NIOSH Dose Reconstruction 

Project Meeting 

On Rocky Flats Site Profile 

Final Minutes 1 of 12 02/16/05 

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Date: 

June 23, 2004 

Meeting with: 

United Steelworkers of America Local 8031 

Attendees: 

Wildon P. Narcisse United Steelworkers of America Local 8031 

John C. Weyandt United Steelworkers of America Local 8031 

F.P.C. (Phil) Cruz Safety Manager, Rocky Flats Security Officers Local Union 1 

Tammy Cockroft United Steelworkers of America Local 8031 

Lewis M. DiGiallonardo Joint Union/Company Safety Committee 

Duronda Pope Joint Union/Company Safety Committee 

John R. Sullivan United Steelworkers of America Local 8031 

J.D. Thompson United Steelworkers of America Local 8031 

Rich Ostrom United Steelworkers of America Local 8031 

Jerry Harden United Steelworkers of America Local 8031 

Darryl Dubrouin Vice President, Rocky Flats Security Officers Local Union 1 

Steven E Trujillo United Steelworkers of America Local 8031 

Thomas R. Deherrera United Steelworkers of America Local 8031 

Carolyn Boller Representative Mark Udall’s staff 

Rudy M. Mastellone Joint Union/Company Safety Committee 

Judy .A. Yeater Joint Union/Company Safety Committee 

NIOSH and ORAU Team Representatives: 

 

Brant Ulsh – National Institute for Occupational Safety and Health (NIOSH) 

William Murray – Oak Ridge Associated Universities (ORAU) 

Robert Meyer – Site Profile Team Leader 

Vernon McDougall – ATL International, Inc. 

Mark Lewis – ATL International, Inc. 

Proceedings 

Mark Lewis opened the meeting at 1:15 p.m. by thanking everyone for coming and introducing 

himself. He explained that his primary function on the team is to get input from union workers, 

and that the reason the National Institute for Occupational Safety and Health (NIOSH) and the 

Oak Ridge Associated Universities (ORAU) requested the meeting was for a free exchange of 

knowledge that would be mutually beneficial. Mr. Lewis said that his 30 years of experience 

with the Paper, Allied-Industrial, Chemical and Energy Workers International Union (PACE) 

give him insight to the valuable knowledge that the workers could contribute to the accuracy and 

completeness of the Site Profile. He stated that he has firsthand knowledge that input from 

unions at Portsmouth (which was his site when he worked with PACE) is being incorporated into 
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their Site Profile and this is a worthwhile venture. He then introduced Bill Murray, saying that 

he will be giving the presentation, Dawn Catalano, who would be taking notes for a complete, 

accurate record, and Vernon McDougall, who could help answer questions. 

Mr. Lewis turned the meeting over to Brant Ulsh, NIOSH Office of Compensation Analysis and 

Support (OCAS). Mr. Ulsh said he could give a quick answer to an early question about how the 

document can help the plant workers. He explained that the Site Profile is used as a tool to do 

dose reconstruction. Mr. Ulsh also said that if something seemed to be missing or not quite right 

in the document, NIOSH and ORAU would welcome any input workers could provide. Mr. Ulsh 

then turned the floor over to Bill Murray, and said that his presentation would explain in detail 

how the process works. After thanking participants for their time and for including NIOSH and 

ORAU in their meeting, Mr. Murray introduced Robert Meyer as the team leader who oversaw 

the development of the Site Profile for Rocky Flats, and then asked everyone to introduce 

themselves around the table. 

Participants voiced opinions of mistrust and dissatisfaction with previous studies at Rocky Flats 

during their introductions. The general feeling was that they had no confidence in the system 

and did not believe accurate dose reconstructions could be done for Rocky Flats, considering the 

fact that so many records are missing. Several participants stated outright that they are seeking 

Special Exposure Cohort (SEC) status due to the extraordinary circumstances and working 

conditions, and felt that the meeting regarding dose reconstruction was futile. 

The attendees said they were familiar with the Energy Employees Occupational Illness 

Compensation Program Act (EEOICPA), and had specific questions and issues they wanted to 

address right away. One attendee suggested that Mr. Murray skip general information slides to 

save time, and no objections were raised. Mr. Murray moved ahead to the section of his 

presentation that described the development of the Site Profile, explaining that they are broken 

down into six sections called Technical Basis Documents (TBDs). Mr. Murray said that the 

TBDs are written by subject matter experts and require multiple reviews and approval by 

NIOSH. Mr. Murray acknowledged that information gaps do exist in the documentation, but 

NIOSH and ORAU make assumptions in dose reconstructions to fill those gaps by using 

claimant-favorable assumptions that are intended to increase the probability the claim will be 

approved. He also said that NIOSH and ORAU are aware of, and have documented, many 

incidents at the Rocky Flats Plant in response to inquires about the accuracy of the Site Profile. 

He explained that NIOSH and ORAU use additional information in reconstructing a dose, such 

as that from the occupational medical X-ray program, taking into consideration the medical 

techniques and equipments that were used historically. For example, X-rays required as a 

condition of employment are included in the dose reconstruction in addition to the dose in the 

DOE records. The amount is based on factors such as type of equipment used, since older 

equipment caused higher doses. None of the X-ray doses is in the official DOE dose records; 

this is one attempt for NIOSH to be claimant favorable. NIOSH and ORAU also look for 

evidence that workers were in a particular area to correlate with incidents and other documented 

doses. 
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Several more questions were asked (see next section) and at about this point the meeting turned 

more to discussion rather than completion of Mr. Murray’s prepared presentation. 

Discussion Session 

Concern/Question: 

What is the development of the Site Profile going to accomplish? I worked with Watson/Miller 

in Washington and do not see that this process can help us. 

William Murray: 

It will help determine what occurred at the plant to help us understand the background for dose 

reconstructions. 

Mark Lewis: 

She suggested we do this – we also have Carolyn Boller from Congressman Udall’s office with 

us today. NIOSH and ORAU have support from lawmakers who have faith in this program. 

Concern/Question: 

Are NIOSH and ORAU aware that $10 million has been allocated for neutron exposure and is 

that the only funding there is? 

Brant Ulsh: 

There are other types of exposures covered as Mr. Murray will explain in detail. 

Question: 

What will NIOSH and ORAU do with the data collected? 

William Murray: 

The information will be incorporated into the Site Profile, and then the information is used to 

process claims and perform dose reconstructions. 

Concern/Question: 

How much will this exercise expedite claims processing? There are folks here who have been 

waiting two years for an answer already. 

Brant Ulsh: 

The Act was only passed in 2000 and NIOSH needed time to establish a process from the ground 

up. The organization, including the contracting team, was built to put the operation in place 

William Murray: 

ORAU was awarded the contract in September of 2002, and we have the responsibility to do the 

dose reconstructions. The first 1,000 claims took 14 months to complete; the next 1,000 were 

done in 14 weeks. This is a very detailed process; NIOSH and ORAU had to be meticulous and 

sure not to overlook anything in developing the process. There have been 4,000 claims 

processed now, and the goal is to complete 200 per week now that guidelines are in place. 
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Concern: (composite) 

Rocky Flats has been the subject of many studies that have not benefited the workers to date. 

The workers’ feeling is that doses can not be reconstructed due to the circumstances and events 

at the plant, and they are seeking Special Exposure Cohort status. Film badges were the only 

items considered ‘legal record,’ but chemical contaminants and incidents must also be taken into 

account, although they are too numerous to be consolidated into a report such as the Site Profile. 

Production and security workers share the same concerns and dilemma. The guards have 

particular difficulty filing claims since they were never on the roster, despite the fact that they 

walked among the workers daily. The guards were never monitored and no record exists that 

they were in areas of concern. No valid dose reconstruction can be completed with such severely 

lacking documentation. The guards were pushed further outside the program (monitoring) 

because they were not part of the protective personnel equipment program. They were 

occasionally given a lead apron, but not much else. They had to remain with the material 

because they were guarding it. Thus there was frequent, unreported movement. Furthermore, 

readings were zeroed out when workers checked their records. Overall, there is no confidence in 

the process. 

Vernon McDougall:

The National Oversight Committee (the Advisory Board on Radiation and Worker Health) 

instructed NIOSH to start up the outreach program in order to get this kind of information for 

Site Profiles. There is keen awareness that records do not contain many instances such as these. 

Comment: (referring to page 4) 

The x-ray devices used in the past were outside the norm, so typical medical dose calculations 

will probably not be appropriate for Rocky Flats. Also, there was no mention of radon in the Site 

Profile. Excessive doses were received resulting in synergistic effects of alpha emitters. There 

were cascades and many alpha exposures over time. 

Question: 

Can we get copies of the TBDs? 

William Murray: 

All approved documents can be found on the website. Mr. Trujillo has indicated that he has a 

copy already printed. 

Question: 

Would it reduce the dose of record to include x-rays? 

William Murray: 

No, the x-rays are calculated in the medical dose in addition to the dose of record. However, 

only x-rays required as a condition of employment, such as annual chest x-rays, are counted in 

the dose reconstruction. If you require an x-ray for an accident or condition outside of work, that 

dose would not be included. 

Concern/Comment: 

X-rays were used to determine beryllium issues here. They were done often and regularly. 
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William Murray: 

Since the X-rays were not considered a condition of employment, they are not included in the 

dose. 

Concern/Comment: 

The medical department did all full body decontamination functions – this should also be part of 

our dose history. There is no workers advocacy in this area. 

Question: 

Why were medically necessary x-rays (for beryllium) not included? 

Brant Ulsh: 

NIOSH looked at this particular situation and decided that only the X-rays that are required as a 

condition of employment would be included in the dose reconstruction. 

Concern/Comment: 

Workers had to go through whatever medical procedures the plant told them to. It was implied 

that keeping your job depended on compliance with requests for medical testing. Everyone was 

going on the assumption that non-compliance would invalidate worker’s compensation rights. 

Brant Ulsh: 

I would strongly encourage you to make formal comment on these issues to NIOSH and submit 

them through official channels as described in Mr. Murray’s handout and presentation. 

Question: 

Are the amounts of dose based on chronic or acute exposure? Was the amount of time spent in 

an area considered? 

Brant Ulsh: 

We use whichever is most claimant-favorable for external exposures, i.e., acute for photon, and 

chronic for environmental and neutron; internal exposures are always chronic. We use air 

concentrations to calculate annual intake for every year in the Site Profile. 

Concern/Comment: 

There were incidents of acute inhalation, particularly by the truck drivers during the fire. 

Concern/Comment: 

We never had ‘whole body counts;’ they were only over each lung and the liver, although the 

liver exams are not done anymore. The term is misleading and makes the program look better 

than it has been for us. 

Concern/Question: 

Will NIOSH and ORAU find the records necessary on background dosimeters for more accuracy 

in the Site Profile? 

William Murray: 

Yes, background badges are calculated in and work in your favor. 
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Concern/Question: 

The panels of doctors who review the claims deduct environmental count from total dose on the 

record and this ends up giving the worker a negative. Is the legal dose going to show that? 

Brant Ulsh: 

NIOSH will add background back into the dose. Individuals who show a zero dose are given a 

missed dose to make up for it. 

Vernon McDougall: 

The legal dose is only part of what NIOSH calculates. The environmental and medical doses are 

added to the record. There are two parts of this law and two sets of claim forms to be submitted. 

One set goes to the Department of Labor (DOL). This is the claim (part) we’re here to discuss 

today that includes compensation of $150,000 and medical coverage for that cancer. The other 

part is for Workers’ Compensation. The Department of Energy processes those claims, and 

that’s where you come across the three doctor panel. The compensation program that NIOSH 

administers, and the team is here to explain today, falls under Subpart B. 

Brant Ulsh: 

Dose calculation is done using modeling based on information provided by the claimant. 

NIOSH tries to help each claimant get closer to get to a greater than 50% probability of causation 

by including doses other than the dose in the DOE records. 

Concern/Question: 

How much dose does it take to get the probability of causation over 50%? 

Brant Ulsh: 

Many factors go into that. For example, in skin cancer cases, ethnicity is important. Latency 

(the length of time between exposure and diagnosis of cancer) is an important factor. For lung 

cancer, higher doses are required to compensate smokers since smoking is known to cause 

cancer regardless of radiation exposure. Age at exposure also goes into the calculation. And 

different cancers have different levels of risk for a given radiation dose. 

Resource Center: 

The Resource Center does not adjudicate, we only figure the probability of causation based on 

numbers from NIOSH. 

Concern/Question: 

Wasn’t there supposed to be a ‘no fault’ stipulation to the effect that if you had certain cancers or 

a certain exposure you were automatically qualified? 

William Murray: 

That situation is a variation of the program. Special Exposure Cohorts (SECs) are granted under 

certain circumstances. The requirement is that NIOSH could not do dose reconstruction for 

individual cases. There are four (4) approved SECs: 3 are gaseous diffusion plants and the 4th is 

a DOE facility in Amchitka Island in Alaska where nuclear devices were detonated underground 

between 1965 and 1971. The SEC claims are limited to 22 specified cancers. For cancers not on 

the list, a dose reconstruction must be done. 
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Brant Ulsh: 

NIOSH is acutely aware of information gaps and has been directed by Congress to take the 

necessary steps to fill them and complete the claims. We first focused on those claims that could 

be done quickly, meaning those that were at either end of the spectrum (clearly compensable or 

clearly non-compensable). We are now moving on those that are in the middle. 

Concern/Question: 

Are other studies considered in the model? One Russian report said that Rocky Flats is off by a 

factor of 10. The particle size is not what we have experienced here. Is the information in the 

TBD based on particle size? 

Robert Meyer: 

Section 5 of the Site Profile has to be revised; the staff working on it came to the realization that 

it was too difficult to determine in the first iteration. 

Question/Comment: 

Is NIOSH aware of Langham’s curve? The Mayak report in Russia is the closest to what’s been 

going on at Rocky Flats – this site needs to be approached as a composite. We know the 

intentions are good, but people need help now. 

Brant Ulsh: 

Our risk models are based on recommendations from the International Commission on 

Radiological Protection, which are based largely on the atomic bomb survivors. Our 

intake/deposition models are also based on ICRP models, which are based on a composite of 

many studies and represent the consensus opinion on the best available scientific knowledge. 

Concern/Comment: 

Plant records are inaccurate and misleading. Badges were worn outside the lead apron, but not 

where it would read the actual exposure. For example, when working in gloveboxes, the badge 

was worn on the chest. But the exposure was to the lower body, so it would not be read. There 

were cases of high neutron and gamma doses in Building 371 that were so extreme that aprons 

were worn on both the front and back. Procedure dictated how the work was to be done. But 

people were in such a rush to get away from the danger that they would cut holes in the 

protective gear in order to work faster. Is that kind of information going to be included in the 

Site Profile? 

Brant Ulsh: 

That is the kind of input NIOSH needs to revise the documents. 

Concern/Comment: 

There have been four (4) deaths out of this plant that were proven to be due to sustained radiation 

exposure. 

Concern/Comment: 

Some highly shielded gloveboxes got in the way of the work; in order to complete tasks, workers 

would handle the material without the protection. This kind of exposure will never show up in 

dose reports. 
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Robert Meyer: 

Everything you mention would be considered in individual cases. Please read sections 5 and 6 of 

the document and make comments that would be helpful overall. 

William Murray: 

These issues also come up in the telephone interviews for evaluation of personal circumstances. 

Concern/Comment: 

There are too many variable at this plant to get an accurate Site Profile. There were no Q/A 

processes for dosimetry prior to 1993; it was supposed to be included in production procedures. 

Information is out there that could help sick people get paid. 

Brant Ulsh: 

NIOSH and ORAU have no way of knowing about these anomalies unless someone brings it up. 

That is the purpose of the outreach program. 

Concern/Comment: 

Workers don’t want to be known for poor work habits. Management shamed workers into 

actions like leaving TLDs off when they reached their limit so they could finish vital work to 

help their country. 

Comment/Question: 

Are NIOSH and ORAU familiar with the Joe Albridge report regarding film badges and dose 

reconstruction? 

Brant Ulsh: 

I am not personally familiar with that report. NIOSH and ORAU are aware of the neutron dose 

reconstruction effort for Rocky Flats, and will use any information that project provides when it 

becomes available. 

Concern/Comment: 

Some people are incapacitated and can only remember so much. For example, ZIPPER (Zero 

Power Plutonium Production [ZPPR] production shut down in 1971 – that’s all we know about 

it. How can you do dose reconstruction without knowing nuclides? Furthermore, classified 

information can’t be disclosed, and NIOSH interviewers can’t see badges. 

Brant Ulsh: 

NIOSH has the ability to conduct classified interviews with claimants who need to discuss that 

kind of information. We have conducted such interviews in the past at a claimants request and 

are willing to do so whenever necessary. 

Concern/Comment: 

Re-engineering created unwarranted doses. Shortcuts were taken because procedures weren’t 

functional enough and did not give sufficient time for the job to get done. 

Robert Meyer: 

Look at what we found (in the Site Profile) and use it as a basis for a write-up to NIOSH; look 

for what’s missing. 
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Concern/Comment: 

We are in the process of doing that. We wanted to prompt you to bring information back to 

NIOSH for further investigation with today’s comments. 

The Site Profile is the company profile only – it does not indicate any interviews or accuracy. 

We feel the records used are skewed. 

Brant Ulsh: 

NIOSH will go back and revise a dose reconstruction if new information is added. 

Question: 

What is the revision process? 

William Murray: 

The Site Profile is revised as we gather new data. Each revision has to go through the review 

process to be sure concerns are addressed thoroughly. 

Mark Lewis: 

Revisions to the document never go through the plant; the reviews are strictly NIOSH and 

ORAU. 

Question: 

Will a claimant get notification if NIOSH or ORAU finds an anomaly in the worker’s record? 

Vernon McDougall: 

Notification is only given on the status of a claim. Records used for the Site Profile do not 

include individual files. 

Brant Ulsh: 

Claimants receive dose reconstruction reports. DOE records are used, and you can access your 

own record in accordance with the Freedom of Information Act. Claimants can also contest 

results if there seems to be an inconsistency. 

Question: 

How does NIOSH deal with a survivor filing a claim who can only relate what the deceased 

said? 

William Murray: 

NIOSH realizes there can be times when the interview does not yield a lot of information from 

survivors. Claimants can name co-workers who might be able to offer more details. 

Question: 

Why are so few claims paid if NIOSH keeps saying the program is claimant-favorable? How 

many claims have actually been paid to Rocky Flats applicants in comparison to the total number 

filed? 

Brant Ulsh: 

That information is on the NIOSH website and without the information on hand the only 

accurate answer would be that about 30% of the dose reconstructions NIOSH and ORAU have 

done so far have had probabilities of causation less than 50%. However, you have to remember 
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that the claims are not done randomly – NIOSH and ORAU do the easy ones first so that 

percentage will most likely change over time. 

DOL: 

There are currently more than 800 claims pending; 863 are at NIOSH. Twenty-five claims have 

been paid a total of $25 million. These are Rocky Flats employees who have been paid mostly 

for chronic beryllium, not for cancer. 

Mark Lewis: 

You can get the breakdown on the website. 

Robert Meyer: 

Sections 2-6 of the Site Profile were approved in January. This has helped get more claims 

processed. 

Brant Ulsh: 

NIOSH does program evaluation reports, and then revises claims with the new information. 

Concern/Question: 

How does NIOSH access dose solubility vs. non-solubility? 

Robert Meyer: 

To do so requires an understanding chemical forms used at the site. This involves experts who 

use the latest data and models to come to a conclusion. 

Concern/Comment: 

The system is fundamentally flawed – doses didn’t migrate enough to be detected. We suspect 

there are many plant workers who received doses but they can not get the numbers because of 

this. 

Robert Meyer: 

Models are run with new information as it is obtained, but NIOSH has to make assumptions 

when data are not available. Doses are calculated using the highest possible numbers. 

Concern/Comment: 

Plutonium is bone-seeking; what’s in my lungs will never show up. 

Robert Meyer: 

If there is any room for doubt regarding solubility, NIOSH will always go higher in the 

assumption. Any reasonable possibility will go on record as whichever will give the claimant the 

highest dose. Most of the claims paid for Rocky Flats have been for lung cancer with positive 

results for plutonium or for leukemia. 

A history of concentrations is accounted for in Section 5 of the Site Profile. Recommendations 

have been made to NIOSH based on findings. The team has been spending a lot of time in the 

records center looking for new information. The fire and accident history makes Rocky Flats 

one of the most difficult sites to evaluate. The team has attempted to put all potentially 

dangerous accidents in Section 2. We have been to Los Alamos where the records are kept to 

check on any additional incidents to research. With this additional information, we can see if we 

originally recommended the right dose. NIOSH will consider all feedback, although paper 
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records are best. Anything that you can document or submit in writing has to be looked at 

according to the review process. 

Concern/Question: 

Have incidents that occurred since 1977 been used? There must be records since then. 

Robert Meyer: 

The team was unable to find any records; if you can get anything it would be greatly appreciated. 

Concern/Comment: 

There was a chronic issue in Building 771 that should have been included in the Site Profile. It 

ended up in a shut-down with no explanation later. 

Robert Meyer: 

The team did see records up to the late 1990’s and used that information for Section 5 of the Site 

Profile for calculating doses. Section 2 is only historical information, so it would not be included 

there. 

Concern/Question: 

What scale is required for an incident to be documented? Accidents happen when workers don’t 

follow procedures and this happens more often than they would like to admit. What size dose is 

required to make it into the documented record? 

Robert Meyer: 

Ideally, these kinds of incidents are used for an individual worker’s dose reconstruction, not the 

development of the Site Profile. 

Concern/Comment: 

Perhaps incidents such as these should be catalogued in a new section of the Site Profile with 

specifics to document time, place, and dose. 

Question: 

Will small incidents such as these raise the baseline? 

Robert Meyer: 

Information about smaller occurrences will more likely be used to fill gaps in dose 

reconstructions. 

Question: 

What have NIOSH and ORAU learned from other meetings? 

Brant Ulsh: 

One example is that a concern was raised at a meeting in Hanford regarding the underestimation 

of organ doses when badges were won at chest level, but the organs were at waist level. This is a 

concern for glovebox workers and we are currently evaluating what effect this might have. 

Concern/Comment: 

Workers saw high counts on badges as a means for the company to administer unjust punishment 

with loss of hours or overtime. Workers would shield or hide their badges in order to stay on 
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payroll; they also would sign waivers in order to get more hours without being properly informed 

of the dangers. 

Question: 

What happens if a worker doesn’t get any diagnosis for 20 years? Will the program be gone? 

DOL: 

This is an entitlement program similar to the black lung program that has been in place since the 

1940s. 

William Murray: 

If there are no more questions the meeting will break up shortly, but please note that the 

addresses and procedures to submit your questions and concerns to NIOSH are included in your 

copy of the presentation. 

Attachments: 

• Sign-in sheet 

• Presentation by William Murray: Development of the Rocky Flats Plant Site Profile 

• Technical Basis Document for Rocky Flats Plant – Introduction