Swipes done on the line are now performed by radiation technicians. Prior to
1990 training and staffing of radiology technical staff was deemed insufficient
to ensure worker safety by the DOE’s own audit, enclosed below. In the early
1990s there were approximately 3 to 6 radiation safety technicians, In
approximately 1992 to 1994, the plant hired a specialist from Texas A&M to
present training that would qualify interested employees for these positions.
Several of those who received this raining later went onto get their NRRPT or
other certifications.

The individuals in the Safety Department were some of the first
employees at the plant to receive and wear lead aprons, Others who came in
contact with the fissile material in weight and leak checking, inventorying,
etc,, were only issued lead aprons after they asked repeatedly for them.
Approximately half of the individuals who worked as safety engineering in
the early years have died. At least one of these workers died of some form of
cancer and another death was heart related, One of the individuals is being
followed for chronic beryllium disease, The cause of death for those who are
no longer living is unknown,

The following three incidents are described in a Pantex Safety Information Document
dated October 1998:

Assembly Cell Contamination w/Plutonium,

On November 6, 1961, at 9:30 p.m., operators on the second shift were removing a
pit (rom a weapon when a tube in the pit

ruptured. As a result of the accidental rupture, radioactive contamination was
released in Building 12-44, Cell 6, This

building is an assembly cell used during the assembly and/or disassembly of weapons
with plutonium bearing pits. Since the

weapon component was under a slight pressure, plutonium particles were blown into
the air, The particulate plutonium was

then caught up in the air conditioning and was scattered throughout the cell. There
were no personnel injuries as a result

of the incident. Three people were in the cell at the time, one foreman and two
operators. Both operators were wearing the

appropriate safety clothing, including respirators. The foreman was approximately
1.8 km (6 fi) away, opening the pit container to receive the pit. He was not wearing a
respirator, One opetator was lifting the pit and looked down and saw the tube bent
completely back against the pit. At the same time he heard a hissing sound, The
operators hurriedly placed the pit back in the high explosive (HE) and, together with
the foreman, quickly evacuated the cell. A nearby safety man told the personnel to
wait in a designated area while he notified safety and supervisory personnel and
obtained monitoring equipment, When contamination was apparent, he furnished the
men with olean respirators and isolated their clothing until the Radiation Safety
personsel arrived. An immediate check by the Radiation Safety personnel indicated



SAFETY INFORMATION DOCUMENT

4 Bederal limits in 1975 were 3 rem per quarter not to exceed 5 x (age of worker - 18} rem.

OCTOBER 1998
1978 $0,460 2.300 5i8 a 14 0,097
1979 178.910 3,140 74 27 4 0,251
1980 147.520 4.500 819 100 vi 0.180,
1981 201,190 5.230 915 320 35 0.220
1982 110.760 2.070 1002 600 66 O11
1983 103.180 2,330 1027, 687 67 0,110
W984 141,708 2.200 1113 464 2 0.127
1985 133.558 2.540 M72 715. 66 0.114
| 1986 85,590 1.510 1129 765. 68 0.076.
1987 34,850 1.410 1160. 976 84 0.030
1988 24,980 1.240 1123 913 81 0.022
1989 33.560 1.440 1438 1264. 83 0.023
1990 23,460 0.740 2090 31862 89 0.011

1991 22.310 0,530 2126 1905 90 0.010

1992 50,591 0.905 2317 1977 85 0.022
1993 44,825 0.850 2624 2228 85 0.017
1994 28.817 0.662 2978 2649 89 0,010
1995 36.623 0.764 3107 2791 90 0.012
1996 27.624 0.712 3209 2852 89 9.008
1997 10,991 0,432 3120 89 0.004



PP SRE ETE TEESE
TEEPE MEE

An abstract from this report is appended below. The relevant section begins

with:

“4.55 RADIATION PROTECTION, PERSONNEL PROTECTIO, AND
FIRE PROTECTION...
45,5, * Compliance Findings: Radiation protection staff unable to fulfill
mission...” On page 4-19

After the Tiger Team Report the Environment, Health and Safety staff

at Pantex grew dramatically in recognition of training, staffing and
documentation inadequacies, The identified inadequacies support workers’
concerns that monitoring, protection and record keeping were historically
inadequate for health and safety of the workforce.



Special Exposure Cohort Petition U.S, Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Controt and Prevention

Mness Compansation Act National institute for Occupational Safely and Health

OMB Number; 0920-0639 Expires: 05/31/2007
Pago 1

pecial Exposure C Petition — Form B

BS)

Genera! Instructions on Completing this Form (complete instructions are available in a separate packet
Except for signatures, please PRINT all information clearly and neatly on the form.

Please read each of Parts A — G in this form and complete the parts appropriate to you. If there Is more
thi etitioner, then each petitioner should complete those sections of parts A — C of the form that apply
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-

pose. A maximum of three petitioners is allowed.

‘Ifyou need more space to provide additional information, use the continuation page provided at the end of
the form and atiach the completed continuation page(s) to Form B.

If you have questions about the use of this form, please call the following NIOSH toll-free phone number and
request to speak to someone In the Office of Compensation Analysis and Support about an SEC petition:
4-800-356-4674,

(A Labor Organization, StartatD on Page 3

you G An Energy Employee (current or former), StartatC on Page2
are: GA Survivor (of a former Energy Employee), StartatB on Page 2
ER Representative (of a current or former Energy Employee), StartatA on Page 1

A Representative Information —~ Complete Section A if you are authorized by an Employee or
Survivor(s) to petition on behalf of a class.

Are you a contact person for an organization? 0) Yes (Go toA.2)

A2 Organization Information:

Name of Organization

Position of Contact Person
A3 Name of Petition Representative:

Mr/MrsJMs. First Name Middle initial Last Name

A4 Address:
Street : Apt # P.O, Box
City State . Zip Code

A Telephone Number: ( } =

A6 Email Address:
Check the box at left to indicate you have attached to the back of this form written authorization to

AT
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization

Name or Social Security Number of First Petitioner;



\
f

AEE NTE

that the personnel were contaminated; however, it was possible to completely
decontaminate them, Urinalysis was immediately begun on these three individuals,
Results indicated that none of the porsons involved had received an internal
deposition of plutonium.

The next day measurements were taken in the area of the cell, both in the enclosed
ramp area and around the exhaust vents :

outside the cell. Jt was determined that no significant radiation contamination was
released to the atmosphere, The second day following the incident, the airborne
radioactive material inside the cell had substantially settled out, and approval was
received to begin decontamination..Subsequent decontamination removed all
detectable plutonium from personnel, equipment, and the operating area. Property
damage was limited to various pieces of tooling and equipment

for which, due to their nature, decontamination was not possible and/or economically
feasible. Cleanup efforts cost approximately $26,000.

‘Tritium Release, 12-44, Cell 1.
Another incident occurred in May 1989, during a normal weapon disassembly and
retirement operations The Pantex Emergency Plan was activated. An
electroexplosive squib was initiated, which resulted in the actuation of the reservoir
valve. Operation of the valve caused deuterium-tritium gas to be transferred into the
pit and resulted in the subsequent release of deuterium-tritium into the assernbly cell.
‘The tritium release to the room occurred when the operator/technician, who did not
roalize the valve had functioned, loosened a pit tube gland nut before removing the
reservoir. None of the five operator technicians present heard or smelled the firing of
the explosive squib. The two operator/technicians working on the weapon did not
notice that the protective cover on the valve’s thermal plug had been ejected.
Investigation of the valve confirmed actuation by means of explosive firing, It should
be noted that although the valve actuation, gas transfer to the pit, and subsequent
personnel exposures are undesirable from an environmental or occupational safety
and health point of view, at no time was there a nuclear explosives safety concern,
which could have endangered any person at Pantex Plant or within the general
population, An estimate of 40 kCi of trittum gas was released into Cell 1 during the
incident. The dose to the maximally exposed individual was 1.3 rem and fess than 1.5
rom for all monitored individuals. The dose estimate at the site boundary was less
than 1 mrom. Tritium is a widely used radioisotope at many DOE laboratories. It
decays by beta emission to He-3 with a half-life of 12.32 years, ‘The maximum
energy of the beta particles emitted is 18,5 keV, and the average energy is about 5.7
keV. With one exception, this is the lowest-energy beta emitter known, These beta
articles
ne not have enough energy to penetrate the dead layer of ‘skin covering the human
body; therefore, tritium is not an external
hazard pat is of concern if the gas is inhaled or absorbed through the skin, The
amount of skin absorption equals the rate of
assimilation through inhalation. Building 12-44, Cell 1 is designated a contamination
area at the Plant and is no longer
used,



Pork Object
Site management should ensure effective inplementation and control of
radiological protection activities within its facilities, (DOB 5482.18 and
$5480.11)

Kindiog
‘M&@H appears to Jack sufficient independence to conduct internal audits of the
sadiation safety program.

Discuss
Bxamples supporting this finding:

o The only technically trained radiation protection staff (Le. health
physicists) outside of the Radiation Safety Department are still part of the
Environmental, Safety and Health (S&H) Division. This lack of
resources {0 suppoit the organizational structure does not allow the
independence required by DOE 5482. 18.

© The ES&H Division ha only one individual responsible for conducting
Quality Assurance/Quality Control (QA/QC) audits of radiation protection
programs required by DOH $480.11. DOB granted the necessary security
clearance for that individual in June 1989. Until that time, the audits
performed by that individual were accomplished without the benefit of
ever having seén the plast operations first-hand nor having reviewed
classified information relevant to the operations under audit (1-S-21).

© Radiation Sefety personnel within the HS&2T Division lack clear
understanding of thelr responsibilides, In particular, staffin the Radiation
Safety and Risk Management Departments have different, and sometimes

conflicting, priorities.
‘M&HL, through its implementation plan for compliance with 3480.11, has

requested additional staff for radiation protection. Whether such action will
eliminate this finding cannot be determined at this time. See Finding S/CF-

B.

S/CF-12
Inadequate training program for radiation protection technicians

4-21

i
|
|
|
i



very high, though imprecise, point estimate (SRR=7.57, 93% CT=1.03--55.72)
for workers employed at least 20 years with a 10-year lag imposed. Multiple
myeloma also exhibited a statistically significant positive exposure-response.
Due to the potential for positive bias in the early-term subcohort, caution
should be exercised in generalizing the exposure-vesponse results. These
Jindings suggest the need for collection of full employment information about
workers employed beyond 1978, as well as the estimation of occupational
exposure for Pantex workers.

In addition to the paucity of radiologic monitoring data, the acouracy of the
available radiation exposure data is called into question by the lack of quality
assurance data, and the subsequent recognition of inadequacies in the
radiation health and safety programs documented by the 1990 Tiger Team
Assessment of the Pantex Plant Amarillo, Texas, DE000634, The report is
replete with reflections of the auditors’ concerns regarding the plants’ health
and safety program adequacy.

Section E.3. 1, 2, page E-5 contains the bullet point: “Responsibilities of
M&H’s ES&H Division are not clearly identified in terms of radiation
protection. (S/CF-11)

Section B.2.6, page E-11 contains the bullet point: “Procedures have not been
written to reflect all surveillance requirements included in the Final Safety
Analysis Report. (S/CF-5)

Section B.3.2.12, page E-14 contains the bullet point: “ The controf of
radioactive sources is inadequate to prevent unnecessary exposure.
(RAD/BMEF-2)”. ,

Section B.3.2.18, page E-18 contains the bullet “ The size and qualifications
of the radiation protection staff are particularly deficient.”

A particularly troubling observation of the auditors on Page F-34 was in
relation to weapons teardown exposures in 1989 and inadequate maintenance
of employee exposure records:

“29 CFR 1910.20(d)(1)(ii): Employee exposure records were not maintained
for at least thirty days: a. Records were not maintained of dpm readings of
clothing, hair and nasal swipes of one of three employees who was exposed to
depleted uranium during a weapon teardown operation in Bay 26, Building
126 b. Records were not maintained of dpm readings taken for employees
who were involved in clean-up of Bay 26, Building 126”



SAFETY INFORMATION DOCUMENT
OCTOBER 1998

TABLE 6.1-3.GPercent of Total Doses Attributed to Neutron Radiation

Year Percent of Total Dose Attributed to Neutron Radiation
it 1988 iL
1989 Jo
1990 8
1991 1
1992 30.
1993, 29
1994 23
1 1995 28
1996 21 |
1997, 22

Sena

TABLE 6,3.1-2.00Pantex Composite Statistical Summary

Avera;

2909

As in the case of the IAAP plant in Middletown, Iowa it appears clear
that too few workers at Pantex were radiologically monitored for accurate and
valid dose reconstructions to be performed for the majority of the workforce.



ULS, Department of Health and Human Services

Special Exposure Cohort Petition
under the Energy Emplayees Occupational Centers for Diseass Control and Preventian
itiness-Gommpensation Aken wren -r———e encore mn =~ eens = ~~ Nationel Hastie for Occupational Safety and Health|

OMB Number: 0820-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Page 8 of 7

—3 @ IMWe have attached a report from a health physielst or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radlatlon exposures at the facility, as relevant to the petition. The report specifies the basis for
belleving these dacumented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical Implementation

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

F.4 0 IWWehave attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facllities Safety Board, or published In a peer-reviewed
Joumal, that identifies dosimetry and related information that are unavailable (due to either a tack
of monitoring or the destruction or loss of records) for estimating the radiation doses of

employees covered by the petition.
(Attach report to the back of the petition form.)

G ti
All Patitioners should sign and date the petition. A maximum of three persons may sign the petition.

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

fact or any other act of fraud to obtain compensation as provided under EEQICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or Imprisonment or both. | affirm that the information

provided on this form is accurate and true.

‘Send this form to: SEC Petition
Office of Compensation Analysis and Support

NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Name or Sociai Security Number of First Petitioner:



PLEASE PRESS FIRMLY PLEASE PRESS

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Performance Objective

‘The radiological protection personnel training and qualification program shauld @

develop end improve the Imowledge and skills necessary to perform assigned
job fimetions. (DOB 3480. 11) ~

Ending
The training program for radiation protection techniclans (RPT) is not fully
adequate

+ caneet
Requitements and guidance for persomee! training aod qualification are
provided in DOB 5480.5, DOBS480, 11, ANSI/ANS3 1, (8:24) ANSINI3.6,
($25), ANL-88-26, (9-26), and NORP 84, (5-21). DOB requires that all
occupational workers in DOE facilities receive, as.@ minimum, orfentation in
radiation safety. The level of taining shall be commensurate with the
employees work aisignmeit. The iraining program shall promote an
awaroness of the risks involved and a level of proficiency consistent with the
assigned task. ‘

Examples supporting the finding include:

© M&K bas uo format documented training or retraining program for its
RPIs. DOE 5480.11 requires RPT retraining every 2 years: (1-5-2)

The records documenting the technical content of training provided to
RPTs (including classroom and applied training) do vot assure that RET's
possess the knowledge of radiation safety fundamentals required by
5480.51 fpara. 9.0.(3))

Several M&E staff responsible for radiation safety are relatively new
etnployees and either lack or just cecently received security clearances.
‘This has contributed to the inability to provide professional observation,
training and guidance to the RPTs.

A review of the investigation reports on the May 17, 1989 tritium release
revealed a lack of specific tritium training for the response team and for
gencral contamination control procedures for site personnel.

"This finding has been known to the staffs at M&#, AAO, AL and HQ since
June 1985 (DOR/EH-0005). M&H has requested authotization in January
1989, to hiré one additional person to help alteviate this problem.

4722



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Emplayees Occupational Cettters for Disease Control and Pravention
Iinegs Compensation Act Naflonal Institute for Occupational Safety and Health

OMB Nutnber: 0920-0639 Expires: 05/31/2007,
Special Exposure Cohort Petition — Form B Puyo 3 of 7
D Labor Organization Information — Complete Section D ONLY if you are 4 labor organization.

D.t —_ Labor Organization Information:

Name of Organization

Position of Contact Person
D.2 Name of Petition Representative:

D.3 Address of Petition Representative:

Street Apt# P.O, Box
Cily State Zip Code
D.4 _ Tetephone Number of Petition Representative: i. -

D.5 Email Address of Petition Representative:

D.6 Period during which labor organization represented employees covered hy this petition
(please attach documentation): Start End

D.7 Identity of other labor organizations that may represent or have represented this class of
employees (If known):

Name or Social Securlly Number of First Petitioner:



under the Energy Employees Oct
riiiness Compensation Act ~~

Special Exposure Cohort Petition
supational Centers for Di

Special Exposure Cohort Petition — Form B
Survivor Information —- Complete Section B if you are a Survivor or repre

B.1 Name of Survivor:

U.S, Department of Health and Human Services

isease Control and Prevention

-w  -+ soos + NaflonaHnetiiute for Qecupational Safely and Health,
OMB Number: 0920-0638 Expires: 05/34/2007

Page 2 of 7
ng a Survivor.

MriMis/Ms. First Name Middle Initial Last Name

B.2 Social Security Number of Survivor:

B.3 Address of Survivor;

Street Apté P.O, Box
City State Zip Code

B.4 Telephone Number of Survivor: 1 }

B.5 Email Address of Survivor:

B.6 Relationship to Employee: O Spouse  Son/Daughter  & Parent

Q Grandparent  Grandchild

Employee Information — Complete Section C UNLESS you are a labor organization,
C1 Name of Employee:

Mr/Mirs/Ms. First Name Middle Initial ~ Tast Name

C2 Former Name of Employee (e.g., maiden nama/legal name change/other):

Mr/Mrs./Ms, First Name Middle Initia) Last Name

C3 Soctal Security Number of Employee:

C4 — Address of Employee (if living):

Street Apt #

P.O. Box

City State Zip Code

C5 Telephone Number of Employee: ( ) =
C.6 Email Address of Employee:

C7 Employment Information Related to Petition:

C7a Employee Number (if known):
C.7b Dates of Employment: Start End

.7¢ Employer Name:

G.7d Work Site Location; __

7a Supervisors Name: __.

Name of Social Security Number of First Petitioner:



T |

Itis unclear why certain workers were monitored and others were not and the
representative nature and accuracy of available records are questioned for
several reasons, The assumption that available records reflect worst case
scenatios or highest exposed work groups does not appear to be borne out by
worker histories, Production workers in the bays working with or around
fissile components were not uniformly monitored. As in the case of [AAP,
workers involved in bomb disassembly or repair and guards were not
routinely monitored in the early years of operation. Similarly radiation
shielding was not the norm in early years. There is concern regarding
technical limitations and accuracy of exposure assessment methodology from
the earlier years of operation including inability to directly measure neutron
exposures, The historical health and safety practices of eatly DOE facility
operations have at best been deemed insufficient by current standards for
protection of workers, The training and practices of DOE site radiologic
health and safety staff in during the Cold War era has been called in to
question at several sites and Pantex was recognized by DOE’s own health and
safety audits repeatedly as being deficient.

‘Worker histories reflect concerns regarding area exposure monitoring
based on technical failures as manifest primarily by frequent “false alarms”, In
addition we heard about several situations in which tritium leaks occurred and
believe there is uncertainty in the accuracy and completeness of radiation
exposure data regarding such events, The impression from reading the
available NIOSH documents is that one such exposure occurred whereas
workers indicated that such events Were not uncommon and reported a
practice of the medical office sending workers home with prescriptions for a
“case of beer”.

In the carly days (uppzoximately 1960 through 1990), the Pantex Plant
Safety Department wes much smaller than it is today. The plant population
for most of this time was approximately half that of what it is today with
1,500 to 1,700 employees. In addition to the difference in overall plant
workforce, there was also a different division of labor, Jobs or functions that
are now performed by radiation technicians and transportation employees
were done by the approximately 12 safety engineers and 4 safety inspectors.
The safety engineers and inspectors received fissile material from Rocky Flats
and other locations, opened the containers, performed swipes, etc., before
placing the items in storage. When the fissile material went to the line, the
items were again swiped by these same individuals. Chemical technicians
performed urinalyses and kept track of dosimeters in use at the time. These
individuals were apparently in another department. There were also 2 to 6
employees in industrial hygiene. Their exact function is not known, but is
assumed to be similar to what they do today. Atleast one of the early IH
employees is stil] employed although she was diagnosed with breast cancer
approximately 20 years ago and has had at least one recurrence of this disease.



Special Exposure Cohort Petition U.S, Department of Health and Human Services
Canters for Disgase Contrat and Prevention

under the Energy Employees Occupational .
tness Compensation Act National Institute for Ocoupatlonat Safety and Health
oes OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition —- Form B Page 5 of7
Basis for Proposing that Records anc information are Inadequate for individual Dose —
Complete Section

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

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

/We have attached either documents or statements provided by affidavit that indicate that
radiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area

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

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored.

Fi

Ba

F.2. Gi I/We have attached either documents or statements provided by affidavit that Indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding monitoring, source, source term, or process
from the site where the employees worked.

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

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have baen lost, altered Illegally, or destroyed,

Name or Social Security Number of First Petitioner:



AGS

45.5.2

« enn eet
‘A Pantex Plant safety study identified assemblies containing radioactive
matexiat that were volnerable to 2 projectile resulting from the accidental or
deliberate firing of security force amament. Considered in the study were

associated

assemblies that were & source of energy sufficient to scatter
radioactive material, Ficld tests confirmed the results of the study.

‘The study resulted in procedurgl changes for the security force and the
development and use of protective armor coverings for assemblies of concern.

@5S-34)

RADIATION PROTECTION, PERSONNEL PROTECTION, AND FIRE
PROTECTION

Overview

‘The téam concentrated [ts assessmeat on Radiation Protection. The findings refiect
a general inadequacy of the radiation protection program as evidenced by extensive
noncompliance with DOB 5480.12, Furthermore, there is little ikelitood that this
situation can be cortected anytime in the near future. ‘This situation has been
‘know to M&H; AAO and AL, for several years but Tittle has been achieved to
correct it (S-23). See Finding S/CF-1, An interim resolution of this concern
was provided by AAO actidn while the Tiger team was on-site. See Appendix N.
tn addition AL has initiated a study teant action to review this concern indepth and
report to the AL manager. ” ‘ .

‘The team performed a lunited review of fire protection. ‘The review showed that

findings from the June 1987 Technical Safety Appraisal have been closed or are
‘on schedule for their resolution. The OSHA team performed an audit on the

” NEPA 101 Life Safety Code in the fire protection area and on personnel protec

tion. ‘The OSHA findings are reported elsewhere. .

Compliance Findings (CF)

We SiCE-10
Radiation protection staff unable to fulfill misston
Perf Object
Procedures, controls and documentation should ensure worker protection from
radiation exposure. (DOE 5480.11)
A-1e

i
i
t



/~

99.
06m iy 50 .
70 Rey.

September 6, 2006
By Cerlified Priorty Mall

Letter of transrnission

SEC Patition

Office of Compensation Analysis and Support
NIOSH

4676 Columbia Parkway

MS-C-47
Cincinnall, OH 45226

This letter fransmits an SEC petifion to which” ~

An additional persona’ commentary transmifs information not in or not ly
referenced in the pubilshed fiterature, including information gathered byjine
Ate Chiaf, Field Services, NAPCA, USPHS In the late 60's. While engaged in
c@rritpollution contra) program probe In the southwest ' (“42-5 Amarillo at the
request of area unions, The leadership of these unions, based on urgent requests
from local members, Wished to activate the Amarillo meirapoiltan statistical area
as Gn air quality conitol ragion. the area was small relative to other candidates in
the state, but it was ailso afficfed with significant point sources of pariculates
and sulfur oxides. From the perspective of the unions, while it was an educational
and cathartic service, the visits, with elem angst of whom were,
employees or wives of employees of Pantex, were not inuifful, Pertinent fo the
issue ot hand, the visiis resulied In ihe transmission of critical information to our
sister agency, then transforming to NIOSH. The primary concems were not those
ossociated with the ambient environment, buf with the work environment.

The particulates of greatest concem were asbestos and metals, especially
beryllium. The agent of greatest concem, however, was ionizing radiation. High
levels of anxiety were generated by a lack of environmerital (area and personal]
and medica) monitoring and the absence of personel exposure records.
Management and governmental assurances of no-effect exposures were
companions to stack controls and minimal safe-practice training. Liaison with the
local medical community and integration of the environmental factor into
nealthcare and wellness programs cid not exis, Ever if o-femilentset-'-- was

— : ver: The
etn ~ ant. April



From the tables below one can see that the majority of the Pantex was not monitored for radiation exposure,

TABLE 6.1-1.CHistary of External Radiation Exposures at Pantex Plant

Total Maximum Numi Namber Percent of Average
Population Individual Monitored | with Zero Plant Population
Dose (Person- Dose (Rem) Dose with Zero Dose (Rem)

Rem) Dose



Spectat Exposure Cohort Petition U.S, Department of Health and Human Services
under the Energy Employees Occupational Centers for Disoase Control and Prevention
Nationa} Institute for Occupational Safety and Health

iness Compensation Act
OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Page 7 of7

Public Burden Statement

Publle reporting burden for this collection of information is estimated to average 300 minutes per response,
Including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions ate to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently

valid OMB number,
Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 5524), you are hereby notified of the
following:

The Energy Employees Occupational Illness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of emplayees to be included in the
Special Exposure Cohort (SEC), EEOICPA authorizes HHS to Implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for Including additional

classes of employees In the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 "Occupational Health Epidemiological Studies and EEOICPA Pragram Records,
HHS/CDC/NIOSH,” These records are treated in 8 confidential manner, unless otherwise compolied by law.
Disclosures that NIOSH may need to make for the processing of your patition or other purposes are listed

below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
fetrieve records required by NIOSH; (b) identifled witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limlted circumstances to conduct further Investigations;
(e) Federal, state and local agencies for law enforcement purposes; and (f} a Member of Congress or a
Congressional staff member In response to a verified inquiry.

This notice applies fo ell forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these
forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to

provide required information may nat be considered by HHS.

Name or Social Security Number of First Petitioner:



Safety Department bes actually decreased. Currently Mé&cH has three RPTs
on its roles and has requasted authorization to hire 20 more in its draft DOB
$480.11 implementation plan A total of 23 RTs Js consistent with recora-
mendations of the plutonium and urastum taanuals of good practices. ($20
and $21) Hoth manwals xecommend ons RPT for each 20 radiation workers
‘as well a$ one or more professional health physicists. These recommended
ratios do not include administrative or supervisory staff. Even if M&d is
successful in recruiting new staff, secucity and training xequirements make
meaningful relief in the near foture unlikely. (1-8-23 through 1-S-26)

Associated with this finding is a best management practios thar wauld provide
a "pre-employment" ot “new emplayes” base liste for radiological exposure
due to site activities. Some DOB sites require whole body counts and bio-
assays of now employees with possible duties involving direct or socideatal
radiation exposuas. ‘This baseline data also assures the contractor that be has
not employed an individval with excessive exposure dae to past activities or
conditions. A whole body counter hioused in 2 low background counting zoom
yas requested by M&H in théir implementation plan to DOE order 5480.11,
January 26, 1989,

ana



RB s(cel3

Inability to comply with DOE radiation protection Order requirements for
occupational workers in the future

P object
,
Implementation of DOB 5480.11 by January 1, 1990

Binding
Ttis nalikely that the Pantex Plant will be able to achieve full compliance with
DOR Order 5480.11 by January 1, 1990, or anytime soon thereafter. ~

Discussion

DOB Order $480.11, Radiation, Protection for Ocoupational Workers, was
effective as of December 21, 1988, with full compilance mandated by January
1, 1990. In accordance with formal DOB/HQ guidance, M&H developed an
implementation plan that addressed the technical approach, cost and schedule
for achieving compliance at the Pantex Plant. The implementation plan
identified technical and administrative approaches for achloving compliance
that would be significantly different from cursent practices and would pose
significant impacts on cost, schedule, manpower, and production. AL
submitted the initial implementation plan to DOE/AQ on Marob 9, 1989.

Reasons why timely implementation of the order is unlikely:

"The draft implementation plan M&H submitted on March 3, 1989 contains
requests for 33 to 35 full time equivalent, personnel and $22 to $25 million
capital funds. A farther requeston May 24, 1989, detailing six exemption
requests plus further details on equipment costs was submitted. Some
exemption requests asked for extension to five years past January 1, 1990.
To dato, neither AL or HQ has provided formal comments to AAO and
MH regarding the adequacy end appropriateness of their implementa-
tion plan.
,

0 ‘The competition for qualified new staff, particularly those with security
clearances, is intense and getting even more severe.

Bven though the order wasnot released until December 1988, the requirements
jdentified in this finding would have been known to most respoasible and
‘conscientious health physicians and their managess within the. DOB community
by at least early 1988. Since then, the net staffing in the Mé&H Radiation

9

4-23

(
‘

t
x
i



[Spocial Exposure Cohort Petition
‘under the Energy Employees Occupational

Hnese-Compensation Act ~~

S|

pecia’

Name of DOE or AWE Facility:

1 Exposure Cohort Petition — Form B

Us. Department of Health and Human Services
Centers for Disease Control and Prevention
+--+. —-National Inetitute for- Occupational Safety-and Health

OMB Number: 0820-0639 Expires: 05/31/2007
Page 4 of7

E.2 Locations at the Facility relevanth

E.3 List job fitles and/or Job duties of employees Included In the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be

lndact in thig-cl

E Y ain wr 7

Ed¢

Start

End

recorded exposure Incidents?:

as necessary):

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

C Yes

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

Q No

Name or Social Securlly Number of First Petitioner:



Baclosed immediately below is the abstract of a 1990 National
Institute for Occupational Safety and Health, NIOSH, study entitled:
MORTALITY UPDATE FOR THE PANTEX WEAPONS FACILITY:
FINAL REPORT HEALTH-RELATED ENERGY RESEARCH BRANCH,
Publication No. 2005-124. This study measured increased Standardized
Mortality Ratios among Pantex workers for breast cancer, prostate caticer,
multiple myeloma and leukemia, somewhat weighted towards earlier periods
of eraployment at the plant.

ABSTRACT
In 1985, Acquavella, et al. [1985] reported the results of a cohort mortality
study of white male workers ever employed at the Pantex Plant between 1951
and the end of study date,
December 31, 1978. Compared to U.S. death rates, the mortality experience
of these workers suggested a strong healthy worker effect overall, but non-
significant elevations were observed for leukemia and brain cancer. For the
current analyses, the National Institute for Occupational Safety and Health
(NIOSH) expanded the study population to include workers of both genders
and all races ever etnployed between 1951 and 1978 and extended vital status
follow-up through 1995, Summary Standardized Mortality Ratios (SMBs)
were generated for these workers (the full NIOSH cohort). Workers
terminating or deceased by December 31, I. 978, for whom complete
employment records were available (the early-term subcohort), were included
in SMR and Standardized Rate
Ratio (SRR) duration of employment analyses. The all-cause SMR for the
early-term subcohort (0,98, 95% confidence interval (CI) = 0.92+1.05) was
higher than that seen in the full NIOSH cohort (SMR=0.81, 95% C1=0.76-
0,86) and by Acquavella et al, 11985] (SMR=0.72, 95% CI=0.64-0.81) and
was close to that expected from U.S. population rates. Brain cancer was no
longer elevated in the full NIOSH cohort (SMR=0.51, 95% CI=0,17-1.19) in
the updated analysis, although the confidence intervals span unity. The
leukemia SMR was elevated (earlyterm subcohort SMR=1.47, 95% CI =
0.73-2.63) but SRR» showed no evidence of a positive exposure-response
relation with increasing duration of employment. Lung cancer SMRs with 10-
and 15-year lags were just below expectation, Breas! cancer was elevated
only in workers with employment durations of 5 to 10 years, The SMR for
prostate cancer was as expected, but this outcome showed a statistically
significant positive exposure-response [slope: 1,36-10-5 per person-year
(PY) year of employment (YOR), standard error: 4.31-10-6 per PY- YOR], with
a





Special Exposure Gohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Hiness Compensation Act Natlonal Institute for Occupational Safety and Health
{ OMB Number: 0920-0839 Expires: 05/31/2007
| Spectal Exposure Cohort Petition — Form B Page 6 of 7

F3 [AWVehave attached a report from a health physicist or other individual with expertise In
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose raconstructions for
membere of the class under 42 CFR Part 82 and related NIOSH technical implementation

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

£4 © WWehave attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (due to either a lack
‘of monitoring or the destruction or loss of records) for estimating the radiation doses of

employees covered by the peiition.
(Attach report to the back of the petition form.)

G Signature of Person(s) Submitting this Petition — Complete Section G.

Alt Petitioners shayld sign apa date the petition. A maximum of three persons may sign the petition.
a _ f/f bfo
Sigfatire 4 4 Y 7). 7 Date
‘ po ene G-AL-Po
Sigifeyure 4 yp arom ace 7 ae Date
: ___. 823706
Signature
Notice: Any peau wiv nicwHgly Makes any Talse statement, misrepresentation, concealment of

fact or any ather act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person Is not entitled Is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under apprapriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true,

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH

4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

pdeusey 199 RCva

Name or Soclal Security Number of First Petitioner: - __-



Cracked Pit, 12-98, Cell 1 (ORPS 1992-68)

On November 12, 1992, during dismantlement of a W-48 unit in Building 12-98, Cell
I (a specially designed weapon disassembly structure), the outer nonradioactive layer
of the plutonium containing component (pit) cracked. The cracking occurred while
the component was being thermally treated to remove the HE, There were no
immediate nuclear explosives safety concerns. The Supervisor and Production
Technicians working in the cell immediately exited the cell and notified the Pantex
Operations Center and Radiation Safety Department that the component had cracked.

- Radiation Safety personnel responded and, dressed in anticontamination clothing and

respirators, entered the cell, Two radiation swipe samples were taken on the pit, with
one smear taken directly over the crack. The results were 9,000 dpm for the smear
taken on a location away from the crack and 57,000 dpm for the one taken directly
over the crack. The component was then triple bagged and placed in a temporary
container to prevent possible spread of plutonium. The filter from the cell's
Continuous Air Monitor was removed and analyzed. The cell was surveyed for
plutonium contamination, Only a tray that the pit had been placed on earlier was
found to be contaminated, Nasal smear samples taken from the workers who
evacuated were not

contaminated. ‘The cracked component was radiographed using a cobalt-60 source.
‘The radiograph confirmed that the crack was restricted to only the outer,
nonradiological matetial. Procedures were developed by key personnel from LLNT.
and Pantex, and the final pieces of HB removed from the component. The pit was
packaged for shipment to LLNL on January 15, 1993. LLNL evaluated the crack and
determined that there was a defective weld in the waist area, The occurrence was
determined to be "not avoidable," All necessary remedial actions were performed in a
manner that ¢liminated tho risk of the spread of plutonium contamination and any
degradation of safety, No nuclear explosive safety concerns existed.



we

TABLE 6.1-2.GHistory of Internal Radiation Exposures at Pantex Platt (Continued)

oe —
Year Total Populxtion Maximum Nuniber Average ]
Cranium Dose Individual Monitored. Population
‘Uranium Dose for rani Dese
(pevson-anrem) (easeun) (rem)
1991 109.0" 109.0, en og
1992 TBO (502.0 239 3.3
1998 76.0 15.0 13 38
1994 00 0.0 @ 08
1995 0.0 00 39 00
1995 00 0.0 6 0.0
1997 oo, 2 09 |
Year Total Population Mid Nusuber Average
Plutonium Base Individual Mouitored Population
Plutonian Dose for Plutonium Dose
(person-maretn) (suremn) uve)
1991 00 0.0 6 DO
1992 0.0 0.0 12 2.0
1993, 0.0 0.0 0 0.0
1994 0.0 00 0 0.0
1995 0.0 0.0 28 00
1996 0.0 0.0 17 00
1997 0.0 0.0 18 0.0
Year Total Population ‘Maxhmun Number Average
Thotiun Dose Individual Monttored Population
‘Thorium Dose for Thorium, Dose
(person-mrem) (ure) (nrem)
199) 0.0 oo i] 0.0
1992 00 00 17 39
1993 0.0 00 @ 00
1994 a0 0.0 9 0.0
1995 0.0 0.0 67 0.0
1996 0.0 0.0 56 0.0
1997 2.0 00 B 0

6-7



noted an outbreak in the aerospace indusiry, but there was no follow up! The

cancers were a sentinel disease, not in the conventional medical sense, but gs a
fe) ion. The Colorado cases surfaced through a vigilant couniy

health officer, not through any program of an employer or the federal or state

governments. The Prati-Whiiney study was initiated by the inadvertent meeting

of two intelligent widows in a grocery store. To this day, despite recognilion of

ihe value of broader, more intense and complete research, Not a single serious

s been conducted in any DOE facility community,

While the jack of definitive records has been recognized, leading to problems of
quantification of risk, there has been a persisting failure fo recagnize the value of
clear qualitative assessment, Multiple material and efficient causes of cancer
and other diseases, agents for which there are no demonstrable thresholds of
elecis, indisputably, have been present. Expected effecis have been clinically
manifested, albeit not quantitatively linked, as reporied by individual workers
and by ongoing NCI research and DOE medical surveillance programs for the
Pantex population. it is reasonable to believe that the ‘false negatives’ implicit in
even the most tigorous epidemiology exist, and that the occupational factor
exists in the calculus of etiologic factors in many cancers in the Pantex

population.

Given the necessity that effects have causes, the moral imperative here is, at the
very least, the granting of this petition.

Respectiully submitted, . ee



Huding
AL, AAQ and M&H are not folly complying with DOB $480,13. The size
and practices of the radiation protection. staff are particularly deficient.

Diswssi
‘The sesnlts of many surveys are Without dooumentaifon, Ieis the practice
for many production surveys to be conducted by staff other than tralned
Radlation Protection Tecknioiats (RPT) of the Radiation Safety Depart
ment, (S-22)

Of those radiation suxveys taken by RPT, the data are not trended far the
purpose of identifying potential problems.

There is currently only one professional health physlofst assigned to
assembly, disassembly and fabrication operations. He both oversees
operations personel snd supervises zadiological protection technicians in.
these areas,

°

0 Only three RPT’ are fonctionally essigned to production operations and
axe respoasible for enguring the radiation protection program for about
400 to 500 radiation workers. (8-20 antl $-21)

‘There 4s no wetten approval of new and revised operating. procedures by
slat? of tid Radiation Safety Department, including those procedures
Involving zadiation safety issves per MC 706 Decontamination 8-28, 28-
9012, Issue Q. (8-29)

© Prlor to Juné 1989, no protective clothing was required for the B-28
program disassembly operations Swipes were made of weapons to
assure they were contamination free, but 10 records exist regarding
possible contamination of the workers. (18-16 throngs 1-5-20)

0 AAO prepared and subunitied an action plan with six draft exemptions that
‘stated that Pantex could not achieve compliance with the order in calender
year 1989. From January to Tune 1989, throe draft plans and five formal
menos were prepared identifying problems with the implementation of
the order.

W OS/ICELS

Radiation protection audits lack sufficlent independence and rigor

4-20 e



Curious about workplace exposures, plant management seldom transmitted
information of value to the examining provider. Thus personal medicat records

are incomplete,

Reference was made to subconiractor, temporary, probationary and short-term
employees who when exposed to high levels of radiation were, in the words of
one participant, “flushed”. To this day, they are not fully represented in the
records or in any study of this and sister populations. In any one cell of high
exposure, there typically had been at least one permanent employee.

It is important to keep in mind that in the early days of nuclear weapons
production, fabrication at Pantex was conducted under wartime conditions that
have been moderated, but not eliminated, over jime. To some extent, this
explains cavalier work procedures, personnel policies insensitive to levels or
duration of exposure, and unacceptable materials handling uniformly found.
Complaint was and is perceived as unpatriotic, and largely unvoiced for a
myriad of reasons. It is also true that the improvements for many have been foo
late, and tog little for many exposed fo radiation, beryllium and other agenis still
to be adequately studied.

About fwo decades later, at a meeting on occupational healih in Amarillo of
councils of nuclear workers from throughout the DOE system convened by the
President of Metal Trades Department, AFL-CIO, including a vocal delegation
from Pantex, the essential perceptions of the workers had significantly changed.
The latency periods had run their course; cases of disease reasonably
Gtiributable to the work environment had appeared among them. Higher fevels
of anxiety and anger had overcome the natural reticence of the patriot -worker
to complain, peer pressures had changed, and the stoic hesitancy to express
Personal pain endemically characteristic of their culture was piérced.
Information on conditions and standard practices of the past and present
became more specific, and exprassad more strongly in the discussion of specific
cases of disease reasonably attributed to their work that appeared among
them. Our worst fears were realized. My notes are clear: there wos high concem
over the absence of adequate personal medical and exposure records, The
DOE workers compensation legislation originated in that meeting.

Sharing this significant chain of human events, the current comprehensive study
by Marsh and Esmen of brain cancers among Pratt-Whitney workers, with many
exposures similar to those found in the DOE system, began with a report by CJ
Johnson, a county health officer in Colorado. Dr. Johnson reported from county
records 12 cases {mostly gliobiastomas] in a population of 3985 Rocky Flats
plutonium workers, at the 1980 annual meeling of fhe Ametican Public Health
Association. in response 16 that and other outbreaks, the Director of NIOSH,

i ing? The urgency was justified, but no substantive
remedial action resulted, John Peters’ paper at the conference, for example,

2 Johnson CJ. Letter to the Editor, AmJEp 127,6:1321-1322 1988,
3 See I Selikoff and EC Hammoud, eds. Brain Tumors in the Chemical Industry’, Annals NYAS 1982,





SAFETY INFORMATION DOCUMENT

OCTOBER 1998

pe ERI
Total

Population
Dose (Person-

Maximwa
Individual
Dose (Rem)

Number
Monitored

Percent of
Plant
with Zero
Dose

1971 LOL 419. 3.560 495 201 al 0.205, 4
1972 70.843 2,950 AGT 179 38 0.152
1973 86.349.

. 1974, 23,606

Total Maximum Number Number Percent of Average
Population Individual Monitored with Zero Plant with Population
Dose Dose Dose Zero Dose Dose

(rem)
61.887, 10.8007 493 49 10
45,765 1.050 463, 33.
58,080 1.630 465, 21 5

6-4



SAFBTY INFORMATION DOCUMENT

OCTOBER 1998

TABLE 6.1-2.CHistory of Internal Radiation Exposures at Pantex Plant

— _— pec erent re A
Year Total Population Trittiam | Maximum Individual Number Average Population
Bose Tritium Dose Monttored Dose
for Tritinm
er'sol-101'C) ar an | (it POE)
1972. 32.0 12.0 4 8.0
1973 9.0 0.0 i 0.0
1974 0.9 0.0 0) 0.0
1975, 0.0. 0.0 Q 0.0
1976 0.0. 0.0 483 0.0
1977. 0.0 9.0 466, 0.0
1978 0.0 0.0 519 0.0
1979 0.0 0.0 712 0.0
1980 612.0 114.0 4 43.8
1981 $82.0 322.0 41 14.2
1982 101.0 37.0 3 20.2
1983 2.0 0.0 () 0.0
1984 2.0 0.0 () 0.0
1985 10 3.0 17 0.6
1986 58,0 6.0 626. 1
1987 8.0 2.0 481 0,02,
1988 6.0 3.0 499 0.01
1989 1811.0 1180.9 212, 8.5
1990 5.0 3.0 2341 9.002
1991 18.0 3.0 Ais 0.02
1992 48.0 5.0 879 0.05
1993 183.0 14.0 1078, 02
1994 115.0 11.0 1108 0.1
Zz 1995 101.0 12.0 971 0.10
1996 16.0 7.0 940 0.017
ee 12 3 gue

6-6