Working Draft 

Review of the Special Exposure Cohort Petition Evaluation Report 

for Rocky Flats Plant 

Data Reliability: Safety Concerns 

 

January 19, 2007 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted.

RFETS SEC Petition Review 1 Working Draft – February 15, 2007 
DRAFT 

SC&A Response to NIOSH Safety Concern Comments 

Background 

During the course of interviews with Rocky Flats Plant Special Exposure Cohort (SEC) 

petitioners and others, individuals stated that former supervisors had gone back and modified 

dose records by replacing positive doses with zeros. When asked by S. Cohen and Associates, 

Inc. (SC&A) if they had corroborating documentation, the interviewees indicated they had filed 

formal safety concerns at the time. SC&A was provided with and reviewed a hard copy list of 

safety concerns provided by the petitioners. This index, covering 1970-1992, gave only brief 

descriptions of each Safety Concern topic. It was inclusive of concerns related to industrial, 

chemical and radiological safety. Given the brevity of the interview visit, the petitioners shared 

several examples of the safety concerns with SC&A. The files ranged from a single sheet where 

the issue was resolved on a one-page form, to several sheets where the issue was elevated to the 

Joint Company/Union Safety Committee (JCUSC). The safety concern list provided by the 

petitioners was reviewed by SC&A with the objective to corroborate the particular concerns 

cited by the interviewees, as one means to establish whether data reliability may be an SECrelated concern. 

In the May 2006 working group meeting on the Rocky Flats Special Exposure Cohort, a 

petitioner indicated that there was a database of safety concerns formally maintained by Rocky 

Flats Environmental Technology Site (RFETS), the former operating contractor that may include 

safety concerns prior to 1970. NIOSH was asked by the Advisory Board working group to 

determine if such a database existed, and whether it contained early safety concerns relevant to 

the petition evaluation. A database containing 4,946 safety concerns from 1970 to 2004 was 

subsequently located in the RFP archived records. NIOSH evaluated this official list of safety 

concerns and identified thirty-three safety concerns that had potential relevance to the SEC. One 

file was actually a subset of another safety concern. SC&A also evaluated the database of safety 

concerns and identified an additional seventeen safety concerns. A majority of the actual 

documentation pertaining to specific safety concerns (that would have relevance to specific SEC 

data reliability issues) were not available and were requested from Legacy Resource 

Management at RFP. The safety concern files provided by DOE include the original safety 

concern filed by the employees, a supervisory response, and documentation relating to resolution 

of the safety concern. 

NIOSH completed a review of the forty-seven safety concern files. The evaluation for Safety 

Concerns 90-169 and 91-048 are ongoing. One safety concern was identical to another but was 

renumbered by JCUSC. The NIOSH evaluation concludes that the safety concerns with 

complete reviews do not have a bearing on the data integrity issues included in the petition, and 

they do not affect the ability to conduct dose reconstruction. NIOSH has indicated that there are 

techniques that can be used to assign the missing dose. For example, bioassay data before and 

after a data gap can be used to assign internal dose during the period of time when bioassays 

were not collected. 

RFETS SEC Petition Review 2 Working Draft – February 15, 2007 
Safety concerns identified included a wide range of subject matter with some issues closely 

related to concerns raised in the SEC petition. The time period of the safety concerns range 

from 1970- 2000, with a majority from the 1990s. A few concerns pose questions regarding the 

accuracy of the personnel monitoring program (internal and external). Other concerns relate to 

the adequacy of the bioassay program in effectively monitoring personnel routinely and for 

incidents. There were several safety concerns related to RFP external dosimetry policies and 

practices including badge exchanges, dosimeter storage, contaminated dosimeters, and 

unauthorized practices. Several of the documents discuss general health physics issues such as 

lack of Radiation Protection Technician (RPT) coverage, or noncompliance with procedures. 

Analysis

SC&A has reviewed the safety concerns and the NIOSH position related to each safety concerns. 

Table 1 gives a list of the safety concerns evaluated including a description of the concern, the 

NIOSH position related to the safety concern, and the SC&A response. The review involved 

evaluation of the safety concern file as well as the response documented by NIOSH in NIOSH 

Evaluation of Specific Safety Concerns (NIOSH 2006a) and NIOSH Evaluation of Specific Safety 

Concerns Set 2 (NIOSH 2006b) provided to the working group and SC&A on August 28, 2006 

and October 31, 2006, respectively. Safety concerns were considered inconclusive when key 

information was not available in the file. One example is where individuals expressed concerns 

about high radiation exposures, but their monitoring status remains unknown. In two cases, 

NIOSH did not specifically evaluate the issues presented in the safety concern. In these cases, an 

evaluation of the relevance of the issue with respect to falsification of records, dosimetry 

investigations, and inadequate or incomplete dosimetry data and records was prepared by SC&A 

and is included in this review. 

SC&A, in its evaluation, has divided the Safety Concerns into three categories in relation to the 

SEC petition. First, there are those Safety Concerns that are not relevant to or bear on NIOSH’s 

ability to adequately conduct dose reconstruction; these include concerns such as those related to 

non-radiological safety issues, hostile work environment, instances when individuals were 

monitored based on the particular event, lack of communication, and lack of training. Second, 

there are issues associated with the processing of dosimeters when the dosimeter or dosimeter 

components were lost, damaged, overexposed, or exhibited other problems. Finally, there are 

Safety Concerns that, in SC&A’s view, reinforce claims and statements made in affidavits or 

public comments. There are two safety concerns that continue to be under investigation by 

NIOSH. These files concern lost or invalid bioassay results (#90-169) and the inadequacy of the 

internal and external dosimetry programs (#92-048). 

Inconclusive Safety Concerns 

Three safety concerns (#89-259, #94-245, #95-061) and a portion of two additional safety 

concern (91-395, #91-496) were considered inconclusive because key information to make a 

determination was not included in the file provided by Rocky Flats. 

Safety Concern #89-259 expresses a concern related to the accuracy and trends in cumulative 

dose. The issue was not clearly defined, making it difficult to ascertain whether the issue was 

RFETS SEC Petition Review 3 Working Draft – February 15, 2007 
directly related to dosimetry, or whether it was one associated with the health physics goal of 

monitoring radiation exposures “As-Low-As-Reasonably-Achievable” (ALARA). Safety 

Concern #91-395 states that radiation exposures to employees in Building 664 were too high and 

unnecessary because grams of plutonium, americium, and uranium were being stored in drums at 

this location (Ausmus 1991). It is unclear whether personnel in the building were required to 

wear dosimetry prior to the establishment of an RCA, or whether the RCA was created prior to 

the drums arriving. NIOSH has assumed that this is not an SEC issue; however, without the 

information discussed above, it is unclear how they were able to come to this conclusion. 

Safety Concern #91-496 specifically expressed concern regarding the lack of background studies 

conducted prior to the locating the badge storage rack in the tunnel north of 

Portal 1. There was an underlying concern that the radiation and environmental conditions at 

this location were not appropriate. For periods of time when location specific backgrounds were 

used in background subtraction, the safety concern is inconclusive. There is no indication how 

the background radiation level changed, and if adjustments were applied to retrospective data. 

For those years where environmental dose levels were used for background subtraction, the 

location of the dosimeter storage areas would not affect the dosimeter results. 

Safety Concern #94-245 involves the confiscation of the TLDs of two workers as a result of 

safety violations. NIOSH indicates that performing work without appropriate dosimetry in a 

Radiological Control Area (RCA) may or may not affect the ability to do dose reconstruction. 

They further indicate that the employees with confiscated TLDs did not work in an RCA during 

the period of time without a TLD. There seems to be some disagreement regarding this fact. 

The employees indicated they did perform radiological work during this time period while the 

JCUSC indicated the employees were not required to perform work in a radiological area without 

a TLD during this time period. No details of the JCUSC investigation were provided in the 

Safety Concern file. In addition, this Safety Concern raises the question of how frequently TLDs 

were taken away from workers and why. Were these workers prevented from entering 

radiological areas during this time period? Certainly, if employees were entering radiological 

areas without TLDs this would put their external exposure in question, and therefore impact dose 

reconstruction. NIOSH assumes the worker did not enter a radiological area. In SC&A’s view, 

not enough information is provided in the Safety Concern field to make this determination. 

Safety Concern #95-061 discusses a situation where the Building manager pulled TLDs from 

workers in Building 776 as a result of a Radiation Work Permit (RWP) violation. There is no 

indication whether individuals having their dosimeters pulled were accordingly banned from 

entry into the RCAs. The larger concern is whether a simultaneous restriction from radiation 

areas was enforced. The safety concern did not indicate what restriction was imposed on 

personnel. Without complete information on the above issues, no determination can be clearly 

made with regard to whether they represent data integrity problems. 

Safety Concerns Not Affecting the Dose Reconstruction Process 

Several of the files reviewed were concerned with Field Radiological Control conditions, and not 

directly related to dosimetry results. Safety Concern #70-2 related to general area radiation 

levels, adequacy of shielding, storage of plutonium, dry box damage, and inadequacies in 

RFETS SEC Petition Review 4 Working Draft – February 15, 2007 
criticality drains. As NIOSH indicated, these are important to the health and safety of workers; 

however, individuals in these areas would have been monitored for internal and external 

exposure. This safety concern is simply noting that several individuals exceeded this level. This 

would not affect dose reconstruction since these individuals were monitored. This safety 

concern indicates that high dose rates were expected for some groups, and that established 

administrative exposure levels were exceeded. Table 2 provided the number of individuals who 

exceeded an annual dose of 5 Rem. This data was compiled by the site for the years 1951-1986. 

Table 2: Exposures in Excess of 5 Rem from 1951-1984 (RI 1987). 

Dose Range 

(Rem) 

Number of Individuals Exposed 

at this Level 

5-6 184 

6-7 59 

7-8 34 

8-9 14 

9-10 6 

10-11 4 

11-12 2 

General area doses rates will be further discussed in the Data Integrity Example Analysis 

response. 

Safety Concern #71-7 concerned the inaccuracy of the stack air sampling results because 

appropriate procedures were not followed. This addresses environmental monitoring issues, 

which have implications for environmental dose. Environmental dose will be discussed in the 

extended review of the RFP site profile review. 

Job coverage, inadequate notification of Health Physics, violation of procedures, and inadequate 

field monitoring were raised in Safety Concerns #85-137, #86-186, part of #91-496, #93-124, 

and #94-080. Although important to a functional Radiological Control program, these concerns 

were not directly related to personnel monitoring and dose reconstruction. Other concerns 

addressed logbook entries of contents in a tanker truck, hostile work environments, lack of 

showering facilities and emergency response kits, and inappropriate labeling of confidential 

information (#89-214, #94-072, #94-079, #94-081, #97-163, #99-023, and #00-075). Safety 

Concern #95-077 dealt with the appropriate procedure for shipping urine samples through the 

mail. Safety Concern #89-148 relates to the lack of procedures available for documenting 

infractions in Radiation Monitoring reports. These concerns were not directly related to 

personnel monitoring or dosimetry documentation. 

The lack of timely turnaround time with respect to external dosimetry supervisor reports was 

brought up in Safety Concerns #87-206 and #92-036. The lapse of dosimeter exchange on the 

part of External Dosimetry was raised in #86-13, and the timeliness of processing was raised in 

#96-182. Although a less frequent exchange frequency may cause additional uncertainty in the 

evaluation of the badge (e.g., fading considerations, appropriate background subtraction), it does 

not constitute an unmonitored situation. The lack of proper distribution of dosimeter results to 

RFETS SEC Petition Review 5 Working Draft – February 15, 2007 
the field (e.g., supervisor reports) was primarily related to the As Low As Reasonably 

Achievable (ALARA) program for minimizing worker radiation exposures below external dose 

limits. The JCUSC raised the issue of manpower shortage in the dosimetry department in Safety 

Concern #86-013 indicating dosimetry delayed usual dosimeter pick-up schedules and thus 

processing for lower risk groups (e.g., third quarter 1985). This delay in processing of badges 

may make comparisons being conducted in other areas of this review difficult. Also, the timely 

processing of dosimeters is of some concern because backlogs may lead to practices such as not 

reading dosimeters from perceived low exposure groups. This was the case with respect to some 

workers assigned to the “cold area” where radioactive material was, in fact, handled. This 

directly relates to the establishment of co-worker dose. Safety Concern #75-34 related to the 

adjustment of dosimeter results after administration of a medical isotope. Assuming an 

investigation was conducted to determine the appropriate dose, this is a reasonable practice. 

Safety Concern #90-202 relates to questions posed to dosimetry about potential exposure from 

the Cf-252 calibration source. It was determined that the individuals of concern were monitored 

for both beta/gamma and neutron exposure. This data can be used in dose reconstruction. 

With regard to dosimeter background concerns, the radiation background at the Dosimeter 

Exchange Board is monitored by a TLD placed in the rack along with those worn by personnel. 

The methodology used for background subtraction has varied over time. Lagerquist (1975) 

indicated, effective January 1986, that the total background subtracted from dosimeters would be 

environmental background (0.34 mRem/day) with instrument background. TLD operating 

procedures in 1983 also indicated that the total background subtracted was determined from 

environment and instrument background (RFETS 1983). The Background Subtraction 

Methodology Study was conducted the second quarter of 1999 at locations across the site. This 

study indicated that using a location specific background may create potential problems because 

the dosimeters were not always stored at the assigned location. Furthermore, the study indicated 

subtracting backgrounds by location will generally reduce the reported dose (Klueber and Savitz 

1999). A TLD background subtraction based on whether the location of the storage area was in a 

hard walled or non-hard walled building was implemented (Baker 1999). In 2001, the actual 

TLD element residual signal together with a time dependent and location dependent background, 

results in a TLD specific background, which is subtracted from the personal dosimeter (RFETS 

2001). Methods for background subtraction prior to 1976 were not located. The concern here is 

whether the location specific background level is appropriate for background subtraction. Based 

on documentation reviewed, the location specific background was not used until 1999. In 1999, 

studies were conducted and a revised methodology was implemented. The study included 

background level data by location. These data could be used to adjust dosimeter results as 

appropriate. Background subtraction is more appropriately addressed as a site profile issue. 

Safety Concern #91-262 questions the practice of wearing dosimetry only when entering 

Radiological Control Areas. Of particular concern was the potential for worker involvement in a 

criticality. There are other means of determining doses in cases where dosimeters are not worn 

during a nuclear criticality. This was demonstrated with the 

Y-12 Criticality Accident in 1958. The JCUSC agreed with the employee that dosimeters should 

be worn at all times when in the Perimeter Security Zone (PSZ). Concerns were expressed by 

the operations groups that this was not consistent with the health and safety procedures. HSP 

18.07, External Radiation Dosimetry, updated June 15, 1991, shortly after the Safety Concern 

RFETS SEC Petition Review 6 Working Draft – February 15, 2007 
was issued, continued to require that dosimetry be worn in Radiation Controlled Areas or when 

posting required it, and that dosimeters be stored on badge racks. The relative exposure in 

uncontrolled areas of the building was not discussed in the safety concern. Available area 

dosimetry systems could be used to assign a dose for those not entering Radiological Controls 

assuming the exposure to the badge and personnel are equivalent. 

Processing of Lost, Damaged, Overexposed, or Otherwise Compromised Dosimeters 

Safety Concern #85-161 #87-005, #87-038, and #91-490 relate to methods utilized to conduct 

external dosimetry investigations, as well as providing another example of individuals 

questioning the accuracy of the dosimetry system. Extended External Dosimetry Investigations 

are documented in personal dosimetry files back to the mid-1980s; however, availability in 

Radiation Dose files was not routine until the late-1990s. 

Safety Concern #85-161 speaks to the conduct of external dosimetry investigations for 

questioned doses. There is not enough information to determine whether this was a site wide 

policy; however, the Safety Concern provides an example of where a dosimetry investigation 

was conducted. It is difficult to determine from a secondary source whether an adequate 

investigation was conducted and whether the response was appropriate to the employees 

concerns. 

In Safety Concern #87-005, a memorandum from R.N. Chanda and G.A. Overholt to P.A. 

Madsen indicates that a review of the dosimetry records was conducted, and it was determined 

that the zeros were the result of wrist dosimeters turn-in without corresponding body dosimeters. 

This individual was assigned to the Non-destructive Assay group in Building 371 where there 

was a potential for exposure. It is difficult to determine from a secondary source whether an 

adequate investigation was conducted and whether the response was appropriate to the 

employees concerns. Direct data should be evaluated in this case, and the individual’s dose 

should be compared to that of his coworkers performing the same tasks. 

Safety Concern #87-038 relates to methods utilized to conduct external dosimetry investigations, 

as well as providing another example of individuals questioning the accuracy of the dosimetry 

system. The dosimeter value was modified due to quality control issues with the dosimetry 

results. There does not appear to be any kind of follow-up investigation of the individual’s 

potential exposure. This is directly related to the issue of how dose was assigned when 

dosimeters were lost, damaged, contaminated, or had quality control problems. The individual 

was on a biweekly exchange period indicating the potential for higher exposure. The adjustment 

to his dose does not reflect this, and adequate justification for this dose is not provided. 

Questionable data of this type should not be used in dose reconstruction. 

Safety Concern #91-496 discusses the responsibility on the part of the employee to protect their 

dosimeter from contamination, tampering, misuse, and other compromising situations. With 

respect to positive control, there is really no system available to prevent individuals from 

tampering with dosimeters. RFP External Dosimetry indicated they evaluate the raw results 

from each element as an indication of inappropriate dose results. There is no discussion included 

RFETS SEC Petition Review 7 Working Draft – February 15, 2007 
in the safety concern regarding the specific process External Dosimetry followed to identify and 

investigate inappropriate dose results. 

Safety Concerns Consistent with Statements in Affidavits or Public Comments 

SC&A has determined that Safety Concern #71-4 does not provided conclusive evidence of a 

site-wide issue. It does, however, provide an example of a situation where the worker believed 

dosimeter badges were not adequately capturing the file readings. The safety concern, itself, 

stated: 

My film badge results for Dec. 1970 did not show the high level of neutron exposure 

which according to instrument readings and film badge results of other monitor on the 

same special job, should have been expected (JCUSC 1971a). 

This safety concern mirrors the concerns cited in former RFP worker affidavits that their 

dosimeters did not reflect actual exposure conditions. The supervisor’s response indicated there 

was an inherent inaccuracy with neutron film dosimetry, and that neutron TLDs were scheduled 

to replace neutron film. There was no explanation of why the worker’s film badge did not reflect 

his co-workers’ dose, or instrument readings. The petition includes affidavits from employees 

documenting similar concerns. 

Safety Concern #74-61 indicated there was a need for quantitative assessment of radioactive 

material within the body. Further discussion with RFP RadCon staff having knowledge of this 

safety concern indicated that the concern was particularly directed at the in vivo counting system. 

NIOSH has indicated that in vivo counting results are not used in their analysis of claimant dose. 

If this is the case, and individuals were adequately monitored via urinalysis, NIOSH could use 

bioassay data for dose reconstructions. If, however, NIOSH decides to use lung count data to 

“bound” intakes, or it is determined that bioassay monitoring was incomplete, this would impact 

internal dose reconstruction. Furthermore, if this data is used in the coworker model, the 

reliability of this data is in question and must be further evaluated. The concern clearly shows 

that some workers, even within the Radiological Control organization, questioned the results 

they were receiving from dosimetry. Whether dosimetry data was inadequate or not cannot be 

determined from the information in the safety concern. This lack of faith in dosimetry results 

has been raised several times throughout the petition. The safety concern provides a historical 

reference to these concerns. 

Safety Concern #89-037 involves the lack of internal and external monitoring for an employee 

who worked in the uranium area. It provides an example situation where missed dose is 

possible. NIOSH has generic methods for assigning dose where there are data gaps; however, 

the exact method for addressing data gaps is still under consideration. Their method for 

identifying data gaps and assigning dose for multiple year data gaps is particularly of concern. 

Although lack of monitoring is not, per se, a data integrity issue, it does have a significant impact 

on dose reconstruction. In addition, gaps in the data of individuals exposed, but not adequately 

monitored, cast doubt on the integrity of the data made available for dose reconstruction. 

RFETS SEC Petition Review 8 Working Draft – February 15, 2007 
Apprehension related to abnormally high or positive in vivo bioassay results were discussed in 

Safety Concern #84-19 and #86-161. Safety Concerns #84-19, #86-169, 

#89-167, #93-061, #93-193, and #99-013 raised problems regarding the timeliness of bioassay 

collection or communication of results. Inconsistencies in instrument results (e.g., wound 

counting) or malfunctions in equipment (e.g., in vivo counter) were questioned in Safety 

Concerns #85-109, #89-203, and #92-003. Although delaying communication of bioassay 

results and subsequent dose assessments is a poor practice, it does not preclude dose 

reconstruction. Untimely bioassay turnaround times delay the collection of follow-up samples 

and complicate the determination of intake conditions. Furthermore, this is not conducive to a 

good ALARA program. Delaying bioassay, whether urine or fecal, or in vivo counting, for a few 

days does not prevent the detection of long-lived insoluble radionuclides taken into the body. 

For soluble material such as tritium, delay in bioassay may affect the ability to detect an 

incidental intake depending on the length of the delay. Assuming the employee was adequately 

monitored via urinalysis, and in vivo counting was not used in dose reconstruction, these issues 

would not present an issue with dose reconstruction. If, however, NIOSH decides to use lung 

count data to “bound” intakes, or it is determined that bioassay monitoring was incomplete, this 

would impact internal dose reconstruction. Furthermore, if this data is used in the coworker 

model, the reliability of this data is in question and must be further evaluated. 

Safety Concern #97-176 demonstrates the lack of proper quality control within the dosimetry 

processing laboratory. An employee was given a TLD badge that did not contain TL elements. 

The TLD had been processed and the elements were not replaced at the time the supervisor came 

in and retrieved the dosimeter. The Radiological Control Technician entered radiological areas 

with inadequate dosimetry (Baker 1997). This is one of many quality control problems 

encountered by External Dosimetry throughout RFP operational history. 

Safety Concern 98-073 relates to multiple employees working in Building 374 questioning the 

accuracy of the monitoring program. The site provided an evaluation of dosimetry results for 

the particular department; however, there is no information provided for specific individuals 

allowing a comparison to previous exposures. The external dosimetry department looked at the 

dosimetry results of Process Specialists and Radiological Control Technicians for the fourth 

quarter of 1997 and the first quarter of 1998. Dosimetry indicated that dose for 12 process 

specialists went down, dose for 7 process specialists went up, and dose for 3 individuals stayed 

the same. For the same time the RCT doses decreased. The average dose for process specialists 

averaged 9.8 mrem in Quarter 4 1997 and 6.1 mrem in Quarter 1 1998. It is difficult to ascertain 

whether there is evidence of inaccuracies in individual files based on a population evaluation that 

appears to be inconclusive. NIOSH has provided a general hypothesis that inaccuracies did not 

exist without substantiating them by looking at individual cases. Some basis for this hypothesis 

should be documented. 

NIOSH, in other cases, also provides such hypotheses in response to specific concerns without 

what SC&A views as an adequate basis or substantiation. In several instances, a broader 

conclusion regarding site-wide data integrity is made on this basis. 

RFETS SEC Petition Review 9 Working Draft – February 15, 2007 
For example, in relation to Safety Concern #89 -037 NIOSH states: 

In any event, this appears to be an example of an isolated failure to follow established 

policies. Corrective actions were taken, and there is no indication that this event 

constitutes a sitewide data integrity issue, and does not have SEC implications. 

During review of logbooks the following entry was found. This incident involved four 

Radiological Control Technicians (RCTs). 

....do not have dosimetry badges on the board this morning....told to report to class then 

go to external dosimetry to get badge. Problem is movement of RCT’s between buildings, 

but no paper work sent to change badge board locations. 

This indicates that RFP site dosimetry was not always aware of facility changes made by 

workers, and may not have adjusted the personal monitoring in a timely manner. Although the 

logbook entry in, and of itself, does not provide conclusive evidence of a site-wide issue, it 

certainly indicates the NIOSH hypothesis that Safety Concern #89-037 is an isolated failure may 

not be correct. 

There is no information included in the Safety Concerns reviewed that taken together would 

conclusively demonstrate a site-wide issue with data integrity. However, there are numerous 

specific examples raised in these concerns that bring into question the accuracy aspects of the 

internal and external monitoring program. Some of these concerns were documented well before 

the enactment of the EEOICPA underscoring that a number of these concerns were not new. 

Safety Concerns Needing Further Basis or Investigation 

NIOSH has indicated that Safety Concerns #90-169 and #92-048 require further investigation to 

determine their relevance to the SEC Petition. In Safety Concern #90-169, the worker submitted 

multiple urine samples including samples sent off site. He was told that the first sample was 

negative. Additional samples were collected. Some samples were lost and another was invalid 

due to poor chemical recovery. This safety concern appears to provide an example of quality 

control issues in the bioassay laboratory. This may or may not affect multiple individuals 

depending on the extent of the bioassay laboratory problems. Safety Concern #92-048 

expresses concern with the adequacy of the internal and external dosimetry programs at RFP and 

their compliance with federal requirements. It further expresses concern over the lack of 

communication between dosimetry and the workforce. 

Summary 

The safety concerns evaluated provide multiple examples where Extended External Dosimetry 

investigations would have been presumably conducted by Radiological Control. However, it is 

difficult to determine from a secondary source whether an adequate investigation was conducted 

and whether the investigation was responsive to the employees concerns. From a review of 

former worker’s Health Physic files, there is evidence that Extended External Dosimetry 

Investigations were documented back to the mid-1980s; however, the documentation did not 

RFETS SEC Petition Review 10 Working Draft – February 15, 2007 
routinely show up in the worker’s file until the late-1990s. This raises an unresolved concern as 

to whether external dosimetry investigations were conducted routinely prior to the late-1990s, 

and if so, why documentation is apparently absent from the Health Physics file.

A number of safety concerns (#74-61, #85-109, #86-13, #86-161, #86-169, #89-037, #89-203, 

#90-169, #91-496, #92-003, #92-048, and #97-176) relate to the lack of quality control in the 

internal and external monitoring programs. These collectively reinforce issues raised in the 

petition regarding data quality. For example, the Neutron Dose Reconstruction Project (NDRP) 

is provided in the petition as illustrative of petitioner concerns over data quality issues. The 

NDRP was initiated as a result of questionable accuracy and completeness in neutron dosimetry 

from 1952 through 1971 (Baker 2002). Other examples of quality control issues in the dosimetry 

program included computer algorithm and transfer errors (RI 1976, Baker 1998), not adjusting 

monitoring requirements for employees transferred to other areas of the site, lost of bioassay 

samples, double background subtraction for dosimeters (Savitz 1996), and failure at blind audits 

(Klueber 1997). A generalized evaluation related to the completeness and accuracy of 

dosimetry results as well as dosimetry investigation procedures will be provided by SC&A 

in its ongoing data integrity evaluation. 

Safety Concerns #90-169 and #92-048 should be further investigated to ascertain their 

applicability to the SEC petition. This lack of trust in the internal and external monitoring 

programs and dosimetry systems are the fundamental concerns raised by the petitioners. 

In conclusion, SC&A concurs with NIOSH’s assessment of many of the forty-nine safety 

concerns and parts of other safety concerns. While these safety concerns do not directly address 

falsification of records, a number of them express a lack of confidence in the monitoring at RFP. 

Although not providing definitive evidence of a systemic problem with RFP radiation dose data 

that would necessarily preclude dose reconstruction, some of them do highlight historic instances 

of poor quality control practices. 

RFETS SEC Petition Review 11 Working Draft – February 15, 2007 
ATTACHMENT 4: SAFETY CONCERNS SUMMARY TABLE 

Rocky Flats Safety Concern Review for Data Integrity Issues 

Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

70-2 

Senior Radiation Monitors raised five safety issues related to general work area radiation levels, adequacy of shielding, storage of plutonium, dry box window damage, and inadequate criticality drains. There was an agreement to reduce storage in the building. A review of the dosimetry results for Manufacturing personnel indicated that there were four individuals receiving over 4 Rem in 1969, and no individuals over 5 Rem. Criticality drains were recognized as an ongoing problem (JCUSC1970). 

While these safety concerns detail valid safety issues and it was important for these issues to be corrected, the concerns do not adversely impact NIOSH’s ability to conduct dose reconstruction of sufficient. NIOSH therefore concludes that these issues do not have SEC implications. 

Although plutonium sshielding, dry box wiinadequacy of criticalsafety issues, this typused in dose reconstrupersonnel set an interexposure level at 4 Rmore than four indivifile with greater than safety concern is simpindividual exceeded taffect dose reconstrucwere monitored. Conassessment.

71-4 

The employee was concerned that the film badge results for December 1970 did not reflect the high level of neutron exposure measured by field instruments and film badge results of a coworker on the same special job (JCUSC 1971a). 

As discussed on previous occasions, it is not reasonable to expect that all workers frequently perform different duties that put them in different proximity to the source. The Safety Concern in and of itself does not in and of itself demonstrate a problem with the integrity of RFP dosimetry data. 

This safety concern ain the petition about dreflecting field conditof the dosimeters has times during the courAn explanation of whrespond to alleged higfurther investigation. 

71-7 

Inadequate notification of Health Physics regarding maintenance work on booster fans potential caused inaccurate stack air sampling results. Other safety issues included such infractions as no dry box overhead alarm, taping a plastic bag and the end of the air duct to contain high level contamination, and an unsafe drill press (JCUSC 1971b, JCUSC 1971c, JCUSC 1971d, JSUSC 1971e, JSUSC 1971f). 

While these are important safety issues and it was important for these issues to be corrected, the concerns do not adversely impact NIOSH’s ability to conduct dose reconstruction of sufficient. NIOSH therefore concludes that these Safety Concerns do not have SEC implications. 

Inaccurate stack air saimplication for envirothe doses from envirosmall in comparison tThis concern should bcontext of the RFP sitprocess. Concurrencassessment.

RFETS SEC Petition Review 12 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

74-61 

The employee has indicated that there is a need for a quantitative method to evaluate radioactive materials taken into the body to prevent unsafe exposures (JCUSC 1974). 

The data were adequate and of sufficient quality to accurately assess the amount of Pu in the body. There is nothing in this Safety Concern that would adversely impact NIOSH’s ability to conduct dose reconstructions with sufficient accuracy; therefore, this issue does not have SEC implications. 

Further discussions wstaff having knowledprovided additional inthe safety concern wathree in vivo counting were used on a routincounter, according to more positive chest ca routine basis. Workaccuracy of the countvivo counts. Dosimetworker filing the concprinciples of the in vi

NIOSH has indicated results are not used in claimant dose. If this individuals were adequrinalysis, NIOSH coconduct dose reconstrNIOSH decides to us“bound” intakes, or it bioassay monitoring wwould impact internaFurthermore, if this dcoworker model, the in question and must 

RFETS SEC Petition Review 13 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

75-34 

Employee concerned about downward adjustment of his TLD readings to account for his receipt of a medical procedure involving the administration of a radionuclide (JCUSC 1975). 

The appropriate consideration of nuclear medicine techniques and the adjustment of the occupational dose record are important for accurate dose reconstruction. If an employee failed to notify the medical/dosimetry staff of such a procedure, dosimetry results may be biased high and it could result in a false positive result in a subsequent whole-body count. The procedure implemented addresses this concern. 

Concurrence with NI

84-19 

“A very high percentage of the personnel working in Room’s 264-266 in 881 are getting abnormally high radiation from the body counter. These areas until recently were closed due to contamination.” (JCUSC 1984) 

There may be a valid concern that the work areas in question may still contain contamination, and it can be inferred that this may be what motivated the filing of this Safety Concern. It appears that the possibility of intake was evaluated using whole body counts and bioassay. In such situations, NIOSH can use these data to conduct dose reconstructions of sufficient accuracy; therefore this Safety Concern does not appear to have SEC implications. 

The bioassay results fused for dose reconstwith NIOSH assessme

85-109 

Workers were involved in decontamination of machine parts in their personal clothing. They questioned this practice but were told to continue. Employees were concerned that radiation monitoring in Bldg. 881 and the Medical Department came up with different results than the personnel involved (JCUSC 1985a). 

While observance of proper contamination control requirements and use of appropriate 

personal protective devices has important safety implications, there is nothing in this Safety Concern that would prevent NIOSH from conducting dose reconstructions with sufficient accuracy. Uptakes resulting from work in contamination areas, if any, would be reflected in bioassay results, which NIOSH would not likely include in reconstructing internal dose. 

Assuming the employmonitored via urinalydata was not used in dwould not present an reconstruction. If, hoto use the data, or it ibioassay monitoring wwould impact interna

RFETS SEC Petition Review 14 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

85-137 

Employees were involved in a bag change and bag out procedures without the support of a Radiation Monitor. Respiratory protection was not worn while holding packages and the packages were not in secondary containment (JCUSC 1985b). 

There is nothing in this Safety Concern that would prevent NIOSH from conducting dose reconstruction with sufficient accuracy. Uptakes resulting from work without proper coverage from Radiation Monitoring personnel, if any, would be reflected in the bioassay results, which NIOSH would use in reconstructing internal dose. 

Concurrence with NI

85-161 

There is survey and decontamination of dosimeters prior to shipping them to External Dosimetry for processing. The site is allowing dosimeters which have to be surveyed to go to dosimetry to be taken home by employees after work (JCUSC 1985c). 

The subject of this concern does not 

adversely impact NIOSH’s ability to conduct dose reconstruction of sufficient accuracy. 

This safety concern qdecontamination of dtime they are shipped processing. Although practice to protect the the questions about wdosimeter became corelative effect on extealso raises questions rfor internal exposure contamination contro

86-13 

The frequency of an employees badge exchange was twice rather than four times per year (JCUSC 1986a). 

This issue does not cast doubt on the integrity of Rocky Flats dosimetry data, does not prevent NIOSH from conducting dose reconstruction with sufficient accuracy, and therefore does not have SEC implementation. 

Concurrence with NI

RFETS SEC Petition Review 15 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

86-161 

Several inspectors received body counts. Four out of the five had high counts for uranium. The employee was concerned about this because there was a sudden focus on counting individuals from Building 460 where he worked. Later it was determined that there was a problem with the counters on the day of his count (JCUSC 1986b). 

NIOSH relies primarily on bioassay data for reconstruction of internal doses at Rocky Flats. It appears that whatever the problem with these particular lung counts was, the problem was addressed and the individuals were recounted. Therefore, NIOSH concludes that there in nothing in the Safety Concern which would prevent dose reconstruction of sufficient accuracy. 

Assuming the employmonitored via urinalywas not used in dose would not present an reconstruction. If, hoto use lung count data is determined that bioincomplete, this woulreconstruction. Furthused in the coworker this data is in questioevaluated. 

86-169 

There is an inadequacy in the scheduling of personnel for body counts and a lack of coverage at the body counter during midshift. The Safety Concern indicated equipment problems created a temporary backlog. The individual filing the concern eventually did receive a body count (Leigh 

and James 1986, JCUSC 1986c). 

It must also be noted that NIOSH dose reconstructions at Rocky Flats rely primarily on bioassay (urinalysis). For these reasons, NIOSH concludes that this Safety Concern does not raise issues that adversely impact our ability to conduct dose reconstructions of sufficient accuracy, and therefore does not have SEC implications. 

Assuming the employmonitored via urinalywas not used in dose would not present an reconstruction. If, hoto use lung count data is determined that bioincomplete, this woulreconstruction. Furthused in the coworker this data is in questioevaluated. 

86-186 

An electrode and base were left in the line after the completion of a job for an extended period of time. The bag was cut resulting in external contamination to the surface of the bag at >1,000,000 c/m smear. Workers involved in the job indicated the incident investigation was not adequate. (JCUSC 1986d). 

 While this is an important safety issue, this Safety Concern does not raise issues that adversely impact our ability to conduct dose reconstructions of sufficient accuracy, and therefore does not have SEC implications. 

Concurrence with NI

RFETS SEC Petition Review 16 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

87-005 

In this concern the worker questions why he received very low or no exposure on his badge for 2 years. A review of his dosimetry files indicated that the zeros in the individual’s records were the result of wrist badges being turned in without a corresponding body badge (JCUSC 1987a, Chanda and Overholt 1987). 

This is an example of an employee who is suspicious of his dosimetry results. The basis for this suspicion is not described in the Safety Concern. However the employee’s records were reviewed by the JCUSC, who determined that (1) all dosimetry results were included in the employee’s radiation file, (2) his results had been consistent for the time period in question; and (3) his results were in line with those of similar employees. Therefore this Safety Concern does not have SEC implications. 

This safety concern reto conduct external doas well as providing aindividuals questionindosimetry system. ThR.N. Chanda and G.AMadsen indicates thadosimetry records wedetermined that the zewrist dosimeters turn corresponding body dindividual was assigndepartment in Buildinpotential for exposuredetermine from a secoadequate investigatiowhether the response employees concerns. evaluated in this casedose should be compacoworkers performing 

RFETS SEC Petition Review 17 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

87-038 

The worker questioned the zero result he received on his dosimeter. The dose was initially 15 g and 246 n it fell outside the average ratio expected for Building 771. The dosimeter result was to be recounted and a 3-1 ratio applied ( JCUSC 1987b). 

The Safety Concern, dated 1/30/87, states the print out (presumably the Supervisor’s High-to-Low Dose Report, distributed after a TLD exchange) dated 1/22/87 shows zeros, and that the initial readings were 15 g and 246 n. It is assumed the 15 g stood for gamma and the 246 n stood for neutron dose, in mrem, although this is not stated in the Safety Concern. The Safety Concern also doesn’t state for which dosimeter exchange period this reassessment was completed. (Further information can be obtained from NIOSH 2006.) 

The dosimeter value wquality control issues results. There does of follow-up investigpotential exposure. Tregarding how dose wdosimeters were lost, or had quality control individual was on a bindicating the potentiThe adjustment to his this, and adequate jusnot provided. This qube used during the doprocess. 

87-206 

Employees were not receiving updated reports on their current dosimetry badge readings in accordance to RFP procedures (JCUSC 1987c). 

This issue does not prevent NIOSH from conducting dose reconstruction with sufficient accuracy, and therefore does not have SEC implementation. 

Concurrence with NI

RFETS SEC Petition Review 18 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

89-037 

Employee worked in an area with uranium; however, only a single sample was collected over a three and a half year period. The same individual was not assigned a dosimeter for a year (JCUSC 1989a). 

NIOSH has established methods for calculating dose in the case of data gaps. There is no indication that this event constitutes a sitewide data integrity issue, and does not have SEC implementation. 

NIOSH states this is aNIOSH has not provistatement that there is wide data integrity isone safety concern. Nmethods for assigning data gaps; however, taddressing data gaps consideration. Their data gaps and assignidata gaps is particularAlthough lack of mondata integrity issue, it impact on dose recongaps in the data of indnot adequately monitointegrity of the data mreconstruction. 

89-148 

The concern expressed was related to lack of procedures for documenting infractions in the Radiation Monitoring reports when individuals enter respirator required areas without a respirator, gloves with removable contamination that have not been changed, or procedural violations which endanger the safety of individuals (JCUSC 1989b). 

While the particular types of issues mentioned have obvious safety implications, a form for reporting such situations was implemented across the plant. These types of issues do not prevent NIOSH from conducting dose reconstructions of sufficient accuracy; and therefore do not have SEC implications. 

Concurrence with NI

RFETS SEC Petition Review 19 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

89-167 

The concern requested that a survey of Building 334 be conducted to verify there was no radiation present. One individual required a wound count and another had a positive bioassay result. A survey was conducted with negative results (JCUSC 1989c). 

Bioassay was employed for the individual involved, and this is the information NIOSH would use to conduct dose reconstructions. There is nothing in this Safety Concern which would prevent NIOSH from conducting dose reconstruction of sufficient accuracy, and therefore it does not have SEC implications. 

Assuming the employmonitored via urinalypresent an issue with however, NIOSH detmonitoring at RFP waimpact internal dose rFurthermore, if this dcoworker model, the in question and must 

89-214 

Procedures for “Personal and Confidential” records were not being followed with quarterly dosimetry records (JCUSC 1989d). 

At some DOE sites, including Rocky Flats, periodic dosimetry results were posted publicly on a master list. This practice would have privacy implications, and this concern appears to be related to this practice. This issue does not appear to have data integrity or other SEC implications. 

Concurrence with NI

89-203 

An individual working a breathing air job received a possible inhalation. The individual received an in vivo count however, 

during the in vivo count the equipment malfunctioned. He was sent home without an adequate count. All personnel were contacted and scheduled for a follow-up in vivo count as soon as the equipment was repaired. Corrective actions were taken regarding the detector problems. (JCUSC 1989e) 

In this situation, NIOSH can use these data to conduct dose reconstructions of sufficient accuracy; therefore this Safety Concern does not appear to have SEC implications. 

Assuming the employmonitored via urinalywas not used in dose would not present an reconstruction. If, hoto use lung count data is determined that bioincomplete, this woulreconstruction. Furthused in the coworker this data is in questioevaluated. 

RFETS SEC Petition Review 20 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

89-259 

Inaccurate cumulative radiation dose equivalent history from Dosimetry and a lack of earlier exposure information once a high cumulative radiation dose equivalent has been set (JCUSC1989f). 

The meaning of the concern in not entirely certain, but the response seems to indicate that the worker was concerned that he/she was not notified when the trends in cumulative dose would eventually put the worker over target dose limits. If the interpretation is correct, the issue does not constitute a data integrity issue or have SEC implications. 

The safety concern is making it difficult to a dosimetry or ALAR

90-169 

The worker submitted multiple urine samples including samples sent off site. He was told that the first sample was negative. One special sample and 4 or 5 samples were collected. Some samples were lost and another was invalid due to poor chemical recovery (JCUSC 1990a). 

Evaluation of this Safety Concern in ongoing. 

There appears to be acontrol in the bioassaaffect multiple indiviConcurrence with the further investigation 

RFETS SEC Petition Review 21 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

90-202 

The submittal did not include a specific concern but rather questions related to the potential exposure of Dosimetry Technicians from Cf-252 source in Building 126. J.M. Hoffman from the External Dosimetry group, issued a memorandum discussing the use of the source, how it is handled by the dosimetry technician, and the dose rates associated the shielded and unshielded source. Calculations of expected annual dose from duties 

associated the source were determined to be 52.1 mrem/person using conservative assumption. A survey of the area was conducted showing minimal exposure rates. 

Upon issuance of the safely concern, Dosimetry Technician personnel dosimeters were processed. The dosimetry results, representing six months of exposure indicated a total dose of less than the detection limit including neutron dose (Hoffman 1990a; Lesses 1990a). A review by Radiological Engineering indicated a lock to prevent inadvertent access should be installed and the Beacon light required repair (Lesses 1990b). No health hazard was believed to exist (JCUSC 1990b). 

The employee was satisfied with the results and the proposed actions were completed. There is nothing in this safety concern that would prevent NIOSH from conducting dose reconstructions with sufficient accuracy. 

The safety concern inemployees were monbeta/gamma and neutcould be used in dose Concurrence with the 

RFETS SEC Petition Review 22 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

91-262 

The safety concern questioned the practice of wearing dosimetry only when entering a Radiological Control Area. If there were a criticality accident, and the employee was exposed, there would be no record of their exposure (JCUSC 1991a). 

The concern expressed is not relevant to NIOSH’s ability to reconstruct doses with sufficient accuracy at Rocky Flats, as there is no evidence that an unplanned criticality ever occurred at Rocky Flats. However, it is true that in such an event, it is frequently possible to reconstruct doses from neutronactivated elements in biological materials such as hair and blood, and in nonbiological materials, as well as from area TLDs and TLDs worn by coworkers, depending on the specifics of the situation. Therefore, this issue does not have SEC implications. 

The JCUSC agreed wdosimeters should be in the Perimeter SecuConcerns were expregroups that this was nhealth and safety procExternal Radiation D15, 1991, shortly afteissued, continued to rworn in Radiation Coposting required it, anbadge racks. There are other meancases where dosimetewas demonstrated witAccident in 1958. Concurrence with NI

RFETS SEC Petition Review 23 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

91-395 

Safety Concern 91-395 states that radiation 

exposures to employees in Building 664 were too high and unnecessary because grams of plutonium, americium, and uranium were being stored in drums at this location (JCUSC 1991b). Anderson (1991a) conducted a radiation survey of the aisles of waste drums and calculated the maximum potential Dose Equivalent for an individual exposed 30 minutes per week in this area. An estimated external gamma dose for this scenario was 631 mRad per year. No elevated levels neutron exposure readings were detected. The estimated dose was below the Administrative Dose Guidelines and deemed to result in no significant health related problems. A Radiological Control Area was established for Building 664 a few months prior to the safety concern. The changes in RCA requirements, including use of a dosimeter, were incorporated into the Building 664 Site Specific Health and Safety Plan (Anderson 1991b). In late 1992, the drums were shipped from Building 664 to Building 569 (Lewis 1992). Further concerns were raised during the JCUSC evaluation about the location of the dosimeter exchange board and elevated background. Radiological Engineering reviewed survey and background dosimeter data from 1991 for the facility. The location of the dosimetry board was preferred and no relocation was necessary (Anderson 1991a). 

While unnecessary radiation exposure to employees could have important safety implications, there is no indication that doses were unmonitored. NIOSH therefore concludes that this issue does not have SEC implications. 

With respect to the stmaterials in the aisle unclear whether persowere required to wear establishment of an Rwas created prior to thNIOSH has assumed issue; however, withodiscussed above, it is able to come to this cIn relation to the radiDosimeter Exchange practice for the dosimTLDs in the rack alonpersonnel. The methbackground subtractioLagerquist (1975) ind1986, the total backgrdosimeters would env(0.34 mRem/day) and TLD operating proceindicated that the totawas determined from instrument backgrounBackground Subtractwas conducted the selocations across the sthat using a location screate potential probldosimeters are not alwassigned location. Fuindicated subtracting will generally reduce (Klueber and Savitz 1

Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

91-395 background subtractio

RFETS SEC Petition Review 24 Working 
(Continued) location of the storag

walled or non-hard wimplemented (Baker1TLD element residuatime dependent and lobackground, results in background which is personal dosimeter (Rfor background subtranot located. The conclocation specific backappropriate for backgBased on documentatlocation specific backuntil 1999. In 1999, revised methodology study included backglocation. These data dosimeter results as asubtraction is more apas a site profile issue. NIOSH assessment thare not an SEC issue.

RFETS SEC Petition Review 25 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

91-490 

Safety Concern 1991-490 expressed apprehension over the lack of positive control to prevent tampering, misuse, and other compromising situations with the current dosimeter storage system and location. External Dosimetry indicated that there were 

procedures in place to monitor for inappropriate dose results (JCUSC 1991c). The second issue raised concerned the affect of temperature and humidity variations on the dosimeter badge. Several reports relevant to the conditions of exposure for environmental dosimeters were made discussed. Based on tests conducted on the TLDs, External 

Dosimetry dosimeters were found adequate to handle environmental conditions encountered including temperature and humidity. A third issue indicated that a background 

control study was not conducted prior to the implementation of the new storage areas for dosimeters. A study began simultaneously with the placement of badges at the new locations. External Dosimetry noted ambient external radiation was monitored during surveys. In addition, as long as the individual stores the badge in the correct location, background levels are not an issue. 

Throughout the operating history of Rocky Flats, suspect dosimetry badge readings were investigated, and in later years formal investigation reports were placed in individual radiation files. There is nothing in this Safety Concern that would prevent NIOSH from conducting dose reconstructions with sufficient accuracy. 

With respect to positino system available to from tampering with External Dosimetry efrom each element as inappropriate dose reNIOSH has not specisecond, third, and fouconcern. InconclusivThe environmental doindicates that dosimettemperature and hummonitoring period of conducted by Bollingdosimeters indicated submerged in water ywith controls. Ong (1TLD elements do not when enclosed in a hoBackground subtractidiscussed under Safetdoes not constitute an Dosimeter storage locmaximum accessibiliThere was a potential tampered with; howeplace to evaluate inapdosimeter results. Emprotect the dosimeter contaminated or physhowever, this did occ

RFETS SEC Petition Review 26 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

91-490 

(Continued) 

A concern arose regarding violation of HSP 18.07, External Radiation Dosimeter. This 

procedure states that all employees shall protect their dosimeter from contamination, physical damage, moisture, and heat (HSP 1991). External Dosimetry issued a revision to this procedure providing clarification on the employee’s responsibility regarding their dosimeter (HSP, 1992). 

Contaminated badges wherever possible; hochips contained in the generally safe from cdamage to a dosimetechips, resulted in a Daccording to former sDosimetry Investigatipersonal dosimetry fi1980s; however, avaiDose files was not rouExternal Dosimetry inconsidered in previou

RFETS SEC Petition Review 27 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

91-496 

Safety Concern 91-496 questions the storage of film badges in the tunnel north of Portal 1. External Radiation Dosimeter requires that background studies be conducted prior to the implementation of badge racks (JCUSC 1991d). Similar concerns were raised in 91-490 so JCUSC addressed them together. A separate safety concern indicating there were violations of HSP 18.07 (HSP 1992), was issued on March 2, 1992 is included in the Safety Concern 91-496 file. Documentation indicated that a Radiation Protection Technician was without dosimeter protection, which resulted in an entire building being without RPT support (JCUSC 1991e). 

However there is nothing in this Safety Concern that would prevent NIOSH from conducting dose reconstructions with sufficient accuracy. Uptakes resulting form work without proper coverage from Radiation Protection personnel, if any, would be reflected in bioassay results, which NIOSH would use in reconstructing internal doses. 

NIOSH has not speciissue of storage of fil

Independent external as well as employees regarding the environtunnel. Although no Radiation Protection dosimeter storage boaenvironmentally suitaconsideration of back1991). For periods of specific backgrounds background subtractioinconclusive. There ibackground radiation adjustments were appdata. For those years dose levels were used subtraction, the locatistorage areas would nresults. With respect to RPT impact the ability to ras all individuals suppoperations within the appropriately monitorNIOSH assessment.

RFETS SEC Petition Review 28 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

92-003 

The Safety Concern was filed by an employee who sustained a minor injury while working in Building 707. The employee reported to Medical for a wound count. He expressed concern over the inconsistency of the wound counter, procedures related to wound counting and training. The corrective actions included training for individuals operating wound counters, verification of background levels, filter changes in Room C, Bldg 112, and thorough cleaning of this room (JCUSC 1992a, Baker and McCoy 1992). 

NIOSH relies primarily on bioassay data for reconstruction of internal doses at Rocky Flats. NIOSH concludes that this issue does not in and of itself compromise the integrity of Rocky Flats data, does not prevent NIOSH from conducting dose reconstructions of sufficient accuracy and therefore does not have SEC implications. 

Assuming the employmonitored via urinalywas not used in dose would not present an reconstruction. If, hoto use the wound coudetermined that bioasincomplete, this woulreconstruction. 

92-036 

External dosimetry reports used by the field to monitor the amount of exposure an employee has received to date for a particular year were not provided for a year (JCUSC 1992b). 

This appears to be an issue of lack of timely reporting of dosimetry results to employees. There is no indication that employees were in fact unmonitored, but rather than the results of such monitoring were not reported promptly to the employees. As such, the safety concern does not have data integrity or other SEC implications. 

Concurrence with NI

92-048 

The internal and external dosimetry programs at RFP are inadequate and not in compliance with requirements. There is a lack of communication between dosimetry and the workforce (JCUSC 1992c). 

Evaluation of this safety concern is ongoing. SC&A agrees that thi

further investigation. internal and external dosimetry systems arconcerns raised by th

93-061 

Safety Concern 93-061 indicates there is untimely turn around time for samples submitted by workers (JCUSC 1993a). 

Three employees submitted this concern and all of them signed the form stating that they were satisfied with the results. Untimely 

bioassay results do not compromise the integrity of Rocky Flats bioassay data, does not prevent NIOSH from conducting dose reconstructions of sufficient accuracy and therefore does not have SEC implications.

Concurrence with NI

RFETS SEC Petition Review 29 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

93-109 

This Safety Concern form is identical to that of Safety Concern 1991-395 and has the same date. It appears that this safety concern was renumbered and additional response was provided. The additional response indicates that the resolutions described in Safety Concern 91-395 were not completed. 

While unnecessary radiation exposure to employees could have important safety implications, there is no indication that doses were unmonitored. NIOSH concludes that this issue does not compromise the integrity of Rocky Flats dosimetry data, does not prevent NIOSH from conducting dose reconstructions of sufficient accuracy and therefore does not have SEC implications. 

Refer to response for 

93-124 

The implementation of Personal Contamination Monitors resulted in discontinuation of monitoring by RPTs. RPT monitoring was still available upon request (JCUSC 1993b). 

The employee indicated his satisfaction with 

the response on the JCUSC Concern form. While contamination monitoring practices at the exit from a radiological contamination 

area could have safety ramifications, the failure to perform such monitoring would not affect NIOSH’s ability to conduct dose reconstruction with sufficient accuracy. Personnel entering such areas were required to participate in bioassay programs, and this is the data NIOSH relies upon for dose reconstruction. Therefore, the Safety Concern does not have SEC implications. 

Concurrence with NI

93-193 

The employee issued a Safety Concern because he was involved in an incident, and was notified 1.5 days after the incident that he required an in vivo count, bioassay sampling, and was restricted from the Material Access Area (MAA). There was acknowledgement that the bioassay sampling should have begun within 24 hours of the incident. Additional training was scheduled for Radiological Engineering regarding their responsibilities related to potential intakes and subsequent measurements (JCUSC 1993c). 

This is an issue with safety implications. Corrective actions were taken, i.e. training was held. There is nothing in this concern that would compromise NIOSH’s ability to reconstruct internal doses with sufficient accuracy; therefore NIOSH concludes that this is not an SEC issue. 

A delay of 1.5 days fourine, in vivo count, oprevent detection of aConcurrence with NI

RFETS SEC Petition Review 30 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

94 -072 

Logbook entries made regarding the contents of a tanker truck do not reflect what was actually in the tanker truck (JCUSC 1994a). 

The subject of the safety concern does not involve the data NIOSH used to conduct dose reconstructions at Rocky Flats (personal external and internal dosimetry). There is nothing in this Safety Concern which would adversely impact NIOSH’s ability to conduct dose reconstructions with sufficient accuracy, therefore this issue does not have SEC implications. 

Concurrence with NI

94-079 

No decontamination and showering facilities are available for Radiological Control Technicians at the Federal Records Center. 

This issue appears to relate to emergency facilities at the Denver Federal Records Center, where records were being sent from Rocky Flats. As such, this issue is not germane to NIOSH’s ability to conduct dose reconstruction of sufficient accuracy. 

Concurrence with NI

94-080 

This safety concern indicates that there was no pre-evolution evaluation conducted for work being performed at the Federal Records Center. There was not a PRE or RWP generated and available at the worksite. There were also no emergency instructions for casualties issued. The response indicated that an evaluation of the need for a Radiation Work Permit was conducted, and any new or additional members will receive a briefing. It was further indicated that an RWP was not required for this job (JCUSC1994b). 

This issue appears to relate to emergency facilities at the Denver Federal Records Center, where records were being sent from Rocky Flats. As such, this issue is not germane to NIOSH’s ability to conduct dose reconstruction of sufficient accuracy. 

Concurrence with NI

94-081 

This concern indicated that there were no emergency response kits and appropriate forms available at the Federal Records Center. Management indicated that they would transport necessary emergency response equipment to and from the Federal Records Center (JCUSC 1994c). 

This issue appears to relate to emergency facilities at the Denver Federal Records Center, where records were being sent from Rocky Flats. As such, this issue is not germane to NIOSH’s ability to conduct dose reconstruction of sufficient accuracy. 

Concurrence with NI

RFETS SEC Petition Review 31 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

94-245 

Two people had their TLD confiscated as a result of an occurrence. TLDs were not returned immediately. The office personnel 

in Bldg. 776 were required to have TLDs but these workers were not (JCUSC1994d). 

While performing work in a RCA without appropriate external dosimetry may or may not affect NIOSH’s ability to perform dose reconstructions with sufficient accuracy, it appears that this did not occur in this particular instance. Therefore the Safety Concern does not have SEC implications. 

NIOSH indicates that without appropriate dor may not affect the reconstruction. They employees with confiwork in an RCA duriwithout a TLD. Therdisagreement regardinemployees indicated radiological work durwhile the JCUSC indwere not required to pradiological area withtime period. No detainvestigation were prConcern File. In addraises the question of were taken away from Were these workers pradiological areas durCertainly if employeeradiological areas witput their external exptherefore impact dose assumes the worker dradiological area, whiSafety Concern does information to make tInconclusive. 

RFETS SEC Petition Review 32 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

95-061 

TLD badges were pulled by the Building Manager of 776 as a result of Radiation Work Permit (RWP) violations. This was due to lack of communication by management to employees using the RWP on a daily basis and without a critique to find a root cause for the violations. Inconsistencies exist within management when pulling TLDs. The supervisor response indicated the company 

policy was to pull TLDs in any case where radiological procedures are violated. (JCUSC 1995a). 

This safety concern appears to be a disagreement between management and the employee. The employee states that there are inconsistencies by management when pulling TLDs. Building management conducted tool box and conduct of operations meetings to reinforce the RWPs. There is nothing in this safety concern that would prevent NIOSH from conducting dose reconstructions with sufficient accuracy. 

There is no indication having their dosimetesimultaneously bannelarger concern is wherestriction from radiaThe safety concern direstriction was imposInconclusive.

95-077 

Retired workers are asked to provide a urine sample and return it via the U.S. mail. Some of these samples are contaminated (JCUSC1995b). 

The protocol for shipping bioassay samples from retired employees was determined to fall within the applicable laws and regulations. This issue does not relate to NIOSH’s ability to conduct dose reconstructions with sufficient accuracy, and therefore does not have SEC implications. 

Concurrence with NI

96-182 

An employee was involuntarily terminated. His dosimeter was not read within the month following (Local 8031, 1996). 

The badge in question was read, though not within the timeframe called for in the site procedures. This is an issue of timeliness in reading the badge, rather than a date integrity issue, and the implication is that this was an oversight. Therefore, this Safety Concern does not have SEC implications. 

Concurrence with NI

97-163 

There was a concern raised over animosity between Mission Support Specialist and Decontamination workers assigned to perform the same work creating a hostile work environment (Local 8031 1997). 

The preliminary description of the Safety Concern mentioned a “hostile work environment”. However, this issue does not appear to have SEC implications, as it does not deal with data integrity, or with NIOSH’s ability to conduct dose reconstructions. 

Concurrence with NI

RFETS SEC Petition Review 33 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

97-176 

An employee was given a TLD badge which did not contain TL elements. The TLD had been processed and the elements were not replaced at the time the supervisor came in and retrieved the dosimeter. The RCT entered radiological areas with inadequate dosimetry (Baker 1997). 

The JSUSC Safety Concern Worksheet indicated that no action was required and that this issue was resolved. The employee also indicated satisfaction with the resolution. A bulletin was sent out on July 10, 1997 describing the issue, as well as the steps to prevent reoccurrence. According to information obtained in HIS_20, a dose reconstruction was performed by dosimetry personnel for the affected individual to address this situation and the individual was assigned positive dose. 

With respect to the indosimetry investigatiodetermine the dose rethis inadequate dosimsome positive affirmaExternal Dosimetry rat least during this timwith NIOSH assessmesituation does not prereconstruction.

98-073 

External dosimetry reports received by employees in Building 374 indicated the many employees received zero doses for first quarter 1998. The employees questioned these results based on the exposures they had received in past reports. Employees felt that based on previous reports, the results were in error. Dosimetry explained to workers that dosimeter results less than 10 mrem were recorded as zero. A population dosimetry investigation was conducted by external dosimetry (JCUSC 1998a, McCoy and Chestnut 1998). 

This Safety Concern provides an example that workers concerns on this subject were investigated. While the accuracy of external dosimetry results is certainly an issue with SEC implications, this Safety Concern does not provide any evidence of inaccuracies in Rocky Flats external dosimetry. 

The External Dosimethe dosimetry results Radiological Control fourth quarter of 1997 1998. Dosimetry indprocess specialists weprocess specialists weindividuals stayed the time the RCT doses ddose for process specmrem in Q4 1997 and It is difficult to ascertevidence of inaccuracfrom the information provided a hypothesis not exist without lookSome basis for this hy

RFETS SEC Petition Review 34 Working 
Safety 

Concern No.

Description of Concern NIOSH Response SC&A 

99-013 

The employee was concerned that he was not notified of a positive bioassay sample and the subsequent dose assessment in a timely manner. The process of notification of the employee of positive bioassay samples was modified such that the employee would be notified in a timely manner (JCUSC 1999a). 

This concern was recognized and addressed. Untimely reporting of bioassay results has potential safety and regulatory compliance implications, but NIOSH concludes that this issue does not compromise the integrity of Rocky Flats bioassay data and does not prevent NIOSH from conducting dose reconstructions of sufficient accuracy. 

Although delaying coresults and subsequenpoor practice, it does reconstruction. Concurrence with NI

99-023 

Employees believe foremen created a hostile work environment with outbursts of anger, name-calling, and arguments with employees, and potential sexual harassment (JCUSC 1999b). 

The Safety Concern details inappropriate behavior by an individual toward his coworkers. While it was important for this situation to be rectified, the subject of this concern does not adversely impact NIOSH’s ability to conduct dose reconstructions of sufficient accuracy. NIOSH therefore concludes that this Safety Concern does not have SEC implications. 

Concurrence with NI

00-075 

A chemist who supervised work in the head space area created a hostile work environment. He threw stainless steel canisters at a cabinet in a contamination area in the vicinity of others (Anonymous 2000). 

The Safety Concern details inappropriate behavior by an individual toward his coworkers. While it was important for this situation to be rectified, the subject of this concern does not adversely impact NIOSH’s ability to conduct dose reconstructions of sufficient accuracy. NIOSH therefore concludes that this Safety Concern does not have SEC implications. 

Concurrence with NI

RFETS SEC Petition Review 35 Working