5 μCi/m3. Two “pressure cookers” were opened at the 

downdraft table, coincident with the elevated tritium-in-air measurements, and were smear-sampled 

for removable tritium contamination. One cooker showed smear levels of 1.16×10-2 μCi; the other 

showed 3.43×102 μCi and was presumed to be the source of the gaseous tritium release.

Results from air samples collected daily in Room 452, Building 777, are available from June 3 to 

September 11, 1974. The air sampler was located near the downdraft table entry to the Special 

Assembly Line where the tritium contaminated “pressure cooker” was opened and was the only 

tritium air sampler in Building 777 at the time. Room air samples were collected in a water bubbler 

during the day shift (approximately 6 or 8 hours sampling time) at an air flow rate of 2 L/min. 

Individual results are shown in Table 7-2 (Building 777 Investigation, 1974, pdf pp. 87-89).
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Table 7-2: Tritium Activity Concentrations in Room Air: Rm. 452 - Special Assembly - Bldg. 777

Analysis Date 

(1974)

H-3

(pCi/m3)

Analysis Date 

(1974)

H-3

(pCi/m3)

Analysis Date 

(1974)

H-3

(pCi/m3)

3-Jun 9,428 8-Jul 3,872 8-Aug 628

5-Jun 12,121 5-Jul 3,030 12-Aug 1,256

4-Jun 20,370 3-Jul 4,655 13-Aug 1,301

7-Jan 5,892 10-Jul 2,602 16-Aug ---

6-Jun 16,498 9-Jul 2,512 20-Aug 2,439

14-Jun 5,387 11-Jul 4,553 21-Aug 3,140

13-Jun 4,553 17-Jul 21,022 22-Aug 3,298

12-Jun 12,358 16-Jul 5,040 23-Aug ---

11-Jun 13,972 15-Jul 6,742 26-Aug 2,927

11-Jun 10,894 19-Jul 5,041 27-Aug 3,089

21-Jun 4,348 18-Jul 4,209 28-Aug 4,874

20-Jun 4,553 24-Jul 1,010 29-Aug 3,986

19-Jun 4,414 23-Jul 4,866 30-Aug 37,676,609

18-Jun 5,781 22-Jul 4,866 3-Sep 1,098,901

17-Jun 6,829 29-Jul 2,512 4-Sep 8,477

26-Jun 4,519 26-Jul 2,118 5-Sep 5,108

25-Jun --- 25-Jul 3,089 6-Sep ---

24-Jun --- 1-Aug 1,842 9-Sep 3,030

2-Jul 3,454 30-Jul 1,727 10-Sep 3,140

1-Jul 4,348 1-Aug 2,269 11-Sep 2,898

27-Jun 5,366 7-Aug 1,179 --- ---

27-Jun 4,553 5-Aug 2,512 --- ---

Source: Building 777 Investigation, 1974, pdf pp. 87-89

The average and standard deviation of daily air sample results prior to August 30, the day of the 

tritium release from the contaminated shipping container, are (5343 ± 4518) pCi/m3. The result on 

August 30 is 37,676,609 pCi/m3, and the sample taken on September 3 indicated a tritium 

concentration in the room air of 1,098,901 pCi/m3. However, the September 3 result is suspect 

because the sample was collected in the same vessel that was used on August 30 and which had not 

been cleaned. Smear surveys of Room 452 on September 3 failed to show significant tritium 

contamination (Building 777 Investigation, 1974, pdf pp. 37-38). Tritium levels in Building 777 were 

known to be somewhat elevated over normal background because of residual contamination present

since the 1973 tritium release. 

The practice of pulling a sample of air from within shipping containers through a tritium air monitor 

to check for contamination was implemented after the 1973 tritium release. This practice was 

discontinued after urinary tritium results in the range of 0.75 μCi/L – 1.3 μCi/L were detected in May 
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1974 for the health physics technician who performed the monitoring. The technician’s urinary 

tritium dropped to less than 0.1 μCi/L beginning in early July 1974 (Building 777 Investigation, 1974, 

pdf pp. 18-19).

All employees who worked in Room 452, Building 777, submitted urine samples after the August 30 

tritium release, with a high result of 32,320 pCi/L. Table 7-3 shows individual results (Building 777 

Investigation, 1974, pdf p. 90).

Table 7-3: Tritium Urinalysis Results - Exposed Workers and Others, August 30, 1974

Worker ID Area Urinary Tritium 

(pCi/L) Uncertainty (pCi/L)

510 777 32320 ± 6170

869 777 25610 ± 6100

180 779 24000 ---

548 777 22370 ± 5800

12 777 21600 ± 5800

112 707 17000 ---

998 777 15740 ± 6100

680 777 15730 ± 5640

449 779 14000 ---

801 707 13700 ± 5370

004 123 630 ± 580

Non-Occupational (Denver) 470 ---

Source: Building 777 Investigation, 1974, pdf p. 90

Three hyphens (---) = Value not provided.

The report indicates that both a Denver resident and a Dow employee who did not work in radioactive 

material-handling areas were sampled with results < 0.01 μCi/L (<10,000 pCi/L). The Denver 

resident is identified in Table 3, and Worker ID 004 is believed, by implication, to be the Dow nonradiological worker.

Over 200 smear results for tritium are tabulated in the RFAO report (Building 777 Investigation, 

1974, pdf pp. 74-82). Most appear to be surveys inside gloveboxes, but there are also workplace area 

results that can be used as indicators of likely sources of internal contamination of workers following 

an event such as the one in August 1974. The workplace smear results are shown in Table 7-4.
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Table 7-4: Tritium Smear Surveys - Work Areas in Buildings 776-777

(This table spans two pages)

Date Bldg/Room Location Maximum Smear (pCi)

9/6/74 776-205 205 Plenum - cold side < 100

9/6/74 776-206 206 Plenum - cold side < 100

9/6/74 777-452 206-532 - top of box < 100

9/6/74 777-430 E.S. Welder 353,000

9/6/74 777-437 Penthouse < 100

9/6/74 777-437 A-1 110,000

9/6/74 777-437 A-2 4,800

9/6/74 777-437 A-3 9,400

9/6/74 777-463 A-5 1,200

9/6/74 777-463 Conveyor Line 7,900

9/6/74 777-463 A-7 7,700

9/9/74 776-205 205 Plenum (hot side) 211,000

9/9/74 776-206 206 Plenum (hot side) 1,230,000

9/10/74 776 - Size Reduction Floor < 500

9/10/74 776-201 Floor 1,100

9/11/74 777-452 Floor at J-24 460

9/11/74 777-452 Floor at K-24 470

9/11/74 777-452 Floor at L-24 640

9/11/74 777-452 Floor at M-24 780

9/11/74 777-452 Floor at K-25 560

9/11/74 777-452 Floor at J-25 950

9/11/74 776-250 Plenum Floor < 100

9/11/74 776-250 Plenum Fan < 100

9/11/74 776-252 Plenum Floor 465

9/11/74 776-252 Plenum Filter 1,636

9/11/74 776-S-8 Plenum Filter < 100

9/11/74 776-S-8 Plenum Deep Beds < 100

9/11/74 776-S-7 Plenum Filter < 100

9/11/74 776-S-7 Plenum Floor < 100

9/11/74 776-S-4 Plenum Filter < 100

9/11/74 776-251 Plenum Floor 3,625

9/11/74 776-251 Plenum Filter 3,603

9/11/74 776-440 Floor 1,000

9/11/74 776-432 Floor K-20 500

9/11/74 776-432 Floor H-19 1,460

9/11/74 776-432 Floor H-20 710
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Table 7-4: Tritium Smear Surveys - Work Areas in Buildings 776-777

(This table spans two pages)

Date Bldg/Room Location Maximum Smear (pCi)

9/11/74 776-432 Floor K-19 520

9/11/74 776-201 #1 System Kathene 160,000

9/11/74 776-201 #4 System Kathene 400,000

9/11/74 776-201 #3/7 System Kathene 450,000

9/11/74 776-201 #8 System Kathene 140,000

9/11/74 776-201 GBDA System Kathene 400,000

Source: Building 777 Investigation, 1974, pdf pp. 74-82

The exhaust plenums and the Kathabar air driers (which use a lithium chloride solution called 

Kathene) appear to have collected the greatest amount of tritium after the release. Workers 

responsible for changing filters in the plenums or recharging the Kathabar systems would appear to be 

at greatest risk for tritium uptake after the initial release.

NIOSH assessed the 1.5-Ci tritium release from a contaminated shipping container that occurred on 

August 30, 1974. The RFAO report provides air survey, bioassay, and smear survey results (Building 

777 Investigation, 1974). Specific urine sample collection dates were not included in the report but 

data were matched to two NOCTS claims, which reported a collection date of September 5, 1974. 

NIOSH performed a dose assessment using the Integrated Modules for Bioassay Analysis (IMBA) 

software. An intake date of August 30, 1974 was assumed, and the largest reported result collected 

after the incident of 36,320 pCi/L was used. There was a slight discrepancy (one digit) between the 

result included in the RFAO report and that in the NOCTS case file; the NOCTS value is assumed to

be correct because it is the handwritten urinalysis record and is also the larger of the two values. The 

resulting dose from NIOSH’s analysis is < 1 mrem (0.15 mrem). Assuming one incident per day at 

0.15 mrem for 250 days results in a dose of 37.5 mrem/year for the pre-1973 time period.

Follow-up on the 1973 Tritium Exposure Period and Methods for Bounding Dose

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.

The report, Investigation of the Tritium Release Occurrence at the Rocky Flats Plant (Release 

Investigation, 1973c, pdf p. 16), describes a 1973 incident that prompted the site to sample a number 

of workers for tritium exposure (Dosimetry Records, name1; Dosimetry Records, name2; Dosimetry 

Records, name3; NOCTS, 2012; Release Investigation, 1973, pdf p. 16). A shipment of scrap 

plutonium from LLNL was discovered to have been contaminated with tritium. This material was 

processed at the Rocky Flats Plant from April 9 to 25, 1973 in Building 779A, Room 154. Because it 
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was not immediately identified as being contaminated, monitoring of potentially-exposed individuals 

did not begin until late September 1973.

Two hundred fifty people were sampled following the discovery; this included all employees who 

worked in areas in which the contaminated scrap was processed. The waste stream from the 

processing of this material was also contaminated, providing opportunities for intake of H-3 at later 

dates; therefore, all employees involved in the processing of wastes from this scrap were also included 

in the urinalysis program. The collection of samples from a tritium-contaminated water bubbler on 

September 19 and September 25, 1973 were also identified as possible opportunities for intakes.

Due to the large sample load, raw urine samples were first analyzed in many of the cases. It was 

noted that the counting efficiency was only about 3% for these analyses, and that the corrections made 

for spectral shift could lead to abnormally-high readings. Nineteen employees were initially 

identified as having elevated tritium levels in their urine. These samples were distilled and reanalyzed. Upon this recheck, fourteen of these employees were found to be below the 10,000 pCi/L 

action level established by the site. The five most-exposed individuals were identified and details of 

their potential exposures, including bioassay results, are included in the investigation report. One of 

these five individuals is in NOCTS. The results of the five workers who exceeded the 10,000 pCi/L 

action level were reviewed by NIOSH. 

Exhibit 14 of the referenced report contains a section on Personnel Exposure Data. The following is 

an excerpt (Release Investigation, 1973c, pdf p. 122):

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.
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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.

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). The pre-distilled 

results were used in the development of this analysis because there were more results available and 

they yielded claimant-favorable doses. The following assumptions were employed in this assessment:

• Equal weight to all samples (measurement error the same for all samples)

• Only pre-distilled samples used for fits (these are shown as blue dots in the figures; distilled 

samples appear in red and are not used in the analysis)

• H-3 in the form of tritiated water (HTO)

• IMBA model for inorganic H-3, as described in Guidance on Use of IMBA Software for DOE 

Safety Applications (DOE, 2006)

• Injection intake (for modeling with IMBA)

• Intake dates based on worker information and examination of fit to urine sample results

The five workers identified as having the largest H-3 urinalysis results are assessed below. Text in 

italics indicates an excerpt from the incident report.
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Case A 

Case A worked in Room [location redacted] from [date range redacted]. 

He was involved in the hydrating [sic: likely hydriding] 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. 

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, as shown in Figure 

7-1. 

Figure 7-1: Case A Chronic Intake of HTO from April 11 through April 25, 1973
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Based on the worker’s history and the bioassay result pattern, an acute intake was assumed to have 

occurred on September 19, 1973. Using the results of samples collected from Sept. 25 to Oct. 4, and 

applying a uniform error to each of the samples, the intake is 38.7 μCi. The corresponding dose is 2.6 

mrem. These samples are presumed to be pre-distilled because later samples from Oct. 5 to Oct. 12 

are labeled as “distilled.” This yields a very good fit to the pre-distilled results (see Figure 7-2). 

Figure 7-2: Case A Acute Intake of HTO on September 19, 1973

Case B

He has worked in [location redacted] since [date redacted]. He was in the room when [action 

redacted]. 

Assuming a chronic intake from July 1 through Sept. 25 (date of first urine sample) yields an 

intake rate of 0.33 μCi/d (for a total intake of 28.1 μCi) and provides a reasonable fit to the results 

(see Figure 7-3). The dose is 1.90 mrem. 

Figure 7-3: Case B Chronic Intake of HTO from July 1 through September 25, 1973
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Assumption of an acute intake on Sept. 19 (date of the first bubbler sample) yields an intake of 

7.28 μCi. This fit (see Figure 7-4) is almost identical to the first scenario. 

Figure 7-4: Case B Acute Intake of HTO on September 19, 1973

A single acute intake on his first day in the area (July 1) yields an intake of 720 μCi and a dose of 

49 mrem (see Figure 7-5). 

Figure 7-5: Case B Acute Intake of HTO on July 1, 1973

The single acute intake on July 1 does not provide a good fit to the later pre-distilled results. The 

first two scenarios (chronic intake from July 1 through Sept. 25, and acute intake on Sept. 19) 

provide similar fits that reasonably follow the pattern of the pre-distilled samples. The chronic 

intake yields a larger intake so it is used for the best estimate.
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Case C

He worked in [location redacted] since [date redacted]. He was not in the room when [action 

redacted]. 

Given that the worker did not start in the area until August 27, an acute intake was assumed on 

this date (see Figure 7-6). Using only the pre-distilled sample results, his intake is 21.3 μCi with a 

dose of 1.4 mrem. 

Figure 7-6: Case C Acute Intake of HTO on August 27, 1973

If a chronic intake is assumed to have started on his first day of potential exposure (August 27) 

and continued until the date of his first sample (Sept. 25), the resulting intake is 0.24 μCi/d for a 

total intake of 7.08 μCi. This fit is shown in Figure 7-7. 

Figure 7-7: Case C Chronic Intake of HTO from August 27 through September 25, 1973

The two fits are very similar, so the acute intake is selected as the best fit as it results in a dose that 

is more favorable to the claimant.
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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 three days, although there are two results on two of those days. 

In one instance, one of the samples was distilled; on the other day, there is a note stating “repeated 

with sample channel ratio.” On the latter day, the results differ by a factor of almost two; the 

larger of these results is assumed to be the pre-distilled analysis and is used for the intake 

assessment. An assumed chronic intake from April 10 through 25 (last date of incident) yields an 

intake of 71.2 μCi/d for a total intake of 1070 μCi (see Figure 7-8). The resulting dose is 72 

mrem. 

Figure 7-8: Case D Chronic Intake of HTO from April 10 through April 25, 1973

A chronic intake from April 10 to June 15 yields an intake rate of 8.84 μCi/d for a total intake of 

581 μCi (39 mrem), as shown in Figure 7-9. 
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Figure 7-9: Case D Chronic Intake of HTO from April 10 through June 15, 1973

Because there are few samples and the results follow no specific pattern, there is little difference 

between the fits. Therefore, the acute intake is assigned because it yields the larger dose. 

Case H

He came in contact with the possible source of tritium on [date redacted]. 

No other information is included in the report. The conclusion in the report is: (It is expected that, 

as a result of a review of his work history and urinalysis data, a dose assignment of less than 3 

rem will be made.) However, no follow-up information is available. 

Because the only available information indicates that an intake would have occurred on April 6, an 

acute intake was modeled (see Figure 7-10). The resulting intake is 1240 μCi with a dose of 84 

mrem. 

Figure 7-10: Case H Acute Intake of HTO on April 6, 1973
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The best estimates for the five cases reviewed are summarized in Table 7-5 below. Tritium 

contamination was associated with plutonium scrap material; therefore, H-3 doses will be assigned 

to all individuals who were monitored for plutonium in 1973. Because monitoring began several 

months after the potential start of exposure, the largest assessed dose (84 mrem) will be assigned. 

Table 7-5: Summary of Intake Assessments for the RFP 1973 Incident

Case Intake Date Intake (μCi) Dose (mrem)

A 9/19/73 38.7 2.6

B 7/1 thru 9/25/73 28.1 1.9

C 8/27/73 21.3 1.4

D 4/10 thru 4/25/73 1070 72

H 4/6/73 1240 84

Follow-up on the Post-1973 Tritium Exposure Period and Methods for Bounding Dose 

For the assessment of tritium exposures at RFP for the 1974-1975 period, a co-worker study was 

performed using data from NOCTS for 1974 and 1975. There are 38 individuals with tritium data in 

1974 and 37 in 1975. ORAUT-OTIB-0075, Use of Claimant Datasets for Coworker Modeling, 

provides justification and guidance. 

When assessing tritium intakes for most sites, it is assumed that intake potential exists only while 

tritium bioassay monitoring is being performed because monitoring is cheap, easy, and requires only 

spot samples, thus presenting less of a burden than other forms of bioassay on both the employer and 

the employee. Because tritium was not of primary concern at RFP and was present only as a potential 

contaminant on equipment, a given individual was not placed on a routine sampling program. Instead, 

a program was established whereby one-tenth of the urine samples collected for plutonium analysis 

were also analyzed for tritium content (Tritium Monitoring, 1974) as well as the collection of samples 

when there was a particular concern. Samples available in NOCTS for these two years indicate that 

analyses were performed throughout the year, with most individuals sampled only once. 

For the purpose of the co-worker study, it was assumed that each worker had the potential to be 

exposed at a constant level throughout the year in which the urine sample was collected. The 95th

percentile was used because one-tenth of the population was sampled. The co-worker study for 1974 -

1975 yielded doses of 0 mrem for everyone. 

For the years after 1975, there are 11 or fewer individuals in NOCTS with tritium data; this is 

insufficient for performing a co-worker study. Results for these years are consistent with those from 

the previous years and show a general decreasing trend. The intake rate from the 1974-1975 

co-worker study (i.e., 0 mrem - see above) will apply to these years; therefore, no additional dose due 

to tritium, as it relates to the assessment performed in this analysis, will be assigned after 1973.
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7.2.1.2 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. This 

assessment corroborates that the original tritium assessment presented in Rev. 0 of SEC-00192 did 

provide a bounding tritium assessment. The assessment provided in this Rev. 1 of the report provides 

a sufficiently accurate assessment of tritium dose at RFP for use in individual dose reconstruction. 

The pre-1973, 1973, and post-1973 dose values are summarized below.

• Pre-1973: Using the largest reported result collected after the August 30, 1974 incident, the 

resulting dose is < 1 mrem (0.15 mrem). Assuming one incident per day at 0.15 mrem for 250 

days results in a dose of 37.5 mrem/year for the pre-1973 time period.

• 1973: Using the bioassay samples collected after tritium incident associated with contaminated 

scrap in mid- to late-April 1973 resulted in a maximizing dose of 84 mrem and is applied as a 

bounding estimate of all unmonitored workers. This dose is more precise than the estimate in 

Revision 0 of the SEC00192 evaluation report, but is still maximizing. 

• Post-1973: A co-worker study using data from NOCTS for 1974 and 1975 resulted in an annual 

dose of less than 1 mrem; therefore, no dose will be assigned for unmonitored tritium after 1973.

7.2.2 Evaluation of Bounding Process-Related Thorium Doses

While the RFP SEC evaluation performed as part of the SEC-00030 petition review included an 

assessment of thorium operations at the site, additional issues were opened during the review and 

assessment of SEC-00192 that required a response to support closure of the issue. As part of the 

thorium follow-up, NIOSH reviewed the SEC-00030 working group discussion on this issue and 

located the final response from the SEC-00030 documentation (NIOSH, 2007). Because the Working 

Group and SC&A rejected the originally-proposed NUREG-1400 approach and the use of GA data 

from operations, NIOSH’s final response proposed using data from a surrogate data source. This 

response preceded the final deliberations with the Board on the use of surrogate data published in IG0004 in 2008. After further review of the air data included in the Albert document, it was found that 

the data were from a study published by the Albany Research Center in Albany, Oregon (Thorium, 

2006). NIOSH determined that the report was a one-time operation conducted under experimental 

laboratory conditions, and therefore, does not meet the surrogate data criteria for use for RFP dose 

reconstruction. The additional information gained from the most recent data captures support the 

reopening of this issue, and the identification of a class for which dose cannot be reconstructed with 

sufficient accuracy.

The principal source of internal thorium radiation doses for members of the class under evaluation 

was associated with RFP thorium research and development operations. There is limited information 

and data available for reconstructing the process-related internal thorium doses of members of the 

class under evaluation. There are limited thorium monitoring data, including two in vitro bioassay 

(urinalysis) results for thorium in 1966 (listed in NOCTS and the SRDB). There are additional urine 
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bioassay records and some area monitoring information for the 1950s and 1960s in the SRDB, but 

there are no clear monitoring results associated with the records. While NIOSH has identified source 

term information to support the existence of thorium on site starting with the beginning of RFP 

operations in 1952 through the late 1960s and early 1970s, these data are a snapshot of the quantity of 

thorium on site at a point in time and do not represent throughput of thorium at the site. In addition, 

classification issues limit NIOSH’s ability to present additional detail on material amounts in this 

evaluation report.

7.2.2.1 Methods for Bounding Thorium Dose at Rocky Flats

NIOSH has found limited personnel and workplace monitoring records and data specific to thorium 

for the period under evaluation that can be used to bound the associated dose. Most of the available 

data are gross alpha concentrations. Limited radionuclide-specific air-sampling data for thorium have

been identified. In addition, NIOSH lacks sufficient source term information that would allow it to 

present an estimate for potential thorium exposures to which the proposed class may have been 

exposed.

7.2.2.2 Internal Thorium Dose Reconstruction Feasibility Conclusion

NIOSH has evaluated the available personnel and workplace monitoring data and has determined that 

these data are insufficient for estimating internal thorium exposures. In the absence of adequate in 

vitro or in vivo bioassay, NIOSH would employ source term data. However, NIOSH lacks sufficient 

source term data that are inclusive of the throughput amounts of thorium (i.e., they only represent a 

snapshot in time in regards to quantities); these data do not support estimating potential internal 

exposures to thorium during the period of RFP thorium operations from April 1, 1952 through 

December 31, 1966.

NIOSH has determined that the significant thorium operations at RFP were secured prior to the end of 

the SEC class being proposed in this report. Therefore, NIOSH finds that the available internal 

monitoring data for RFP are adequate to support sufficiently accurate dose reconstruction beginning 

January 1, 1984. Furthermore, NIOSH believes that maturation of RFP work practices and programs 

as well as the nature of work performed after 1983 were such that dose from potential intakes of 

residual thorium can be bounded with sufficient accuracy.

Although NIOSH found that it is not possible to completely reconstruct internal thorium radiation 

doses for the period from April 1, 1952 through December 31, 1966, NIOSH intends to use any 

internal thorium monitoring data that may become available for an individual claim (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures). Dose reconstructions 

for individuals employed at RFP during the period from April 1, 1952 through December 31, 1966, 

but who do not qualify for inclusion in the SEC, may be performed using these data as appropriate.
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7.2.3 Evaluation of Bounding Process-Related U-233 Doses

Production of U-233 also results in the unavoidable production of uranium-232, a problematic 

contaminant with a half life of 72 years. U-232 decays via alpha emission to thorium-228, a member 

of the thorium decays series, which subsequently decays to produce several strong gamma-emitting 

radionuclides. In addition to being an internal dose hazard, U-232 and its gamma-emitting progeny 

represent a significant external radiation hazard. The purpose of the “thorium strike” operation was to 

remove Th-228 from U-233, thus reducing the gamma radiation levels. 

7.2.3.1 U-233 Urinalysis Information and Available Data

Previous SEC reviews and evaluations did not dispute the adequacy of the RFP internal monitoring 

practices for uranium – workers with potential for uranium exposures were assigned to bioassay 

programs. The RFP Site Profile provides a method for assessing dose from uranium exposures for 

individual dose reconstructions that does not discriminate between uranium isotopes. However, the 

Site Profile does not specifically address potential intakes of U-233, or the associated U-232. 

Operators involved with the U-233 process that were listed in the early U-233 operations logbook 

were used to support a review of participation in the RFP uranium bioassay program for the early 

years of the U-233 operation (Logbook, 1965-1967, pdf pp. 4-5). Of the 46 individuals involved in U233 operations at that time, as listed in the logbook, 18 are NOCTS claimants. All of these 18 

NOCTS claimants participated in the RFP bioassay program over their entire employment period (this 

includes uranium, plutonium, and gross-alpha bioassay results as well as some chest-count data in 

their dosimetry records). All but one claimant have uranium bioassay results in the period associated 

with the U-233 work represented in the logbook.

7.2.3.2 U-233 Airborne Survey Data

NIOSH has identified some limited air monitoring data for operations involving U-233. A source 

document states that “thorium purification” of U-233 solution was carried out in Building 771 from 

April 26 through May 1, 1965 (Investigation Summary, 1965, pdf pp. 8-9, 17, 44). Data presented in 

Table 7-6 appear to indicate relatively-low air concentration levels during this operation (RFP, 

1965a). 

Table 7-6: April 1965 Air Sample Results from Building 771, Room 114

Date Maximum Percent of Radiation Control Guides (RCG)

4/26/65 32%

4/27/65 <25%

4/28/65 <25%

4/29/65 39%

Source: RFP, 1965a, pdf pp. 12, 19, 25-26
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From these data, however, it is unclear what the relative concentrations of Th-228 may have been. As 

is often the case with air monitoring data, the representativeness of the sampling locations to actual 

worker breathing zones is also uncertain. 

An RFP interviewee indicated that thorium strikes occurred in Building 81, Room 266 (Personal 

Communication, 2007). The air sampling data associated with that location and operations period 

(April 26-29, 1965) are below 50% RCG (Air Monitoring, 1965, starting at pdf p. 115). As with the 

data presented in Table 7-6, it is unclear from the Building 81 data what the Th-228 concentrations 

may have been and the representativeness of the sample locations is also questionable. 

In a logbook that appears to be related to U-233 operations during the 1965-1967 time period, the 

author states (Logbook, 1964-1967):

Air samples were all way below MPL with the exception of those taken inside plastic house 

around the furnace in Rm. 142. During foundry operations air samples inside plastic house 

varied from 35% MPL to 13,054% MPL. Furnace operations have to be watched closely for 

airborne problems.

The term “MPL” is assumed to be Maximum Permissible Level established by the AEC; NIOSH has 

no confirmed relationship between MPL and RCG.

7.2.3.3 Evaluation: Bounding Ambient Environmental Internal U-233 Doses

The predominant forms of uranium processed at RFP were depleted and enriched uranium, consisting 

of the naturally occurring isotopes, U-234, U-235, and U-238. For this reason, these uranium isotopes 

were likely to have been the predominant contributors to the ambient environmental dose from all 

uranium isotopes at RFP. Methodologies for evaluating environmental dose from enriched and 

depleted uranium are described in ORAUT-TKBS-0011-4. Because of the data issues and limitations 

presented in this report, no specific methods to bound environmental doses from U-233 and U-232 

have been pursued or defined.

7.2.3.4 Methods for Bounding U-233 Dose at Rocky Flats

If uranium bioassay data are available for individual claimants who are known to have been 

potentially exposed to U-233 and U-232, it may be feasible to reconstruct their internal doses by 

making claimant-favorable assumptions with regard to the uranium isotopes present in their

urinalyses. However, since U-233 has a much higher specific activity when compared to the other 

naturally-occurring uranium isotopes (“140 times that of enriched U-235 normally handled at Rocky 

Flats” [Investigation Summary, 1965]), NIOSH cannot assume that it was handled in a similar manner 

as other uranium isotopes. For this reason, co-worker models using internal dosimetry data for other 

uranium isotopes cannot be used to bound intakes of U-233 or U-232 for workers who were not 

specifically monitored for uranium. 

In the absence of thorium bioassay records, NIOSH has not developed an acceptable method for 

reconstructing potential internal dose from Th-228 that would have been associated with U-233 

processes.
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7.2.3.5 Internal U-233 Dose Reconstruction Feasibility Conclusion

For claimants with available uranium bioassay records and who were known to have been potentially 

exposed to U-233 and U-232, it may be feasible to reconstruct internal doses to these isotopes by 

making claimant-favorable assumptions with regard to the uranium isotopes present in their 

urinalyses. However, in its review of available bioassay records for individuals identified as having 

worked in U-233 processing areas, NIOSH has determined that uranium bioassay data may not be 

available for all potentially affected individuals. Additionally, these same workers were also 

potentially exposed to Th-228. NIOSH lacks thorium bioassay data for Rocky Flats personnel. 

NIOSH also recognizes that the available U-233 inventory numbers do not necessarily represent 

production throughput. Furthermore, NIOSH has determined that workplace air monitoring and 

contamination surveys for U-233 processes are insufficient for bounding dose reconstruction 

purposes. In the absence of adequate personnel or workplace monitoring data, NIOSH would employ 

source term data. However, NIOSH lacks sufficient source term data that are inclusive of the 

throughput amounts of U-233 or its progeny (i.e., they only represent a snapshot in time in regards to 

quantities); these data do not support estimating potential internal exposures to U-233 or its progeny 

during the period of RFP U-233 operations from 1964 through 1983. Without uranium and thorium 

bioassay results, NIOSH has concluded that it cannot estimate with sufficient accuracy the potential 

internal exposures to U-233, U-232, and Th-228 which the proposed class may have received.

Although NIOSH found that it is not possible to completely reconstruct internal U-233/U-232/Th-228 

radiation doses for the period from 1964 through 1983, NIOSH intends to use any related internal 

monitoring data that may become available for an individual claim (and that can be interpreted using 

existing NIOSH dose reconstruction processes or procedures). Dose reconstructions for individuals 

employed at RFP during the period from 1964 through 1983, but who do not qualify for inclusion in 

the SEC, may be performed using these data as appropriate.

7.2.4 Evaluation of Bounding Process-Related Np-237 Doses

Insufficient information exists for evaluating bounding doses for neptunium exposures. Only two 

bioassay results obtained in 1966 have been captured (Monthly Reports, 1965-1967, pdf pp. 74, 78; 

Logbook, 1966-1969, pdf pp. 3, 5). NIOSH has not captured workplace air monitoring, surface 

contamination surveys, or process details sufficient to reconstruct the neptunium exposure 

environment for any year under evaluation.

7.2.4.1 Np-237 Urinalysis Information and Available Data

Two bioassay results obtained in 1966 have been captured (Monthly Reports, 1965-1967, pdf pp. 74, 

78; Logbook, 1966-1969, pdf pp. 3, 5).

7.2.4.2 Np-237 Airborne Survey Data

Any ambient environmental exposures to monitored individuals will be accounted for in assigning the 

process-related dose based on individual monitoring data. Therefore, no additional dose from ambient 

environmental internal exposures would be assigned unless: (1) the ambient environmental dose is 
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assigned separately to ensure claimant-favorability in the dose reconstruction; or (2) the ambient 

environmental dose is representative of the internal exposures for monitored individuals with little or 

no workplace exposure potential.

The primary internal exposure pathway (ambient or workplace) cannot be determined for unmonitored 

workers, since there is no evidence of a personnel monitoring program for neptunium.

7.2.4.3 Internal Np-237 Dose Reconstruction Feasibility Conclusion

Beginning in 1962, neptunium was processed at Rocky Flats by request from other DOE sites. 

NIOSH currently believes that activities associated with neptunium virtually ceased after 1983, even 

though neptunium inventories existed until the end of 1988. Whether neptunium was handled or 

processed from 1984-1988 at Rocky Flats is still being evaluated. Less than 1,500 g of neptunium 

was reported in inventory for any year, and processing capacity was limited to quantities of less than 

500 g per batch. The number of Rocky Flats employees who worked with neptunium appears to have 

been quite limited, but no personnel records have been captured with information about these workers 

or their work assignments with neptunium exposure potential. Only two neptunium bioassay results 

have been captured by NIOSH. The bioassay results are not accompanied by additional information 

about the specific task performed, the conditions under which the exposure occurred, the degree to 

which neptunium work was part of the employee’s regular job assignment, or whether other 

employees might also have been exposed. Neptunium-handling procedures appear to have been the 

same as those for plutonium, with separation provided between the neptunium and workers by hoods 

or glove boxes. The processing resulted in purified neptunium as oxide, fluoride, or metal that was 

then used in further processing or fabrication of specific items specified by the requesting DOE site. 

Neptunium exposure potential for RFP workers existed at every processing step, including extraction 

and purification, hydrofluorination, reduction to metal, alloying with U and Pu, casting, and rolling. 

Urinalysis procedures for neptunium existed, given that two neptunium bioassay results from 1965 

were captured; however, there is no information about the procedures, which may have been 

performed in the 771 Building rather than in the environmental and personnel monitoring labs 

(Personal Communication, 2013s, pdf p. 3).

NIOSH has evaluated the available personnel and workplace monitoring data and has determined that 

these data are insufficient for estimating internal neptunium exposures. In the absence of adequate in 

vitro or in vivo bioassay, NIOSH also lacks sufficient source term data to support estimating potential 

internal exposures to neptunium during the period of RFP neptunium operations from 1962 through 

December 31, 1983.

According to a report published in 1981, some early work with neptunium was accomplished at 

Rocky Flats in open hoods, which were later replaced by alpha containment gloveboxes (SRDB 

127272, pdf p. 7). There is insufficient information to determine how much neptunium was processed 

in the open hoods or when the neptunium work was moved to gloveboxes. It is clear, though, that all 

neptunium processing was performed in gloveboxes by the time of the 1981 report. It is also apparent 

from interviews with knowledgeable individuals that in vitro bioassay techniques were improved by 

1981 (with ion exchange separation, electroplating, and isotope-specific pulse-height analysis); these 

improved techniques provided the capability of isolating and quantifying neptunium in bioassay 
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samples (Personal Communication, 2013s, pdf pp. 4-5; Personal Communication, 2013r, pdf pp. 3-5). 

In addition, in vivo techniques improved greatly beginning in 1976 with the use of high-purity 

germanium detectors in place of sodium iodide or phoswich detectors for resolving interfering 

photopeaks in whole-body and organ counts (ORAUT-TKBS-0011-5, Appendix B).

There is no information to determine conclusively when neptunium operations ceased at Rocky Flats, 

but nuclear material inventories, which fluctuated substantially during the period from 1962 through 

1983, became relatively stable after 1983 (Inventory, 1966-1988). This inventory stability suggests 

that plant receipts and shipments of the material were much less dynamic from 1984 through 1988,

indicating that there was little or no neptunium processing during this period. After 1988, there was 

no accountable neptunium on site. NIOSH believes that RFP neptunium operations ceased by the end 

of 1983. Therefore, in the absence of bioassay results (except for two in 1965) and of workplace air 

or contamination results for neptunium, and because of the uncertainty of Rocky Flats’ ability to 

adequately measure neptunium in biological samples at the time of the two known neptunium 

bioassay results in 1965, NIOSH finds that the available internal and workplace monitoring data for 

neptunium are inadequate to support sufficiently accurate dose reconstruction during the period of 

neptunium operations before the end of 1983. Furthermore, NIOSH believes that maturation of RFP 

work practices (e.g., alpha containment gloveboxes, contamination control) and programs (e.g., 

documented laboratory techniques, improved radiological monitoring technology, improved record 

keeping) as well as the nature of work performed after 1983 were such that dose from potential 

intakes of residual neptunium after 1983 can be bounded with sufficient accuracy.

In the absence of adequate personnel or workplace monitoring data, NIOSH would employ source 

term data. However, NIOSH lacks sufficient source term data that are inclusive of the throughput 

amounts of neptunium (i.e., they only represent a snapshot in time in regards to quantities); these data 

do not support estimating potential internal exposures to neptunium during the period of RFP 

neptunium operations from 1962 through December 31, 1983.Without sufficient bioassay results, 

NIOSH has concluded that it cannot estimate with sufficient accuracy the potential internal exposures 

to neptunium which the proposed class may have received.

Although NIOSH found that it is not possible to completely reconstruct internal neptunium radiation 

doses for the period from 1962 through December 31, 1983, NIOSH intends to use any internal 

neptunium monitoring data that may become available for an individual claim (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures). Dose reconstructions 

for individuals employed at RFP during the period from 1962 through December 31, 1983, but who 

do not qualify for inclusion in the SEC, may be performed using these data as appropriate.

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. SEC-00030 concluded that all external dose 

except neutrons could be estimated with sufficient accuracy. Because this revision of SEC Evaluation 

Report SEC-00192 was initiated based upon NIOSH’s subsequent research and determination that 

internal radiation exposures to U-233, thorium, and Np-237 could not be reconstructed, 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 
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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 

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.
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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.]

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.
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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.

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]:
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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 

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. 
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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.

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. 
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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.

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.
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• 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.

• 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.
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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.

• 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.
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• 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.

•

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.
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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. 

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.
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• 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), U-233, Am-241, Np-237, Cm-244, and 

Po-210. Purification of Am-241 began in 1962 and continued to 1979. U-233 processing at RFP 

was conducted from 1965-1982. Operations involving U-233 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.

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).
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• 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.

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.
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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).

Documents captured by NIOSH in evaluating the feasibility of reconstructing tritium doses, 

however, led NIOSH to also re-examine the feasibility of estimating doses from other 

radionuclides that were present ancillary to the primary mission at the Rocky Flats plant or that 

were handled in small quantities. The feasibility of reconstructing doses for Rocky Flats Plant 

workers from exposures to uranium-233/thorium-232 and neptunium-237 during the period 

January 1, 1962 (the start of Np operations) through December 31, 1983 (the end of Np and U-233 

operations) was also evaluated.

• 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).

7.5.1 Post-SEC-00192, Rev. 0 SEC Issues Follow-up

After the presentation of the SEC-00192, Rev. 0 evaluation report, the report was assigned to a Board 

working group. Working group reviews identified additional issues requiring additional response and 

follow-up; except as noted, these issues are addressed in this revised evaluation report.

• ISSUE: During subsequent Board working group reviews and meetings, the petitioner brought up 

issues regarding the 1989 FBI raid at RFP and the potential relationship between the 

environmental issues leading to the raid and the Occupational Radiological Monitoring program at 

the site.

RESPONSE: Follow-up and response on this issue has been performed outside of the scope of this 

revised evaluation report. Therefore, the documented response will be submitted separately from 

this report.
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• ISSUE: During subsequent Board working group meetings, the petitioner brought up issues 

regarding other potential thorium exposures at the RFP site.

RESPONSE: Although an assessment of thorium exposures was performed as part of the 

SEC-00030 RFP evaluation, other thorium issues or unresolved thorium issues remain that require 

closure. The unresolved issues, other than Mg-Th alloys, have been assessed and included in this 

revised SEC evaluation report.

• ISSUE: As part of the working group follow-up reviews and interviews/site visits for RFP 

information, the working group identified the potential for more U-233 thorium strikes than were 

estimated in the SEC-00030 RFP evaluation report. As part of the follow-up to these additional 

thorium strikes, NIOSH identified issues with reconstructing U-233/U-232 dose and Th-228 dose 

relating to the U-233 and thorium-strike operations.

RESPONSE: Although an assessment of U-233 operations and thorium exposures from thorium 

strikes was performed as part of the SEC-00030 RFP evaluation, additional issues or unresolved 

question remain that require closure. The unresolved U-233 operations and thorium strike issues 

have been assessed and included as part of this revised SEC evaluation report.

• ISSUE: As part of the working group follow-up reviews and interviews/site visits for RFP 

information, NIOSH and the working group identified issues relating to neptunium operations at 

RFP.

• RESPONSE: The unresolved neptunium operations and issues have been assessed and included as 

part of this revised SEC evaluation report.
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7.6 Summary of Feasibility Findings for Petition SEC-00192

Table 7-7 summarizes the results of the feasibility findings at Rocky Flats Plant for each exposure 

source during the time period April 1, 1952 through December 31, 2005.

Table 7-7: Summary of Feasibility Findings for SEC-00192

April 1, 1952 through December 31, 2005

Source of Exposure

April 1, 1952 through

December 31, 1983

January 1, 1984 through

December 31, 2005

Reconstruction 

Feasible

Reconstruction 

Not Feasible

Reconstruction 

Feasible

Reconstruction 

Not Feasible

Internal1 X X

 - Tritium X X

 - Thorium X X

 - U-233 X NA

 - Np-237 X X

External2 --- --- --- ---

1 Internal includes an evaluation of bioassay data. 2 Refer to the SEC-00030 evaluation report for a discussion of external exposure sources and dose reconstruction 

 methods.

As of September 12, 2013, a total of 1963 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 1519 individuals (~77%).

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

Rocky Flats during the period from April 1, 1952 through December 31, 1983, but who do not qualify 

for inclusion in the SEC, may be performed using these data as appropriate.
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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 

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 has determined that there are insufficient data related to thorium, U-233 and Np-237. Based 

on the sum of information available from available resources, NIOSH’s evaluation determined that it 

is not feasible to estimate radiation dose with sufficient accuracy for members of the NIOSHevaluated class for the time period from April 1, 1952 through December 31, 1983. Therefore, the 

resulting NIOSH-proposed SEC class must include a minimum required employment period as a basis 

for specifying that health was endangered for this time period. NIOSH further determined that it is 

feasible to estimate radiation dose with sufficient accuracy for members of the NIOSH-evaluated class 

for the time period from January 1, 1984 through December 31, 2005. Therefore, a health 

endangerment determination is not required for this time period.

9.0 Class Conclusion for Petition SEC-00192

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class to be added to the SEC includes: All employees of the Department of Energy, its 

predecessor agencies, and their contractors and subcontractors who worked at the Rocky Flats Plant in 

Golden, Colorado, from April 1, 1952 through December 31, 1983, for 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 for one or more other classes of employees included 

in the Special Exposure Cohort.

Based on its research, NIOSH has concluded that sufficient data are available to reconstruct internal 

dose for RFP workers from January 1, 1984 through December 31, 2005.
SEC-00192 09-30-13 Rocky Flats Plant

Page 103 of 135

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

Air Monitoring, 1965, Union Request Item 6, Routine Air Sample Results, Building 881, 4/65-5/65; 

SRDB Ref ID: 107651, pdf p. 115 onward

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
SEC-00192 09-30-13 Rocky Flats Plant

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Building 771, 1994, Operational History of Building 771, Historical Release Report, Building 

Historics; November 1994; November 1994; SRDB Ref ID: 105185

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

Building 9202, 1974, Oak Ridge National Laboratory, Health Physics Considerations Associated with 

Processing U-233 in Building 9202, Oak Ridge National Laboratory; May 10, 1974; SRDB Ref ID: 

28129

Buildings 9205 and 9212, 1964, Oak Ridge National Laboratory, Health Physics Procedures for 

Processing U-233 in Buildings 9205 and 9212; Oak Ridge National Laboratory; July 31, 1964; SRDB 

Ref ID: 31062

Building 3019, 1994, Oak Ridge National Laboratory, Historical and Programmatic Overview of 

Building 3019, Oak Ridge National Laboratory, U.S. Department of Energy Office of Environment 

Management; August 1994; SRDB Ref ID: 22706, pdf p. 24

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, 1992, Rocky Flats History-Rocky Flats Toxicologic Review and Dose Reconstruction Task 

3⁄4 Report; prepared by Chem Risk; February 1992; SRDB Ref ID: 8777
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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

Conner, 1967, Preparation of Np-237 Metal; William V. Conner; January 1967; SRDB Ref ID: 

126393, pdf pp. 3-4

Conner, 1969, Preparation of Radiochemically Pure Neptunium Metal Foils, RFP-1415; William V. 

Conner and Donald L. Basso; December 30, 1969; SRDB Ref ID: 124034

Conner, 1981, Neptunium Processing at the Rocky Flats Plant, RFP-2899; William V. Conner and 

Donald L. Basso; Printed September 20, 1981; SRDB Ref ID: 24722

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

Dosimetry History, Dose Assessment, W. C. Inkret; Los Alamos National Laboratory; date unknown; 

SRDB Ref ID: 953, pdf p. 11

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
SEC-00192 09-30-13 Rocky Flats Plant

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Dow, 1965, Observations of Gamma Emissions Associated with Thorium Removal From a U-233 

Sample, Rocky Flats Division; K. J. Freiberg and R. A. Kirchner; June 16, 1965; SRDB Ref ID: 

120532, pdf p. 13

Dow, 1972, Casting of Multiple U-233 Metal Target Disks, Rocky Flats Division; D. L. Basso and W. 

V. Conner; May 17, 1972; SRDB Ref ID: 122946

Dow, 1973, Photographs of Tritium Operations at Dow Chemical Company U.S.A., Rocky Flats 

Division; Dow Chemical, October 2, 1973; SRDB Ref ID: 122691

Dow, 1974, Shipments of Non-routine SS or Non-SS Material to Dow Chemical Company U.S.A., 

Rocky Flats Division; memorandum to AEC and various AEC sites; October 21, 1974; SRDB Ref ID: 

111301

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

Enriched Uranium Urinalysis, 1959, Comparison of Enriched Uranium Analysis Procedures, Process 

Analysis department, Technical Division, Y-12 Plant; Report Y-B92-125; December 11, 1959: SRDB 

Ref ID: 12505

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 Reports 2/64 – 5/65, Health Physics Incident Reports, Building 71, 2/64 – 5/65, Rocky Flats 

Plant; SRDB Ref ID: 126862

Incident Summary, 1976, Factual Development Outline of 1973 Tritium Release, memorandum by 

Dawson, Nagel, Sherman & Howard; February 27, 1976; SRDB Ref ID: 111269

Investigation Summary, 1965, Investigation of Uranium 233-235 Crossover Incident (Deleted 

Version) memorandum by Rocky Flats Division; June 11, 1965; SRDB Ref ID: 122664

Internal Dosimetry, 2002, Rocky Flats Explanation of Internal Dosimetry Terms and Practices for 

EEOICPA File Review; Rocky Flats Plant; Modified December 4, 2002; SRDB Ref ID: 8677

Inventory, 1966-1988, List of RFP MT82 Inventories Exported to Excel; various dates from 1966 

through 1988; SRDB Ref ID: 126758

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
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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

Logbook, 1965, Selected Pages from 1965 Urinalysis Record, Bioassay Log; Rocky Flats Plant; 

SRDB Ref ID: 27048

Logbook, 1964-1967, K. Freiberg’s Logbook; hand-written with various dates from 1964 through 

1967, but including notes on 1964; Rocky Flats Plant; SRDB Ref ID: 32362, pdf pp. 4-5 

Logbook, 1966-1969, Special Analysis Logbook; various dates from 1966 through 1969; SRDB Ref 

ID: 26259

Logbook, 1969-1972, Kittinger’s Logbook Number IV, Rocky Flats Plant; various dates from 1969 

through 1972; SRDB Ref ID: 24648

MDA, 2003, Minimum Detectable Activity for Urinalysis Methods at Rocky Flats, Roger B. Falk, Oak 

Ridge Associated Universities; June 5, 2003; SRDB Ref ID: 23634

Monthly Progress Reports, 1953-1963, Monthly Progress Reports for Personnel Meters, Body Counts 

and Bioassay Data, The Dow Chemical Company, Rocky Flats Division; various dates in 1953-1963; 

SRDB Ref ID: 24631

Monthly Progress Reports, 1958, Monthly Progress Reports for Chemistry Lab and Personnel Meters, 

1/58 – 12/58, The Dow Chemical Company, Rocky Flats Division; SRDB Ref ID: 24684

Monthly Reports, 1956-1957, Monthly Status Reports – Chemistry Lab and Personnel Meters, 1/56 –

12/57, The Dow Chemical Company, Rocky Flats Division; various dates in 1956-1957; SRDB Ref 

ID: 24683

Monthly Reports, 1960-1961, Monthly Status Reports – Chemistry Lab and Personnel Meters,1/60 –

12/61, The Dow Chemical Company, Rocky Flats Division; various dates in 1960-1961; SRDB Ref 

ID: 24699

Monthly Reports, 1963-1965, Monthly Status Reports – External Dosimetry and Development, 10/63 

– 12/65, The Dow Chemical Company, Rocky Flats Division; various dates in 1963-1965; SRDB Ref 

ID: 24630

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

Monthly Reports, 1968-1971, Monthly Status Reports – Includes Wound Counts and Inhalations, 1/68 

– 12/71, The Dow Chemical Company, Rocky Flats Division; various dates in 1968-1971; SRDB Ref 

ID: 24693
SEC-00192 09-30-13 Rocky Flats Plant

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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

NIOSH, 2007; NIOSH Response to ABRWH Request for Supplemental Information Related to the 

Rocky Flats Plant SEC Petition, May 17, 2007; SRDB Ref ID: 127752

NOCTS, 2012, Rocky Flats Plant NIOSH Claim [claim number, name redacted]; NIOSH OCAS 

Claim Tracking System: Online; accessed August 22, 2012

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

ORNL, 1994, The ORNL Chemical Technology Division, 1950-1994; Oak Ridge National Laboratory; 

October, 1994; SRDB Ref ID: 32270, pdf pp 192-196

ORNL, 1998, Strategy for Future Use and Disposition of Uranium-233: History, Inventories, Storage 

Facilities, and Potential Future Uses; Oak Ridge National Laboratory; June, 1998; SRDB Ref ID: 

117226, pdf pp. 17-20

Personal Communication, 2003, Personal Communication with [redacted]; Email interchange; July 

30, 2003; SRDB Ref ID: 25014
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Personal Communication, 2007, Personal Communication with [redacted]; In-person Interview by 

ORAU staff; May 15, 2007; SRDB Ref ID: 92798

Personal Communication, 2008, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; May 14, 2008; SRDB Ref ID: 44428

Personal Communication, 2009, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; February 2, 2009; SRDB Ref ID: 59674

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

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122515

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122516

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122517

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122550

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122551

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122553

Personal Communication, 2012s, Personal Communication with [redacted]; In-person Interview by 

ORAU staff; November 6, 2012; SRDB Ref ID: 122666

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122667

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122668

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

Interview by ORAU staff; November 6, 2012; SRDB Ref ID: 122669

Personal Communication, 2013a, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 15, 2013; SRDB Ref ID: 122627

Personal Communication, 2013b, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 15, 2013; SRDB Ref ID: 122628

Personal Communication, 2013c, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 16, 2013; SRDB Ref ID: 122624

Personal Communication, 2013d, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 18, 2013; SRDB Ref ID: 122625

Personal Communication, 2013e, Personal Communication with [redacted]; In-person Interview by 

ORAU staff; January 22, 2013; SRDB Ref ID: 122623
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Personal Communication, 2013f, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 22, 2013; SRDB Ref ID: 122629

Personal Communication, 2013g, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 23, 2013; SRDB Ref ID: 122626

Personal Communication, 2013h, Personal Communication with [redacted]; Telephone Interview by

ORAU staff; January 31, 2013; SRDB Ref ID: 122670

Personal Communication, 2013i, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; January 31, 2013; SRDB Ref ID: 122671

Personal Communication, 2013j, Personal Communication with [redacted]; In-person Interview by 

ORAU staff; February 5, 2013; SRDB Ref ID: 122466 

Personal Communication, 2013k, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 4, 2013; SRDB Ref ID: 122805

Personal Communication, 2013l, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 4, 2013; SRDB Ref ID: 122806

Personal Communication, 2013m, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 4, 2013; SRDB Ref ID: 122807

Personal Communication, 2013n, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 5, 2013; SRDB Ref ID: 122808

Personal Communication, 2013o, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 14, 2013; SRDB Ref ID: 122907

Personal Communication, 2013p, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 7, 2013; SRDB Ref ID: 123337

Personal Communication, 2013q, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; March 11, 2013; SRDB Ref ID: 123762

Personal Communication, 2013r, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; July 18, 2013; SRDB Ref ID: 126995

Personal Communication, 2013s, Personal Communication with [redacted]; Telephone Interview by 

ORAU staff; August 20, 2013; SRDB Ref ID: 127272

Personal Communication, 2013t, Personal Communication with [redacted]; email to ORAU staff; 

September 18, 2013; SRDB Ref ID: 127751
SEC-00192 09-30-13 Rocky Flats Plant

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Personnel, 1973, Personnel, Major Work Performed, and Work Locations for Individuals Receiving 

Tritium Exposures, Rocky Flats Plant; 1973; SRDB Ref ID: 111084

Procedures Review, 1957, A Current Review of Body Fluid Analysis, Procedures, and Method of 

Reporting – January 1957, P. E. Brown, D. M. Davis, L. C. Henley; Oak Ridge National Laboratory; 

January 1957; SRDB Ref ID: 8544

Progress, Jun1966, Industrial Hygiene and Bioassay Monthly Progress Report for June 1966; S. E. 

Hammond; July 8, 1966; SRDB Ref ID: 24691, pdf pp. 72-75

Progress, Jul1966, Industrial Hygiene and Bioassay Monthly Progress Report for July 1966; S. E. 

Hammond; August 5, 1966; SRDB Ref ID: 24691, pdf pp. 76-79

Release Investigation, 1973a, Investigation of the Tritium Release Occurrence at the Rocky Flats 

Plant, author unknown; Rocky Flats Plant; November 26, 1973; SRDB Ref ID: 110941, pdf p. 123 

onward

Release Investigation, 1973b, Investigation of the Tritium Release Occurrence at the Rocky Flats 

Plant, author unknown; Rocky Flats Plant; November 26, 1973; SRDB Ref ID: 111284, pdf p. 123 

onward

Release Investigation, 1973c, Investigation of the Tritium Release Occurrence at the Rocky Flats 

Plant, author unknown; Rocky Flats Plant; November 26, 1973; SRDB Ref ID: 24165, pdf pp. 16, 122

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, 1965a, Routine Air Sample Results in Building 71; Rocky Flats Plant; April, 1965; SRDB Ref 

ID: 126861, pdf pp. 12, 19, 25-26

RFP, 1965b, Observations of Gamma Emmissions Associated with Thorium Removal from a U-233 

Sample; Rocky Flats Plant; June 16, 1965; SRDB Ref ID: 24725

RFP, 1974a, Environmental Monitoring Equipment Tritium and Radioiodine Sampler Assembly 

Drawing, Sheet 1 of 8; Rocky Flats Plant; September, 1974; SRDB Ref ID: 122779

RFP, 1974b, Environmental Monitoring Equipment Tritium and Radioiodine Sampler Assembly 

Details; Rocky Flats Plant; September, 25, 1974; SRDB Ref ID: 122781
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RFP, 1974c, Environmental Monitoring Equipment High Volume Air Sampler Assembly and Tritium 

and Radioiodine Sampler Assembly Mounting Detail; Rocky Flats Plant; November 4, 1974; SRDB 

Ref ID: 122783

RFP, 1974d, Environmental Monitoring Equipment Tritium and Radioiodine Sampler Assembly 

Drawing, Sheet 2 of 8; Rocky Flats Plant; November 25, 1974; SRDB Ref ID: 122780

RFP, 1974e, Environmental Monitoring Equipment High Volume Air Sampler Assembly and Tritium 

and Radioiodine Sampler Assembly On and Off Site Electrical Hook Up; Rocky Flats Plant; 

December 17, 1974; SRDB Ref ID: 122786

RFP, 1974f, Environmental Monitoring Equipment High Volume Air Sampler Assembly and Tritium 

and Radioiodine Sampler Assembly On Site Electrical Hook Up; Rocky Flats Plant; December 18, 

1974; SRDB Ref ID: 122784

RFP, 1974g, Environmental Monitoring Equipment High Volume Air Sampler Assembly and Tritium 

and Radioiodine Sampler Assembly Off Site Electrical Hook Up, Rocky Flats Plant; December 18, 

1974; SRDB Ref ID: 122785

RFP, 1975, Environmental Monitoring Equipment Tritium and Radioiodine Sampler Wiring Diagram; 

Rocky Flats Plant; February 28, 1975; SRDB Ref ID: 122782

RFP, 1976, Thorium Use at Rocky Flats; Rocky Flats Plant; June 2, 1976; SRDB Ref ID: 24733

RFP, 1977a, Research and Development Semiannual Progress Report for January through June, 

1976, Chemistry Research and Development Extract, Uranium-233 Processing; Rocky Flats Plant; 

February 14, 1977; SRDB Ref ID: 122538

RFP, 1977b, Photographs of Tritium Monitoring; Rocky Flats Plant; October 11, 1977; SRDB Ref ID: 

122692

RFP, 1978a, Research and Development Semiannual Progress Report for July through December, 

1977, Chemistry Research and Development Extract, Uranium-233 Fabrication Project; Rocky Flats 

Plant; May 29, 1978; SRDB Ref ID: 122539

RFP, 1978b, Tritium Detector Details; Rocky Flats Plant; June 7, 1978; SRDB Ref ID: 122789

RFP, 1978c, Tritium Detector Details; Rocky Flats Plant; June 7, 1978; SRDB Ref ID: 122790

RFP, 1978d, Tritium Detector Flow Diagram; Rocky Flats Plant; June 7, 1978; SRDB Ref ID: 

122791

RFP, 1978e, Tritium Detector Assembly; Rocky Flats Plant; June 7, 1978; SRDB Ref ID: 122788

RFP, 1978f, Tritium Detector Assembly; Rocky Flats Plant; July 25, 1978; SRDB Ref ID: 122787
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RFP, 1979, Research and Development Semiannual Progress Report for January through June, 1978, 

Chemistry Research and Development Extract, Uranium-232 Daughter Segregation Study; Rocky 

Flats Plant; February 10, 1979; SRDB Ref ID: 122540

RFP, 1983, Photographs of Tritium Air Sampling Station; Rocky Flats Plant; October 10, 1983; 

SRDB Ref ID: 122693

RFP, 1990a, Occurrence Reports 1990-199, Volume I; Rocky Flats Plant; SRDB Ref ID: 17824

RFP, 1990b, Effluent and/or Room Air Sampling with Tritium Bubblers; Rocky Flats Plant; March 20, 

1990; SRDB Ref ID: 24307

RFP, 1994a, Rocky Flats Proposed Declassification Action February 6, 1994 Redacted; Rocky Flats 

Plant; February 6, 1994; SRDB Ref ID: 118369

RFP, 1994b, Building Histories for Buildings 371, 444, 447, 460, 707, 771, 776/777, 881, 883, and 

991, Historical Release Report (HRR); Rocky Flats Plant; November, 1994; SRDB Ref ID: 103770, p. 

164

RFP, 1999, History of Uranium-233 Processing at the Rocky Flats Plant; Rocky Flats Plant; April 1, 

1999; SRDB Ref ID: 22101

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

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
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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

Thorium, 2006; Health and Safety Aspects of Thorium Production; accessed July 9, 2006 from 

http://thoriumenergy.blogspot.com/2006/07/health-and-safety-aspects-of-thorium.html; SRDB Ref 

ID: 40074

Thorium Bounding, 2008, Establishing Bounding Internal Dose Estimates for Thorium Activities at 

Rocky Flats, B. A. Ulsh, B. L. Rich, M. H. Chew, R. L. Morris, M. Sharfi, M. R. Rolfes; Health 

Physics, July 2008, Volume 95, Number 1; SRDB Ref ID: 122613

Thorium U-233 Symposium, 1958, Thorium U-233 Symposium; sponsored by The United States 

Atomic Energy Commission; January 9-10, 1958; SRDB Ref ID: 119811 

Thorium U-233 Shipping, 1965, Assumptions - Class II Rail Shipment, General Electric, Richland, 

Washington; October 28, 1965; SRDB Ref ID: 34158, pdf pp. 10-11 

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 Bioassay Results, 1993, Tritium Bioassay Results, letter from V. L. Howard to E. Kray; 

Rocky Flats Plant; April 15, 1993; SRDB Ref ID: 110932

Tritium Bubbler Results, 1992, Tritium Bubbler Results 1977-1981; Rocky Flats Plant; SRDB Ref ID: 

111095
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Tritium Bubbler Results, 1998, Tritium Bubbler Results, March 19, 1998; letter from Thermo NUtech 

to C. Hoelzel; Rocky Flats Plant Environmental Technology Site; SRDB Ref ID: 122712

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

Tritium Releases, 1968, An Historical Summation of Environmental Incidents Affecting Soils at or 

Near the Rocky Flats Plant, 1968; SRDB Ref ID: 8265

Tritium Releases, 1976-1983, Tritium Releases, 1976-83; Rockwell International; various dates in 

1976-83; SRDB Ref ID: 24164

Tritium Releases, 1987, Tritium Releases Air Emissions, Report by M. R Boss; Rockwell 

International; March 23, 1987; SRDB Ref ID: 110900

Tritium Report, 1973, Tritium Incident Draft Report, Report by C. Barrick; Rockwell International; 

1973; SRDB Ref ID: 110901

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
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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

Vejvoda, 2005, Summary of Rocky Flats Plant Waste Buried in the Subsurface Disposal Area, 

ICI/EXT-04-00717, Rev. 0; Edward Vejvoda; April 2005; SRDB Ref ID: 33009

Wittenberg, 1970, Liquid Actinide Metals Research; Layton J. Wittenberg and Robert DeWitt; April 

1, 1970; SRDB Ref ID: 81987

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
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Worker Outreach Meeting email follow-up interchange, 2012c, Colorado Worker Outreach Meeting 

with former RFP Workers 10:00 AM session; Email follow-up with a participant at the public outreach 

meeting by ORAU and NIOSH staff; Meeting: May 24, 2012, email follow-up interchange: May 25 

and 29, 2012; SRDB Ref ID: 118770
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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 Two histories of the Atomic Energy Commission. 02/10/2011 2
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Page 122 of 135

Table A1-1: Data Capture Synopsis for Rocky Flats Plant

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

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, a safety concern regarding neutron dosimetry results, 

resuspension of environmental plutonium contamination, and the 

ORAU "Health Surveillance of Rocky Flats Radiation Workers".

08/15/2013 8

College Hill Library, Westminster, CO Investigation of the 1969 fire in Building 776-777. 08/09/2006 4

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 Management Consolidated Business 

Center (EMCBC) - Denver

Tritium release documentation, disassembly incident investigation, 

tritium effluent sampling, a documented communication, 1989 FBI raid 

search warrant, affidavit, and document lists, Rockwell president's notes 

on radiological program deficiencies, list of materials provided to the 

Grand Jury, types of records required by the Grand Jury, and responses 

to audits of Rocky Flats.

08/06/2013 27

DOE Environmental Measurements Laboratory Beryllium reports. 02/10/2009 3

DOE Germantown Beryllium reports, the 1965 weapons plant specific missions policy, 

records and claims search procedures, and the data tracking spreadsheet 

from the July 2012 data capture at DOE Germantown.

08/08/2012 6

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, waste disposal reports, sitewide mass balance and operational 

emissions support document, and a Neutron Dose Reconstruction 

Project spreadsheet.

01/24/2012 18
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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

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 70

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 48

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

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, individual 

dosimetry records, termination reports, tritium stack releases, 

neptunium analysis procedures, tritium process photographs, diagrams 

of tritium detection equipment, personnel strength reports, 

neutron/gamma surveys, incident reports, routine air sample reports, 

actinide analysis procedures, internal dosimetry audits, criticality safety 

non-compliance report, 1989 FBI raid search warrant and affidavit, and 

lists of documents seized during the FBI raid. 

08/08/2013 428

DOE Nuclear Materials Management and Safeguards 

System (NMMSS)

Material transfer and inventory records. 07/10/2013 3

DOE Oak Ridge Operations Office Former radiation worker medical surveillance files and radiation 

exposure history requests for workers starting at Rocky Flats, a visit to 

Mound, FOIA requests and responses, and the strategy for future use of 

U-233.

07/09/2012 31

DOE Oak Ridge Operations Records Holding Task Group 1953, 1954, and 1962 Production Division progress reports. 06/25/2013 3
SEC-00192 09-30-13 Rocky Flats Plant

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Completed

Uploaded

To SRDB

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, the method by which the Rocky 

Flats site was selected, waste shipments, transuranic shipments, 

research and development reports on U-233, investigation of the 

uranium 233-235 crossover incident, and the preparation of neptunium 

metal.

04/23/2013 13

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, Colorado 

Department of Health meeting minutes, and remedial action closeout 

reports.

04/07/2006 256

[Name redacted] 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, materials 

transfer notes, and reference to a Rocky Flats paper on plutonium 

monitoring.

08/02/2012 3

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
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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Hanford Hanford monthly reports referencing Rocky Flats, material transfers, 

plutonium feed and fuel specifications, incident reports, plutonium 

contracts, distribution of updated site profiles, a 1991 assessment of 

Building 559, a 1967 material balance report, a 1952 report listing 

Rocky Flats visitors to Hanford, and a TRIM finding aid identifying 

Rocky Flats internal dosimetry documents.

01/02/2013 46

Hanford / SC&A Volume III of the investigation of the 1969 Building 776-777 fire. 08/09/2006 1

Idaho National Laboratory (INL) INL reports addressing issues with Rocky Flats fuel and waste and 

health physics logbooks.

06/07/2012 28

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 - Defense Technical Information Center (DTIC) Defense Nuclear Facility Safety Board reports, Los Alamos actinide 

research reports, plutonium machining and handling reports, plutonium 

stabilization and disposition reports, a report on mold and crucible 

coatings, and an indoor air modeling report.

09/28/2012 39

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, a reference to Rocky 

Flat's use of a shrouded probe stack sampler, button shipments to Rocky 

Flats, plutonium oxide reports, and trip reports.

06/06/2013 27

Internet - DOE Legacy Management Considered Sites Legacy Management's site management guide, quality assurance plan, 

sampling and analysis plan, and an interim mixed waste inventory 

report.

08/01/2012 5

Internet - DOE National Nuclear Security Administration 

(NNSA) - Nevada Site Office

No relevant documents identified. 04/03/2012 0
SEC-00192 09-30-13 Rocky Flats Plant

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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - DOE OpenNet A plutonium uptake incident description, U.S. Transuranium Registry 

summary reports, a summary history of the nuclear weapons program, 

Appendix B of Linking Legacies, openness press conference fact sheets, 

1970 environmental branch activities, a 1964 AEC financial report, and 

a 1957 H-Division progress report.

12/14/2012 16

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, the 

decontamination and decommissioning waste estimate validation, DOE 

research and technology development annual summaries, contamination 

control reports, neptunium production and recovery, nuclear waste 

management reports, and the evaluation of an electro refining cell.

05/03/2013 61

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, 

meteorological reports, transuranic waste characterization, storage, 

security reports, and production of neptunium.

07/31/2013 226
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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

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, decommissioning 

gloveboxes, DOE Legacy Management updates and plans, the 

appendices to the Rocky Flats historical release report, and the report of 

the Rocky Flats Grand Jury. 

08/29/2013 536

Internet - Health Physics Journal Establishing bounding internal dose estimates from thorium activities at 

Rocky Flats.

02/14/2013 1

Internet - Journal of Occupational and Environmental 

Hygiene

No relevant articles not already in the SRDB identified. 08/29/2013 0

Internet - National Academies Press (NAP) An analysis of cancer risks in populations near nuclear facilities 

including Rocky Flats and health, safety, and environmental 

management in the nuclear weapons complex.

03/27/2012 2

Internet - National Institute for Occupational Safety and 

Health (NIOSH)

Reports on residual radioactive and beryllium contamination at atomic 

weapons employer and beryllium vendor facilities.

08/31/2011 3

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, stockpile stewardship documents, 

seismic and fire hazards at DOE sites, storage of weapons-usable 

materials environmental impact statement documentation, the 

flammability and explosion potential of transuranic waste, and an article 

on DOE waste disposal practices.

09/16/2012 47
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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - Oak Ridge National Laboratory (ORNL) ORNL operations and chemical technology reports referencing Rocky 

Flats, a 1956 report on metal recovery, and a 1957 report on the status 

of radioactive waste disposal.

11/08/2012 9

Internet - Oak Ridge National Laboratory (ORNL) Library A 1969 ORNL radioisotope program report referencing Rocky Flats. 11/15/2012 1

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 Army Corps of Engineers (USACE) No relevant documents identified. 04/03/2012 0

Internet - US Environmental Protection Agency NEPIS No relevant articles not already in the SRDB identified. 08/29/2013 0

Internet - US Transuranium and Uranium Registries No relevant documents identified. 04/03/2012 0

Jim Langsted CD A Defense Nuclear Facilities Safety Board (DNFSB) report, Rocky 

Flats responses to DNFSB reports, and employee medical and 

radiological records.

09/11/2012 6

Kansas City Plant Mention of Rocky Flats closure during testimony on pits production, 

environmental reports referencing Rocky Flats, solid waste generated 

by Albuquerque Operations in 1979, and Rocky Flats' assistance in 

decontaminating the Kansas City Plant heavy machining area.

12/04/2012 6

Kansas City Plant / SC&A A report on protective coatings for uranium-niobium alloys. 08/19/2013 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, plutonium body burdens, documentation 

on nuclear worker autopsies, and cleaning procedures for components.

12/13/2007 27

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

Mesa State College The Health and Safety Laboratory quarterly fallout report from January 

1972. 

04/18/2011 1

Missouri Department of Natural Resources The Plutonium Working Group reports on plutonium storage 

environmental, safety, and health vulnerabilities.

10/01/2008 2

Mound Laboratory An analysis of dosimeter comparison studies. 11/18/2003 1
SEC-00192 09-30-13 Rocky Flats Plant

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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Mound Museum Material transfers, plutonium accountability and shipments, the Mound 

Laboratory index which mentions Rocky Flats, and newsletters 

mentioning Rocky Flats.

02/01/2012 26

National Archives and Records Administration (NARA) -

Atlanta

A DOE indoor radon study, summaries of AEC accidents and high 

exposures, and directories of AEC consultants to contractors. 

10/20/2005 7

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, responses to union requests 

for data, thorium inventory information, a redacted 1989 EPA 

interview, and a DOE initial agency decision regarding a whistleblower 

case.

05/01/2013 65

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

New York State Archives A Tonawanda Area report showing that two radium sources were 

imported for Rocky Flats and a Lake Ontario Ordnance Works (LOOW) 

waste report where Rocky Flats was on distribution.

03/19/2012 2

Nuclear Information and Records Management Association 

(NIRMA)

The activities of the Rocky Flats Records Management Program during 

and after the 1989 FBI raid.

03/04/2013 1

Nuclear Regulatory Commission Public Document Room References to Rocky Flats plutonium equipment and practices in 

Nuclear Materials and Equipment (NUMEC) special nuclear materials 

license documentation.

11/22/2006 5
SEC-00192 09-30-13 Rocky Flats Plant

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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

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 6

Oak Ridge National Laboratory (ORNL) Records of shipments from ORNL to Rocky Flats, work at Rocky Flats 

for ORNL, and brief trip synopses.

01/17/2013 9

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 research 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.

07/18/2013 474

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 Discussions of tritium contamination of returned components and the 

study of automated component handling in the staging area.

06/23/2011 3

Portsmouth Gaseous Diffusion Plant A notation that Rocky Flats does not use extra shielding with its 14MeV 

neutron generator from Portsmouth.

05/10/2012 1

Sandia National Laboratories, California A safe operating procedure naming Rocky Flats as a potential 

component disassembly location.

04/29/2013 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

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 46
SEC-00192 09-30-13 Rocky Flats Plant

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Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

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, the vulnerabilities of plutonium 

storage, sample analyses, documents issued to SC&A by Y-12, a history 

of the INL Waste Management Complex including Rocky Flats waste, 

and documented communications. 

04/07/2011 21

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 35

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 working group report. 02/16/2006 1

SC&A / Pinellas The 1993 annual DOE report on waste generation and minimization. 06/24/2010 1

SC&A / Stanford Linear Accelerator Center (SLAC) A SLAC article detailing how SLAC technology was used to identify 

Rocky Flats soil contaminants.

06/13/2011 1

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 6

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 09-30-13 Rocky Flats Plant

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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, recycled uranium transfers, 

beryllium work, 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 159

U.S. Transuranium and Uranium Registries A review of two Rocky Flats whole body donor cases as part of a 

management proposal.

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 4109
SEC-00192 09-30-13 Rocky Flats Plant

Page 133 of 135

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 02, (83 13) 09-20-13

Defense Technical Information Center (DTIC)

https://www.dtic.mil/

COMPLETED 09/28/2012

See Note above 1,319 62

DOE CEDR

https://www.orau.gov/cedr

COMPLETED 05/22/2012

See Note above 9 0

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 06/06/2013

See Note above 0 0

DOE Legacy Management Considered Sites

http://www.lm.doe.gov/considered_Sites/

COMPLETED 08/01/2012

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 12/14/2012

See Note above 160 0

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 05/03/2013

See Note above 7,811 5

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 07/31/2013

See Note above 5,038 19

Google

http://www.google.com

COMPLETED 08/01/2013

See Note above 4,141,787 399

HP Journal

http://journals.lww.com/health-physics/pages/default.aspx

COMPLETED 02/14/2013

See Note above 158 1
SEC-00192 09-30-13 Rocky Flats Plant

Page 134 of 135

Table A1-2: Databases Searched for Rocky Flats Plant

Database/Source Keywords / Phrases Hits Selected

Journal of Occupational and Environmental Health 

http://www.ijoeh.com/index.php/ijoeh

COMPLETED 08/29/2013

See Note above 82 0

National Academies Press

http://www.nap.edu/

COMPLETED 03/27/2012

See Note above 12,974 0

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/web-based.html

COMPLETED 09/16/2012

See Note above 90 0

USACE/FUSRAP

http://www.lrb.usace.army.mil/fusrap/

COMPLETED 04/03/2012

See Note above 10 1

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

Ref ID: 120765

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
SEC-00192 09-30-13 Rocky Flats Plant

Page 135 of 135

Table A1-4: Interlibrary Loan Documents Requested for Rocky Flats Plant

Document Number Document Title Requested

Date

Received

Date

NA

Ref ID: 8779

Estimated Airborne Release of Plutonium During the 1969 Fire in 

Buildings 776-777

11/15/2012 11/29/2012

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 Could not 

locate

Table A1-5: OSTI Documents Requested for Rocky Flats Plant

Document Number Document Title Requested

Date

Received

Date

RFP-1848

Ref ID: 122946

Casting of Multiple 233U Metal Target Disks dated May 1972 01/14/2013 03/18/2013

RFP-2680-A

Ref ID: 122949

Chemistry Research and Development Semiannual Progress Report, 

January-June 1977 dated October 1977

01/14/2013 03/18/2013

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