Print Page 2 of 2

information in the site profile, although it is possible that | may have overlooked it.

| respectfully request that you review the above mentioned document, If your conclusions agree with mine, | ask
that you seek the most exeditious route to add the workers in Rocky Flats Building 460 as a member of the
Special Exposure Cohort.

Respectfully,

8/17/2011



RAWMIATIOIN WIUINEDORIING KEPORT soe,

OF DATE ae
TIME OF
POSSIBLE INHALATION occur 222 ¢

INCIDENT. 4 ACCIDENT __

DISTRIBUTION

i i
i HP
LEFT LEFT SALRIGHT [NAME EM PLOY.NO. Bild. Sur
i Director
1 ‘Sent to medical at brs. for: tenmed. Super. arc eso
' Decontamination.._____Bady Count Wound Ind. Safety
- i Description of wuund: Other
W Abrasion_______Puncture _ Laceration___
rid
Ne Burn. —
tn Contamination Levels
whe — ee
{
sy

\ vd pGetite Sort , we Palm \ Back__
Luts Zhs |

RADIATION MONITORING FINDINGS:

REPORTED B

itor

7
LOCATION: Room No.______ Glove Box No.______ Other nee oie ke Bhel YY,

DESCRIPTION OF FINDINGS: Contamipation levels and extent or condition and cause. .
Erte fine hgh a= Loe = BL3Y- £5295 Lund to be Smiaris
andl Aree D L000 Low. a

NUMBER OF P.],___ SAM ALARM Location®.

= z Radiation Monitoring Supervisor Signature
THIS FORM TO BE FILLED OUT AND RETURNED WITHIN 24 HRS., ADDITIONAL INFORMATION MAY BE REQUIRED PER HSE 3.0

IMMEDIATE SUPERVISOR'S FINDINGS: REPORTED BY.

. Re ee ae a eae nd mae
-* "BERSONINEL INCLUDED AT TIME OF INCIDENT (Name & Employee Number)

ee ee

REPORT OF INVESTIGATION a __
a37
CORRECTIVE ACTION.
Sse Pye BA ee
4+ gRocenune VIOLATION = PROCEDURE NEEDS REVIEWED ____

ST OF ACCIDENT OR INCIDENT
(Rev. 2-78)



1980 Incinerator Fire:
Building 771

¢ Note high temperature
HEPA filters

oe i |
|
| Slide TS REP-5378



worker model for claimants who worked in Building 440 may result in the underestimation of radiation
dose to the claimants who worked in that building during that time period.

NIOSH Site Profile does not consider high exposures at the stacker retriever -The attached email dated
8/1/06, states that a person who emptied the americium birdcages in the Stack-Retriever would have
been exposed to radiation levels as much as “couple of hundred” millirrem per hour. If a “couple of
hundred” millirem means 200 millirems, this translates to 2 rems/hour. | was responsible to repair the
Stacker-Retriever every time it jammed up. Criticality engineers had to come over to make sure that the
materials were not too close to going critical before | could start the re-hanging of the bird cages. Yet, it
appears that NIOSH did not consider this relevant information in my dose reconstruction. Therefore, it
is quite likely that NIOSH is not considering this value for other Rocky Flats personnel who worked on or
near the stacker retriever.

The highest number of zero readings occurred during the D & D period — As noted in SC& A’s report, the
year with the highest level of zero readings was 2004 which had 79.7% of badges reporting zero
readings.

In conclusion, the claimants from the Rocky Flats site should be added as a member of the Special
Exposure Cohort without delay.

Signature sheet for the petitioners can be found on the following page.


Sundin, David $, (COCINIOSH/OD) —

l
From: Tuesday, August 01, 2006 2:55PM
Sent: 1

=
oe: ———
Ge: 7 Tre
Subject: : Stacke

Brant,

| finally got to look at your write up. —_
“ cate ie bi . right up
of “materials in birdcages”, dose rates
1 to add that during loading and unioading f en icky asa
So Pee a denger coud have been as high as a couple of hundred mi/hr. This dose rate drops off very q
relationship to where personnel are present.
i i ften
Only conceivable way he could have measured a 8R/hr field, is a very large Americium can. Did not happen very ofter

And to add if you are standing working in a 8R/hr field you are not a very good RCT!!!

Talk with you today soon.

Mel

From: Ulsh, Brant A. (CDC/NIOSH/OD)
Sent: Friday, July 28, 2006 10:59 AM
To: Mel Chew

Subject: Stacker/retriever

Mel:

Thanks for the info on the stacker/retriever. | have taken a whack al a rough draft response to this matrix item, but | would
welcome your review/comments. MS Word's “Wack changes’ feature would be especially convenient, but (tt take
comments in whatever format you can provide. Feel free to share this with Bob Morris if you think that might be helpful.
Thanks,

Brant

<<Matrix tem 20 part 1.doc>>



1980 Incinerator Fire:
Building 771

' © Inside of glovebox
with melted ceiling

window/light



‘manually using existing glove ports

OST funded
modifications to
the Alpha 12-1A
detector so that

it could detect
higher limits of
activity needed to
characterize SCO
waste, The 12-1A
air-proportional
ion chamber could
previously detect
just 2M DPM.
With the addition
of an attenuator
screen to the front
of the chamber, its limit of detection was increased to 200M
DPM. Also, with OST support, the Ludlum 195 high-range alpha
chamber, which can detect up to 1B DPM, was deployed. The
Ludlum 195 can be performance tested in the field, an important
advantage over the 12-1A since survey equipment frequently
becomes too contaminated for release from a contamination area.

— __ ait

The use of chemical to decontaminate gloveboxes is performed

The Technology

The first successful decontamination process was developed
by Environmental Alternatives, Inc. This process used a
complex blend of acids and other chemicals which are applied
to equipment’s surfaces in a three-step process. This extraction
solution used micro-emulsification and chemical ion exchange
to bind itself to contaminants. After a 24-hour waiting period,
surfaces were surveyed to determine if SCO criteria were
achieved.

Another method funded and developed with OST support used
Cerium Nitrate (CN) to decontaminate surfaces. During the site’s
production era, CN was used in Building 771 as a plutonium
recovery surrogate in process experiments. For decontamination,
CN was first injected with steam into tanks and other equipment.
Later methods simply applied diluted solutions of CN to interior
surfaces, which were then wiped and rinsed with a neutralizer.
Following a 20-30 minute waiting period, surfaces were surveyed
to determine if SCO criteria were met.

Case Study: Size-reduction vs.
chemical decontamination

This section will compare packaging of two B77! gloveboxes
of similar size. One was decontaminated and packaged as

Technology Supporting the Path to Closure

cky Flats, contact David Maloney, H

For more information about Technology at

Kaiser-Hill Company, (303) 966-7566, or Gary Huffman, DOE, Rocky Flats Field Office,
(303) 966-7490

ne
jectinology

SCO. The other one, too highly contaminated to achieve SCO.
criteria and too large to be re-located to a central size-reduction
enclosure, was size-reduced in-place after a containment tent was
constructed.

*Line 15 was 14-feet long about 6-feet high and had about 300
square feet of surface area. Line 15 used hydrogen peroxide
to convert plutonium nitrate solution into plutonium peroxide
cake, A highly volatile process, precipitation created the solid
for further processing into metal. After all internal equipment
was removed, Line 15 was decontaminated in just over a day
and packaged whole in a single cargo container.

+Line SR12 employed a process for converting plutonium
oxide into plutonium tetrafluoride using fluorine gas. An 11-
foot section of the 25-foot glovebox was decontaminated to
SCO and packaged in a cargo container. The interior surfaces
of the remaining 14 feet were too highly contaminated to
achieve SCO criteria. At over 10-feet high, the remaining
sections encompassed about 430-square feet of surface area.
To construct the tent and conduct size-reduction operations
required 25 working days and more than 1,500 hours. Nine
SWBs were required to correctly package SR12’s glovebox
surfaces.

Although SR12 was slightly larger in this comparison, the
advantages of decontamination are evident. Had all 240
gloveboxes in B771 undergone size-reduction, the project would
not be ahead of schedule for demolition and would probably be
behind schedule.

Summary

Due to the success of chemical decontamination technology, the
Rocky Flats Closure Project life-cycle estimates for TRU waste
were reduced by nearly 30 percent ~ from an estimated 17,500
cubic meters to 12,500 cubic meters.

The most significant benefit of chemical decontamination has
been thousands of hours of avoided worker exposure to high
airborne radioactivity, exertion and several industrial hazards that
result from size-reduction evolutions.

After the decontamination process a glovebox is weighted,
packaged and loaded into w curgo container,

|



Boeing: History -- Products - Rockwell International B-1 Bomber Page 1 of 2

ry

Qaoene

The B-1 Lancer is a swing-wing bomber intended for high-
speed, low-altitude penetration missions. By the end of
1977, three Rockwell International B-1 As had made 118
flights with more than 21 hours at supersonic speeds. The
next version was the B-1B. It first flew Oct. 18, 1984, could
operate at 60,000 feet and had a range of more than 7,000
miles. The U.S. Air Force ordered 100 B-1Bs in 1982 and
the first B-1B aircraft was delivered to the Air Force at
Edwards Air Force Base, Calif., in October 1984, just 33
months after contract go-ahead.

Initial delivery to the Strategic Air Command took place in June 1985, at Dyess AFB, Texas. On
Oct. 1, 1986, the B-1B achieved Initial Operational Capability and by November 1986, B-1Bs were
coming off the production line at a rate of four per month. B-1Bs were based at Dyess AFB, Texas;
Ellsworth AFB, South Dakota; McConnell AFB, Kansas; Robins AFB, Georgia; and Mountain
Home AFB, Idaho. In 2001, the U.S. Air Force decided to retire 33 B-1Bs and remove the aircraft
from Mountain Home and the Georgia and Kansas Air National Guard bases. This has now been
accomplished and the remaining aircraft were consolidated at Dyess AFB and Ellsworth AFB.

The B-1B holds 61 world records for speed, payload and distance. The National Aeronautic
Association recognized the B-1B for completing one of the 10 most memorable record flights for
1994.

The first combat use of the B-1B was in December 1998 during operation Desert Fox, where the
aircraft penetrated Iraqi air defenses to destroy Republican Guard barracks. This debut mission
validated the B-1B's conventional role and its ability to operate in a force package. In 1999 six B-
1Bs were deployed to Royal Air Force Base Fairford, England, to support Operation Allied Force in
Kosovo. Those six aircraft dropped more than 20 percent of the total tonnage in the conflict. In
operation Enduring Freedom, B-1Bs dropped 40 percent of the weapons and 70 percent of the

precision-guided JDAM weapons.

B-1B Home page

Specifications

First flight: Dec. 23, 1974
Span: 137 feet (extended), 79 feet (swept aft)
Length: 146 feet

http://www. boeing.com/history/bna/b1b.htm 8/17/2011



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

under the Energy Employees Occupational Centers for Disease Control and Prevention
llinees Compensation Act National Institute for Occupational Safety and Health

. OMB Number: 0920-0639 Expires: 09/20/2013
Petitioner Authorization Form Page 1 of 2

Use of this form and disclosure of Social Security Number are voluntary. Failure to use this form or disclose
this number will not result in the denial of any right, benefit, or privilege to which you may be entitled.

Instructions:

|f you wish to petition HHS to consider adding a class of employees to the Special Exposure Cohort and you
are NOT either a member of that class, a survivor of a member of that class, or a fabor organization
representing or having represented members of that class, then 42 CFR Part 83, Section 83.7(c) requires
that you obtain written authorization. You can obtain such authorization from either an employee who is a _
member of the class or a survivor of such an employee. You may use this form to obtain such authorization
and submit the completed form to NIOSH with the related petition. Please print legibly.

For Further Information: If you have questions about these instructions, please call the following NIOSH
toll-free phone number and request to speak to someone in the Division of Compensation Anatysis and
[Support about an SEC petition: 1-877-222-8570.

Authorization for individual or Entity to Petition HHS on Behalf of a Class of Employees for
Addition to the Special Exposure Cohort

Name of Class Member or Survivor

Street A Clananhs. ‘ Apt. # P.O. Box

City,

Apt. # P.O. Box

to petition the Department of Health and Human Services on behalf of a class of employees
t

Ni " urvivor)
for the addition of the class to the Special Exposure Cohort, under the Energy Employee's
Occupationai Iliness Compensation Program Act (42 U.S.C. §§ 7384-7385).

Petitioner named above will have all the rights

August 12th 2011
Date

Name or Social Security Number of First Petitioner:


SIGNATURE OF PERSONS SUBMITTING THIS PETITION

| affirm that the information provided in the petition is accurate and true.

l affirm that the information provided in the petition is accurate and true.


Print Page 1 of 2

Print - Close Window

Subject:RE: Rocky Flats Building 460

From: Rutherford, LaVon B. (CDC/NIOSH/OD
Po

To:
Ce: | low0@CDC.GOV;

bo
Date: Wed, 09 Dec 2009 05:24:42

Thanks for the e-mail and the documents. We will take a look at the information and get back to you. | can't give
you a good time line on when, but it should be in the next week or so. If you don't hear from me before that feel
free to send me e-mail reminder.

LaVon Rutherford
SEC Health Physics Team Leader

From
Sent: Tuesday, December 08, 2009 10:07 PM

To: Rutherford, LaVon B. (CDC/NIOSH/OD)

Ce: Denise Brock; Mark A. Griffon; Paul Ziemer; Wade, Lewis (CDC/NIOSH/OD) (CTR); Phillip Schofield
Subject: Rocky Flats Building 460

Hello Mr. Rutherford,

Denise Brock, after consulting with you, suggested that | send the attached documents regarding the presence of
uranium and plutonium in building 460 at the Rocky Flats facility. Historically, this building was designated a
"cold" building, both by the workers and by NIOSH and SC & A.

Some months ago, | was provided with a copy of DOL's Site Exposure Matrix (SEM) for these two elements. The
attached copies of the SEM shows that these elements were present in building 460. | thought, for sure, that this
information on the SEM was inaccurate. However, Greg Lewis of the DOE was kind enough to contact DOL and

request the source document DOL used to determine that these elements were present in 460:

“Rocky Flats Plant Sitewide Process Descriptions, Material Mass Balances, and Operational Emissions

Support Document".

A copy of this document was reviewed by Larry Elliott and hopefully is still in your possession. Mr. Elliott reported
back that no processing of plutonium or uranium was perfomed in building 460. That is correct, and is something
that is common knowledge.

However, it appears that these elements were present in that building via storage of waste machine oils. | have
attached two pages of the document for your review. You will note that the attachment titled "DOE doc 460 lube
oil storage” clearly states that used oil was stored in that building. And, the second attachment, "DOE doc 460"
shows that machine oils from Building 444 (uranium building) and 707 (neutron building) are among the buildings
which produced the waste machine oils.

lL understand from a couple of former Rocky Flats workers (who wish to remain anonymous fat this time) that the
55 gallon drums leaked occasionally. | also understand that air monitoring may have been performed in the
storage area in building 460.

Since this was a "cold" area, it is unlikely that the workers were monitored for radiation exposure.

worked in building 460 from 1985, or so, until 1989. He has no internal or external dosimetry records for those
years. . | also understand that x-rays were used for non-destructive testing in building 460. | have not found this

http://us.mg5.mail.yahoo.com/neo/launch?.rand=1 djhesd6eogd5 8/17/2011


Rockwell B-1 Lancer - Wikipedia, the free encyclopedia Page 1 of 11

Rockwell B-1 Lancer
From Wikipedia, the free Z
(Redirected from B-1 Lancer)

‘The Rockwell (now part of Boeing) B-1 LaacerTM) is a four-engine variable-sweep wing strategic bomber used by the B-I Lancer
United States Air Force (USAF). First envisioned in the 1960s as a supersonic bomber with sufficient range and payload to
Teplace the Boeing B-52 Stratofortress, it developed primarily into a low-level penetrator with long range and supersonic
speed capability at high altitude.

‘Designed by Rockwell Intemational, the bomber’s development was delayed multiple times over its history, as the theory
of strategic balance changed from flexible response to mutually assured destruction and back again. The initial B-1A.
version was developed in the easly 1970s, but its production was canceled, and only four prototypes were built. In 1980,
the B-1 resurfaced as the B-IB version with the focus on low-level penetration bombing. It entered service in 1986 with
the USAF Strategic Air Command as a nuclear bomber.

In the 1990s, the B-IB was converted to conventional bombing use. It first served in combat during Operation Desert Fox
in 1998 and again during the NATO action in Kosovo the following year. The B-1B continues to support U.S. and NATO.
military forces in Afghanistan and Iraq. The Lancer is the supersonic component of the USAF's long-range bomber force, ‘AB-IB flying over the Pacific Ocean.
along with the subsonic B-52 and Northrop Grumman B-2 Spirit. The bomber is commonly called the "Bone" (originally Role Supersonic Strategic bomber
from "B-One"). With the retirement of the General Dynamics/Grumman EF-111A Raven in 1998 and the Grumman F-14 eens
‘Tomeat in 2006, the B-1B is the U.S. military's only active variable-sweep wing aircraft. The B-1B is expected to continue National origin United States

to serve into the 2020s, when itis to be supplemented by the Next Generation Bomber. ‘Manufacturer North American
Rockwell/Rockwell International
Boeing
Contents First flight 23 December 1974
1 Devel t Introduction 1 October 1986
. level om ackground ‘Status In service

m 1.2 Design studies and delays
= 1.3B-1A program
1.4 New problems and cancellation
= 1.5 Shifting priorities
= 1.6 B-1B program
m 1.7 Upgrades

Primary user United States Air Force
Number built B-1A: 4
BIB: 100

Unit cost US$283.1 million in 1998 (B-1B)
a

2 Design

= 3 Operational history

= 3.1 Strategic Air Command
= 3.2 Conventional role

m 4 Variants
m5 Operators
= 6 Aircraft on display
7 Accidents and incidents
= 7.1 Crashes
m= 7.2 Other accidents and notable incidents
m 8 Specifications (B-1B)
= 9 Notable appearances in media
= 10 See also
11 References
m 12 External links

Development

Background

In December 1957, the U.S. Air Force selected North American Aviation’s proposal to replace the Boeing B-52 Stratofortress with the B-70 Valkytie.! The Valkyrie was a
six-engine bomber that could reach Mach 3 speeds at high altitude (70,000 feet / 21,000 m)'! to avoid interceptor aircraft, the only effective anti-bomber weapon in the 1950s.

Soviet interceptors were unable to intercept the high-flying Lockheed U-2;"" the Valkyrie was to fly at similar altitudes and much higher speeds.'“! By the late 1950s,
however, anti-aircraft surface-to-air missiles (SAMs) could threaten high-altitude aircraft, as demonstrated by the 1960 downing of Gary Powers's U-2.7!

‘The USAF Strategic Air Command (SAC) began moving its bombers to low-level penetration before the U-2 downing. This tactic greatly reduces radar detection distances by
use of terrain masking "I As that time SAMe were ineffective against low-flying airccaf,'*""" Atso during this era, iow flying aircralt were difficult to detect by higher flying
interceptors since their radar systems could not readily pick out opposing aircraft against the radar clutter from ground reflections. Higher drag at low level operations limited
the B-70 to subsonic speed while dramatically decreasing its range"! The result would be an aircraft with similar speed but less range than the B-52 it was meant to replace.
Unsuited for this new role and because of a growing intercontinental ballistic missile (ICBM) force, the B-70 bomber program was canceled in 1961 by President John F,
Kennedy,!*"" and the two XB-70 prototypes were used in a supersonic research program,!"!

Although never intended for the low-level role, the B-52's flexibility allowed it to outlast its intended successor as the nature of the air war environment changed. The B-52's
large airframe with internal room allowed the addition of improved electronic countermeasures suites.) During the Vietnam War the concept that all future wars would be
nuclear was tured on its head, and the "big belly” modifications increased the B-52's total bomb load to 60,000 pounds (27,215 kg)."5] turing it into a powerful tactical
sireraf as wel In spite ofits flexibility, the B-52 was far fom perfect; higher speed would aid even low-level approach in the strategic role, something the F-111 took
advantage of:

Deeign studies and delays

http://en.wikipedia.org/wiki/B-1_Lancer 8/17/2011


mil IVi/Ail

UNITED STATES POSTAL SERVICE

a

Mailing Envelope

For Domestic and International Use

a *

= EXPRESS
Bead ivan.

UNITED STATES POSTAL SERVICE @

DELIVERY (POSTAL USE ONLY)

& 9
Addressee Copy
Label 1B, March 2004
Post Office To Addressee

Dey
CUSTOMER USE 0!

PHONE (

titi

ee

SES

When used internationally
affix customs declarations
(PS Form 2976, or 2976A),

-

USPS packaging products have been
‘awarded Cradto to Cradie CertificationTM
for their ecologtcally-inteligent design,
For more information go to
mbdo.comtusps

‘reco to Cache CotadTMaacortcaton mark of W200,

Please recycle,

‘Service? and is provided solely for use in sending Express Mail? shipments.
vice; Oct. 2008; Ait rights reserved.

Misuse may be a violation of federal law . This packaging is not tor resale. EP13F © U.S, Postal Ser

This packaging Is the property of the U.S. Postal


98-23-17411:57 RCVD

SPECIAL EXPOSURE COHORT PETITION
under the
Energy Employees Occupational Illness Compensation Act

‘ormer worker at the Rocky Flats, hereby petition the National Institute for
Occupational Safety and Health (NIOSH) to designate the following workers from the Rocky Flats facility
in Golden Colorado as members of the Special Exposure Cohort (SEC).

All workers employed at Rocky Flats from April 1, 1952 to December 31, 2006.

| was employed by Rockwell Internationa hile employed at Rocky Flats. | was a
| Iwas employed fro: 78 until 93.

——
{ have named as the authorized representative for this

petition.



U.S. Depariment of Labor Employment Standards Administration

Office of Workers’ Compensation Programs

Division of Energy Employees Occupational
Iliness Compensation

Washington, D.C. 20210

MAY: 3 2010

Mr. Stuart L. Hinnefeld, Interim Director

Office of Compensation Analysis and Support
National Institute for Occupational Safety and Health
4676 Columbia Parkway, Mailstop C-46

Cincinnati, OH 45226

Dear Mr. Hinnefeld:

My staff has reviewed the proposed SEC class definition for the Mound site,
Miamisburg, Ohio, presented in your letter dated April 12, 2010. NIOSH found
that it cannot estimate radiation doses with sufficient accuracy. The proposed
class definition is as follows:

All employees of the Department of Energy, its predecessor agencies, and
its contractors and subcontractors who worked in the R and SW Buildings
at the Mound site for a number of work days aggregating at least 250
work days from March 1, 1959 through March 5, 1980, or in combination
with work days within the parameters established for one or more other
classes of employees in the Special Exposure Cohort.

Because we sometimes have difficulty placing workers in specific buildings, we
consulted the Department of Energy (DOE) to determine whether records were
available that would enable us to place workers in the R and SW Buildings.
DOB checked with their staff and have confirmed that they do not have the
ability to validate.gpecific work locations in support of a building-specific SEC
class. In light of these evidentiary challenges, NIOSH may want to reconsider
the SEC class definition.

We appreciate the opportunity to review this SEC definition and look forward to
having a similar opportunity as more SEC classes are proposed. As always, we
provide comments, if applicable, in the interest of improving the consistency and
fairness of claims adjudication carried out in connection with any new SEC class
and to speed the process of determining which cases should ultimately be
considered a part of the class.

wid


Boeing: History -- Products - Rockwell International B-1 Bomber Page 2 of 2

Height: 34 feet
Gross weight: 477,000 pounds

Four 30,000-plus-pound-thrust General Electric F-101-GE-102 turbofan engines with

Power plant:
afterbumers,
Speed: Mach 1.2 at sea level
Crew: Four
Operatin,
P 9 30,000-plus feet
altitude:
Up to 84 Mark 82 conventional 500-pounds bombs, or 30 CBU-87/89/97, or 24
Armament:

JDAMS, or can be reconfigured for wide range of nuclear bombs

http://www. boeing.com/history/bna/b1b.htm 8/17/2011


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

under the Energy Employees Occupational Centers for Disease Control and Prevention
Iliness Compensation Act National institute for Occupational Safety and Health
P. OMB Number: 0920-0639 Expires: 09/20/2013
Petitioner Authorization Form Page 2 of 2

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 3 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 are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

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

The Energy Employees Occupational Iliness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

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

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

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

Use of this form is voluntary. Failure to use this form will not result in the denial of any right, benefit, or
privilege to which you may be entitled.

Name or Social Security Number of First Petitioner:



1980 Incinerator Fire:
Building 771

¢ Note inlet baffle and
suppression piping

TK ss



covered under the SEC. The Rocky Flats claimants have waited four years or more for the resolution by
DOL in applying the Ruttenber database to the SEC class definition. Itis obvious that DOL is “having
difficulty in placing workers inside” the buildings NIOSH has designated as a member of the Rocky Flats
SEC class.

There are other site profile issues, according the SC&A matrix that remain unresolved for four years.
This could possibly result in the underestimation of dose for Rocky Flats workers.

INFORMATION THE BOARD DID NOT HAVE WHEN DECIDING THE
ROCKY FLATS SEC PETITION

Presence of Plutonium in Building 460

Originally, the DOL Site Exposure Matrix showed that plutonium was present in Building 460. NIOSH was
advised of this in the attached email dated December 8, 2009. According to the statement submitted
with that email, a former radiation control technician related that waste drums from the 700 complex
were stored in Building 460 in 1988 when the governor of Idaho refused to allow shipments of
radioactive waste from Rocky Flats into the state. Building 460 was a “cold” building and workers were
not monitored for exposure to radiation

Contaminated Equipment Present in Building 440, 444 and 447

According to the attached Radiation Monitor Report dated 2-8-84, an Empire lift-a-loft was shipped
from Building 371 to Buildings 440, 444 and 447. These buildings were also considered “cold” buildings
and workers were not monitored for radiation exposure. This report was forwarded to NIOSH on
9/26/10 and yet NIOSH has yet to resolve this issue.

Co-worker models are inaccurate for some buildings

NIOSH Site Profile does not include the 1980 fire in Building 771’s incinerator — NIOSH was notified of
the existence of this incident on 4/11/11, as noted in the attached email. RFP-4969 summarizes an
incident where a fire occurred on July 2, 1980 in Building 771’s incinerator. This incident is not
mentioned in the Rocky Flats site profile. NIOSH does not assign ambient dose because either the
worker was monitored or NIOSH uses coworker data to fill in the gaps. However, SC&A found that in
1980 53% of the badges had a zero for radiation reading. If there was a release from the fire (which may
be possible looking at the attached pictures of melted HEPA filters), then the coworker badge readings
may not be accurate and reflect this incident.

NIOSH Site Profile does not include the plutonium recovery system in Building 440 post 1996
http://faculty.evsu.edu/thompsoa/Portfolio/htmipages/RFENWP3.html
http://rockyflats.apps.em.doe.gov/references/126-Chemical%20Decon%200f%20Gloveboxes. pdf —
NIOSH was formally notified of this deficiency, also on 9/26/10, in the attached email from Terrie Barrie
to Mark Griffon. NIOSH has failed to resolve this issue. This failure to investigate and reise the co-



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Subject:1980 "fire" at Rocky Flats Building 771 incinerator
From: |
To: his8@cdc.gov;
| Carolyn_Boller@markudall.senate.gov;
Ce: Adam_Jones@MarkUdall.senate.gov; jonathan.asher@mail.house.gov;
Stuart.feinhor@mail.house.gov;
Date: Mon, 11 Apr 2011 19:57:20

Hello Stu,

Attached is Rocky Flats’ document RFP-4969 which summarizes an event (fire?) in Rocky Flats Building 771 in
July 2, 1980. | discovered this document fairly recently. This event is not mentioned in DCAS' technical
documents, yet it appears to be significant. While the report states that there was no environmental release, |
would also like to direct your attention to the second attached document titled RF 1980 fire HEPA filter pictures,
which shows the conditition of the HEPA filters after the 1980 "fire". It appears to me, that at the very minimum,
some of the worker present in Building 771 during and shortly after this incident may have been exposed to an
unmonitored exposure.

| respectfully request that DCAS investigate this incident and determine whether the site profile, and subsequent
dose reconstruction methodology, accurately represents the totality of the work environment for the workers at the
Rocky Flats site.

Thank vou for your consideration and | look forward to your earliest response.

o—

IANWAG

8/17/2011



ROCKY FLATS

Chemical decontamination of gloveboxes and
tanks improves safety, reduces TRU waste

Summary

Using Office of Science & Technology
(OST) funding, the Rocky Flats team
has developed methods to successfully
decontaminate waste to Surface
Contaminated Objects (SCOs) hundreds
of contaminated gloveboxes and tanks
destined for more hazardous and

costly size reduction. The single most
significant decommissioning innovation,
chemical decontamination has slashed
months from the site’s already
accelerated closur

The Need

More than 900 gloveboxes at RFETS
were used to protect workers from the
hazards of processing plutonium, americium, uranium and other
radioactive isotopes. Hundreds of tanks stored plutonium and
actinide liquids used for recovery processes. The majority of
gloveboxes and tanks were contaminated to Transuranic (TRU)
levels and without decontamination would have to be disposed
according to the acceptance criteria.

decontamination process.

Per acceptance criteria of the Waste Isolation Pilot Plant (WIPP),
TRU waste must either be packaged in a Standard Waste Box
(SWB), a small metal container that accommodates just 1.9
cubic meters of waste or a 55-gallon drum. Additionally, WIPP
requires TRU waste to be counted in an approved assay system
and undergo visual examination to verify packaging contents.

To meet these requirements, after field characterization. RFETS
TRI] wacte ic trancfarred to by =

counters confirm a container’s gram loading, Then, before it itcan
be shipped, TRU waste is stored at RFETS for up to 144 days and
tested for gas generation. This repeated handling of TRU waste is
both costly and poses hazards to workers.

Even more hazardous are activities required to size-reduce tanks
and gloveboxes for packaging into the small SWBs. The largest
of RFETS gloveboxes was 64-feet long and the largest of tanks
had a capacity of more than 20,000 gallons. For equipment that
could be moved, a central size-reduction containment enclosure
with extensive air handling equipment was utilized. Size-
reduction involved using cutting tools like Sawzalls, nibblers

A scrub brush is used during the second step of the

and plasma-arc torches to cut through
quarter-inch thick stainless steel. Workers

in some cases reached through glove ports
and exerted great effort in supporting cutting
tools. Waste was repeatedly handled en route
to the SWB. For gloveboxes too large to be
relocated, custom tents were built around
them to contain high airborne radioactivity
released by cutting contaminated steel. In
situ size-reduction evolutions were costly
and time consuming because workers must
don supplied air suits which requires a series
of lengthy entry and exit steps.

Precursors to Chemical
Decon Success

In 1996, waste managers began studying
alternatives for disposing of large process equipment. They
concluded that decontamination would generate excessive
secondary waste, be too labor intensive and expose workers to
unknown hazards.

After the Department of Transportation (DOT) in 1997 released
exceptions to regulations that would allow transporting low-level
waste in certain conveyances, decontamination was again studied
at RFETS, The DOT exceptions stipulated limits for a waste’s
removable and total contamination in Disintegrations Per Minute
(DPM) averaged over 100 square centimeters. Waste that meets
these criteria are called Surface Contaminated Objects (SCOs).

Because waste’s contamination had to be characterized in terms
vi sul fave area, ue ratio OT surtace area to mass tor a variety

of materials had to be established. Detailed procedures for
characterization were developed that, in part, established surface
area to mass ratios for a variety of surfaces so that surface area
could easily be established when waste was weighed.

Per DOT guidelines, waste that meets SCO criteria can be
packaged in a variety of conveyances. The most accommodating
is a cargo container, which has a capacity of 38 cubic meters.
Packaging waste as SCO avoids all of the costly and stringent
criteria for packaging TRU waste. More importantly, it avoided
hazardous and risky size-reduction evolutions for thousands of
cubic meters of waste.



upon such a small number of people to develop a scientific methodology flies in the face of sound
science.

Recently, NIOSH reversed its evaluation report for Savannah River SEC petition after they and SC&A
reviewed classified documentation. Because the Rocky Flats SEC petition was the first large facility to be
reviewed and because the SEC petition process was in its infancy, classified documentation was not
reviewed for Rocky Flats by the Board’s technical contractor. The Rocky Flats claimants are denied the
consistent investigation afforded to subsequent SEC petitioners.

NIOSH Ignored Sworn Testimony in SEC Petition 00030

Many sworn affidavits were submitted by the Rocky Flats SEC Petitioner attesting to the common
practices at the site. These sworn affidavits were largely dismissed by NIOSH because they were not
backed up by documentation. Yet, as noted above, NIOSH readily accepted, in at least one instance, an
unsworn testimony over a document.

Some of the sworn statements seem to be backed up by SC&A’s investigation. As an example, many of
the sworn affidavits attested to the fact that despite being in high radiation areas, the workers’
dosimetry badges came back as “zero” readings. SC&A confirmed, in their report, Completeness of
Records 1969-1970, dated February 6, 2007,
http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/rfsecrev/sca-rfspgap6970.pdf, that many years had
a high percentage of badges had “zero” readings. in fact, the highest level during the production years
was in 1982 where 63.2% of badges had zero readings. During the cleanup period, in 2004 a full 79.7%
of badges had zeros.

NIOSH Class Definition for the approved Rocky Flats SEC is inconsistent with other SECs and difficult
for the Department of Labor (DOL) to administer

Recently, NIOSH has determined that they could not determine whether a worker had access to a
particular building for General Electric facility in Evendale, OH and the Ames Laboratory in Ames, IA.
Therefore, all workers during the SEC time period for those sites, whether or not that worker was
actually present in the buildings where the radioactive materials were present, are or can be eligible for
compensation if they have one of the specified cancers.

Additionally, DOL has stated in the attached letter to the Director of the Division of Compensation
Analysis Support dated May 3, 2010, concerning the Mound Plant:

Because we sometimes have difficulty placing workers in specific buildings, (emphasis added)
we consuited the Department of Energy (DOE) to determine whether records were available
that would enable us to place workers in the Rand SW Buildings. DOE checked with their staff
and have confirmed that they do not have the ability to validate work locations in support of a
building-specific SEC class. In light of these evidentiary challenges, NIOSH may want to
reconsider the SEC class definition.

Asimilar situation exists for the SEC class definition for the Rocky Flats plant. NIOSH’s class definition
for the current Rocky Flats SEC class is building specific. However, it is known that workers, such as
electricians, painters, etc., who were assigned to other buildings, were often detailed to the buildings

3


PREMISE FOR SEC PETITION

The premise of this SEC petition is threefold. First, NIOSH has failed to reconcile outstanding site profile
issues as noted in the February 2007 report to the Advisory Board on Radiation and Worker Heaith’s
(Board) contractor, Sanford Cohen and Associates (SC&A). Second, there is a lack of consistency in
considering sworn affidavits from former production workers versus NIOSH’s reliance on unsworn
statements made by former Rocky Flats dosimetry personnel. Lastly, the Board was unaware of some
possible exposures before they voted on the SEC petition in June of 2007.

Section 83.1 of the Procedures for Designating Classes of Employees as Members of the Special
Exposure Cohort under the Energy Employees Occupational Illness Compensation Program Act of 2000
(EEOICPA), states the purpose of the procedures are “... to ensure that the process is timely and
consistent with the requirements specified in EEOCPA.” Part of the SEC petition process is to determine
which issues reach the level of and SEC issue and which are merely related to the site profile. This
petition will show that the SEC process, including resolving site profile issues after the Board voted on
the original Rocky Flats SEC petition, is neither timely nor consistent.

OUTSTANDING SITE PROFILE SSUES
THORIUM USE AT ROCKY FLATS

NIOSH accepted an unsworn statement from the supervisor for the thorium strikes as the basis
for their methodology for reconstructing dose for thorium exposure. This unsworn statement
contradicts document RFP 5331, which states that thorium was present in Buildings 559, 771,
774,777, 7774, 779A and 883. This document was reviewed by NIOSH and rejected.
Additionally, a representative from SC&A uncovered two NIOSH interviews with this individual
which is also contradictory about where tritium strikes were performed at Rocky Flats.

SC&A’s report to the Board, dated February 15, 2007, page 3, states that they did not review classified
documents for thorium use at Rocky Flats

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/rfsecrev/sca-rfspotherad.pdf.

This is unfortunate. They did review the unclassified 1976 report titled, “Thorium Use at Rocky Flats”.
This report, in part, identifies that the major use of thorium and thorium alloy was to fabricate parts.
While NIOSH assumed that only light machining was done, and therefore thorium exposure was low,
that assumption has not been verified by the Board. Thorium parts were/are used not only in nuclear
weapons but also aircraft. Rockwell International had a contract to fabricate parts for the B 1 B bomber,
but it appears that the details of the thorium/thorium alloy parts are still classified information.

NIOSH stated that they interviewed five (5) Rocky Flats personnel that would seem to be familiar with
the machining operations at Rocky Flats and therefore knowledgeable as to the presence of thorium at
Rocky Flats http://www.cdc.gov/niosh/ocas/pdfs/sec/rocky/ncom2bdrfsec.pdf. This is a very small
sampling of interviews. There were hundreds of machinists at Rocky Flats at any one time and literally
thousands of people who would have some knowledge of the machining operations for the site. To rely

2



If you have any questions in regard to this matter, please feel free to contact me
at (202) 693-0081. “

Sincerely,

Rach P fectry

Rachel P. Leiton
Director, Division of Energy Employees
Occupational IlIness*Compensation

vlad


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