[Effective Date: Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS5-0066 Page 24 of 54

the facilities covered in the site profile; Atomics International in Los Angeles County, which is
shown as a BE DOE (Beryllium and DOE) facility, and Energy Technology Engineering Center
(ETEC), Santa Susana, Area IV. There are no listings for the associated facilities operated by AI
in Canoga Park, De Soto, or Downey,

DOE has developed a database of the covered sites, which is accessible through the web site,
http://www.hss.energy.gov/healthsafety/F WSP/Advocacy/faclist/findfacility.cfim. This database
includes the following “covered” facilities:

« Area TV of the Santa Susana Field Laboratory, which is shown as a DOE facility with
the operator, North American Aviation (NAA).

« Atomics International (shown as Beryllium Vendor and with the locations of Los
Angeles and Ventura Counties) and includes, but is not necessarily limited to, the
following locations; Area IV of the SSFL, portions of the Downey facility, the Vanowen
Building at the Canoga facility, and the De Soto facility. The description notes that the
AI Division of NAA is a statutory beryllium vendor under the EEOICPA, but that the
company also worked with radioactive materials under contract with the Atomic Energy
Commission (AEC) at numerous locations. (It should be noted, as stated above, that the
AI site is shown as a BE DOE facility in the most recent Federal Register notice).

* Canoga Avenue Facility, which is shown as a DOE facility with the operator, NAA.
+ De Soto Avenue Facility, which is shown as a DOE facility with the operator, NAA.
* Downey Facility, which is shown as a DOE facility with the operator, NAA.

Therefore, the list of covered sites in the DOE database is not consistent with the list of covered
sites identified in the August 23, 2004, Federal Register.

The nomenclature related to these facilities is further confused by the document titles of the six
Technical Basis Documents (TBDs) identified below, where various facility names are used in
the titles,

* ORAUT-TKBS-0038-1, Technical Basis Document: Atomics International —
Introduction, Rev. 01 (ORAUT 2006a)

© ORAUT-TKBS-0038-2, Technical Basis Document: Energy Technology Engineering
Center — Site Description, Rev. 00 (ORAUT 2006b)

e ORAUT-TKBS-0038-3, Technical Basis Document: Atomics International —
Occupational Medical Dose, Vol. 3, Rev. 00 (Atomics International TBD, 2006a,
ORAUT 2006c)

* ORAUT-TKBS-0038-4, Technical Basis Document: Area IV of the Santa Susana Field
Laboratory, the Canoga Avenue Facility (Vanowen Building), the Downey Facility, and
the De Soto Avenue Facility (sometimes referred to as the Energy Technology

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

References

Ref la ORAUT-TKBS-0038-1: “Atomics International — Introduction”, Revision 001
titled dated 8/30/2006 (NIOSH report; copy not enclosed)

Ref 1b ORAUT-TKBS-0038-2: “Energy Technology Engineering Center (ETEC)—Site
Description”, Revision 00, titled dated 2/2/2006
(NIOSH report; copy not enclosed)

Ref lc ORAUT-TKBS-0038-3: Area IV of the Santa Susana Field Laboratory, the Canoga
Avenue Facility (Vanowen Building), the Downey Facility, and the De Soto
Avenue Facility (sometimes referred to as Energy Technology Engineering
Center [ETEC] or Atomics International) — Occupational Medical Dose, Revision
02, dated 10/3/2008
(NIOSH report; copy not enclosed)

Ref 1d ORAUT-TKBS-0038-4: “Area IV of the Santa Susana Field Laboratory, the
Canoga Avenue Facility (Van Owen Building), the Downey Facility, and the
DeSoto Avenue Facility (sometimes referred to as Energy Technology
Engineering Center [ETEC] or Atomics International) - Occupational
Environmental Dose”, Revision: 01, Effective Date: 03/08/2007

(NIOSH report; copy not enclosed)

Ref le ORAUT-TKBS-0038-5: “Energy Technology Engineering Center —
Occupational Internal Dose”, Revision 00. dated 2/2/2006
(NIOSH report; copy not enclosed)

Ref If ORAUT-TKBS-0038-6: Atomics International -
Occupational External Dose, Revision 01, dated 11/16/2006
(NIOSH report; copy not enclosed)

Ref 2. SEC Petition Evaluation Report, Petition SEC-00093, Report Rev 01 , Report
Submittal Date: February 6, 2008
(NIOSH report; copy not enclosed)

Ref3 Technical Support for the Advisory Board on Radiation & Worker Health Review
of NIOSH Dose Reconstruction Program, Review of the Santa Susana Field
Laboratory (SSFL)- Area IV Special Exposure Cohort (SEC) Petition-00093 and
the NIOSH SEC Petition Evaluation Report”, report No. SCA-SEC-TASK5-0066,
dated January 30, 2009, and prepared by S, Cohen and Associates
(report prepared for NIOSH, copy enclosed)

22


Bl

B.2
B.3

B4
B.5
B6

| Special Exposure Cohort Petition
under the Energy Employees Occupational
iilness Compensation Act

Special Exposure Cohort Petition — Form B

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention
National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Page 2 of 7

Survivor Information — Complete Section B if you are a Survivor or representing a Survivor.

Name of Survivor:

Mr./Mrs./Ms. Middle Initial Last Name
Social Security Number of Survivor:

Address of Survivor:

First Name

Street

Apt #

P.O. Box

City

State

Telephone Number of Survivor:

¢ a

Zip Code

Email Address of Survivor:

Relationship to Employee: OQ Spouse Q Son/Daughter Q Parent

C.2

C3
C4

C5
Cé

C7
C.7a

C.7b
C.7¢
C.7d

C.7e

Q Grandparent Q > Grandchild

Employee Information — Complete Section ‘C UNLESS you are a labor organization.

Mr/Mrs./Ms. Middle Initial Last Name
Former Name of Employee (e.g., maiden name/legal name change/other):

First Name

Mr./Mrs./Ms, First Name Middie Initial Last Name

Social Security Number of Employee: —_|

Address of. _— " a
3 A

ity
Telephone Number of Employee:

Email Address of Employee:
Employment Information Related to,

Employee Number (if known): —ha—

Dates of Employment: Stat _f9 #7 > End (790 (1993
Employer Name: Z Vo rth American A via tein G se Altech ment Ht)
Work Site Location: Various ~~ see HHachment A

Supervisor's Name: _# €€ 4 He chamen fa A

Name or Social Security Number of First Petitioner:



Effective Date: [Revision No. {Document No. age No.
January 30, 2009 .) SCA-SEC-TASKS-0066 Page 33 of 54

The unsupported assumption that in all three cases a “typographical error” was, in fact, made
may not be correct, given the discrepancies between the values reported by NSEC relative to
those of Shepard:

Shepard 1959 NSEC
Gross alpha 7.5 dpm/t 0.2 cpm/ml or 200 epm/I
Gross beta 75 dpm/l 1 cpm/ml or 1,000 epm/t
MFP 60 dpm/l 2 cpm/ml or 2,000 cpm/l

If, in fact, the NSEC data were correctly reported in the units of cpm/ml, and adjusted for
yield(s) and counting efficiencies, MDA values (redefined in dpm/I) are likely to more than
double. Such large differences are hard to explain and raise questions about the credibility of
bioassay data provided by contract laboratories as a whole. Since this concern applies to the
time period post-1958, it brings into question NIOSH’s ability to perform internal dose
reconstructions post-1958. This issue needs further investigation.

4.3.8 Potential Difficulties Associated with Uranium Bioassay Data

Uranium at SSFL to which workers may have been exposed existed in various degrees of
enrichment (i.e., 2% to 93%). Section 5.3 of TBD-5 discusses the two independent methods
used to assess uranium in urine; the fluorometric method only identifies uranium concentrations
in ug/ml, while the radiometric method assesses the gross alpha activity in dpm/l. Given the
potentially wide range of specific activities of uranium defined by fluorometric urine data, all
fluorometrically analyzed urine would also require a concurrent radiometric evaluation of that
sample in order for these data to be useful to dose reconstruction.

From information contained in Section 5.3 of the TBD, it is unclear whether urine samples were
consistently analyzed by both fluorometric and radiometric methods. This is particularly evident
from the internal monitoring records pre-1961, where there appears to be no distinction made
between the types of urinalysis methods used. From 1961-1962, there was a transition period
where uranium in general was monitored, as well as Uranium Radiometric (UR) and Uranium
Fluoride (UF). After 1962, the type of urinalysis methods used was usually specified.

It is not unreasonable to assume that for the early years, concern for the chemical toxicity of
uranium may have limited urine bioassay to the fluorometric method. If this assumption is true,
the absence of concurrent radiometric analysis of urine samples would severely limit the value of
early fluorometric data.

Thus, in the event that a fluorometric urine bioassay cannot be matched with a concurrent
radiometric analysis, a claimant-favorable default value should be used that defines the
enrichment level of uranium. NIOSH should further explore this issue, as it might apply to the
post-1958 time period.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: Revision No. [Document No. |Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 44 of 54

supply wells. This issue should be re-evaluated to determine if this exposure route can be
properly assessed in earlier years and, if so, how to assess this exposure.

In the absence of empirical data involving neutron spectra for reactors and Pu fuel storage
facilities, the lack of dosimeter calibration methods, and the relative insensitivity of NTA film to
neutrons with less than 500 keV, there remains an undefined level of uncertainty for recorded
neutron doses. Therefore, the use of Y-12 data as surrogate values may not be appropriate.
There is no discussion of neutron-to-photon ratios in the site profile; however, it is mentioned as
an option for calculating thermal neutron exposure in the ER report. The ER indicates there are
source term data available to bound low-energy photon dose; however, no specific information
on source terms is provided. Furthermore, there is no consideration for dose from skin
contamination incidents. Additional work is needed in this area to either better define the likely
neutron dose or provide a plausible bound for the dose.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

assembly or testing (or other processing) would be inspected, and then these operations
preformed using the Vanowen building’s extensive material processing machining,
hardware fabrication and laboratory testing capabilities that, in the 1950’s, greatly
exceeded those available at SSFL/Area IV.

Deliveries to the SSFL/Area IV site, following receiving inspection, were by company
trucks using company drivers, North American Aviation was a union shop. All
deliveries between company sites were made using company transportation. The road up
the hill to the SSFL was a private, rather narrow, windy road; access was controlled by a
company guard gate at the bottom of the hill. Only company trucks, company cars, and
employee’s cars had access. Few supplier trucks were allowed on this private road, but
only after a permit from the company was obtained.

These activities at the Vanowen building continued until all the facilities at the DeSoto
building 001 were completed in the early 1960’s.

(b) No evidence has been uncovered of bioassay monitoring ever being performed for
employees at the SSFL/Area IV - Canoga Facility site during the 1950’s. Eight reports
have been found, Ref 6-a through Ref 6-h, which address radiation monitoring data at
North American Aviation sites. These reports present monitoring data for North
American Aviation sites including Downey, Canoga Park, SSFL, Area IV, DeSoto, and
in the later reports, out-lying sites east and west of the SSFL. No differences in
monitoring or radiation recording at the various sites are noted in those reports. None
mention bioassay monitoring, or results of such monitoring, Although other reports may
exist that indicate bioassay monitoring at the SSFL/Area IV - Canoga Facility site at
dates prior to 1960, these reports do not.

Ref 6-i, A Comprehensive Dose Reconstruction Methodology for Former
Rocketdyne/Atomics International Radiation Workers, authored by John D Boice, et. al,
and published in the Health Physics Journal, Nov 2005, presents a detailed review of over
46,000 Rocketdyne and Atomics International workers, covering the 1948 to 1999 time
period. Twelve and one-half (12.5%) of the total work force were monitored (in some
manner) over this period. However the data presented does not address specific time
periods. I find only one reference to 1950’s monitoring data and that is for--- urinary
data for a worker exposed to uranium before starting work at Rocketdyne/Atomics
International in the early 1960’s The earliest references for bioassay monitoring are that
“urine monitoring started in 1963”, and “bioassay sample......... summary cards for the
time period Jan 1, 1961 to Dec 31, 1967”. Nothing in the report indicates any
differences in monitoring, ot monitoring data, between the SSFL site and the site
addressed in this Petition.

(c) The planning for the move out of Vanowen building to the new facility at DeSoto had
been ‘in the works’ for at least four years prior to the move (which initiated in 1959), It

12



Effective Date: IRevision No, [Document No, [Page No.
January 30, 2009 0 SCA-SEC-TASKS5-0066, Page 39 of 54

... Because the stack effluent concentrations were at the point of release, a further
reduction factor of 0.01 was taken to account for the lessened overall intake due
to contribution from multiple, widely spaced facilities; atmospheric dispersion of
stack effluent over the course of a year’s exposure; and building wake effects.
[Emphasis added.]

4.5.2 Surrogate Use of the Time-integrated Average Yearly Gross Alpha/Gross Beta
Stack Emission Corresponding to Years 1971 to 1999

The surrogate use of the time-integrated average yearly gross alpha/gross beta stack emissions
corresponding to years 1971 to 1999 (when stack measurements were taken) is likely to
underestimate stack emissions for years 1954 through 1970. SC&A’s conclusion is supported by
the steady reduction in facility operations over time, as illustrated in Figure 4.5.2-1. For
example, nuclear reactor programs were essentially phased out in the early 1970s.

Sections 4.6.4, 4.6.5, and 4.6.6 of TBD-4 acknowledge the lack of external dose rate monitoring
data prior to 1974, and provide unsupported/unreferenced assumptions that were used to derive
annual external dose estimates for a restricted number of facilities, as given in Table 4-4 of the
TBD.

45.3 Exposure to Onsite Water Supply Wells

The SEC ER states that onsite water supply wells were the primary water source from 1949 to
1964, which differs from Section 4.7 of TBD-4, which states, “Potable water is not a source of
occupational radioactive material at SSFL, because the SSFL facilities used either bottled water
from an off-site vendor (Moore et al. 1962) or the city water supply.” In addition, other
references (Winzer 1980 and 1981; Curphey 1983) indicate that well water was a source of
drinking water into the 1980s.

Although the ER stated that the drinking water supply wells did not have elevated levels of
tritium (>1,000 pCi/1) (concern with tritium given current tritium plume on site), the ER has tried
to bound any contamination that may have existed onsite by assuming the onsite supply wells
were contaminated with tritium at a concentration of 30,000 pCi/l. More recent Boeing reports
(Boeing 2003, 2004, 2005, and 2006) have documented tritium concentrations as high as
117,000 pCi/L in the monitoring wells (not the drinking water wells). Therefore, this issue
should be re-evaluated to determine if this exposure route can be properly assessed in earlier
years, and if so, how to assess this exposure.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV ~Canoga Facility site

concurrent radiometric evaluation of that sample in order for these data to be useful to
dose reconstruction.

From information contained in Section 5.3 of the TBD, it is unclear whether urine
samples were consistently analyzed by both fluorometric and radiometric methods. This
is particularly evident from the internal monitoring records pre-1961, where there appears
to be no distinction made between the types of urinalysis methods used. From 1961—
1962, there was a transition period where uranium in general was monitored, as well as
Uranium Radiometric (UR) and Uranium Fluoride (UF). After 1962, the type of
urinalysis methods used was usually specified,

It is not unreasonable to assume that for the early years, concern for the chemical toxicity
of uranium may have limited urine bioassay to the fluorometric method. If this
assumption is true, the absence of concurrent radiometric analysis of urine samples would
severely limit the value of early fluorometric data.

Thus, in the event that a fluorometric urine bioassay cannot be matched with a concurrent
radiometric analysis, a claimant-favorable default value should be used that defines the
enrichment level of uranium. NIOSH should further explore this issue, as it might apply
to the post-1958 time period.

Section 4.3.9 There are Unanswered Questions Regarding the Completeness and
Quality of Personnel Exposure Records
In Section 5.2 of the TBD, the following statements appear:
Page 10:
...Al established health and safety files on each employee that contained
radiation exposure records, injury records, and other “pertinent” data
(Lang undated, 1960). Today, personel radiation exposure records are in
the Radiation Safety Records Management System (RSRMS), which
encompasses about 170 file cabinets. [Emphasis added.]
Page 12:
The bioassay records in the individual files generally consist of:
+ Individual Personnel Keysort Cards (Figure B-2, Attachment B), which
were used to track the type, frequency, and week of sample collection.
.. The forms can be difficult to read due to the quality of the capies,
and dose reconstructors should refer to the forms listed below for
urine and fecal data. This form might be the only place in vivo [?|
data are listed, [Emphasis added.]
Section 5.7 (page 23):
The bioassay results from ETEC and its predecessor organizations are
apparently not available in a computerized format. The units used to
report the results are generally included in the hard-copy reports. ...
[Emphasis added.]
Section 5.8 (page 23):
No codes have been found [for excreta samples]. ...

29



MAY-16-01 WED 15:48 NRC R IV FAX NO.’ 8608188 P03

Michael F. Weber ~2-

] No further action is planned by the Region for this license file unless NMSS
recommands or rediaste that additional action be ta ken.

If you have any questions concerning this memorandum or its enclosures, please
call Ms. Linda L. Howell of my staff at (817) 860-8213.

Attachments:
As stated


Effective Date:
January 30, 2009. 9 SCA-SEC-TASK5-0066 Page 4 of 54

evision No. [Document No. age No.

44

45

4.6

4.3.2 Monitoring for Internal Exposure of SSFL Workers was Incomplete
and Poorly Documented for Most Years of Facility Operation
4.3.3 Insufficient Correlation between Bioassay Data and Potential
Exposures to Specific Radionuclides...
4.3.4 Missing Radionuclides in Bioassay Da’
4.3.5 No Coworker Model....
4.3.6 Lack of Source Term Dat
4.3.7 NIOSH?’s Interpretation of Reported Values by the Contract
Laboratory Nuclear Science and Engineering Corp. (NSEC) may not
be Correct...
4.3.8 Potential Difficulties ‘Associated with Uranium Bioassay Data
4.3.9 There are Unanswered Questions Regarding the Completeness and
Quality of Personnel Exposure Records
4.3.10 Use of SSFL Site Survey Data/Source Term cannot be Regarded as
Useful Surrogate Data for Bioassay Data in Dose Reconstructios
Lack of Information with Certain Facility Incidents
4.4.1 Overview,
4.4.2 Sodium Reactor Experiment Coolant. Failure
44.3 The Sodium Burn Pit
Lack of Information on the Environmental Exposures
4.5.1 OVErVIEW...csscecescsseners
4.5.2 Surrogate Use of the Time-integrated Average Yearly Gross
Alpha/Gross Beta Stack Emission Corresponding to Years 1971 to

Assignment of External Dose
4.6.1 No Coworker Model...
4.6.2 Workers Were Unlikely to Have "Been Monitored for Thermal
Neutrons...
4.6.3 Dosimeter Response to Low-Energy Photons .

5.0 Conclusions.

6.0 — References........
Appendix A: Petitioner/Worker Interview.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. |Document No. ‘Page No.
January 30, 2009 0 SCA-SEC-TASKS5-0066 Page 29 of 54

4.3.2 Monitoring for Internal Exposure of SSFL Workers was Incomplete and Poorly
Documented for Most Years of Facility Operation

In Section 5.2 (p. 10) of TBD-5, the evaluation of the SSFL internal monitoring program is
prefaced with the following statement:

Early 1960s AI documents describe all the elements of a comprehensive radiation
safety program, including a laboratory with bioassay capability. .... [Emphasis
added.]

This statement, however, was tempered by numerous admissions in subsequent sections of the
TBD. A sampling of statements suggesting deficiencies and data limitations include the

following:
Page 13:
Specific radionuclides could be determined “where required” (Lang 1960).
Some detail has been found on early urinalysis methods. In addition to the in-
house laboratory capability, bioassay services were contracted to the following
vendors: (Eight vendors are listed.]

... Information on the periods during which ETEC used these laboratories was not
found. [Emphasis added.]

In addition to the eight contract laboratories, ETEC had its own in-house laboratory, which
analyzed urine for uranium content by fluorometric method. Exposure to uranium may have
existed in various states of enrichment up to 93%.
Page 14:
Due to its higher specific activity, EU activity could be determined by counting...

No specific information on sensitivities for the in-house laboratory was
obtained... [Emphasis added.]

Page 15 (Regarding thorium):
No details of early thorium analyses were recovered...
Page 15 (Urinalyses for period 1967-1974):
Partial documentation on bioassay methods from 1967 through 1974 was found.

... These documents are believed to refer to services offered by UST [one of the
eight contract laboratories]. [Emphasis added.]

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B; for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

dose; however, no specific information on source terms is provided. Furthermore, there is
no consideration for dose from skin contamination incidents. Additional work is needed
in this area to either better define the likely neutron dose or provide a plausible bound for
the dose.

32



ffective Date: (Revision No. [Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 32 of S4

4.3.5 No Coworker Model

The site profile has not cited an internal coworker model as necessary, and the document does
not address the use of a coworker model for those individuals potentially exposed but not
monitored, A review of some of the claimant files indicates that some workers, who it appears
should have been monitored, were not monitored, and those workers who were monitored were
not monitored on a routine basis. In many cases, the dose reconstruction reports rely on
guidance that has been developed for internal dose determinations based on other site
information, rather than relying on site information. A coworker model would allow for more
precise determinations of the doses the SSFL workers received. It is unclear whether there are
data for coworker models for all the relevant radionuclides, especially for the early years
through 1961/1962.

4.3.6 Lack of Source Term Data

TBD-5 states the following:

Without bioassay or air sample data, the last resort is determination of airborne
concentrations using source term evaluations (NIOSH 2002, p. 19). Data on the
amount of dispersible material available does not appear to be available for
ETEC.

4.3.7 NIOSH’s Interpretation of Reported Values by the Contract Laboratory Nuclear
Science and Engineering Corp. (NSEC) may not be Correct

Section 5.3.1.2 (page 14) of TBD-S5 attempts to clarify data reported by NSEC related to
urinalyses for gross alpha, gross beta, and MFPs:

Gross Alpha

Shepard (1959) gave a minimum measurable concentration of 7.5 dpm/L for gross
alpha counting. NSEC gave its minimum measurable concentration as

0.2 cpm/mL (NSEC 1957). It is assumed that this is a typographical error and
0.2 dpm/mL was intended. [Emphasis added.]

Gross Beta

Shepard (1959) gave a minimum measurable concentration of 75 dpm/L for gross
beta counting. NSEC gave its minimum measurable concentration as 1.0 cpm/mL
(NSEC 1957). it is assumed that this is a typographical error and 1.0 dpm/mL
was intended. {Emphasis added.]

Mixed Fission Products

... for beta activity with an approximate minimum detectable amount (MDA) of
60 dpm/sample [is assumed] (ORAU 2004, p. 27) .... NSEC gave its minimum
measurable concentration as 2.0 cpm/mL (NSEC 1957). It is assumed that this is
a typographical error and 2.0 dpm/mL was intended. [Emphasis added.}

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



HAY-16-01 WED 16:48 NRC R IV FAX NO, 8608188 P, 04

ATTACHMENT. 1

4 License No.: R-19

Dockat No.; 50-50

Licensee Name: Atomics International
A Division of North Amarican Aviation, Inc.

License Active: August §, 1957 - June 30, 1958

Business
Address:  P.0. Box 309
Canoga Park, California 1

Location: Reactor Room
Vanowen Facility
21600 Vanowen Street
Canoga Park, California

Activity: Operation of the 5-Watt Model L-47 Research Reactor
Background Information

Atomics International was formed as a Division of North American Aviation,
Inc., in 1985. Ouring the late 1950’s, Atomics International performed a
number of atomic energy-related activities. Under contract to the Atomic
Energy Commission (AEC) since 1948, North American Aviation/Atomics
International developed saveral prototype reactors, including sodium and
organic moderated reactors. Other projects in prograss during the 1957-1958
time frame included research into the SNAP-II satellite power system and the
Project Pluto ramjet engine. In addition, Atomics International fabricated
and installed several research reactors.

(In 1966, North American Aviation merged with Rockwell-Standard to form North
American Rockwell. The corporation’s name was subsequantly changed to
Rockwell International. Rockwell stilt has one NRC-licensed site in Canoga
Park, the Rockwell International Hot Laboratory under License SNM-2Z1.)

During December 1956-January 1957, Atomics International apparently submitted
three applications to the AEC to construct, manufacture, “possess, and use a
5-watt nuclear research reactor. Atomics International wanted to construct a
prototype reactor, the Model 1-47, for demonstration, oxparinentat ion. and
sales purposes, (A complete copy of the application package dated January 10,
1957, was obtained from Rockwell International’s files; a partial copy of the
December 7, 1956, application package was obtained; the application package
dated January 24, 1957, that was referenced in the construction permit could

not be located.) ‘

Construction Permit No. CPRR-24 was issued on August 2, 1957 (the license for
this reactor erroneously stated that tha Permit was issued on July 2, 1957),
to North American Aviation for construction of the 5-watt (thermal)
utilization facility. Ihe facility was @ “homogeneous solution-type reactor
utilizing highly enriched uranyl sulfate as fuel in distilled light water."



[Effective Date:
January 30, 2009

IRevision No.
0

[Document No.

SCA-SEC-TASKS-0066

Page No.

Page 10 of 54

Section 3.0 of this report summarizes specific concerns and issues raised in the SEC Petition-
00093, as well as NIOSH’s ER of the petition. In the ER, NIOSH provided responses to the
petition’s concems, along with the conclusion that dose reconstruction is not feasible for SSFL
workers for the years 1955 through 1958.

As a result of our review of the petition, NIOSH’s evaluation of the petition, the SSFL Site
Profile, and other documents, SC&A identified a total of five major findings (that in some cases
are supported by more detailed findings), which are cited in Section 4.0 of this report. A
discussion is provided for each finding that serves to explain the technical basis for our concern.

© Subsection 4.1: Which areas (Area IV, Canoga Park, DeSoto, and Downey) should be
considered in the SEC Petition and when did operations begin at Area IV

e Subsection 4.2: Concern whether the internal monitoring program was sufficiently robust
to estimate exposures before and after January 1, 1959

* Subsection 4.3: Lack of information related to the potential exposures associated with
facility “incidents” (Sodium Reactor Experiment, Sodium Burn Pit, etc.)

e Subsection 4.4: Lack of information on the environmental exposures (surrogate data,
drinking water, etc.)

© Subsection 4.5: Justification for assignment of external dose estimates is not provided
and there is no coworker model for external exposures (personnel records are also of

concern)

Section 5.0 provides concluding comments regarding the impacts of our findings on dose
reconstruction for SSFL workers.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. [Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASKS5-0066 Page 52 of 54

Stephenson, R.M., 1963a. Radiological Safety Incident Report from R.M. Stephenson (Health
and Safety Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident
A-0541:; Room 1059 — SSFL, March 11, 1963.

Stephenson, R.M., 1963b. Radiological Safety Incident Report from R.M. Stephenson (Health
and Safety Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident
A-0498: Room 1252, SNAP — SSFL, August 28, 1963.

Tuttle, R.J., 1985. Annual Review of Radiological Controls—1982, Rockwell International,
Energy Systems Group, Canoga Park, California. January 29, 1985.

Tuttle, R.J., 1986a. Annual Review of Radiological Controls—1982, Rockwell International,
Rocketdyne Division, Canoga Park, California. February 12, 1986.

Tuttle, R.J., 1986b. Annual Review of Radiological Controls—1984, Rockwell International,
Rocketdyne Division, Canoga Park, California. March 18, 1986.

Tuttle, R.J., 1986c. Annual Review of Radiological Controls—1985, Rockwell International,
Rocketdyne Division, Canoga Park, California. July 11, 1986.

Tuttle, R.J., 1988a. Annual Review of Radiological Controls—1986, Rockwell International,
Rocketdyne Division, Canoga Park, California. July 5, 1988.

Tuttle, R.J., 1988b. Annual Review of Radiological Controls—1986, Rockwell International,
Rocketdyne Division, Canoga Park, California. July 28, 1988.

Tuttle, R.J., 1989. Annual Review of Radiological Controls—1988, Rockwell International,
Rocketdyne Division, Canoga Park, California. May 12, 1989.

Weber, R.K., 1963. Radiological Safety Incident Report from R.K. Weber (Health and Safety
Department, Atomics International) to R.F, Wilmes, Subject: Uranium Fire Incident A-0360:
Building 004, Room 424-68 — SSFL, December 20, 1963.

Winzer, C.E., 1980. Internal Letter from C.E. Winzer (Atomics International) to “Those Listed,”
Subject: Drinking Water Supply—SSFL, August 14, 1980.

Winzer, C.E., 1981. Letter from C.E. Winzer (Atomics International) to Mr. John Curphey,
District Sanitary Engineer for the State of California, Department of Health Services, Sanitary
Engineering Section, 3704 State Street, Suite 212, Santa Barbara, California 93105, January 9,
1981,

Young, L.N., 1965. Incident Report from L.N. Young (Health and Safety, Atomics
International) to R.M. Hill, Subject: Uranium Fire Incident A-0489: Building 022, AMP
Evaporator ~ SSFL, May 18, 1965.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

accessibility. The reactors were in close proximity to a walkway between the Vanowen
Building (038) and the Engineering Annex (0-4), and after Building (043) was constructed,
close to that building.

The distance form the rear of the Vanowen Building (038) to the Main Building (001) was
approximately 40 feet. (see Figure A).

The Vanowen and the Main buildings were separated by an east-west access road; access was
available from Owensmouth St. and Canoga Ave. Although the main entrance was off
Canoga Ave., in the 1950’s the rear (Owensmouth) gate was the most-used entrance for
company trucks, deliveries and at times by company automobiles. This gate was also used
regularly by employees (it was handy for employee drop-offs). Note the green-roofed guard-
shack near the water tower. This rear gate was closed in the mid-1960’s due to the greatly
increased traffic on Owensmouth Street when the Topanga Shopping Mall was constructed
on the west side on Owensmouth Street between Vanowen and Victory Blvds).

Loading docks were on the north side of the Main building (001) and south side of the
Vanowen building (038) (re: Figure A), and were directly and easily accessible for deliveries,
and to employees for off-loading, receiving inspection and in-factory delivery. Considerable
truck and pedestrian traffic, and constant employee activity occurred at the two loading
docks, The Main building (001) was a very large, major manufacturing building for the
Corporation. The Vanowen building (038) was the “hub” for the Corporation’s nuclear
programs, Several times, assemblies of all the North American Aviation employees that
worked at the site occurred in this central open-air area between the buildings for special
Corporate events, As shown in Figure A, there was “full” employment at the site in the
1950’s and 1960's.

Emissions from the Vanowen building would have affected all employees working at the
SSFL/Area IV - Canoga Facility site.

(c) the NIOSH position in Ref. 2, “Petition Evaluation Report, Petition SEC-00093, Rev
01, submittal date: February 6, 2008’ regarding the employees to be included in the
Special Exposure Cohort for the SSFL/Area I site

In Ref 2, page 3, paragraph 4 the following is written---
“The revised NIOSH- proposed class includes all employees of the Department of Energy
(DOE), its predecessor agencies, and DOE contractors and subcontractors who worked

in any area of Area IV of the Santa Susana Field”...... (underlining added)

And on page 4, paragraph 1 states (relative to the changes made between Revision 00 and
Revision 01 to that document) ----



Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention

ness Compensation Act National institute for Occupational Safety and Health
os OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition -—- Form B Page 6 of7

Basis for Proposing that Records and Information are Inadequate for individual Dose —
Complete Section F.

Complete at least 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.

Fi Q \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.

F.2 Q 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 been lost, altered illegally, or destroyed.

Name or Social Security Number of First Petition]


Effective Date: [Revision No. {Document No. (Page No.

January 30, 2009 0 SCA-SEC-TASK5-0066 Page 7 of 54
UR Uranium Radiometric
WwW Watt
WB Whole Body

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


[Effective Date: [Revision No. [Document No. [Page No.
{__ January 30, 2009 0 SCA-SEC-TASK5-0066 Page 38 of 54

Based on information provided in TBD-5, it is unclear (1) whether workers exposed during these
early incidents were adequately monitored for internal exposure, and (2) if workers were, in fact,
monitored, whether their exposure records exist. A particular concern involves the potential
exposures associated with the SRE. Worker exposures may have included a complex mixture of
highly enriched uranium, actinides, MFPs, and various activation products, including large
amounts of Na-24.

4.5 LACK OF INFORMATION ON THE ENVIRONMENTAL EXPOSURES

4.5.1 Overview

Occupational environmental dose refers to radiation exposures received by workers while onsite
but outside the SSFL facilities from facility discharges to the atmosphere, ambient external
radiation originating in the facilities, and inadvertent ingestion of site-generated radionuclides.
The environmental monitoring program was established at Area IV in May 1954, before
construction of the first radiological facility, with emphasis on soil, vegetation, and water
sampling.

TBD-4 provides guidance and data for assigning occupational environmental doses for Area IV,
and the Downey, Canoga, and De Soto sites that make up SSFL, for all years, starting with 1954
through 1999. Due to insufficient environmental monitoring/data limitations, the TBD relied on
the following data and applied the following assumptions in order to provide the dose
reconstructor the means to estimate inhalation intakes that are radionuclide-specific and for all
years of facility operations.

Average annual gross alpha/gross beta concentrations in facility stack emissions
were the basis for estimating potential worker environmental inhalation intakes.
Most of the available SSFL stack emission data include annual average gross
alpha and gross beta concentrations at the stack point of release. Years with
data vary by facility, but gross alpha/gross beta concentration information is
available for most years between 1971 and 1999. ...

..Identification of specific radionuclides released from various facilities in stack
emissions are available ... from 1988 to 1999 and were used to characterize
radionuclide emissions for all years. ...

...In years where data were not available, stack concentrations were assumed to
be the average yearly gross alpha and gross beta concentrations in stack effluents
from years 1971 to 1999, for which data were available.

... Furthermore, the average percentage that each identified radionuclide
contributed to the gross alpha or gross beta concentration determined from 1988
to 1999 data was applied to each of these years to make radionuclide-specific
stack concentration estimates...

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. [Document No. age No.
January 30, 2009 0 SCA-SEC-TASK5-~0066 Page 47 of 54

DOE 1998. DOE Standard: The Department of Energy Laboratory Accreditation Program
Administration, DOE-STD-1111-98; U.S. Department of Energy DOE); December 1998.

Eggleston, R.R., 1983. Annual Review of Radiological Controls—1980, Rockwell International,
Energy Systems Group, Canoga Park, California, October 12, 1983,

Eggleston, R.R., 1984. Annual Review of Radiological Controls—1981, Rockwell International,
Energy Systems Group, Canoga Park, California. May 29, 1984.

Federal Register, August 23, 2004 (Vol. 69, No. 162, pp. 51825-51831).

Harrison, D.J., 1986. Internal Letter from D.J. Harris (Member, Technical Staff, Nuclear
Operation, Rockwell International) to “Those Listed,” Subject: Uranium Fire Incident A-0165:
Ignition Incident during Disassembly of Assembly #204, Cell 4 - SSFL, October 30, 1986.

Hart, 1962, Distribution of Fission Product Contamination in the SRE, NAA-SR-6890; R.S.
Hart; March 1, 1962; SRDB Ref ID: 39770 ‘

Hart, R.S., 1979. Annual Review of Radiological Controls—1975, Rockwell International,
Atomics International Division, Canoga Park, California. July 2, 1979.

Hart, R.S., 1980a, Annual Review of Radiological Controls—1976, Rockwell International,
Energy Systems Group, Canoga Park, California. April 28, 1980.

Hart, R.S., 1980b. Annual Review of Radiological Controls—1976, Rockwell International,
Energy Systems Group, Canoga Park, California. May 22, 1980.

Hart, R.S., 1980c. Annual Review of Radiological Controls—1976, Rockwell International,
Energy Systems Group, Canoga Park, California. August 6, 1980.

Hughes, Lara, NIOSH, 2008. Spreadsheet (SSFL_1959_data.xls) provided to Greg Beronja,
SC&A, Inc.

Kellehar, R.G., 1966. Memorandum to R.E. Alexander, Subject: A Basis for Routine Urine
Sampling of Workers Exposed to Plutonium-239. October 19, 1966.

Klostermann, J.P., 1961. Radiological Safety Incident Report from J.P. Klostermann
(Operational Health Physics, Atomics International) to E.C. Hickey, Subject: Uranium Fire
Incident A-0378: Building 009 — SSFL, July 13, 1961.

Lang, J.C., 1960. Radiological Safety at Atomics International, Al-Memo 5468, Atomics
International, Canoga Park, California. July 13, 1960.

Loba, MLL., 1959. Radiological Safety Incident Report from M.L. Loba (Operational Health
Physics, Atomics International) to Health Physics Supervisor, Subject: Uranium Fire Incident A-
0422: Room 807 — SSFL, September 10, 1959.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



.| Special Exposure Cohort Petition . U.S. Department of Health and Human Services
under the Energy Employees O; ipalion: 1a] : Centers for Disease Control and Prevention
FF bo pi2:40 IN National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010

liness Compensation Act

General Instructions on Completing this Form (complete instructions are available in a separate packet):
Except for signatures, please PRINT ail 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
th: ¢ petitioner, 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.

If you need more space to provide additional information, use the continuation page provided at the end of
the form and attach 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:
1-877-222-8570.

QA Labor Organization, StartatD on Page3
Ifyou An Energy Employee (current or former), StartatC on Page 2
are: QA Survivor (of a former Energy Employee), StartatB on Page 2

OA Representative (of a current or former Energy Employee), StartatA on Page 4

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

A... Are you a contact person for an organization? G Yes (Go to A.2) Q No (Go to A.3)

A.2 Organization Information:

Name of Organization

Position of Contact Person
A.3 Name of Petition Representative:

Mr./Mrs./Ms. First Name Middle Initial Last Name

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

A5 Telephone Number: ( ) :
A6 — Email Address:

AZ  @ Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization

if you are represénting a Survivor, go to Part B

Name or Social Security Number of First Petitioner:


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

under the Energy Employees Occupational Centers for Disease Control and Prevention
itiness Compensation Act . National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B Page 4 of 7
Proposed Definition of Employee C; Covered hy Petition — Complete:Section E.

E.1 Name of DOE or AWE Facility: sce Hlfachmen-

E.2 Locations at ths Facility peteyant to this Petigion:

£.3 List job titles 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

included in this flags: 4 4, en x fA

E.4 Employment Dates relevant to this petition:
stat Mov £9 SS End Sure 760 Ane ment

Start End
Start End

E.5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: O Yes Q No

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

as nee DM cccty m on Pa 4h

Name or Social Security Number of First Petitioner:



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

(SC&A notes that all chest measurements only quantified the amount or the activity of U-
235. Without a firm understanding of the level of enrichment, the more important
contribution of U-234 to total alpha activity cannot be determined.)

Page 25 (On solubility type, fraction activity, and particle size per facility):
In the absence of any measurements or studies, NIOSH guidance requires
the use of defauit solubility classes and particle size values from the
International Commission on Radiological Protection. ... With one
exception, facility-specific solubility and particle size data for ETEC has
not been found. Activity fractions were not available with the exception of
those for limited fuel fabrication operations. ... Table 5-9 lists
[recommended/default] this information (emphasis added). [Our review of
Table 5-9 indicates that to date, (1) a solubility class has not been assigned
to all radionuclides, (2) activity fractions are lacking for several facilities,
(3) activity fractions are based on inappropriate data, and (4) activity
fractions fail to identify select radionuclides (e.g., Na-24, radioiodines)}.

Section 4.3.3 Insufficient Correlation between Bioassay Data and Potential

Exposures

Two sources (NIOSH 2008, ORAUT 2006e) state that there is sufficient bioassay and

other supporting data available for 1959 and beyond to establish an upper bound for

uranium, mixed fission products (MFPs), Po-210, plutonium, SR-90, tritium, and
thorium. Of the 37 internal monitoring records available to SC&A, 78% were monitored

for uranium, 62% for mixed fission products, 0% for polonium, 24% for plutonium, 5%

for strontium, 14% for tritium, and 0% for thorium.

SC&A does not believe that these sources have clearly demonstrated a correlation
between the bioassay data available and the potential exposures to specific
radionuclides. They have not clearly defined for which workers each of the
procedures were conducted, including gross alpha and gross beta. From a brief
review of claimant files, it appears that monitoring was not routine for all workers
handling radioactive material. Furthermore, detection limits for 1975-1988 are
unavailable, and Table 5-9 in TBD-5 containing solubility type and fraction of
activity is incomplete in many cases, Hence, it appears that there were significant
limitations in the bioassay program in 1959, and perhaps for a few years beyond
1959,

Section 4.3.4 Missing Radionuclides in Bioassay Data The site profile indicates that
bioassay data were available for gross alpha, gross beta, uranium, fission products,
plutonium, thorium, Po-210, Sr-90, H-3, P-32, S-35, C-14, Pm-147, americium, and
curium. Of the 37 internal monitoring records available to SC&A, the vast majority of
monitoring was for uranium and mixed fission products; 78% and 62%, respectively.
Fission products were monitored for 49% of the workers. Only a few monitoring records
exist for the following radionuclides: 8% for cesium, 3% for beryllium, 3% for mercury,
3% for potassium, 0% for polonium, 24% for plutonium, 5% for strontium, 14% for

27



[Effective Date: [Revision No.
January 30, 2009 0

|Document No.

SCA-SEC-TASK5.0066

[Page No.
Page 54 of 54

APPENDIX A: PETITIONER/WORKER INTERVIEW

To be provided at a later date.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.



lEffective Date: Revision No. [Document No, Pee No.
January 30, 2009 0 SCA-SEC-TASKS5-0066 Page 49 of 54

Mooers, A.R., 1961c. Radiological Safety Incident Report from A.R. Mooers (Operational
Health Physics, Atomics International) to R.F, Wilmes, Subject: Uranium Fire Incident A-0455:
Room 1059 — SSFL, July 24, 1961.

Moore, J.D., W.L. Fisher and P.A Rowe, 1962. Environmental Monitoring Semi/Annual Report
January 1, 1962 to June 30, 1962. NAA-SR-7650, Atomics Intemational, Canoga Park,
California. November 30, 1962.

NIOSH (National Institute for Occupational Safety and Health) 2002. External Dose
Reconstruction Implementation Guideline, Rev. 1, OCAS-IG-001, Office of Compensation
Analysis and Support, Cincinnati, Ohio.

NIOSH. 2008. SEC Petition Evaluation Report, Petition SEC: 00093: Santa Susana Field
Laboratory (SSFL), February 6, 2008.

NSEC (Nuclear Science and Engineering Corporation) 1957. Urinalysis Service Brochure,
September 1957, Pittsburgh, Pennsylvania.

Oldfield, K.G., 1961. Radiological Safety Incident Report from K.G, Oldfield (Operational
Health Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0550:
Building 4, Room 423-29 — SSFL, February 14, 1961.

ORAU (Oak Ridge Associated Universities), 2004, Technical Basis Document for the Hanford
Site—Occupational Internal Dose, ORAUT-TKBS-0006-5, Rev. I, Oak Ridge, Tennessec,
November 24.

ORAUT (Oak Ridge Associated Universities Team) 2006a. Technical Basis Document: Atomic
International — Introduction, ORAUT-TKBS-0038-1, Rev. 01. Oak Ridge Associated
Universities Team, Cincinnati, Ohio. August 30, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2006b. , Technical Basis Document: Energy
Technology Engineering Center — Site Description, ORAUT-TKBS-0038-2, Rev, 00. Oak Ridge
Associated Universities Team, Cincinnati, Ohio. February 2, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2006c, Technical Basis Document:
Atomics International — Occupational Medical Dose, ORAUT-TKBS-0038-3, Rev. 01. Oak
Ridge Associated Universities Team, Cincinnati, Ohio. September 8, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2006d. Technical Basis Document: Energy
Technology Engineering Center - Occupational Internal Dose, ORAUT-TKBS-0038-5, Rev. 00.
Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 22, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2006e. Technical Basis Document for
Atomics International — Occupational External Dosimetry, ORAUT-TKBS-0038-6, Rev. O1.
Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 6, 2006.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —-Canoga Facility site

the corner of Canoga Ave and Victory Blvd; and a new, four-story office building was
constructed at the south-east corner of Canoga Ave and Victory. Blvd.)

It was the practice of the Corporation to use floor space, test labs and manufacturing facilities
where-ever they existed for which-ever of the Corporation’s programs or divisions needed
them, and such usage could be re-assigned overnight, immediately. As a result employees of
a Corporation division or subdivision often worked, for varying periods, in locations not
normally associated with their division or subdivision.

In the late 1950’s construction began at a new site (i.e., the DeSoto Facilities site)
approximately 4 miles north-east of the Canoga Facilities site. I believe that occupancy at
the DeSoto site first started in the large manufacturing building (101) in 1959. Vanowen
building employees and manufacturing capabilities started transferring to the DeSoto Facility
site. As the administrative and engineering buildings (building 102 and 103) were completed
employees moved in. The L-77 reactor in the Vanowen building was later moved into
Building 104 at the DeSoto Facilities site. The entire move into the DeSoto site was
completed, as I recall, over a period of about 2 years. As space became available in the
Vanowen building other North American Aviation operations and employees moved into the
building.

The Corporation’s aggressive building program is discussed to illustrate the growing “floor
space” needs that occurred in the 1950’s. The Corporation was similarly aggressive in its
policy of allocation of building floor space to which-ever Corporation division, subdivision,
etc. had immediate needs.

(f) the practice of employee loan-outs and transfer of employees between divisions,
subdivisions, departments and work groups located at the SSFL/Area IV - Canoga Facility
site

North American Aviation utilized an internal support system called “Interdivisional Work
Authorization’s” (IDWA’s) to effectively permit rapid, easily-implemented transfer of a task
or work effort from one Corporate division to another, and with a minimum of paperwork.
Such a task or work effort could be an engineering analysis or design task, laboratory testing,
machining, welding or assembly of hardware, etc. The IDWA system was encouraged by the
Corporation and permitted a task or work effort to be transferred from one Corporate division
(or subdivision, etc.) to another, to balance division work loads and/or to utilize special
capabilities that might be available (i.e. specialized machine tools, unique lab capabilities,
available test facilities, etc).

When an IDWA was used, personnel from the sponsoring group were assigned as the
interface. and provided on-location support and direction. This would result in an
employee’s work location to be temporally changed for what was often an extended period.



Effective Date: (Revision No. cument No, \Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 19 of 54

NIOSH concludes the following based on the reports reviewed:

Although there is not a consensus on the exact amount of gaseous radioactive
materials released to the environment following the incident, all pertinent
Scientific reports conclude that a significant amount of fission products were
released into the primary sodium coolant, with a percentage of that inventory
being released to the reactor’s cover system, and subsequently released into the
atmosphere through reactor building vent systems and from gaseous storage
tanks. The type and range of releases to the environment following the fuel
damage run from less than 1 Ci of iodine-131 (Christian, 2005) to a conservative
upper bound estimate of approximately 3000 Ci of iodine-131 (Lochbaum, 2006).
Based on documented stack releases during the incident, AI concluded that since
no iodine-131 was detected in cover gas, only about 28 Ci of the noble gases
krypton-85 and xenon-133 were released from the stacks to the environment
(Rutherford, 2005).

Based on their review of claims in NOCTS, NIOSH concluded that personnel monitoring exists
for members of the proposed class (both internal monitoring and external monitoring) during the
timeframe of the SRE event. NIOSH also notes that some air monitoring measurements from the
reactor area and stack monitoring also exist.

Section 4.4.2 of this report presents our concerns related to the robustness of the internal
monitoring of staff who may have worked in the SRE area. The potential that all staff may not
have been properly monitored, combined with the seriousness of this event, suggests that it may
be necessary to develop an exposure model for this incident or conclude that exposures cannot be
properly evaluated.

Response to #2: iati
NIOSH’s response to this issue is captured in the following statement:

The Tiger Team Report cited by the petitioner does not state that the dosimeters
were inadequate, but that they were not Department of Energy Laboratory
Accreditation Program (DOELAP) accredited, and it specifically focuses on the
D&D period versus the period being evaluated in this report. As it relates to the
program being discussed in the Tiger Team report, it was common practice (and
is noted as an option in Section 7 of the DOELAP Administrative Standard DOE-
STD-1111-98) for smaller programs to be exempted from DOELAP accreditation,
contingent upon using a National Voluntary Laboratory Accreditation Program
(NVLAP)-accredited commercial service (DOE, 2006). However, this is pertinent
only beginning in 1986 when the DOELAP requirements were implemented.
Therefore, as discussed previously, the period cited in the petition is after the
period of the evaluation and does not impact this evaluation report.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



‘59 nuclear reactor accident remains vivid for former Santa Susana Field Laboratory w... Page 1 of 6

Kee 5

'59 nuclear reactor accident remains vivid for
former Santa Susana Field Laboratory worker

Field lab meltdown | 50 years later delayed reaction

By Teresa Rochester
Sunday, July 12, 2009

Something was wrong. John Pace saw it in the men’s faces, heard the anxiety in their voices and felt the
nervous excitement in the nuclear reactor control room at the sprawling Santa Susana Field Laboratory. “I
knew something had happened,” said Pace, then a 20-year-old Moorpark resident working as a reactor
trainee at the Sodium Reactor Experiment in the hills of eastern Ventura County.

At 6:25 p.m. on July 13, 1959, the experimental reactor’s power went out of control, forcing a manual
emergency shutdown after an automatic shutdown failed to kick in. It was the beginning of a partial
meltdown, a rarity in U.S. history.

For 13 days, officials turned the damaged reactor on and off despite high radiation levels, more emergency
shutdowns, and the release of radioactive gases into the air. In some cases, the readings exceeded
monitoring instruments’ capacity to measure them.

Workers at the reactor, operated by Atomics International, would discover that 13 out of 43 fuel elements
were damaged during that period as portions of steel tube encasements melted into the uranium alloy fuel
rods.

“The key to the excitement was they barely got the thing shut down before going critical and having an.
explosion,” Pace said in a recent interview, recalling the events of that night 50 years ago. “They just felt so
good that they were still alive and they got it shut down.”

Pace was handed a roll of tape to keep radiation from seeping out of the reactor room and told to get to
work. He sealed and double-checked doorways and other openings leading from the reactor area to nearby
offices. A rookie tasked with learning on the job, Pace had received his security clearance and accepted the
job only four months earlier.

For the next 49 years, Pace honored the top-secret nature of the work at the reactor, which was used in
physics experiments and intermittently generated electricity for the town of Moorpark.

In recent years, knowledge of what occurred that summer has weighed heavily on the retiree’s shoulders.

His reluctance to speak out began to wane when he saw a TV documentary about the little-known partial
nuclear meltdown. Pace watched himself working on the reactor in vintage film, recorded for training
purposes in fall 1959 and featured in the History Channel’s “Modern Marvels” episode about California’s

first partial meltdown.

Moved to bear witness
mhtmi:file://C:\Documents and Settings\Vernon\Desktop\Corhort Petition\'59 nucle... 7/23/2009



“78 UA Zh JO spuowrorinbe ay unpIM Appiqvortdde Jo Aoemooe penyouy JO} YVTCIH
TOYO Ay pue BoTEIpEY wo prog Arostapy arp Aq pamolAas wseq Jou sey pur jeuoIstoap-osd sy 1wOdex sup ‘JaaamMoHL
“UOHRRAUISIP Jo} pareo]o udeq say pue UOHEULIOZUI IY KoBAlEd 10} POMOIADI UdEq Sey WOdaI SIAL ?AOLLON

SOTAWDY AI vor Jo LreuuINg ILe'sy omni

piece: parwis |
-209jsnu 19) e992 an.Abid |
9§ peuTHaeIZe KL OUY |

bn,

0964

: 13 z
OGG “2208 : dma) taccweu tina Riey PARR ry i g*
r &
S6Gs-F968 Le,
i
ig Pe i 5
“aan i?
ag
a
‘omy. (OMMPLNdS pesuEAY
ieee Peer H
E
arctic aaa i
cori i
fyedseves Seiwasi #4, TeUORRUsAS Daya MONDAY UOSYOAY YUON
qewsts gait SEBEEZEE asoLresss
9S 50 OF Seg 9900-SASVL-DS-VOS 0 6007 “0 Arenuey

“ON a8eq| “oN uaUMOG) “ON WOISTATY| rated aanoayyal



Ree, 3

Draft

ADVISORY BOARD ON
RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

Review of the Santa Susana Field Laboratory (SSFL) Area IV
Special Exposure Cohort (SEC) Petition-00093
and the NIOSH SEC Petition Evaluation Report

Contract No. 200-2004-03805
Task Order No. 5
SCA-SEC-TASKS5-0066

Prepared by

S. Cohen & Associates
1608 Spring Hill Road, Suite 400
Vienna, Virginia 22182

Saliant, Inc.
5579 Catholic Church Road
Jefferson, Maryland 21755

January 2009

Disclaimer

This document is made available in accordance with the unanimous desire of the Advisory Board
on Radiation and Worker Health (ABRWH) to maintain ail possible openness in its
deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the
time of its release, this report is pre-decisional and has not been reviewed by the Board for
factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once
reviewed hy the ABRWH, the Board’s position may differ from the report’s conclusions, Thus,
the reader should be cautioned that this report is for information only and that premature
interpretations regarding its conclusions are unwarranted,


Effective Date: [Revision No. |Document No, Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 13 of 54

(5) Cold Trap Vault (Building 4695)

(6) Liquid Radioactive Waste Vault (Building 4653)

(7) Interim Radioactive Waste Storage Area (Area 4654)
(8) Intermediate Contaminated Storage Area (Area 4689)

2.2.3 Systems for Nuclear Auxiliary Power Reactors

The Systems for Nuclear Auxiliary Power (SNAP) program operated from 1956 to 1971 to
support the development and testing of small reactors designed to provide power for research
missions in space. The SNAP reactors were uranium-zirconium hydride reactors that used fully
enriched (93%) uranium dispersed in fuel rods containing zirconium hydride. Seven SNAP
reactors were tested and operated in Buildings 4010, 4024, 4028, and 4059.

2.3. CRITICAL TEST FACILITIES

Several programs used critical test facilities (i.c., low-power reactors) in Area IV. Use of these
low-power reactors began in 1954, and continued until 1974. The critical test facilities included
SNAP development test facilities, which were housed in Buildings 4373, 4012, 4019, and 4024.
Critical test facilities supporting the development of civilian nuclear power included Buildings
4009 and 4100.

2.4 NUCLEAR SUPPORT OPERATIONS

Starting in 1956, several operations were conducted in Area IV to support nuclear programs.
These included the manufacture, management, and disassembly of fuel for reactor operations, as
well as the operation of nuclear waste management facilities for offsite disposal.

2.4.1 Reactor Fuel Manufacturing

As part of the nuclear reactor development work performed for the government, three different
reactor fuel manufacturing operations occurred at the SSFL in Buildings 4003, 4055, and 4064.
The first operation was the assembly of fuel elements for the SRE, the second was a plutonium
fuel manufacturing facility, and the third was a uranium carbide fuel pilot plant. There was also
a Fuel Storage Facility, used to store the Special Nuclear Materials (enriched uranium and
plutonium) used to make the fuels.

2.4.2 Disassembly and Examination of Reactors and Used Reactor Fuel Assemblies

During reactor test operations, it was often necessary to examine reactor fuel assemblies and
other test specimens to determine how they were performing. This involved handling and
examining highly radioactive items, for which the Hot Lab operated in Building 4020 from 1959
to 1990. The Hot Lab was a 16,000-f? facility containing four large hot cells with remote
manipulators and cranes, a mock-up atea, an operating area, and decontamination areas.
Construction was completed in 1959, and the facility was used until 1990.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: Revision No. |Document No. Page No.
January 30, 2009 9 SCA-SEC-TASKS-0066 Page 18 of 54

The ER (p. 11) states the “NIOSH-proposed class includes all employees who were monitored or
should have been monitored for internal radiological exposures while working in all areas of
Area IV.”

While the original petition requested that all employees be considered, NIOSH has restricted the
employces included in the class to either those who were monitored or should have been
monitored. This inconsistency needs to be addressed and further instruction should be provided
as to who is covered.

Furthermore, the actual proposed addition to the class restricts the addition to those employees
who were actually monitored, rather than to the potentially broader class of those “who were
monitored or should have been monitored.” NIOSH normally includes this broader definition in
its SEC class additions, and it is unclear why NIOSH has proposed a narrower addition to the
SEC class in this case. Specifically, while the practice of issuing badges to workers who entered
controlled areas is documented for the most part, the issue of environmental doses and doses due
to exposure to the sodium burn pit and other areas outside buildings needs to be taken into
account in the class definition.

Data and information employed by NIOSH in its evaluation are cited in Section 4.0 of the ER.
The recommendation to approve the SEC status of this modified class was based on NIOSH’s
conclusion that it could not estimate internal exposures with sufficient accuracy during the
period from 1955 through 1958 (which is a period NIOSH has stated as having limited internal
monitoring data). NIOSH states that this timeframe corresponds with the date after which an
established bioassay program existed at SSFL and after which sufficient internal monitoring has
been identified.

Sections 5.0 and 6.0 of the ER provide summary descriptions of SSFL processes, SSFL
monitoring practices, and available monitoring data, These data closely paraflel information
contained in the six TBDs that define the SSFL Site Profile and provide the technical basis for
Section 7.0 of the ER.

While Sections 7.1, 7.2, and 7.3 of the ER address the generic feasibility of internal and external
dose reconstruction for SSFL workers, Section 7.4 addresses specific issues and concerns
identified in the SEC petition, as summarized below.

3.3. NIOSH’S RESPONSE TO MAJOR ISSUES RAISED IN SEC-00093

3.3.1 Responses to Six Issues Identified in the SEC Petition and During Discussions with
the Petitioner

Response to Issue #1: SRE Incident and Release of Core Gases

NIOSH states that several documents were reviewed in the preparation of the ER (Lochbaum
2006; Hart 1962) beyond what was reviewed as part of the site profile. It should be noted that
there are at least two key documents (AI 1959 and 1961) that were prepared related to this
incident that were not reviewed as part of the site profile or ER.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


iffective Date: [Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 14 of 54

2.4.3 Fabrication, Use, and Storage of Radioactive Sources

Operations at SSFL required many instruments for detecting and measuring radioactivity, and
these instruments were calibrated periodically using known quantities and types of radioactivity
called sources, which were sealed containers that included small measured quantities of
radioisotopes. Sources were also used for some forms of radiography, irradiation testing, and
other applications. Sources were manufactured in the Hot Lab at SSFL, and used in various
facilities at SSFL and elsewhere. Approximately 140,000 Ci of radioactive material (primarily
Pm-147) were fabricated into sources at the Hot Lab. They were stored in secured locations and
used under carefully controlled conditions.

2.4.4 Preparation of Radioactive Material for Disposal

The operation of nuclear reactors generates radioactive waste and other radioactive material that
must be disposed of offsite. Other operations at the SSFL (fuel fabrication, reactor and fuel
examination, etc.) also generated radioactive waste. Radioactive waste was prepared for disposal
at the Radioactive Material Disposal Facility (RMDF) with support at the Interim Storage
Facility (ISF) in Building 4654.

2.4.5 Research on Reprocessing Used Reactor Fuel

The Hot Cave in the Engineering Test Building supported licensing of nuclear fuel reprocessing.
The used fuel assemblies from nuclear reactors contain unused fissionable material, fissionable
transuranic products (mainly plutonium), and fission products. Rockwell developed a process to
make a partial separation of used fuel, removing part of the fission products so that the material
could be used again as reactor fuel. The experiments used up to one kilogram quantities of
unirradiated uranium and thorium, and up to 100-g quantities of highly irradiated materials.

2.4.6 Operation of Particle Accelerators

Rockwell operated a Van de Graaff generator in Building 4030, bombarding tritium targets with
deuterons to produce neutrons. A second Van de Graaff generator was operated for neutron
activation of materials.

2.4.7 Research Using Radioisotopes

Some of the research at the SSFL required the use of special radioisotopes. For these tests, small
quantities of specially prepared radioisotopes were brought to the SSFL, used in laboratories
under carefully controlled conditions, and then either returned to the vendor or stored safely
when reuse was required,

2.4.8 Miscellaneous Operations

Two of the facilities at SSFL, the Conservation Yard and the Sodium Disposal Facility (also
referred to as sodium burn pit), were not intended for use with radioactive materials, but both

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. [Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 43 of 54

5.0 CONCLUSIONS

After a thorough review of SEC Petition-00093 and the large number of relevant/support
documents, it is still unclear as to which of the four facilities should be covered in the petition
and the initial year of coverage, which is dependent on whether all four facilities are covered in
the petition or if it is just Area TV of SSFL that is covered, The list of covered sites in the DOE
database is not consistent with the list of covered sites identified in the August 23, 2004, Federal
Register. If only Area IV of SSFL is covered in the petition, it is not clear whether the initial
date of coverage is 1953, 1954, or 1955. Ifit is determined that all four facilities will be
included in the SEC Petition, the initial coverage date will need to be changed to 1947 or 1948.
NIOSH and DOE should make this decision, based on further research.

SC&A agrees with the findings in the SEC ER that the internal monitoring program was
insufficiently robust to estimate exposures before January 1, 1959. Only limited amounts of
internal personnel monitoring data for pre-1959 exposures were identified, which is consistent
with NIOSH’s findings that an SSFL routine bioassay program was not initiated until August
1958 (Kellehar 1966). Our review of the percentage of workers being monitored for internal
exposure indicates that the percentage continued to increase after 1959, until it plateaued several
years later. A determination needs to be made by NIOSH on whether the percentage of workers
who were monitored in the several years after 1958 indicates a fully functioning internal
monitoring program.

In addition, monitoring for internal exposure of SSFL workers was incomplete and poorly
documented for most years of facility operation. These deficiencies and data limitations are
stated throughout sections of the TBD. For 1959 and beyond, SC&A does not believe that
NIOSH has clearly demonstrated a correlation between the bioassay data available and the
potential exposures to specific radionuclides.

There is a lack of information concerning two major facility incidents that had significant
potential for internal or external exposure to personnel; the SRE coolant failure and the sodium
burn pit. TBD-5 does not specifically address radiological incidents that may have resulted in
internal exposures to workers’ that were unmonitored and, based on our review of claimant files,
it does not appear that all workers who should have been badged were indeed badged. As noted,
the poor track record of badging employees appropriately indicates a need for NIOSH to revisit
the limitation for its proposed addition to the SEC class only to employees who were monitored.
The information in TBD-S is unclear as to whether workers exposed during these early incidents
were adequately monitored for internal exposure and, if workers were monitored, whether their
exposure records exist.

SC&A questions the data and unsupported/unreferenced assumptions that were applied in order
to reconstruct occupational environmental doses, due to insufficient environmental monitoring
and data limitations. This includes inhalation intake estimates that are radionuclide-specific and
the surrogate use of the time-integrated average yearly gross alpha/gross beta stack emissions
corresponding to years 1971 thru 1999, which likely underestimate stack emissions for years
1954 through 1970. There are also conflicting reports concerning the exposure to onsite water

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: [Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 53 of 54

Young, W.A., 1960. Internal Letter from W.A. Young (Solid Waste Chemistry Unit, Atomics
International) to R.H. Beight, Subject: Uranium Fire Incident A-0006: Explosion in Room 426-
13 ~ SSEL, July 27, 1960.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82,



[Effective Date: [Revision No. Pocurent No. Page No.
January 30, 2009 0 SCA-SEC-TASKS5-0066 Page 8 of 54

1.0 INTRODUCTION
1.1. SCOPE AND PURPOSE OF SEC REVIEW

During the meeting of the Advisory Board on Radiation and Worker Health (the Board) held in
Redondo Beach, California, on September 4, 2008, S. Cohen & Associates (SC&A) was directed
by the Board to perform a “paper” review of the Santa Susana Field Laboratory (SSFL) Special
Exposure Cohort (SEC) Petition-00093 and the NIOSH SEC Petition Evaluation Report (ER) for
said petition.

The scope of this review addresses specific issues of concern raised in the petition and NIOSH’s
response to these concerns, as given in the ER. SC&A reviewed hundreds of documents that
were considered relevant to the petition. Documents reviewed include the following:

© Documents that were referenced and/or enclosed in the petition
© Documents referenced/cited in the ER and site profile
« Documents contained in the NIOSH Site Research Query Database

The purpose of this review is to provide the Board with an independent assessment of issues and
concerns that surround the petition and NIOSH’s response and proposed methods for
accommodating these issues/concerns. Findings identified in our review are expected to provide
the Board with a preliminary overview of potential issues that may impact the feasibility of
dose assessment. Following a formal, multi-step resolution process, any unresolved findings
may then be used by the Board for determining whether radiation doses can be estimated with
sufficient accuracy, as defined in 42 CFR §83.13(c)(1). In addition, since this review was
limited to a paper study, there will likely be a need to follow up this report with a site visit,
interviews with claimants and petitioners, and the retrieval and review of additional documents,
in accordance with Board-approved procedures for the review of SEC petitions and associated
evaluation reports. It is for this reason that this report is referred to as “preliminary” and as a
“paper study.”

1.2. TECHNICAL APPROACH AND REVIEW CRITERIA

The approach used by SC&A to perform this review follows the protocols described in the draft
report prepared by SC&A entitled, Board Procedures for Review of Special Exposure Cohort
Petitions and Petition Evaluation Reports, Revision 1 (SC&A 2006a), and the Report to the
Working Group on Special Exposure Cohort Petition Review (SC&A 2006b). The latter is a set
of draft guidelines prepared by a Board-designated working group for evaluation of SEC
petitions performed by NIOSH and the Board. The former is a set of draft procedures prepared
by SC&A and approved by the Board for use by SC&A on an interim basis (ABRWH 2006,

p. 132). The procedures are designed to help ensure compliance with Title 42, Part 83, of the
Code of Federal Regulations (42 CFR 83) and implement the guidelines provided in the report of
the working group.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



- |Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Contrgi and Prevention
\liness Compensation Act National Institute for OccupationalSafety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
pecial Exposure Cohort Petition — Form B Page 3 of 7

Labor Organization Information — Complete Section D ONLY if you are a.iabor organization.

Ss

D.1.—_ 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
City State Zip Code
D.4 ‘Telephone Number of Petition Representative: )

D.5 ‘Email Address of Petition Representative:

D.6 Period during which tabor ofganization represented employees covered by this petition
(please attach documentatign): Start End

D.7 Identity of other labor grganizations that may represent or have represented this class of
employees (if known

Name or Social Security Number of First Petitioner:



MAY-16-01 WED 15:49 NRC R IV FAK NO. 6608188 P, 08

~3-

Several former employees of Atomics International ware interviewed, including
W. L. Fisher, former Branch Chief of the Nuclear Materials Licensing Branch in
Region IV. None could recall the final disposition of the L-47 reactor.

Records were located that indicated that Atomics International had a wel]
defined radioactive waste handling and disposal program, including a method of
dispasing of spent reactor fuel, Atomics International most likely disposed
of the reactor and the spent fuel through their normal waste disposal channels
in compliance with AEC regulations in effect at the time.

Summary

Additional information related to the L-47 reactor, Docket File 50-50, was
obtained during the site visit. This information included limited amounts of
construction, operation, environmental monitoring, and decommissioning
racords, Unfortunately, records associated with the disposal of the L-47
reactor were not located. Records were identified that provided disposition
information for some of the reactor fuel.

| former Reactor Room was tourad and was found to be free of radioactive

e
materials which indicated that the area had been successfully femediated by

either Atomics International or Roc: nternattonal in the past.



ffective Date: (Revision No. |Document No. Page No.
J 30, 2009 0 SCA-SEC-TASKS-0066 Page 31 of 54

Page 25 (On solubility type, fraction activity, and particle size per facility):

In the absence of any measurements or studies, NIOSH guidance requires the use
of default solubility classes and particle size values from the International
Commission on Radiological Protection. ... With one exception, facility-specific
solubility and particle size data for ETEC has not been found. Activity fractions
were not available with the exception of those for limited fuel fabrication
operations. ... Table 5-9 lists {recommended/default] this information (emphasis
added). [Our review of Table 5-9 indicates that to date, (1) a solubility class has
not been assigned to all radionuclides, (2) activity fractions are lacking for several
facilities, (3) activity fractions are based on inappropriate data, and (4) activity
fractions fail to identify select radionuclides (e.g., Na-24, radioiodines)].

4.3.3 Insufficient Correlation between Bioassay Data and Potential Exposures to Specitic
Radionuclides

Two sources (NIOSH 2608, ORAUT 2006e) state that there is sufficient bioassay and other
supporting data available for 1959 and beyond to establish an upper bound for uranium, mixed
fission products (MFPs), Po-210, plutonium, SR-90, tritium, and thorium. Of the 37 internal
monitoring records available to SC&A, 78% were monitored for uranium, 62% for mixed fission
products, 0% for polonium, 24% for plutonium, 5% for strontium, 14% for tritium, and 0% for
thorium.

SC&A does not believe that these sources have clearly demonstrated a correlation between the
bioassay data available and the potential exposures to specific radionuclides. They have not
clearly defined for which workers each of the procedures were conducted, including gross alpha
and gross beta. From a brief review of claimant files, it appears that monitoring was not routine
for all workers handling radioactive material. Furthermore, detection limits for 1975-1988 are
unavailable, and Table 5-9 in TBD-5 containing solubility type and fraction of activity is
incomplete in many cases. Hence, it appears that there were significant limitations in the
bioassay program in 1959, and perhaps for a few years beyond 1959.

4.3.4 Missing Radionuclides in Bioassay Data

The site profile indicates that bioassay data were available for gross alpha, gross beta, uranium,
fission products, plutonium, thorium, Po-210, Sr-90, H-3, P-32, S-35, C-14, Pm-147,
americium, and curium. Of the 37 internal monitoring records available to SC&A, the vast
majority of monitoring was for uranium and mixed fission products; 78% and 62%, respectively.
Fission products were monitored for 49% of the workers. Only a few monitoring records exist
for the following radionuclides: 8% for cesium, 3% for beryllium, 3% for mercury, 3% for
potassium, 0% for polonium, 24% for plutonium, 5% for strontium, 14% for tritium, and 0% for
thorium. Potential exposure to radionuclides such as U-233 and U-234 could have occurred
during these operations, but it may not be possible to determine this, given the limitations of
uranium monitoring (see below).

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



‘ffective Date: [Revision No, [Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066, Page 17 of S4

3.2

Issue #2: Radiation Badges. This issue was based on a Tiger Team report indicating
“inadequate radiation badges.”

Issue #3: Tritium Plumes. The petitioner was concerned that there may have been
employee exposure to the tritium plumes through the consumption of drinking water.

Issue #4: Uranium Fires. The petitioner references many uranium fires and cites two
incidents of a sodium explosion, and it appears to express concern that there was
insufficient or no monitoring associated with these and similar incidents.

Issue #5: Air Monitoring. The petitioner was concerned that there was insufficient air
monitoring, and NIOSH agrees with this prior to 1958.

Issue #6: The Sodium Burn Pit. The concern with the pit is that there was no monitoring
of the pit and no records were maintained.

SEC PETITION EVALUATION REPORT

On February 6, 2008, NIOSH issued its SEC Petition Evaluation Report (ER) for SEC-00093.
Section 1.0 of the ER states that this report evaluated “. . . the feasibility of reconstructing doses
for all employees who worked in any area of Santa Susana Field Laboratory-Area IV during the
time period from January 1, 1955 to December 31, 1965...” [Emphasis added.]

Under 42 CFR § 83.13(c)(1), the feasibility to reconstruct doses includes the following:

.. . radiation doses [that] can be estimated with sufficient accuracy if NIOSH has
established that it has access to sufficient information to estimate maximum
radiation dose for every type of cancer for which radiation doses are
reconstructed, that could have been incurred in plausible circumstances by any
member of the class, or if NIOSH has established that it has access to sufficient
information to estimate the radiation dose of members of the class more precisely
than an estimate of the maximum radiation dose. [Emphasis added.]

The ER responded to specific concerns and issues raised in the SEC Petition, as summarized
above in Section 3.1, and concluded the following:

... Based on its full research, NIOSH modified the petitioner-requested class to
define a single class of employees for which NIOSH cannot estimate radiation
doses with sufficient accuracy. The NIOSH-proposed class includes all
employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors and subcontractors who were monitored while working in any
area of Area IV of the Santa Susana Field Laboratory for a number of work days
aggregating at least 250 work days from January 1, 1955 through December 31,
1958, or in combination with work days within the parameters established for one
or more other classes of employees in the SEC. [Emphasis added.]

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.



‘59 nuclear reactor accident remains vivid for former Santa Susana Field Laboratory w... Page 6 of 6

~ ‘removed, Pace said.

“With the seal broken on the lid of the reactor, it released radioactive contamination that had to be cleaned
up,” he wrote in pencil on a copy of the photograph.

Pace believes the exposure to contamination caused his health problems and those of other workers, He was
diagnosed with a precancerous skin condition and has trouble with his lungs.

He and Geneva were unable to conceive children for seven years after he left the Field Lab. In 1966, his
doctor diagnosed him with temporary sterility, which he links to the reactor, and his wife had a number of
miscarriages before giving birth to their three children.

He doubts report on exposure

While visiting the lab last winter, Phil Rutherford, manager of health, safety and radiation services for the
Boeing Co., said he showed Pace his “dosimetry report,” which documents how much radiation a person has
been exposed to, Pace’s report showed “a minor level of exposure.”

Pace said that several years ago he heard there was such a report, but he puts no faith in it because the
records are incomplete, because some were lost and workers’ exposure wasn’t always recorded because film
badges weren’t always worn.

“We didn’t wear our badges there all the time,” Pace said, adding that supervisors would tell the workers not
to wear them. “That’s what they wanted.”

Pace said he understands that officials today are limited in their f understanding of what happened to the
documents available to them.

“I have no ill feelings towards them because they were not there,” Pace said of officials today. “They can
only go on the records they have.”

He said he was motivated to speak up to add to the public’s knowledge about the events, which some
researchers have blamed for possibly hundreds of cancer cases among workers and people who lived near
the hill.

“It’s a cleansing feeling to get it out of you and be able to speak about it,” Pace said. “It relieves a lot of
pressure, but it’s a scary thing also.”

Pa

© 2009 Ventura County Star

mhtmi-file://C:\Documents and Settings\Vernon\Desktop\Corhort Petition\'59 nucle... 7/23/2009



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Ref 4 letter from the Atomic Energy Commission, dated June 28, 1960, granting North
American Aviation permission to move the L-77 reactor from the Vanowen
building to the DeSoto site.

(copy enclosed)

Ref5 News article in the Ventura County Star, July 12, 2009
(copy enclosed)

Ref 6a Environmental Surreys, Quarterly Progress Report, A. A. Jarrett and J. N Roth,
Oct., Nov., Dec. 1955m, dated Mar 12, 1956
(available at: http:/Avww.etec.energy.gov/Health-and-Safety/ASER. html, copy
not enclosed)

Ref 6b Environmental Surreys, Quarterly Progress Report, A. A. Jarrett and J. N Roth,
Jan, Feb, Mar 1956, dated May 8, 1956
(available at: http://www.etec.energy.gov/Health-and-Safety/ASER. html, copy
not enclosed)

Ref 6c Environmental Surreys, Quarterly Progress Report, A. A, Jarrett and J. N .Roth,,
Apr., May., Jun 1965, dated Aug. 7, 1956
(available at: http://www.etec.energy.gov/Health-and-Safety/ASER. html, copy
not enclosed)

Ref 6d Environmental Surreys, Rough Draft, Quarterly Progress Report, J. N .Roth,
dated Nov. 15, 1956
(available at: http://www.etec.energy.gov/Health-and-Safety/ASER.html, copy
not enclosed)

Ref 6e Environmental Monitoring, Annual Report 1959, Atomics International, dated
June 24, 1960
(available at: http://Awww.etec.energy.gov/Health-and-Safety/ASER.btml, copy
not enclosed)

Ref 6f Environmental Monitoring Report 1960, Annual Survey, Atomics International,
(available at: http://www.etec.energy.gov/Health-and-Safety/ASER. html, copy
not enclosed)

Ref 6g Environmental Monitoring Report, April 1, 1960 to June 30, 1960, Atomics
International, Canoga Park
(available at: http://www.etec.energy.gov/Health-and-Safety/ASER html, copy
not enclosed)

23


Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area [V —Canoga Facility site

And in Ref 2, Section 7.2.1 Process-Related Internal Doses at SSFL-Area IV --- 7.2.1.1
Urinalysis Information and Available Data from Ref 2----

“Based on limited pre-1959 internal monitoring data and associated program or source
term information, NIOSH has concluded that there is insufficient information to support
establishing a bounding internal exposure scenario for the proposed worker class that
worked in Area IV of the SSFL from 1955 through 1958.”

And in Section 7.2.2 Ambient Environmental Internal Radiation Doses at SSFL-Area IV

“Ambient environmental air sampling data exist for the period evaluated in this report;
however, no stack effluent concentration data are available for the period prior to 1965.
The facilities operating during the pre-1965 period were mainly small reactor
facilities” ...
and

“The use of facility ambient air monitoring data for assessing internal radiation doses
was evaluated for performing EEOQICPA dose reconstructions. However, NIOSH has
concluded that the ambient environmental method (described above) does not support a
bounding internal exposure evaluation method for the pre-1959 time period, when the
facility lacked a routine urinalysis program.”

And from Section 7.2.4 Internal Dose Reconstruction Feasibility Conclusion of Ref 2----

“NIOSH has established that unmonitored intakes of radionuclides associated with
reactor operations (and associated operations) may have occurred in Area IV of the
SSFL prior to 1959 and that these exposures may have resulted in unmonitored doses to
site workers and workers incidentally exposed in these facilities.”

“NIOSH has also determined that there was no established routine bioassay program for
Area IV of the SSFL prior to August 1958.”

and

“There is insufficient information associated with the source terms for the operations
during this timeframe to support developing a method to estimate or bound internal
radiological exposures based on source term (or any currently available) information or
data. For this reason, NIOSH has concluded that it cannot bound or reconstruct pre-
1959 internal doses with sufficient accuracy for any member of the evaluated worker
class.

Also from Ref 2, Section 7.3.2 Ambient Environmental External Radiation Doses at SSFL

19



MAY-16-01 WED 16:48 NRC R IV FAX NO, 8608188 P. 06

See!

+o Ne”

a

pe

a

=Qe
The Model L~47 laboratory reactor was considared by some to be a” ,
reactor;" t ‘iginal name of the reactor was the “Penny Ante." this model
was quick] ‘ced with the more popular, and more powerful model, the

1O-watt Model 1-77.

The 1-47 reactor was installed in the Reactor Room of the Vanowen Buyildi

Canoga Park. The operating Jicense No. R-19 was issued on August 5. 1957" in
Records indicate that the L-47 reactor began operating on August 29, 1957, and
operated for 73 watt~hours in 1957 (operations data was not located for 1958).

On May 26, 1958, the AEC was informed that the licensee had “dismantled its
L-47 laboratory reactor and placed it in storage." In addition, the licensee
requested that the AEC terminate the R-19 license. The reactor was placed
into storage because the licensee thought that the reactor might be reused at
tojater date. Regardless, License R-19 was terminated by the AEC on Juna 30,

Records were identified that stated that the racommended amount of fuel to be
purchased for the reactor was 2000 grams of fully enriched uranium-235 in the
form of uranyl sulfate. The amount of fuel actually purchased was not clearly
identified, Records also indicate that the remaining L-47 reactor fuel (201
grams) was transferred to the Armour Research Foundation in dune 1958.

In mid-1958, North American Aviation replaced the L-47 reactor with an L-77
reactor (License No. R-40, issued May 17, 1968; Docket 50-94). This second
reactor was located in the same Reactor Room of the Vanowen factlity as the
L-47 reactor. The L-77 reactor operated at the Vanowen facility unti]
February 1960.

On March 29, 1960, Atomics International requested that license No. R-40 be
revised to allow them to relocate the 1-77 reactor from the Vanowen facility
to their new Desoto facility, Laboratory Building 004, in Canoga Park.
Construction Permit No. CPRR-54 was issued on Juné 27, 1960, which authorized
the transfer to take placa. The revised operating license was issued the next
day. The L-77 reactor was permanently shut down in September 1974.

Rackwell International Site Visit

On November 15, 1995, the former Reactor Room (Room 914 on older facility
maps, current maps identify the area as Room 554) of the Vanowen Guilding was
toured. The NRC jnspector was escorted by the Radiation Protection/Health
Physics Services Manager for Rockwell International /Rocketdyne. The area was
being usad as office space for an adjacent warehouse at the time of the visit.
,, A Ludlum Model 19 microR meter was used to scan the area for radioactive

materials. No readings above background were identified in of arau
former Reactor Room.

A vecords yauins was performed diving the site visit. A Timited amount of
5 sslanlag records were identified for the Vanowen site. Unfortunately,
tidicating the where-abouts of the L-47 reactor were not identified.

Hadlation Protection/Health Physics Services Manager was not
is r@TALGE Lo te LAY rencher,

3

aware of any addi


Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

SC&A agrees with the findings in the SEC ER that the internal monitoring program was
insufficiently robust to estimate exposures before January 1, 1959. Only limited amounts
of internal personnel monitoring data for pre-1959 exposures were identified, which is
consistent with NIOSH’s findings that an SSFL routine bioassay program was not
initiated until August 1958 (Kellehar 1966). Our review of the percentage of workers
being monitored for internal exposure indicates that the percentage continued to increase
after 1959, until it plateaued several years later. A determination needs to be made by
NIOSH on whether the percentage of workers who were monitored in the several years
after 1958 indicates a fully functioning internal monitoring program.

In addition, monitoring for internal exposure of SSFL workers was incomplete and
poorly documented for most years of facility operation. These deficiencies and data
limitations are stated throughout sections of the TBD. For 1959 and beyond, SC&A does
not believe that NIOSH has clearly demonstrated a correlation between the bioassay data
available and the potential exposures to specific radionuclides.

There is a lack of information concerning two major facility incidents that had significant
potential for internal or external exposure to personnel; the SRE coolant failure and the
sodium burn pit. TBD-5 does not specifically address radiological incidents that may
have resulted in internal exposures to workers’ that were unmonitored and, based on our
review of claimant files, it does not appear that all workers who should have been badged
were indeed badged. As noted, the poor track record of badging employees appropriately
indicates a need for NIOSH to revisit the limitation for its proposed addition to the SEC
class only to employees who were monitored. The information in TBD-S is unclear as to
whether workers exposed during these early incidents were adequately monitored for
internal exposure and, if workers were monitored, whether their exposure records exist.

SC&A questions the data and unsupported/unreferenced assumptions that were applied in
order to reconstruct occupational environmental doses, due to insufficient environmental
monitoring and data limitations. This includes inhalation intake estimates that are
radionuclide-specific and the surrogate use of the time-integrated average yearly gross
alpha/gross beta stack emissions corresponding to years 1971 thru 1999, which likely
underestimate stack emissions for years 1954 through 1970. There are also conflicting
reports concerning the exposure to onsite water supply wells. This issue should be re-
evaluated to determine if this exposure route can be properly assessed in earlier years
and, if so, how to assess this exposure.

In the absence of empirical data involving neutron spectra for reactors and Pu fuel storage
facilities, the lack of dosimeter calibration methods, and the relative insensitivity of NTA
film to neutrons with less than 500 keV, there remains an undefined level of uncertainty
for recorded neutron doses. Therefore, the use of Y-12 data as surrogate values may not
be appropriate. There is no discussion of neutron-to-photon ratios in the site profile;
however, it is mentioned as an option for calculating thermal neutron exposure in the ER
report. The ER indicates there are source term data available to bound low-energy photon

31



ffective Date: evision No. {Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 23 of 54

4.0 PRELIMINARY FINDINGS ASSOCIATED WITH THE SEC
PETITION

41 OVERVIEW

This section of the SEC review process identifies discrete issues of concern that may adversely
affect the ability to estimate SSFL worker exposures. Findings presented below are grouped as
follows:

« Section 4.1: Which areas (Area IV, Canoga Park, DeSoto, and Downey) should be
considered in the SEC Petition and when did operations begin at Area IV

© Section 4.2: Concern whether the internal monitoring program was sufficiently robust to
estimate exposures before and after January 1, 1959

e Section 4.3: Lack of information related to the facility “incidents” (SRE, Sodium Burn
Pit, etc.)

e Section 4.4: Lack of information on the environmental exposures (surrogate data,
drinking water, etc.) :

e Section 4.5: Justification for assignment of external dose estimates is not provided, and
there is no coworker model for external exposures (persomnel records are also of concern)

4.2 AREAS CONSIDERED IN THE SEC PETITION AND COVERAGE DATES

4.2.1 Areas Addressed by Petition

The petitioner submitted SEC Petition Form B to the NIOSH Office of Compensation Analysis
and Support (OCAS) on June 22, 2007. The petition referenced the employer as Atomics
International, and the following locations were noted as being relevant to the petition:

¢ SSFL Buildings 059, 010, and 143

« DeSoto 101

« The Burn Pit

e Santa Susana Field Laboratory

However, the petitioner submitted a revised Form B on November 16, 2007, in which the
specific SSFL buildings, DeSoto 101, and Burn Pit were removed from the list of locations. It
appears the petitioner was asked to remove these other operations, since the petition should focus
on the DOE facility or AWE facility “covered” facility) at which the class worked as per

42 CFR Part 83.9(c)(1)(i).

Periodically, DOE publishes a list of facilities “covered” under EEOICPA. The latest
publication of these sites was on August 23, 2004 [Federal Register/Vol. 69, No. 162/Monday,
August 23, 2004 (pp. 51825-51831)]. There are two sites shown on this list that could apply to

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[tetive Date: Revision No. [Document No. Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 41 of 54

4.6 ASSIGNMENT OF EXTERNAL DOSE

TBD-6 contains documentation to assist in the evaluation of occupational external doses from
processes that occurred at SSFL. An objective of this document is to provide supporting
technical data using claimant-favorable assumptions to evaluate occupational external doses that
can be reasonably associated with worker radiation exposures. This document addresses the
evaluation of unmonitored and monitored worker exposure, missed dose, and the bias and
uncertainty associated with the monitoring of external dose.

4.6.1 No Coworker Model

TBD-6 has not cited an external coworker model approach as necessary, and the document does
not address the use of a coworker model for those individuals potentially exposed but not
monitored. It appears that individuals may have been unknowingly exposed. An October 22,
1962, memorandum from F.H. Badger® to the Health and Safety File regarding “Health and
Safety Observations at RMDF” states that, “Routine smear surveys have repeatedly revealed
significant contamination or radiation dose rates in areas usually thought to be free of radioactive
material.” One of the examples provided was a 4 Rad/hr capsule lying in an area thought to be
uncontaminated.

In addition, in an April 1991 Tiger Team Assessment, the DOE noted several issues with the
external radiation dosimetry program. The report, as an example, noted that “In 1989 and 1990,
extremity doses were not added in to exposure records or reported to the Radiation Exposure
Information Reporting System (REIRS).”

Based on the poor track record of badging employees appropriately, the conclusion of no
monitoring being equal to no work in a radiation area does not seem to be justified. The dose
reconstructor should be able to look at a job title and determine potential exposure, and then be
linked to a coworker model. This issue is also relevant to how NIOSH has defined the SEC from
1955 to 1958, which at present does not include employees who “should have been monitored,”
but is limited to employees who were monitored. This SC&A conclusion indicates a need for
NIOSH to revisit the limitation.

4.6.2 Workers Were Unlikely to Have Been Monitored for Thermal Neutrons

As stated in Section 6.2 of TBD-6, “...Both fast and thermal neutrons were measured and
recorded as whole-body (WB) dose in rem” (emphasis added). This statement is contradicted in
Section 6.4, where it states, “...It is assumed that the dose recorded was the result of fast neutron
exposure” (emphasis added).

The second statement is likely to be correct, since the common practice at DOE facilities was to
assess NTA film for tracks produced by proton recoil. It is'unlikely that NTA dosimeters were
modified and calibrated for tract analysis of thermal neutrons. [Tracks in emulsions exposed to

3 BH. Badger was employed by Atomics International. His title was Analyst, Health Physics, Senior
Health and Safety Operations.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Attachment A-1:
For completeness, the excerpts and summaries from the report---

“Technical Support for the Advisory Board on Radiation & Worker Health Review
of NIOSH Dose Reconstruction Program, Review of the Santa Susana Field
Laboratory (SSFL)- Area IV Special Exposure Cohort (SEC) Petition-00093

and the NIOSH SEC Petition Evaluation Report”,
Report no. SCA-SEC-TASK5-0066, dated January 30, 2009
Prepared by S. Cohen and Associates and Saliant, Inc,

and used in Attachment A, are shown as complete sections or sub-sections below---

Section 4.3.2 Monitoring for Internal Exposure of SSFL Workers was Incomplete
and Poorly Documented fer Most Years of Facility Operation

In Section 5.2 (p. 10) of TBD-S5, the evaluation of the SSFL internal monitoring program
is prefaced with the following statement:
Early 1960s AI documents describe all the elements of a comprehensive
radiation safety program, including a laboratory with bioassay capability.
... [Emphasis added.]

This statement, however, was tempered by numerous admissions in subsequent sections
of the TBD. A sampling of statements suggesting deficiencies and data limitations
include the following:

Page 13:
Specific radionuclides could be determined “where required” (Lang
1960). Some detail has been found on early urinalysis methods. In
addition to the in-house laboratory capability, bioassay services were
contracted to the following vendors: {Eight vendors are listed.]
... Information on the periods during which ETEC used these laboratories
was not found. [Emphasis added.}

In addition to the eight contract laboratories, ETEC had its own in-house laboratory,

which analyzed urine for uranium content by fluorometric method. Exposure to
uranium may have existed in various states of enrichment up to 93%.

Page 14:

Due to its higher specific activity, EU activity could be determined by
counting...

25



~2=

A. Pursuant to Section l04c of the Act and Title 10, CFR, Chapter
1, Part 50, "Licensing of Profluction and Utilization Facilities"
to possess and operate as a utilization facility the nuclear
research reactor designated below;

B. Pursuant to the Act and Title 10, CFR, Chapter 1, Part 70, "Special
Nuclear Material", to possess and use 1.5 kilograms of contained
uranium-235 as fuel for operation of tlie reactor;

Cc. Pursuant to the Act and Title 10, CFR, Chapter 1, Part 30, "Licensing
of Byproduct Material" to possess but not to sepsrate such byproduct
material as may be produced in the operation of tlie reactor.

This license applies to the reactor which ie owned by North American

Aviation, Inc., and located at Canoga Park, California, and described in

North American Aviation, Ine.'s application dated January 20, » 1958, andre
amendments thereto dated March 7° 1958, prt 15, 1558, Septenber 25, -
1959, February, 8, 1960, and March 29, 1960, (herein referred to as "the
application"), The reactor is of: the solution-type, is moderated by
light water and uses as fuel a solution of uranyl sulfate containing \
uranium enriched to 20% or more in the. igotope uranium-235. It is

designed to operate at a thermal power level of ten (10) watts and is

designated by North American Aviation, Inc., as the "L-77" reactor.

This license shall be deemed to contain and be subject to the conditions
specifigd in Section 50,54 of Part 50; is subject to all applicable pro-

visions of the Act and rules, regulations and orders of the Commission

now or hereafter in effect; and is subject to the additional conditions

specified or incorporated below:



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

“The change in the proposed class definition was triggered by the additional information
collected by NIOSH indicating that there was a possibility that not all workers who
entered controlled areas were necessarily monitored for external radiation exposure,”

And on page 18, in paragraph 2, the Ref 2 NIOSH report states---

“Following World War II the potential of atomic energy captured the interest of the
United States... 0000s 100 0+. SSFL was initially established in 1947 .......... to meet the
requirements to static-fire large rocket engines: however it also met NAA’s requirement
for a nuclear Test Facility. As a result, Area IV was established in 1953 at SSFL as a
Nuclear Research and Development Facility._Since then, SSFL-Area IV has housed both
nuclear development and rocket development groups, albeit in distinct and separate

locations.” (underlining added)

Further, the NIOSH Ref 1-d report, ORAUT-TKBS-0038-4, on page 6, paragraph 1, in:
Section 4.2 Purpose the following is stated-----

“Occupational environmental dose refers to radiation exposures received by workers,
while on the site but outside the Santa Susana Field Laboratory (SSFL) facilities, from
facility discharges to the atmosphere, from ambient external radiation originating in the
facilities, and from inadvertent ingestion of site-generated radionuclides. The receptors
of concern are SSFL employees who did not wear external dosimetry or who were not
monitored for internal exposures. (underlining added)

Note that this statement does not read ‘receptors of concern are SSFL/Area IV
employees’.

NIOSH has clearly stated in these NIOSH reports that working in any area of the “Site” is the
approach established by NIOSH for a Special Exposure Cohort when at lack of monitoring
and/or proximity to the radiation source exists, and when the radiation release source is---

“from facility discharges to the atmosphere, from ambient external radiation originating
in the facilities, and from inadvertent ingestion of site-generated radionuclides”.
(from Ref 1-d, page 6, paragraph 1,as stated above)

This is the basis I have taken in preparing this Petition for the SSFL/Area IV - Canoga
Facility site: to include all employees that worked at the site.

(d) the type of possible radiation exposures to employees, the availability (and lack
thereof) of a comprehensive monitoring data base, and the lack of monitoring that took
place for radiation exposure (during the time period addressed in this Petition)---which
existed at the SSFL/Area IV site, and similarly existed at the SSFL/Area IV - Canoga Facility
site (and which applies to all employees of North American Aviation at the SSFL/Area IV -

Canoga Facility site).



Effective Date: [Revision No. |Document No. Page No.
January 30, 2009 0 SCA-~SEC-TASK5-0066 Page 42 of 54

thermal neutrons may be produced by nitrogen in the gelatin that captures a thermal neutron and
releases a 0.58 MeV proton-N'“(n, p) C4]

In the absence of empirical data involving neutron spectra for reactors and Pu fuel storage
facilities, the lack of dosimeter calibration methods, and the relative insensitivity of NTA film to
neutrons with less than 500 keV (or as much as 1 MeV), there remains an undefined level of
uncertainty for recorded neutron doses. Therefore, the use of Y-12 data as surrogate values may
not be appropriate.

TBD-6 assumes that the NTA film effectively measured all neutron exposure received at AI, and
does not consider correction factors for the insensitivity of NTA to neutrons at energies below
500 keV. Actual neutron energy spectrum data are limited to a few facilities (i.e., SRE). There
is no discussion of neutron-to-photon ratios in the site profile; however, it is mentioned as an
option for calculating thermal neutron exposure in the ER report.

4.6.3 Dosimeter Response to Low-Energy Photons

TBD-6 does not discuss issues associated with the response of dosimeters to low-energy photons.
There are statements to the effect that the dosimeter was similar in design to the Hanford
dosimeter, The Hanford dosimeter applied a correction factor for exposure of plutonium facility
workers to compensate for badge shortcomings. The ER indicates there are source term data
available to bound low-energy photon dose; however, no specific information on source term is
provided. Furthermore, there is no consideration for dose from skin contamination incidents.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. [Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 48 of 54

Loba, M.L., 1960. Radiological Safety Incident Report from M.L. Loba (Operational Health
Physics, Atomics International) to R. Wilmes, Subject: Uranium Fire Incident A-0343: Pluto
Area, Room 1244 — SSFL, December 1, 1960.

Loba, M.L., 1961a. Radiological Safety Incident Report from M.L. Loba (Health and Safety
Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0398:
Room 1059 — SSFL, May 2, 1961.

Loba, M.L., 1961b. Radiological Safety Incident Report from M.L. Loba (Operational Health
Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0503: Room
1063 — SSFL, October 31, 1961.

Loba, M.L., 1962. Radiological Safety Incident Report from M.L. Loba (Health and Safety
Department, Atomics International) to R.F, Wilmes, Subject: Uranium Fire Incident A-0516:
Room 1261 — SSFL, August 9, 1962.

Loba, M.L., 1970. Internal Letter from M.L. Loba (Associate Health Physics, Operational
Safety, North American Rockwell) to W.F. Heine, Subject: Uranium Fire Incident A-0636:
Depleted Uranium Fire in Room 119-42, HQ-001 — SSFL, June 18, 1970.

Lochbaum, D.A., 2006. An Assessment of Potential Pathways for Release of Gaseous
Radiocativity Following Fuel Damage During Run 14 at the Sodium Reactor Experiment.
October 5, 2006; SRDB Ref JD: 37247.

Mooers, A.R., 1959a. Radiological Safety Incident Report from A.R. Mooers (Operational
Health Physics, Atomics International) to Health Physics Supervisor, Subject: Uranium Fire
Incident A-0528: Room 807 — SSFL, August 20, 1959.

Mooers, A.R., 1959b. Radiological Safety Incident Report from A.R. Mooers (Operational
Health Physics, Atomics International) to Health Physics Supervisor, Subject: Uranium Fire
Incident A-0450; Room 901 —SSFL, August 31, 1959.

Mooers, A.R., 1960. Radiological Safety Incident Report from A. R. Mooers (Atomics
International) to Health Physics Supervisor, Subject: Uranium Fire Incident A-0235: HQ I,
Room 1063 — SSFL, June 22, 1960,

Mooers, A.R., 1961a. Radiological Safety Incident Report from A.R. Mooers (Health and Safety
Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0453:
HQ 1, Room 1059 — SSFL, March 20, 1961.

Mooers, A.R., 1961b. Radiological Safety Incident Report from A.R. Mooers (Health and Safety
Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0353:
SS Vault, Room 1142 ~ SSFL, May 8, 1961.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Since the Canoga facilities, Canoga Park and Vanowen building (etc.) are all addressed in
the NIOSH documents in Ref 1-a through 1-f as a part of the SSFL/Area IV site, I have used
as the site name for this Petition the designation: SSFL/Area IV — Canoga Facility site.
(Note: The site was sold to Boeing in (circal 994), and subsequently sold to United

Technologies, the present owner.)
\

Attachment A — C.7e Supervisors Name:
During the period addressed in this Petition, 1 worked under the supervision, at various times,
of the following managers or supervisors:

Attachment A - E.1 Name of DOE or AWL facility.

The SSFL/Area IV - Canoga Facility site (as addressed in Attachment A — C.7d, previously)
has been defined in the EEOIC Program and NIOSH documents using, or as a part of,
numerous “names”, that have included “Canoga Park, Atomics International, SSFL/Area IV,
ETEC, Vanowen building, Rocketdyne, North American Aviation, and Rockwell
International”.

The SSFL/Area IV - Canoga Facility site is noted in Ref. 1-b, ORAUT-TKBS-0038-2 report,
Energy Technology Engineering Center (ETEC)—Site Description on page 8, as follows—

“In addition to the facilities in SSFL that supported DOE, Rockwell under contracts or
grants to DOE or its predecessor agencies, had performed DOE activities at the
Downey, Canoga Park, and DeSoto Facilities. These three facilities are all located
outside the boundaries of the SSFL site. Since Rockwell International workers could
have worked at any and all of these sites as well as Area IV., Section 2.2,2 in this site
descriptions describes them”...

On page 22 in Ref. 1-b, the following is written in Section 2.2.2, Canoga Park-—

“AEC-funded activities at Rockwell's Canoga Park, California, occurred in the Van
Owen Building from approximately 1954 to 1960. This work had been performed at
North American Aviation’s Downey Facility, but was moved to Canoga Avenue at the
end of 1955. Principal work in the Vanowen Building included design, development,
and operation of small aqueous fuel reactors, fuel development, and radiochemistry,
and beryllium machining is believed to have occurred”.

Also in Table 2-4, in Ref. 1-b, the two reactors that were assembled and operated in the
Vanowen building at the Canoga Facility site are listed. In the table, the facility is listed as
“Canoga Park Plant VanOwen Building” and the L-47 and L-77 reactors are listed as having
the following operating period — 1954 -1960.



ffective Date: [Revision No. [Document No. [Page No.
January 30, 2009 9 SCA-SEC-TASK5-0066 Page 46 of 54

Begley, F.E., 1976. Incident Report from Begley, F.E. (Radiation and Nuclear Safety, Rockwell
International) to R.J. Tuttle, Subject: Uranium Fire Incident A-0640: SNM Transfer Can Drop
C/001 — SSFL, September 2, 1976.

Boeing 2003. Site Environmental Report for Calendar Year,2002, DOE Operations at the
Boeing Company, Rocketdyne Propulsion & Power, The Boeing Company. September 2003.

Boeing 2004. Site Environmental Report for Calendar Year 2003, DOE Operations at the
Boeing Company, Rocketdyne Propulsion & Power, The Boeing Company. September 2004.

Boeing 2005. Site Environmental Report for Calendar Year 2004, DOE Operations at the
Boeing Company, Santa Susana Field Laboratory, The Boeing Company. September 2005.

Boeing 2006. Site Environmental Report for Calendar Year 2005, DOE Operations at the
Boeing Company, Santa Susana Field Laboratory, The Boeing Company. September 2006.

Boice, J.D., S.S. Cohen, M.T, Mumma, E.D. Ellis, K.F. Eckerman, R.W. Leggett, B.B. Boecker,
AB. Brill, and B.E. Henderson, 2006. Mortality among Radiation Workers at Rocketdyne
(Atomics International), 1949-1999. SRDB Ref ID: 39396.

Boice, J.D., R.W. Leggett, E.D. Ellis, P-W. Wallace, M.T. Mumma, S.S. Cohen, A.B. Brill, B.
Chadra, B.B. Boecker, R.C. Yoder, and K.F. Eckerman, 2006. A Comprehensive Dose
Reconstruction Methodology for Former Rocketdyne/Atomics International Radiation Workers.
Health Physics, 90 (5): 409-430; May 2006; SRDB Ref ID: 37539.

Christian, J.D., 2005. Chemical Behavior of lodine-131 During SRE Fuel Element Damage in
July 1959, response to plaintiff’s expert witness Arjun Makhijani, May 26, 2005. SRDB Ref
ID: 35752.

Clow, H.E., 1966. Internal Letter from H.E. Chow (Health Physics, Radiation Safety Unit,
Atomics International) to D.R. Shoemaker, Subject: Fire in Building 021- ETEC, November 15,

1966.

Curphey, J., 1983. Memorandum from J. Curphey (District Sanitary Engineer for the State of
California, Department of Health Services, Sanitary Engineering Section) to T.J. Gannon
(Rockwell International), Subject: Rockwell International Corporation, Rocketdyne Division,
System No. 56-004. March 9, 1983.

Dempsey, G.D., 1989. Site Visit to Santa Susana Field Laboratory Operated by Rockwell/
Rocketdyne, U.S. Environmental Protection Agency. July 28, 1989.

DOE, 2006, DOE Standard: Guide of Good Practices for Occupational Radiological Protection
in Plutonium Facilities, DOE-STD-1128-98; U.S. Department of Energy (DOE); December
2006; SRDB Ref ID: 34061

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



3%

of the proposed operation prepared by the Hazards Evaluation Branch of
the Division of Licensing and Regulation, both on file at the AEC’ s
Public Document Room. A copy of item (2) above may be obtained at the
AEC's Public Document Room or upon request addressed to the Atomic Energy
Commission, Washington 25, D. C., Attention: Director, Division of Licensing
and Regulation. ° :

FOR THE ATOMIC ENERGY COMMISSION

LL Pie
Director
<f > Divislon of Uisensing & Regulation

Dated at Germantown, Maryland
this 27¢4 day of pure ,/ fee,



ffective Date: [Revision No. [Document No. Page No.
Jam 30, 2009 0 SCA-SEC-TASKS-0066 Page 25 of 54

Engineering Center [ETEC] or Atomics International) — Occupational Environmental
Dose, Rev. 01 (ORAUT 2007)

© ORAUT-TKBS-0038-5, Technical Basis Document: Energy Technology Engineering
Center — Occupational Internal Dose, Rev. 00 (ORAUT 2006)

e ORAUT-TKBS-0038-6, Technical Basis Document: Atomics International —
Occupational External Dosimetry, Rev. 01 (ORAUT 2006e)

The TBDs focus on Area IV of the Santa Susana Field Laboratory, but also address the Canoga,
Downey, and De Soto facilities. Dose reconstructions that are prepared for employees of AI
include work conducted at all four of these facilities. It is noted above that the Al Division of
NAA operated all four of these facilities, and their internal and external dose monitoring
programs were the same for all the facilities.

In addition, TBD-1 (p. 6) states, “The name Atomics International (Al) is used to represent all
[all meaning the four facilities; Area IV, Downey, Canoga Avenue, and De Soto Avenue] of
them unless more specific location information is warranted.” Therefore, when the petition
refers to the facility as Al and it is shown as a covered DOE facility, it is easy to understand why
there would be some confusion as to what locations are covered.

Given the above, we believe NIOSH should re-assess the SEC Petition being only applicable to
Area IV at SSFL.

4.2.2 Coverage Dates

The initial date of coverage is dependent on whether all four facilities are covered in the petition,
or if just Area IV of SSFL is covered.

If all four facilities are covered in the petition, the initial year of coverage should be 1947 or
1948, TBD-2 (p. 9) states, “The SSFL was initially established by North American Aviation
(NAA) in 1947 to meet the requirements for a field test laboratory to static-fire large rocket
engines, but it also met the NAA’s need for a nuclear research facility.” The first year of
coverage shown for the Downey facility in the DOE database is 1948, which is also noted as the
first year of coverage in TBD-1 (ORAUT 2006a) (p. 6). TBD-2 (p. 27) discusses AEC-funded
activities taking place at Downey between 1948 and 1955.

If only Area IV of SSFL is covered in the petition, it is not clear whether the initial date of
coverage is 1953, 1954, or 1955. The initial date of coverage for Area IV is shown as 1955 in
42 CFR Part 83.9 and the DOE “covered facilities” database. However, there are conflicting
references in the TBDs as to when operations began at Area IV. TBD-2 (p. 9) states, “Area IV
was established at the SSFL in 1953 as a nuclear research and development facility.” Later in
this same document on the same page, it is stated that “Nuclear R&D activities in Area IV
increased rapidly from 1953 into the late 1960s, then declined.” Figure 2-3 in TBD-2 also shows
that Area IV was established in 1953 to provide nuclear-related research. TBD-2 (p. 13) states,
“Between 1954 and 1980, several nuclear reactors were built, tested, and operated in Area IV.”

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. |Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 21 of 54

Response to Issue #6:_The Sodium Burn Pit

NIOSH concludes that while there may have been radiological contamination at the Sodium
Burn Pit, the following facts appear to support a low exposure and ability to bound dose
estimates:

« It appears contaminant levels were low (56 pCi/g maximum) related to radioactive
contamination (principally cesium-137), and that contaminants were primarily in the
lower pond.

¢ Contamination was not identified in areas outside the ponds.

¢ The Sodium Burn Pit was an outdoor area not continuously occupied, nor
continuously used.

* Because the pit was not an operations area, exposures for individuals that may have
intermittently occupied the Sodium Burn Pit would have been lower than exposures
for individuals who performed operations work with source materials that were
delivered to this location.

* Radiological exposure controls were in place (¢.g., workers were required to maintain
a safe distance from the pits, including lined and unlined pits/ponds), because of the
violent reactions that could occur if sodium or potassium made contact with the
water.

¢ Bioassay results were available for affected and/or associated members of the
proposed class, including worst-case exposure scenarios for the proposed worker
class.

This issue is discussed in Section 4.3.
3.3.2 Other Issues

Two other issues were identified by NIOSH in preparing the ER. The first issue dealt with the
identification of workers with blank radiation exposure record sheets in their file (a sheet with no
entries). The second issue dealt with the monitoring of firemen from other sites who got
involved with fires or events at SSFL Area IV.

Response to “Other” Issue #1

NIOSH discovered through an interview with a current Radiation Safety Officer at SSFL that all
individuals were issued a blank record sheet in his/her file called a “blue card.” If an individual
entered into a “controlled” area, they were required to have a film badge and any exposure was
entered into their file. This practice was corroborated by NIOSH through random personnel
record reviews and through other reviews (Boice et al. 2006a and Boice et al. 2006).

SC&A acknowledges this practice.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Jor the period before 1959”... and in Section 4.6.5, External Dose Before 1959, “No data
are available for the period before 1959” and “Environmental external doses from 1952 to
1955 for Downey and from 1954 to 1960 for the Canoga Park Vanowen Building are
estimated” ..., and in Ref 1-e, in Section 5.3.1.1 Jn Vitro Urine Analysis, 1948 ~ 1957
“Apparently, no bioassay program existed before August 1958.” And in Section 5.3.3 Fecal
Sample Analysis “Although fecal sampling was mentioned as both a routine and a special
bioassay method in site documents, little detail has been found about the analytical methods
used”...

The nuclear activities at the SSFL, Area IV and those that were in the Vanowen building at
SSFL/Area IV - Canoga Facility site were performed by technical staffs (that including the
monitoring personnel) managed by a small core of Program Managers and Directors all
reporting, at that period, to the same Division President, Dr. Chauncey Starr

Attachment A-F.3 Requests that attached report(s) from a health physicists or
other individual...,

S. Cohen & Associates and Saliant, Inc. were contracted by the Advisory Board on Radiation
and Worker Health (ABRWH) to conduct an independent review of (a) the NIOSH position
regarding the establishment of a Special Exposure Cohort for the SSFL/Area IV site, and (b)
the NIOSH recommendations and technical positions, as presented in the Ref 2 report, SEC-
00093.

The report prepared by 8. Cohen & Associates and Saliant, Inc., titled “ ADVISORY
BOARD ON RADIATION AND WORKER HEALTH, National Institute for Occupational
Safety and Health, Review of the Santa Susana Field Laboratory (SSFL) Area IV Special
Exposure Cohort (SEC) Petition-00093 and the NIOSH SEC Petition Evaluation Report,

‘was prepared under contract to NIOSH, Contract No. 200-2004-03805 , Task Order No. 5 ,
SCA-SEC-TASK5-0066, dated January 2009 (i.e. Ref 2), which addressed Revision 00, of the
SEC-00093 report (prior to Revision 01), substantially concurs with the Ref 3 NIOSH SEC -0093
report (Revision 01) in the formation of a Special Exposure Cohort group for SSFL/Area IV.

Specifically, in Ref 2, Section 5, Conclusions, on page 43, the following comments are written---
In paragraph 2—

“SC&A agrees with the findings in the SEC ER that the internal monitoring program was
insufficiently robust to estimate exposures before January 1, 1959. Only limited amounts
of internal personnel monitoring data for pre-1959 exposures were identified, which is
consistent with NIOSH’s findings that an SSFL routine bioassay program was not
initiated until August 1958 (Kellehar 1966)”......

In paragraph 3—~

15



Effective Date: {Revision No. [Document No. [Page No,
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 12 of 54

Area IV increased rapidly from 1953 into the late 1960s, and then began to decline. AI was
eventually merged into Rocketdyne in 1984 as a result of this decline.

The LMEC was created in 1966 as a government-owned and contractor-operated organization;
its purpose was to provide development and non-nuclear testing of Liquid Metal Reactor (LMR)
components and to establish the Liquid Metal Information Center (LMIC) for the Atomic Energy
Commission’s (AEC’s) Liquid Metal Fast-Breeder Reactor (LMFBR) program. The LMEC was
renamed Energy Technology Engineering Center (ETEC) in 1978 to reflect DOE’s desire to
broaden its mission beyond the LMFBR program.

Several corporate mergers and organizational changes occurred over the years. In 1967, NAA
merged with Rockwell Standard to become North American Rockwell. In 1973, the corporate
name changed to Rockwell International (RI). Rockwell International with AI and Rocketdyne
continued to exist as independent divisions until 1984, when Al was absorbed by the Rocketdyne
division. The Boeing Company purchased RI in 1996, and Rocketdyne is now a division of
Boeing.

Before the remaining research activities ended in 1998, three primary types of operations were
conducted at Area IV: (1) development and testing of nuclear reactors, (2) nuclear support
operations, and (3) non-nuclear energy R&D.

2.2 DEVELOPMENT AND TESTING OF NUCLEAR REACTORS

Between 1953 and 1980, several nuclear reactors were built, tested, and operated in Area IV.
These included both nuclear reactors and critical test assemblies. Nuclear reactor programs
focused on the development and operation of homogeneous water boiler-type reactors, sodium-
cooled graphite-moderated reactors, and uranium-zirconium hydride reactors.

2.2.1 Homogeneous Water Boiler Reactors

The water boiler reactors were operated in Buildings 4073 and 4093. The water boiler reactors
used a 93% enriched uranyl sulfate solution held in a critical configuration in a spherical vessel.
Rather than actually boil, the neutron and gamma flux caused radiolytic decomposition of water
into hydrogen and oxygen in the form of tiny bubbles, which gave the impression of boiling.
Area IV contained two water boiler reactors.

2.2.2 Sodium-Cooled Graphite-Moderated Reactors

The Sodium Reactor Experiment (SRE) facility consisted of 12 structures, including the reactor
building, office buildings, and support structures. Eight structures were directly involved in
Operations with radioactive materials:

(1) Reactor Building (Building 4143)
(2) Component Storage Building (Building 4041)

(3) Temporary Hot Waste Storage Building (Building 4686)
(4) Site Service Building (Building 4163)

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82,



Effective Date: [Revision No. |Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 16 of 54.

3.0 OVERVIEW OF THE SEC PETITION-00093 AND NIOSH’S
EVALUATION REPORT

3.1. SEC PETITION-00093

SEC Petition-00093 qualified on October 19, 2007. The petition requested that NIOSH consider
the following class: “All employees who worked in all areas of SSFL-Area IV during the time
period from 1955 to the present (which incorporated the post-1987 remediation period).”

The petition provided information and affidavit statements in support of the petitioner’s belief
that accurate dose reconstruction over time is impossible for the SSFL-Area IV workers in
question. NIOSH deemed the following information and affidavit statements sufficient to
qualify SEC-00093 for evaluation:

As identified in Item F.1 of the SEC-00093 Form B and discussed in the July 30,
2007 call, the petitioner discussed the sodium burn pit, the lack of internal
monitoring data, and indicated that no records were kept. The petitioner also
discussed a Tiger Team report indicating that the report detailed “inadequate air
monitoring” and that “no internal monitoring was done.”

The information and statements regarding the lack of pre-1959 internal monitoring data qualified
the petition for further consideration by NIOSH, the Advisory Board on Radiation and Worker
Health, and the Department of Health and Human Services. NIOSH determined that the time
period from 1955 to 1965 should qualify for the purposes of the SEC petition evaluation, which
includes the employment period in the original SEC-00093 petition.

Additional or more specific information that was included in the petition, but not mentioned
above, includes the following:

+ Faulty HEPA filters associated with the radiation storage buildings

+ Improper dosimeter badges

¢ Norecord of radionuclides released during the partial meltdown of the SRE

¢ Evidence of spills incompletely documented

« Monitoring wells placed upgradient of the site

¢ No soil or water sampling for tritium and a general lack of characterization of the site

« Radiological survey showing tons of radioactive waste stored in boxes by

Building 143—high levels of Cs-137 and Co-60

A summary of the key elements defined in SEC-00093 include the following:

e Issue #1: SRE Incident and Release of Core Gases. The basis for this issue being

identified was a concern that monitoring records do not exist for this incident and that
there was a release of core gases.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



|Effective Date: Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 45 of 54

6.0 REFERENCES

42 CFR 83. Title 42, Part 3, of the Code of Federal Regulations. Procedures for Designating
Classes of Employees as Members of the Special Exposure Cohort Under the Energy Employees
Occupational Illness Compensation Program Act of 2000; Final Rule, Federal Register/ Vol. 69,
No. 104/Friday, May 28, 2004, p. 30764,

ABRWH 2006. Verbatim transcript of the 38" Meeting of the Advisory Board on Radiation and
Worker Health, Volume IV, Day Three, held at the Marriott Metro Center, Washington, DC, on
June 16, 2006. U.S. Department of Health and Human Services, Public Health Services.

AI (Atomics International) 1959, SRE Fuel Element Damage, An Interim Report (NAA-SR-
4488). November 15, 1959.

Al (Atomics International) 1961. SRE Fuel Element Damage, Final Report (NAA-SR-4488
(supp). 1961.

Alexander, R.E., 1967a. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit,
Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0606: Radiation
Safety Unit Weekly Newsletter for Week Ending February 4, 1967 - SSFL, February 9, 1967.

Alexander, R.E., 1967b. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit,
Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0605: Radiation
Safety Unit Weekly Newsletter for Period Ending February 18, 1967 ~ SSFL, February 28, 1967.

Alexander, R.E., 1967c. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit,
Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0611: Radiation.
Safety Unit Weekly Newsletter for Week Ending March 11, 1967 — SSFL, March 24, 1967.

Alexander, R.E., 1967d. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit,
Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0615 and A-0616:
Radiation Safety Unit Weekly Newsletter for Period Ending May 27, 1967 — SSFL, June 1,
1967.

Alexander, R.E., 1968a. “Restriction of Employees from Radiologically Controlled Areas,”
Atomics International, Canoga Park, California. January 10, 1068.

Badger, F.H., 1960. Radiological Safety Incident Report from F.H. Badger (Operational Health
Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0344: HQ
0010, Room 115 - SSFL, December 5, 1960.

Badger, F.H., 1961. Radiological Safety Incident Report from F.H. Badger (Health and Safety
Department, Atomics International) to R.F, Wilmes, Subject: Uranium Fire Incident A-0454:
Cresta Grinder, Room 1059 - SSFL, May 2, 1961.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV ~Canoga Facility site

Another “work efficiency” practice at North American Aviation was the use of employee
transfers and less-formal employee loan-outs. These options were used to balance both
long-term and short-term periods of needs for a specific category of personnel, thereby
minimizing lay-offs and hiring. Either of these options could be accomplished in a day or
two; paperwork was required for a transfer but not for a “loan-out”, Both transfers and
"loan-outs’ could be within a Corporate division or between Corporate divisions. All the
personnel involved needed was a good “charge number”, and thus get paid.

Loan-outs were common for laboratory and test activities. Electronic and computerized test
data recording was a dream for the future in the 1950’ and most of the 1960’s. For a test, in
that period, data was recorded on paper disks and paper roles with mechanical
instrumentation, or it’s was an engineer reading a gage and writing down the data. The
mechanical recorders also need an engineer or technician to make sure the recording pen did
not hang-up. Also test observers were needed; reliable combustion and leak sensors were a
thing of the future. A test, if at all complex, could require ten of more additional personnel
for set up, and more than twice that number for the actual testing.

As a result the daily workplace for many SSFL/Area IV - Canoga Facility site personnel
could, and most often did, vary daily and weekly.

The comments vy at worker at SSFL/Area [V at the time of the Sodium Reactor
Experiment incidents, regarding employee assignments within the Corporation, clearly
acknowledges this work-sharing operational approach which was prevalent at North
American Aviation at that time. As he is quoted in the article in the Ventura County Star,
July 12, 2009 (Ref. 5)--- “It’s true, said, that workers from Rocketdyne, Atomics
International's sister division that conducted rocket engine tests at the lab, were brought
over to help with the cleanup.”

Attachment A—E.4 Employment Dates relevant to this petition.

The dates for this Petition for the establishment of a Special Exposure Cohort for the
SSFL/Area IV — Canoga Facility site are: Nov. 15, 1955 through June 28, 1960.

I worked for North American Aviation at the Canoga Facility site from mid-November 1955
through mid-August 1984, (Following this period I worked at the DeSoto Complex, in
Chatsworth, CA. I worked for a short period at the Westlake building site in Westlake
Village, CA)

iin hs i M3! also spent numerous days
working at the SSFL (all areas).

10



Effective Date: Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASK5S-0066 Page 20 of 54

We concur with NIOSH’s response, assuming the petitioner was not referring to some other
concern than the adequacy of the badges. As noted, SC&A has not interviewed the petitioners
for this preliminary report.

Response to Issue #3: Tritium Plumes

NIOSH states that tritium has never been detected (1,000 pCi/l) in any of the water supply
wells, They further state that the primary supply wells (WS-5, WS-6, WS-i2, and WS-13) were
in Areas I, II, and III at SSFL, while one well (WS-7) was in Area IV and contributed a small
percentage of the water supply. NIOSH has proposed to bound this exposure by assuming that
workers consumed water from a shallow monitoring well that has had the highest tritium
concentration, NIOSH points out that this well has never been a source of drinking water and is
downgradient of the source of tritium (Building 4010). NIOSH also stated in the evaluation
report that since 1991, the mean concentration of tritium in this well has been 2,940 pCi/l.
Through some modeling and migration and decay assumptions, NIOSH concluded that workers
could have consumed water with 30,000 pCi/l of tritium in the 1950s and 1960s.

The above assumptions seem to be claimant favorable, except for the fact that more recent
Boeing reports (Boeing 2003, 2004, 2005, and 2006) have documented tritium concentrations as
high as 117,000 pCi/I in the monitoring wells (not the drinking water wells). Therefore, the
above modeling should be reviewed in light of this more recent information. Concentrations for
the period January 1, 1959, to December 31, 1965, need to be provided or inferred by a
scientifically defensible method in order to estimate tritium dose for this period.

Response to Issue #4: Uranium Fires

NIOSH has concluded that there are data available for the various uranium fires that would allow
dose estimates to be bounded and, based on our review of this information (Alexander 1967a, b,
c, and d; Badger 1960 and 1961; Begley 1976; Klostermann 1961; Loba 1959, 1960, 1961a,
1961b, 1962, and 1970; Oldfield 1961; Mooers 1959a and 1959b, 1960, and 1961 a, b and c;
Owens 1978; Rudkin 1964 a, b and c; Stephenson 1961, 1962, 1963a, and 1963b; Weber 1963;
Young 1960 and 1965), we concur with this conclusion.

Response to Issue #5: Air Monitoring

NIOSH has concurred that there is a lack of area air monitoring for the period at SSFL-Area IV
prior to 1958, which impacts the feasibility of estimating internal radiation doses with sufficient
accuracy for the proposed worker class during that time period, After 1958, NIOSH will base its
dose reconstructions primarily on bioassay data.

Our discussion on the adequacy of the bioassay program prior to and after January 1, 1959, is
presented below in Section 4.3

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



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

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

OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 6 of 7

F.3 a \We have attached a report from a health physicist or other individual with expertise in
tadiation 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 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.) gee # Heachm ent #
F.4 \We have 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 petition.

(Attach report to the back of the petition form.) #2 ft He deh) non t A

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

All Petiti imum of three persons may sign the petition.

nn eee eons
ignaure Sa fe 7

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 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 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 Social Security Number of First Petitioner: __|


|Effective Date: (Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 37 of 54

were: (1) To limit personnel exposure to an average dosage rate of
1.25 rem/quarter (5 rem/yr). (p. I-19)

© Throughout the recovery effort the radiation exposure to each individual was
limited to less than 5 rem/yr. It was occasionally necessary to permit the
weekly exposure for some key individuals to reach 600 mrem per week, in
which case the individual was not exposed to radiation during the following
week. Such exposures required a special permit, and only 30 permits were
issued, For the 150 persons directly involved in the work, the average
exposure was 2 rem/yr.

This information is pertinent to reconstructing both external and internal exposures associated
with this incident.

44.3 The Sodium Burn Pit

The sodium burn pit was built to clean nonradioactive metallic sodium and NaK from various
scrap test components. Contamination was identified in the sodium burn pit in 1978, at which
time monitoring of the area began and continued until 1983. Prior to 1978, no radioactivity was
expected in this area, thus raising questions whether individuals involved in these activities
would be considered for internal monitoring. It is unclear when the radioactive contamination
was introduced to the burn pit or how far back in time the potential exposure to radiation exists.
Given the violent nature of the operation, it would be expected that this operation would have
generated an airborne hazard. Since the sodium burn pit was not expected to result in radiation
exposures, there was no routine monitoring. But this does not mean that routine exposure can be
ruled out. Additional information should be gathered on this site to demonstrate that
unmonitored workers are not likely to have received sufficient dose to be of concern, or a model
should be developed to bound the exposures that could have been received.

The TBD also does not consider exposure to contaminated soil that has resulted from spills and
other incidental releases, For example, a review by a U.S. Environmental Protection Agency
(EPA) official in 1989 (Dempsey 1989) identified Building.064, the Special Nuclear Materials
Storage Area, that had been contaminated as a result of a spill. This EPA official also had
concerns about the validity of some, if not all, of their environmental data:

In the Rocketdyne procedure, soils are heated in a muffle furnace for 8 hours at
500°C. Several problems were identified: first, this temperature is sufficient to
volatilize most man-made radionuclides of concern, including cesium-137 and
strontium-90. Second, from the Rocketdyne procedure, soil is sieved through a
coors crucible to obtain uniform particle size.... This procedure is a screening
method at best and is not an accurate quantitative procedure.

TBD-5 does not specifically address radiological incidents that may have resulted in internal
exposures to workers’ that were unmonitored.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Ref 6h Environmental Monitoring Report, Oct. 1, 1960 to Dec. 30, 1960, Atomics
International, Canoga Park
(available at: http://www.etec.energy.gov/Health-and-Safety/ASER html, copy
not enclosed)

Ref 6-I A Comprehensive Dose Reconstruction Methodology for Former
Rocketdyne/Atomics International Radiation Workers, authored by John D Boice,
et. al, and published in the Health Physics Journal, Nov 2005
(copy not enclosed; report copyright; available at)
http:/Awww.boeing.com/aboutus/environment/santa_susana/factsheets/dose_recon
struction2006.pdf

Ref7 United States Nuclear Regulatory Commission Memorandum, and Attachment 1,

Subject: Rockwell International Site Visit, dated Jan. 29, 1996,.
(copy enclosed)

24



ffective Date: Revision No, {Document No. [Page No.
January 30, 2009 i} SCA-SEC-TASKS-0066. Page 35 of 54

Section 5.11 (page 26):

If bioassay data are not adequate to evaluate an individual’s internal doses, dose
reconstructors can use workplace monitoring data (NIOSH 2002). The following
types of workplace data might be available for ETEC: breathing zone air
samples, general area air samples, and surface contamination surveys. However,
these data are not likely to be in individual exposure records. Data on
respirator use are not likely to be available ... resuspension factors are not likely
to be available. [Emphasis added.]

Section 5.12 (page 30):

Without bioassay or air sample data, the last resort is determination of airborne
concentrations using source term evaluations (NIOSH 2002, p. 19). Data on the
amount of dispersible material available does not appear to be available for
ETEC. [Emphasis added.]

This “guidance” is deficient and places an unrealistic responsibility on the dose reconstructor
because, at a minimum, the dose reconstructor will need to make judgments regarding (1) how to
use general air sampling data when breathing zone data are not available or limited, and (2) what
resuspension factors should be assigned. It is important that additional guidance be provided that
ensures that claimant-favorable assumptions are applied in a consistent manner.

4.4 LACK OF INFORMATION WITH CERTAIN FACILITY INCIDENTS
44.1 Overview

Table 2-6 in TBD-2 presents major site incidents that had significant potential for internal or
external exposure to personnel. The two primary incidents of concern are the SRE and the
Sodium Burn Pit.

4.4.2 Sodium Reactor Experiment Coolant Failure

TBD-2 contains a discussion of the SRE coolant failure in Section 2.2.1.1.2 and in Table 2-6.
Section 2.2.1.1.2 provides very little information on the incident, and does not discuss any
potential exposure information. Table 2-6 (30 pages after Section 2.2.1.1.2) provides more detail
on the incident, but does not provide any worker exposure information. There is information in
Table 2-6 about exposure being negligible for nearby residents (a maximum theoretical
calculated dose of 0.06 rem to someone living in Susana Knolls, the nearest residential area at
the time), but does not present exposure information for workers.

Based on our review of claimant files, it does not appear that all workers who should have been
monitored were monitored. NIOSH (Hughes 2008) provided SC&A with a spreadsheet
containing information on claimants who worked at Area IV in 1959, and whether they were
internally or externally monitored. The key finding from this spreadsheet (the spreadsheet
cannot be provided given Privacy Act concerns) is that 42% of those claimants, who were

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: iRevision No. |Document No. IPage No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 28 of 54

The figures above indicate that while the number of personnel that were internally monitored
was increasing during this period, it was not until roughly 1963 when the percentage of workers
monitored “somewhat” stabilized above 25%. Hence, there is some question whether the
bioassay data collected and analyzed from 1959 through 1963 was sufficient for internal dose
reconstruction or to develop a coworker model for internal dose reconstruction.

4.3.1.3 1966-2004

In 1970, standards for bioassay sampling were published (Staszesky 1970). Work in areas where
unencapsulated radioactive material was present required baseline and termination urine
samples. A new baseline could be required for a change in job assignment. For new operations,
a “pilot” bioassay program consisting of weekly urine samples could be required until a pattern
was established. Regular work in these areas required a quarterly routine urine sample, but
monthly samples could be required in a case of high exposure potential. Periodic fecal samples
and in-vivo counts could also be required, Employees who periodically performed work in these
areas were subject to semiannual urine samples. Personnel who frequently entered these areas,
but did not perform hands-on work, such as project engineers, industrial engineers, etc., provided
annual routine urine samples.

SC&A has observed no cases where workers had a significant increase in the monitoring
frequency after 1970. This is consistent with the data, which show that overall internal
monitoring frequencies did not change over time (Figures 4.3.1.3-1 and 4.3.1.3-2).

By the mid-1970s, the definition of who was included in the routine bioassay monitoring
program had changed to “personnel whose work assignments potentially expose them to
respirable-sized radioactive aerosols” (Hart 1979). By the late 1980s, the criterion was
“personnel whose work assignments potentially expose them to radioactive aerosols” (Tuttle
1989). Quarterly urine sampling was the norm through the 1980s (Hart 1979, 1980a, 1980b, and
1980c; Eggleston 1983 and 1984; Tuttle 1985, 1986a, 1986b, 1986c, 1988a, 1988b, and 1989).

In the mid-1970s, fecal sampling was used, but “only when gross internal contamination” was
suspected (Hart 1979). Using the concept of a Maximum Possible Body Burden (MPBB), an
excretion rate was determined by radionuclide that would indicate that one MPBB had been
received. For several years prior to 1968, the policy was to restrict employees from work in
potential airborne areas until their body burden was less than 25% of the MPBB (Alexander
1968a). Starting in January 1968, ETEC imposed a restriction from work in areas with potential
airborne exposure (or in some cases, from all radiation areas) if the bioassay results indicated the
receipt of 50% or more of the MPBB. The restriction remained in place until two consecutive
bioassay samples indicated that the remaining deposition was less than 25% of the MPBB
(Staszesky 1970).

The figures above indicate that the internal monitoring seems to have stabilized during this
period and decreased in later years as operations ceased.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisiona! and has not been teviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —-Canoga Facility site

proposed addition to the SEC class only to employees who were monitored. The
information in TBD-5 (i.e., Ref 1d) is unclear as to whether workers exposed during
these early incidents were adequately monitored for internal exposure and, if workers
were monitored, whether their exposure records exist.

and also on page 44 of Ref 3, the following is added----

“SC&A questions the data and unsupported/unreferenced assumptions that were applied in
order to reconstruct occupational environmental doses, due to insufficient environmental
monitoring and data limitations. This includes inhalation intake estimates that are
radionuclide-specific and the surrogate use of the time-integrated average yearly gross
alpha/gross beta stack emissions corresponding to years 1971 thru 1999, which likely
underestimate stack emissions for years 1954 through 1970. “

and the following, on page 44 of Ref 3, is also stated---~-

“In the absence of empirical data involving neutron spectra for reactors and Pu fuel
storage facilities, the lack of dosimeter calibration methods, and the relative insensitivity
of NTA film to neutrons with less than 500 keV, there remains an undefined level of
uncertainty for recorded neutron doses. Therefore, the use of Y-12 data as surrogate
values may not be appropriate. There is no discussion of neutron-to-photon ratios in the
site profile; however, it is mentioned as an option for calculating thermal neutron
exposure in the ER report. The ER indicates there are source term data ayailable to
bound low-energy photon dose; however, no specific information on source terms is
provided. Furthermore, there is no consideration for dose from skin contamination
incidents. Additional work is needed in this area to either better define the likely neutron
dose or provide a plausible bound for the dose.”

These last three comments from Ref 3 are highlighted here, not to address the 1959 reactor
incidents, but rather to further detail the Ref 3 comments regarding radiation monitoring, as it
existed at North American Aviation’s facilities in the 1950’s and early 1960's.

Alll of these comments directly reflect on the ability of anyone to establish, or bound, the
radiation exposure doses, internal or external, to which North American Aviation employees
at the SSFL/Area IV - Canoga Facility site may have been exposed.

Attachment A~F.4—_ Attached technical report(s), issued by an agency of the
Executive Branch of Government

As previously stated in Attachment A ~ F.3/F.4 “NIOSH (from Ref 2) cannot estimate
internal exposures with sufficient accuracy during the period from 1955 through 1958......
and therefore the Special Exposure Cohort group for the SSFL/Area IV has been established.
This statement is from Ref 2, a report issued by NIOSH, an agency of the Executive Branch
of the U, S. Government.

17



Effective Date: (Revision No. {Document No. Page No,

January 30, 2009 0 SCA-SEC-TASK5-0066 Page 2 of 54
S. COHEN & ASSOCIATES: Document No.
SCA-SEC-TASK5-0066
Technical Support for the Advisory Board on Effective Date:
Radiation & Worker Health Review of Draft —- January 30, 2009
NIOSH Dose Reconstruction Program Revision No.

Review of the Santa Susana Field Laboratory (SSFL)-
Area IV Special Exposure Cohort (SEC) Petition-00093 | Page 2 of 54
and the NIOSH SEC Petition Evaluation Report

Supersedes:
Task Manager:
Date:
Gregory P. Beronja
Project Manager:
Date:
John Mauro, PhD, CHP

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



fective Date: ‘evision No. |Document No. Page No.
January 30, 2009 9 SCA-SEC-TASK5-0066 Page 22 of 54

esponse to “Other” Issue #2

NIOSH teamed through interviews and reviews of dosimetry information that firemen typically
wore film badges when working in areas with the potential for radiological exposures. One
person interviewed mentioned that firemen wore badges at all times. However, one fireman did
not have monitoring records in his file. The SEC Petition ER concludes the following:

As previously discussed and stated, the availability of personnel records for
monitored individuals supports NIOSH’s ability to reconstruct dose with
sufficient accuracy for those proposed worker class members. Because the
available data also includes a representation of the maximum potential exposures
(a bounding exposure scenario) for the proposed worker class, NIOSH contends
that this supports the ability to bound the associated dose for all members of the
proposed worker class, including dose associated with the exposure scenarios
presented by/for these firemen.

SC&A is in agreement with the above statements.

3.4. NIOSH’S CONCLUSIONS

The ER concluded that, based on the limited pre-1959 internal monitoring data and associated
program or source information, there is insufficient information to support establishing a
bounding internal exposure scenario for the proposed worker class that worked in Area IV of the
SSFL from 1955 through 1958. NIOSH has identified post-1958 radiological internal
monitoring program data and the original monitoring data for individuals working in the highest-
exposure areas at Area IV, and therefore has concluded that doses can be bounded for the class
evaluated for the period from 1959 through 1965.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

“NIOSH has determined that ambient environmental external dose information is not
available during the period evaluated in this report (sufficient data are not available
until the mid-1970s” (underlining added)

and

“The use of facility ambient external monitoring data for purposes of assessing external
ambient environmental radiation doses was evaluated for purposes of performing
EEOICPA dose reconstructions. However, NIOSH has concluded that the ambient
environmental method (described above) does not support a bounding external exposure
evaluation method for the 1955-1958 timeframe, in support of radiological dose
reconstructions for the proposed worker class.” (underlining added)

North American Aviation, through is Atomics International division managed and operated
both the partial section of the SSFL/Area IB site and the Vanowen building at the SSFL/Area
IV - Canoga Facility site that were used for nuclear operations.

Operations, including radiation monitoring, at the SSFL/Area IV and Canoga Facility site, as
previously reviewed, were under the direction and supervision of the same division president,
and were the same. Operations, monitoring, and monitoring deficiencies that existed at the
SSFL/Area IV site also existed at the SSFL/Area IV - Canoga Facilities site. This fact is
reflected throughout both the NIOSH-prepared SEC-0093 report (Ref 2) and the S. Cohen &
Associates and Saliant, Inc (Ref 3) report, prepared for the “Advisory Board on Radiation &
Worker Health Review”. Re; On page 25 of the S. Cohen & Associates and Saliant, Inc.
report (Ref 3), the following is written---- “the AI Division of NAA operated all four of these
facilities, and their internal and external dose monitoring programs were the same for all the
Jacilities”.

This Petition is presented with the request that NIOSH, the DOE and the DOL apply the
same criteria (the criteria used in establishing the Special Exposure Cohort for all North
American Aviation employees at the SSFL/Area IV site) to this Petition, and thus to
recommend and establish a Special Exposure Cohort for all North American Aviation
employees at the SSFL/Area IV - Canoga Facility site for the period from Nov. 15, 1955 to
June 28, 1960.

Thank you.
Je 23, 2009
date

(Note: All information provided in this petition (other then my work history, supervision names, and non-technical
related work information or experiences) is based on information from NIOSH, DOL, DOE, North American
Aviation and other published repots, and is not based on any classified information derived from my memory or
other sources.)

20



.

.
g
2

5
.
3
&
3

iste 7-1-60 rr/gz

Ade Mail

Be¢E FI

UNITED STA“E,: ““~ pEegsy nO
ATOW!'C ENERGY COMMISS! ON So
¥ wo MUN

“INGTON 2.

1960 °
ass: Cpt.

JOW 29 196

Atomics International

A-Division of North American
Aviation, Inc.

P, 0. Box 309

Canoga Park, California

Attention: Mr. T. F. Mumphrey, Director
Contract Administration

Gentlemen:

to possess and operate the 10 watt (thermal) nuclear research
reactor designated as the "L-77" at a new location at the Company's
DeSoto facility in Canoga Park, Calffornia, as requested in its
epplications for license amendnent s dated February 8, 1960 and
March 29, 1960, .

. Aes,
Also enclosed is a related notice which has-been submitted -to -
the Office of the Federal Register for filing and publication.

Division of Licensing and Regulation

Enclosures: . : rn
1, Amendment No. 1 to License No. K-40
2, Kotice to Office of the Federal Register



\Effective Date: Revision No. [Document No. Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 9 of 54

Key review criteria identified in the report of the working group include the following:

e Timeliness

e Fairness

e Understandability
© Consistency

© Credibility and validity of the dataset, including pedigree of the data, methods used to
acquire the data, relationship to other sources of information, and internal consistency

¢ Representativeness and completeness of the exposure data with respect to the area of the
facility, the time period of exposure, the types of workers, and processes covered by the
data

The working group guidelines also recommend that NIOSH include in its SEC evaluation a
demonstration that it is feasible to reconstruct individual doses for the cohort, including sample
dose reconstructions.

SC&A’s implementation of the SEC Review process includes the following steps:

(1) Conduct a critical review of the petition and relevant reports, as well as documents and
data that are enclosed and/or referenced in the petition/reports.

(2) Identify additional issues/concerns that emerged from SC&A’s document review, which
are independent of those stated in the petition.

(3) As part of the SEC review, develop a preliminary technical position for issues identified
in the petition, as well as SC&A’s independent findings.

SC&A’s draft report with its preliminary findings will subsequently undergo a multi-step
resolution process, including interviews with site workers and others who can provide insights
into the issues of concern. Resolution includes a transparent review and discussion of draft
findings with members of the Board’s working group, petitioners, claimants, and interested
members of the public. This resolution process is intended to ensure that each finding is
evaluated on its technical basis in a fair and impartial manner. A final report will then be issued
to the full Board for deliberation and a final recommendation.

13 ORGANIZATION OF THE REPORT

Following this introduction, Section 2.0 of this report provides summary data contained in the
SSEL Site Profile. The site profile specifies relevant background information and methods to be
used by NIOSH for the reconstruction of internal and external doses, and includes brief site
profile summaries of materials and quantities processed, facility descriptions, and proposed
methods for dose reconstruction.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisionat and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: evision No, Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 50 of 54

ORAUT (Oak Ridge Associated Universities Team) 2007. Technical Basis Document: Area IV
of the Santa Susana Field Laboratory, the Canoga Avenue Facility (Vanowen Building), the
Downey Facility, and the De Soto Avenue Facility (sometimes referred to as Energy Technology
Engineering Center [ETEC] or Atomics International) — Occupational Environmental Dose,
ORAUT-TKBS-0038-4, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio.
March 8, 2007.

ORAUT-OTIB-0002. 2004. Technical Information Bulletin - Maximum Internal Dose
Estimates for Certain DOE Complex Claims, ORAUT-OTIB-0002, July 5, 2004.

ORAUT-OTIB-0006. 2005. Dose Reconstruction from Occupationally Related Diagnostic X-
Ray Procedures, Rev. 3. National Institute for Occupational Safety and Health (Kathren and
Shockley), August 2, 2005.

ORAUT-OTIB-0024. 2005. Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in
Uranium and Thorium Compounds, Rev. 00. National Institute for Occupational Safety and
Health (Bloom), April 7, 2005.

ORAUT-PROC-0060. 2005. External On-Site Ambient Dose Reconstruction for DOE Sites,
Rev. 00. National Institute for Occupational Safety and Health (Maher), March 7, 2005.

ORAUT-PROC-0061. 2006. Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 00.
National Institute for Occupational Safety and Health (Griffin), July 21, 2006.

Owens, D.E., 1978. Internal Letter from D.E. Owens (Radiation and Nuclear Safety, Rockwell
International) to R.J. Tuttle, Subject: Uranium Fire Incident A-0065: Emergency Response-
Uranium Fire at T028 — SSFL, March 28, 1978.

Pinney, S.M. and R. Hornung. 2006. Methods for Radon Exposure Estimates for Fernald
Workers, University of Cincinnati, 2006; slide presentation of the study.

RAC 1995, The Fernald Dosimetry Reconstruction Project, Tasks 2 and 3 Radionuclide Source
Terms and Uncertainties, RAC Report No. CDC-5. (Radiological Assessments Corporation),
Neeses, South Carolina, 1995.

Ross, K.N. and J.E. Beckeltheimer. 1970. “Thorium Metal Production Housekeeping,” June 8,
1970.

Rudkin, R.D., 1964a. Incident Report from R.D. Rudkin (Health and Safety, Atomics
International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0434: Building 1, Room 1126
~ SSEL, January 20, 1964.

Rudkin, R.D., 1964b. Incident Report from R.D. Rudkin (Health and Safety, Atomics
International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0407: Building 1, Room 1126
—SSFL, February 20, 1964.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: IRevision No. [Document No. [Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066, Page 27 of 54

40%

g

g

3
&

% Wokers Intemally Monitored
iy
2

g

coy
R

1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966
Year

Figure 4.3,1-2: Percentage of Workers Monitored Internally from 1956-1966

4311 1948-1958

TBD-5 describes the internal dosimetry (bioassay) program at SSFL, with key excerpts presented
below. As part of the ER, NIOSH located personal and area monitoring data in the NIOSH Site
Research Database (SRDB) and in its NIOSH OCAS Claims Tracking System (NOCTS), which
have been used to estimate doses to individual employees in the proposed class. NIOSH
identified only limited amounts of internal personnel monitoring data for pre-1959 exposures,
which is consistent with its finding that an SSFL routine bioassay program was not initiated until
August 1958 (Kellehar 1966).

The figures above indicate that there was essentially no internal monitoring taking place prior to
1959, which is consistent with NIOSH’s findings in the SEC ER.

43.1.2 1959-1965

Entry into the bioassay program was based on job assignment, but monitoring procedures were
generally invariable across occupations. However, firefighters appeared to be monitored more
frequently than other workers. By the early 1960s, the bioassay program “normally” consisted of
urinalysis for personnel whose work assignments involved “potential exposure to radioactive
materials.” The frequency of sampling during the 1960s was slightly higher than in any other
time period and varied from one to four per year, depending on the nature of the employee’s
work, past exposure history, etc. Special bioassay sampling, consisting of more frequent urine
testing, was in place very early (1960), but “only when gross internal contamination” was
suspected (Hart 1979).

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: Revision No. [Document No. iPage No,
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 51 of 54

Rudkin, R.D., 1964c. Incident Report from R.D. Rudkin (Health and Safety, Atomics
International) to R-F. Wilmes, Subject: Uranium Fire Incident A-0436: HQ 1, Room 1131 and
1114~-SSFL, March 12, 1964.

Rutherford, 2005, Sodium Reactor Experiment (SRE) Original Accident Release Data,
memorandum to E. Crawford; Phil Rutherford; January 21, 2005; SRDB Ref ID: 19161 and
19162

Santa Susana Field Laboratory SEC Petition. 2007. SEC Petition on SSFL to the Office of
Compensation and Analysis, SEC-00093 :

SC&A, 2005a. Second Supplemental Review of the Mallinckrodt Site Profile Revision 1
(Effective Date March 10, 2005), Second Supplement to SCA-TR-TASK1-0002, July 1, 2005.

SC&A. 2005b. Third Supplemental Review of the Mallinckrodt Site Profile Revision 1
(Effective Date March 10, 2005), Third Supplement to SCA-TR-TASK1-0002. August 16, 2005.

SC&A. 2006a. Board Procedures for Review of Special Exposure Cohort Petitions and Petition
Eyaluation Reports, Revision 1. SCA-TR-TASK5-0002, June 12, 2006.

SC&A. 2006b. Report to the Working Group on Special Exposure Cohort Petition Review,
Draft. January 16, 2006.

Schafer, G.K., 1961. Radiological Safety Incident Report from G.K. Schafer (Health and Safety
Department, Atomics International) to J.C. Lang, Subject: Uranium Fire Incident A-0456:
SNAP, Room 1273 ~ SSFL, October 13, 1961.

SEC Petition Evaluation Report, Petition SEC-00093, NIOSH, Report Submittal Date—February
6, 2008.

Shepard, J.L., 1959. “Quotation on Urinalysis,” letter to Atomics International, U.S. Nuclear,
Burbank, California. May 19, 1959,

Special Exposure Cohort Petition—Form B: June 22, 2007; OSA Ref ID: 103252.

Staszesky, F.M., 1970. Radiation Energy Analysis (To establish standards for bioassay sampling
for radiation workers), Atomics International, Canoga Park, California, August 12, 1970.

Stephenson, R.M., 1961. Radiological Safety Incident Report from R.M. Stephenson (Health
and Safety Department, Atomics International) to J.C. Lang, Subject: Uranium Fire Incident A-
0357: Fed Area, Room 1026 — SSFL, November 27, 1961.

Stephenson, R.M., 1962. Radiological Safety Incident Report from R.M, Stephenson (Health
and Safety Department, Atomics International) to R.F, Wilmes, Subject: Uranium Fire Incident
A-0355: FEPF, Room 1153 — SSFL, March 26, 1962.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV ~Canoga Facility site

tritium, and 0% for thorium. Potential exposure to radionuclides such as U-233 and U-
234 could have occurred during these operations, but it may not be possible to determine
this, given the limitations of uranium monitoring (see below).

Section 4.3.6 Lack of Source Term Data on page 32
TBD-S states the following:

Without bioassay or air sample data, the last resort is determination of airborne
concentrations using source term evaluations (NIOSH 2002, p. 19). Data on the
amount of dispersible material available does not appear to be available for
ETEC.

Section 4.3.7 NIOSH’s Interpretation of Reported Values by the Contract
Laboratory Nuclear Science and Engineering Corp. (NSEC) may not be
Correct

Section 5.3.1.2 (page 14) of TBD-5 attempts to clarify data reported by NSEC related to
urinalyses for gross alpha, gross beta, and MFPs:

Gross Alpha

Shepard (1959) gave a minimum measurable concentration of 7.5 dpm/L

Jor gross alpha counting. NSEC gave its minimum measurable

concentration as 0.2 cpm/mL (NSEC 1957). It is assamed that this is a

typographical error and 0.2 dpm/mL was intended. [Emphasis added.]

Gross Beta

Shepard (1959) gave a minimum measurable concentration of 75 dpm/L

Sor gross beta counting. NSEC gave its minimum measurable

concentration as 1.0 cpm/mL (NSEC 1957). It is assumed that this is a

typographical error and 1.0 dpm/mL was intended. [Emphasis added.]

Mixed Fission Products
... for beta activity with an approximate minimum detectable amount (MDA) of 60
dpm/sample (is assumed] (ORAU 2004, p. 27) ... NSEC gave its minimum measurable
concentration as 2.0 cpm/mL (NSEC 1957). It is assumed that this is a typographical
error and 2.0 dpm/mL was intended. [Emphasis added

Gross alpha 75 dpm 0.2 cpm/ml or 200 cpm/i
Gross beta 75 dpm/1 1 cpm/ml or 1,000 epm/I
MFP 60 dpm/l 2 cpm/ml or 2,000 epm/I

Section 4.3.8 Potential Difficulties Associated with Uranium Bioassay Data
Uranium at SSFL to which workers may have been exposed existed in various degrees of
enrichment (i.e., 2% to 93%). Section 5.3 of TBD-5 discusses the two independent
methods used to assess uranium in urine; the fluorometric method only identifies uranium
concentrations in ug/ml, while the radiometric method assesses the gross alpha activity in
dpm/I. Given the potentially wide range of specific activities of uranium defined by
fluorometric urine data, all fluorometrically analyzed urine would also require a

28



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

International) — Occupational Environmental Dose”, Report No. ORAUT-TKBS-0038-4, on
page 7, the following is written ----

“Between 1955 and 1960, nuclear research and development was preformed at a
facility known as the Vanowen Building (Building 0038) on Canoga Ave. in Canoga
Park, CA. Two small aqueous 93% enriched urayl sulfate research reactors
designative L-47 and L~77 were designed, developed, and operated at the Vanowen
facility, The maximum power ratings were 5 and 10 watts, respectively. Other
operations included reactor design, fuel development, and radiochemistry. L-47
operated between August 1957 and June 1958, and L-77 operated between May 1958
and Feb1960. The reactors were in the southeast corner of the building in what is now
a loading dock”. (Added note: the Vanowen building has been demolished.)

The arrangement of the Vanowen building (038) was as follows. The front (facing Victory
Blvd) had a row of managers’ offices, than (moving to the rear) were engineering offices and
bull-pens; further back were manufacturing and assembly areas, Many small, and a few
larger, laboratories for testing and research were located in the rear part of the building and
along the west side of the building (nearest Owensmouth St.) On the west~side of the
building, facing Owensmouth St., numerous, partially-enclosed test cells were located. As
stated above, the L-47 and L-77 reactors were on the far south-east corner of the Vanowen
building.

The Main Building (001) and the Vanowen building (038), in the 1950’s and early 1960’s,
each had a cafeteria/lunch room which was available for breakfast or lunch. Each location
was available to all employees of North American Aviation. (I specifically recall having
lunch in the Vanowen cafeteria/lunch room shortly after it opened in late-1955 or early1956)
to “check it out”).

(b) the close proximity and the essentially common environment for all the buildings and
locations at the SSFL/Area IV - Canoga Facility site

All the buildings on the SSFL/Area IV - Canoga Facility site are in close proximity. Figures
A clearly illustrates this close proximity and lack of boundaries between buildings at the site.
(The photograph shown was taken before the two-story (Engineering) building addition was
added to the Main building (001) on the south-east corner, before the large, two-story high
furnace-braze addition was added to the south side of the Main building (001), and before
Building 043 was constructed.

Location of the two reactors in the south-east corner of the Vanowen building (038) placed it
near the center of the site (see Figure A).

All the areas outside the buildings in the site were paved in the 1950’s and 1960’s, with
asphalt or concrete. Parking lots were on the north, east and south sides as shown in Figure
A. Employee walking paths and access surrounded the buildings, and permitted easy worker



Effective Date: [Revision No. |Document No. |Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 11 of 54

2.0 KEY INFORMATION AND DATA PRESENTED IN THE SSFL SITE
PROFILE

The most current site profile for the Santa Susana Field Laboratory (SSFL) consists of six
Technical Basis Documents (TBDs) that were issued at various times (see References for
specific dates). These TBDs will be referenced throughout this report and include the following:

ORAUT-TKBS-0038-1: Introduction
ORAUT-TKBS-0038-2: Site Description
ORAUT-TKBS-0038-3: Occupational Medical Dose
ORAUT-TKBS-0038-4: Occupational Environmental Dose
ORAUT-TKBS-0038-5; Occupational Internal Dose
ORAUT-TKBS-0038-6; Occupational External Dose

Throughout this report, individual TBDs are referenced simply by number. For example,
ORAUT-TKBS-0038-1 will be identified as TBD-1. Collectively, the six TBDs of the site
profile are intended to provide core information, data, and guidance that are intended to assist in
the dose reconstruction of individual workers who may have been exposed to internal and
external occupational radiation at SSFL as stated in ORAUT-TKBS-0038-1:

... The purpose of this document is to provide a site profile that contains
technical basis information for evatuation of the total occupational dose for
EEOICPA claimants who were employed at the Atomics International (Al) facility
as described above.

2.1. PRINCIPAL OPERATIONS

SSFL consists of a total of 2,850 acres and is located in the Simi Hills of Ventura County,
approximately 30 miles northwest of downtown Los Angeles, California. Based on ownership
and operations, SSFL is divided into four administrative and operational portions—Area I,
Area II, Area III, and Area IV. DOE operations are conducted in a 290-acre westernmost
administrative and operational portion designated as Area IV.

SSFL was initially established in 1947 by North American Aviation (NAA) to meet the
requirements for a field test laboratory to static-fire large rocket engines; however, it also met
NAA’s need for a nuclear research facility. As a result, Area IV was established in 1953 at
SSFL as a nuclear research and development (R&D) facility. Since then, SSFL has housed both
nuclear development and rocket development groups, although in distinct and separate locations.
Atomic Energy Research Development (AERD) also conducted operations in SSFL-Area IV. In
December 1955, the nuclear development and rocket development groups were transformed into
separate divisions—Atomics International (AI) and Rocketdyne.

Two distinct Al groups were housed in Area IV and supported by DOE, One focused on
development of civilian nuclear power, and the other was a center of excellence for research and
testing of non-nuclear components related to liquid metals. These two groups were referred to as
Al and Liquid Metal Engineering Center (LMEC), respectively. Nuclear R&D activities in

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV Canoga Facility site

Attachment A —E.2 Locations at the Facility relevant to this petition.

This Petition includes all facilities and all locations at the SSFL/Area IV - Canoga Facility
site, including the Main building (001), the Vanowen building (038), the Engineering
Annex (004), the small building originally used as a cafeteria (043) that is not shown in
Figure A, the several small outbuildings that are shown on Figure A, and the manufacturing
building (009), which is on the east-side of Canoga Ave.

Attachment A-E.3 List of job titles and job duties included in this petition.

This Petition, as detailed in Attachment A — F.1/F.2, beginning on page 13, is based on the
deficiencies in monitoring of effluents, gasses and particulate emissions, and the deficiencies
and lack of bioassay monitoring (and data) from the nuclear activities at the SSFL/Area IV —
Canoga Facilities site and located in the Vanowen building (038), including the two nuclear
reactors located in the south-east comer of the Vanowen building (038), as reported in the
various U. 8. Government reports cited in this Petition.

This Petition is for the coverage of all employees of North American Aviation that worked in
the SSFL/Area IV - Canoga Facility site. This inclusion of all North American Aviation site
employees is based on:

(a) the arrangement of the Vanowen Building (038), and the location and operation of the
two nuclear reactors in that building located on the SSFL/Area IV - Canoga Facility site;
(b) the close proximity and the essentially common environment for all the buildings and
locations at the SSFL/Area IV - Canoga Facility site;

(ce) the NIOSH position in Ref. 2, the “Petition Evaluation Report, Petition SEC-00093,
Rev 01, submittal date: February 6, 2008’ regarding the employees to be included in the
Special Exposure Cohort for the SSFL/Area IV site;

(d) the type of possible radiation exposures to employees, the availability (and Jack
thereof) of a comprehensive monitoring data base, and the lack of monitoring that took
place for radiation exposure (during the time period addressed in this Petition);

(e) the Corporation’s practice of common usage of the facilities at the SSFL/Area IV -
Canoga Facility site; and

(f) the practice of employee loan-outs and the transfer of employees between divisions,
subdivisions, departments and work groups located at the SSFL/Area IV - Canoga
Facility site.

(a) the arrangement of the Vanowen Building (038), and the location and operation of the
two nuclear reactors in the SSFL/Area IV ~ Canoga Facility site

The Vanowen Building housed operating nuclear reactors and numerous nuclear support
activities. In Ref.1-d “Area IV of the Santa Susana Field Laboratory, the Canoga Avenue
Facility (Van Owen Building), the Downey Facility, and the DeSoto Avenue Facility
(sometimes referred to as Energy Technology Engineering Center [ETEC] or Atomics



[Effective Date: [Revision No. |Document No. [Page No.
January 30, 2009 9 SCA-SEC-TASK5-0066 Page 5 of 54

ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

or the Board

AEC Atomic Energy Commission

AERD Atomic Energy Research Development
AWE Atomic Weapons Employer

AI Atomics International

ATR Advanced Test Reactor

BE Beryllium

CFR Code of Federal Regulations

Ci Curie

cpm Counts per minute

D&D Decontamination and Decommissioning
DOE Department of Energy

DOELAP Department of Energy Laboratory Accreditation Program
dpm Disintegrations per minute
EEOICPA — Energy Employees Occupational Illness Compensation Program Act of 2000

EPA Environmental Protection Agency
ER Evaluation Report

ETEC Energy Technology Engineering Center
EU Enriched Uranium

FR Federal Register

FWSP Federal Work Study Program
HEPA High Efficiency Particulate Air
HHS Health and Human Services

ISF Interim Storage Facility

keV Kilo Electron Volt

L Liter

LMEC Liquid Metai Engineering Center
LMFBR Liquid Metal Fast-Breeder Reactor
LMIC Liquid Metal Information Center
LMR Liquid Metal Reactor

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV ~Canoga Facility site

“In addition, monitoring for internal exposure of SSFL workers was incomplete and
poorly documented for most years of facility operation.”

And in paragraph 4—-

“The information in TBD-S [i.e., Ref 1-e, ORAUT-TKBS-0038-5, Technical Basis
Document: Energy Technology Engineering Center — Occupational Internal Dose, Rev.
00 (ORAUT 2006d)] is unclear as to whether workers exposed during these early
incidents were adequately monitored for internal exposure and, if workers were
monitored, whether their exposure records exist. “

S. Cohen & Associates and Saliant, Inc. address the SSFL/Area IV - Canoga Facility site in
the Special Exposure Cohort report (SEC-00093), with regard to radiation monitoring in
several statements.

In Ref 3, Section 5, Conclusions, on page 43, paragraph 1, the following comments are written---

“After a thorough review of SEC Petition-00093 (Ref 2) and the large number of
relevant/support documents, it is still unclear as to which of the four facilities (i.e.,
SSFL/Area IV, Canoga, Downey, and De Soto facilities) should be covered in the
petition and the initial year of coverage, which is dependent on whether all four facilities
are covered in the petition or if it is just Area IV of SSFL that is covered.

And in Ref 3, on page 25 of Section 4.2.1 Areas Addressed by Petition, a further statement
addresses the Canoga Facility site---

“The TBDs (i.¢.,Refs 1-a through 1-f) focus on Area IV of the Santa Susana Field
Laboratory, but also address the Canoga, Downey, and De Soto facilities. Dose
reconstructions that are prepared for employees of AI include work conducted at all four
of these facilities. It is noted above that the AI Division of NAA operated all four of these
facilities, and their internal and external dose monitoring programs were the same for all

the facilities”. (Underlining added).

In Ref 3, Section 5 Conclusion, page 43, the following is written regarding two major facility
incidents at the SSFL/Area IV (which addresses monitoring at North American Aviation in
the 1950’s and which is applicable to all North American Aviation facilities)---

There is a lack of information concerning two major facility incidents that had significant
potential for internal or external exposure to personnel; the SRE coolant failure and the
sodium burn pit. TBD-5 (i.e., Ref 1d) does not specifically address radiological incidents
that may have resulted in internal exposures to workers’ that were unmonitored and,
based on our review of claimant files, it does not appear that all workers who should
have been badged were indeed badged. As noted, the poor track record of badging
employees appropriately indicates a need for NIOSH to revisit the limitation for its

16



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Attachment A —E.5 Is the Petition based on one or more unmonitored, unrecorded,
or inadequately monitored recorded exposure incident

Yes
If yes provide the Date(s) of the incident and a complete description .

This Petition for a Special Exposure Cohort for the SSFL/Area IB — Canoga Facility site is
based (as previously stated) on the deficiencies in monitoring of effluents, gasses and
particulate emissions, and the deficiencies and lack of bioassay monitoring (and data) from
the nuclear activities located in the Vanowen building (038), including the two nuclear
reactors located in the south-east corner of the Vanowen building (038), as detailed in
Attachment A —F.1/F.2. This Petition is based on the facts that the same situations that
existed regarding air-borne nuclear-radiation effluents, dose monitoring deficiencies and lack
of bioassay monitoring that existed at the SSFL/Area IV site, as established and documented
by NIOSH in Ref 2, SEC-00093, also existed at the SSFL/Area IV ~ Canoga Facility site.

The dates presented for this Special Cohort Group Petition (Nov. 15, 1955 through June 28,
1960) are essentially consistent with the dates established by NIOSH for the SEC-00093
petition.

The SEC period “start date” for this Petition is Nov. 15, 1955, Although nuclear operations
began at the Vanowen building in the SSFL/Area IV -- Canoga Facility site in 1954, the Nov.
15, 1955 date is based on the date I began working at the site. I do not know of, nor can I
locate, any North American Aviation employee that worked at the site prior to this date and
that has an EEOIC Program defined presumptive cancer, and thus provide a basis for an
earlier start-date.

The cohort period ending-date for this Petition differs from the ending-date for the SEC-
00093 Special Exposure Cohort for the SSFL/Area IB because of the following factors.

(a) Nuclear inspection, machining, processing and nuclear reactor operations, and the
potential for radiation hazards and emissions, existed at the Vanowen building. The
Vanowen building was not a remote or seldom used building. From the beginning of
nuclear operations at SSFL/Area IV and the Vanowen building, the Vanowen building at
the SSFL/Area IV ~ Canoga Facility site was the “hub” for North American Aviation’s
nuclear reactor program operations. The Vanowen building’s loading docks were the
delivery site for materials, and vendor supplied parts and fabricated hardware destined for
either SSFL/Area IV or the nuclear activities in the Vanowen building. At the loading
docks materials, supplies and vendor parts were off-loaded and receiving inspection
performed.

The Vanowen building was the principle manufacturing facility for the SSFL/Area
nuclear reactor operations. Incoming materials or hardware requiring machining,

11



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

under the Energy Employees Occupational Centers for Disease Control and Prevention

liiness Compensation Act National institute for Occupational Safety and Health

5 OMB Number: 0920-0839 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B Page 7 of 7
Public Burden Statement

Public 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 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 lliness 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
Controf 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 evaiuation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain fimited 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 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 not be considered by HHS.

Name or Social Security Number of First Petitioner: __|



ffective Date: Revision No. {Document No.
January 30, 2009 o

SCA-SEC-TASK5-0066

\Page No.
Page 34 of 54

4.3.9 There are Unanswered Questions Regarding the Completeness and Quality of

Personnel Exposure Records

In Section 5.2 of the TBD, the following statements appear:

Page 10:

...Al established health and safety files on each employee that contained radiation
exposure records, injury records, and other “pertinent” data (Lang undated,
1960). Today, personnel radiation exposure records are in the Radiation Safety
Records Management System (RSRMS), which encompasses about 170 file

cabinets. [Emphasis added.]

Page 12:

The bioassay records in the individual files generally consist of:

+ Individual Personnel Keysort Cards (Figure B-2, Attachment B), which were
used to track the type, frequency, and week of sample collection. .... The
forms can be difficult to read due to the quality of the copies, and dose
reconstructors should refer to the forms listed below for urine and fecal data.
This form might be the only place in vivo [?] data are listed. {Emphasis

added.]

Section 5.7 (page 23):

The bioassay results from ETEC and its predecessor organizations are

apparently not available in a computerized format. ‘The units used to report the
results are generally included in the hard-copy reports. ... [Emphasis added.]

Section 5.8 (page 23):

No codes have been found [for excreta samples]. ...

These statements suggest that (1) all personnel records currently exist in hardcopy form only,

and (2) records may be of poor quality, difficult to interpret, and incomplete.

SC&A concludes that the use of these records for dose reconstruction will require a
comprehensive assessment regarding the quality and completeness of records contained in the
170 file cabinets, and requires guidance to dose reconstructors for their interpretation/use.

4.3.10 Use of SSFL Site Survey Data/Source Term cannot be Regarded as Useful Surrogate
Data for Bioassay Data in Dose Reconstruction —

Th the absence of an individual’s in-vitro/in-vivo bioassay data, the TBD provides the following
information and guidance to dose reconstructors:

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Figure A

SSFL/Area IV — Canoga Facility site

(aerial view looking south)

21


Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —-Canoga Facility site

NIOSH has stated in their report Ref. 2, SEC Petition Evaluation Report, Petition SEC-00093
Report Rev 01 , that---

“NIOSH cannot estimate internal exposures with sufficient accuracy during the period
from 1955 through 1958 (which is a period with limited internal monitoring data). This
includes the time from the beginning of Area IV radiological activities in 1955, to late
1958 (selected as December 31, 1958 for SEC evaluation purposes). This timeframe
corresponds with the date after which an established bioassay program existed at SSFL
and after which sufficient internal monitoring has been identified.”

And in the Ref 1-d report, ORAUT-TKBS-0038-4, on page 8, in Section 4.5 “Inhalation of
On-site Airborne Radionuclides” the following regarding the SSFL/Area IV site---

“The environmental monitoring program at Area 1V was established in May 1954 before
construction of the first radiological facility (Sapere and Boeing 2005, p. 3-13), with
emphasis on soil, vegetation, and water sampling in the environment around Area IV.
The program had been initiated in 1952 at the Downey Facility but was terminated in the
move to Canoga Park (Moore, Fisher, and Rowe 1962). From 1959 to present, ambient
gross beta activity in air has been measured continuously in five locations. From 1963
on, gross alpha activity was measured. Ambient air samples are currently analyzed for
isotopic content (Sapere and Boeing 2005, p. 3-15)”

However the next sentence reads---

“No information is available for the Downey or Canoga Park facilities other than the De
Soto facilities; information for the De Soto facilities is not available until ambient data
are reported together with Area IV data in environmental monitoring reports.”

This lack of monitoring in the 1950”s (including direct, airborne, effluent and bioassay
monitoring), although considered adequate at that time, has resulted in today’s lack of
reliable and complete monitoring data. These deficiencies in the monitoring practices,
monitoring data and monitoring equipment used in the 1950’s (and later) and has been
addressed in a detailed manner in the NIOSH Subcontractor Report, Ref 3, “Technical
Support for the Advisory Board on Radiation & Worker Health Review of NIOSH Dose
Reconstruction Program, Review of the Santa Susana Field Laboratory (SSFL)- Area IV
Special Exposure Cohort (SEC) Petition-00093 and the NIOSH SEC Petition Evaluation
Report”, report no. SCA-SEC-TASK5-0066, dated January 30, 2009, and prepared by S.
Cohen and Associates. Key elements are summarized below. (For completeness, these
briefly summarized excerpts from the report, SCA-SEC-TASK5-0066, are shown in
Attachment A-1. as full texts.)



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

No specific information on sensitivities for the in-house laboratory was
obtained.... {Emphasis added.]
Page 15 (Regarding thorium):

No details of early thorium analyses were recovered...
Page 15 (Urinalyses for period 1967-1974):

Partial documentation on bioassay methods from 1967 through 1974 was found. ... These
documents are believed to refer to services offered by UST [one of the eight contract
laboratories]. [Emphasis added.]

Page 17 (Urinalysis for period 1975-1988):
The following analytical methods were taken from a series of annual
reports... The measurement “type” in parentheses appears in many
personnel bioassay records. The detection limits should have improved
over the years. However, a listing was not found. ... [Emphasis added.]

Page 18 (On the method for analyzing mixed fission products):
Mixed fission products were precipitated from a basic oxalate media. ...
Alkali metals such as 137Cs did not precipitate. In addition, volatile
fission products such as 1-131 were lost. ... [Emphasis added.]

Page 19 (On in-vitro methods for individual radionuclides):
Although fecal sampling was mentioned as both a routine and a special
bioassay method in site documents, little detail has been found about the
analytical methods used. ... [Emphasis added.]

Page 20 (On the use of whole-body counting for monitoring workers):
.. whole-body counting for fission or activation products was apparently not part
of the routine bioassay program at ETEC. Between 1975 and 1988, only 25
counts on 25 individuals were summarized in annual reports. ...All WBCs were
reported positive for 137Cs. Ten counts were performed in 1977 and 15 were
performed in 1979. [Emphasis added.]

Page 20/21 (On the use of chest counting):
In 1967, the first chest (lung) counts for uranium using a medical system
were performed at UCLA. The 186-keV gamma ray from the decay of
235U was used to quantify the amount of EU in the lung ... Calibration of
this system was crude, ... [Emphasis added.]
Starting in 1968, Helgeson Nuclear Services provided lung counting
services. ... The results were reported in milligrams of 235U + 2 sigma...
By 1977, two 5-in.-diameter, thin-window phoswich detectors were used,
... [to detect U-235]

26



‘59 nuclear reactor accident remains vivid for former Santa Susana Field Laboratory w... Page 3 of 6

Atomics International, confirmed the event.

Questions persist today about the extent of damage caused by the meltdown on workers, those living in the
shadows of the facility and the environment. :

One scientist hired by defendants in a suit against the facility’s owner described the disaster as likely
releasing 15 to 260 times more radiation than Three Mile Island. The claim was rebuttted by a researcher for
Boeing and the U.S. Department of Energy, whose predecessor agency had partnered with Atomics
International on the development of 10 small reactors, including the SRE, at the Field Lab. Other incidents,
more minor, occurred with some of the other reactors.

Health studies have arrived at contradictory conclusions. Those living around and working at the lab have
higher cancer rates, according to some. Others determined that workers were not more prone to cancers.

Late notice limits study

Scientists’ efforts to reach conclusions were partially hampered by limited information about the incident at
the high-security site, researchers say.

Five weeks passed before Atomics International acknowledged something had happened on the hill.

By then, removal of the 13 damaged fuel bundles was under way. Efforts to dislodge a jammed fuel element
went awry, the company conceded. That action contaminated the building, and decontamination had started,
Pace said.

The incident and the high radiation exposure in the reactor room and its exhaust stack are recorded in the
company’s reports. But the company’s Aug. 29, 1959, press statement ignored the event and the power
surge and downplayed what happened to the fuel in the reactor’s core. It claimed only a single fuel bundle
was damaged. f

“The fuel element damage is not an indication of unsafe reactor conditions,” the statement read, “No release
of radioactive materials to the plant or its environs occurred and operating personnel were not exposed to
harmful conditions.”

An interim report on the surge and meltdown would later conclude that no radiological hazard was present
in the reactor areas. The same report, published Nov. 15, 1959, detailed high levels of radiation in the
reactor building and stated reactor gases were released twice — on July 15 and July 22.

Reactor gases were released frequently during the two weeks after the surge, Pace said. Every time the
reactor was brought up to power and then shut off, radioactive ‘gases were released, often without being held
in holding tanks to diminish their radioactivity, he said.

More firsthand accounts sought

Gregg Dempsey, a senior science advisor with the U.S, Environmental Protection Agency, met Pace in
December 2008 and found his recollections valuable. Dempsey is a key member of a team conducting a
study to determine radiation levels at the Field Laboratory. He would like to find more people who worked
there,

“He was very aware of what was going on around him because he was expected to learn it,” Dempsey said
of Pace, “The reason I enjoyed talking to him is his memory of his time there was so sharp.”

mhtmi-file://C:\Documents and Settings\Vernon\Desktop\Corhort Petition\'59 nucle... 7/23/2009



UNITED STATES ATOMIC ENERGY, SSION
DOCKET NO. 50-94

NORTH AMERICAN AVIATION, INC.

NOTICE OF ISSUANCE OF UTILIZATION FACILITY LICENSE AMENDMENT

Please take notice that the Atomic Energy Commission has issued Amend-
ment No. 1, set forth below, to License No. R-40. The amendment authorizes
North American Aviation, Inc. to possess and operate the 10 watt (thermal)
nuclear research reactor designated as the "L~77" at a new location at the
DeSoto facility of North American Aviation, Inc., in Canoga Park, California
as requested in its applications for license amendments dated February 8,
1960 and March 29, 1960. Prior public notice of the proposed issuance of
this amendment was published in the Federal Register on June 10, 1960, 25
FR 5192

In accordance with the Commission's "Rules of Practice" (10 CFR 2) the
Commission will direct the holding of a formal hearing on the matter of the
issuance of the License amendment upon receipt of a request therefor from
the licensee or an intervener within thirty days after issuance of the
license amendment. Petitions for leave to intervene or requests for formal.
hearing shall be filed by mailing s copy to the Office of the Secretary, Atomic
Energy Commission, Washington 25, D. C., or by delivery of a copy in person
to the Office of the Secretary, Germantown, Maryland, or the AEC's Public
Document Room, ize Street, Washington, D, C. For further details see q))
the applications for license amendments dated February 8, 1960 and March 29,

1960, submitted by North American Aviation, Inc. and (2) a hazards analysis



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

Re: Section 4.3.2 in the report--- “monitoring for internal exposure of SSFL workers was
incomplete and poorly documented for most years of facility operation—teferring to the
1950’s and 1960’s.

Re: Section 4.3.3 in the report--- “Insufficient correlation between bioassay data and
potential exposures” —to specific radionuclides exist in what data that is available.

Re: Section 4.3.4 in the report--- “missing radionuclides in bioassay data” exist in most
of the monitoring records.

Re: Section 4.3.6 in the report--- there is a “Lack of Source Term Data”

and “without bioassay or air sample data, the last resort is determination of airborne
concentrations using source term evaluations”, and “data on the amount of dispersible
material available does not appear to be available for SSFL/Area IV”.

Re: Section 4.3.7 in the report--- “Interpretation of reported values by the contract
Laboratory Nuclear Science and Engineering Corp. (NSEC) may not be correct”
“related to urinalyses for gross alpha, gross beta, and MFPs”.

Re: Section 4.3.8 in the report--- “potential difficulties associated with uranium bioassay
data” exists, and “it is unclear whether urine samples were consistently analyzed by both
fluorometric and radiometric methods”.

Re: Section 4.3.9 in the report--- “there are unanswered questions regarding the
completeness and quality of personnel exposure records”.

Re: Section 4.3.10 in the report--~ “Use of SSFL Site Survey Data/Source Term cannot
be Regarded as Useful Surrogate Data for Bioassay Data in Dose Reconstruction” and
the guidelines are “deficient and place an unrealistic responsibility on the dose
reconstructor ”.

The lack of viable radiation dose monitoring data for the SSFL/Area IV site is directly
applicable, and in the same manner, to the SSFL/Area IV — Canoga Facility site, which is
addressed in this Petition.

(e) the Corporation’s practice of common usage of the facilities at the SSFL/Area IV -
Canoga Facility site

All of the buildings and other facilities at the SSFL/Area IV - Canoga Facility site were
either owned or leased by the parent Corporation, North American Aviation. As can be seen
in Figure A, “business was booming” for both the divisions that shared this site in the
1950’s,, and this business boom continued until the very late 1960’s. During this period floor
space, of any type, at the SSFL/Area IV - Canoga Facility site was at a premium. In the early
1960’s three additional manufacturing building were constructed, and leased, south-east of



‘59 nuclear reactor accident remains vivid for former Santa Susana Field Laboratory w... Page 2 of 6

‘Along with the televised account of the incident, Pace was moved by recent news reports of workers
sickened by exposure to chemical and radioactive exposure at the Cold War-era facility, workers who faced
difficulties or were rejected when they applied for a federal government compensation program because
they lacked the needed proof of their employment and work assignments.

Pace’s recollections dovetail with many of the accounts found in documents from that era, and he has come
forward with them as state and federal agencies and the company involved are negotiating a further cleanup.

He remembers records being thrown out back after the reactor building was contaminated in August 1959.
The paperwork landed in a heap behind the building, along with office furniture and other debris, Pace said.

But some events he witnessed were not recorded in Atomics International’s internal reports on the incident.

“I see these stories, and it just hurts me inside to know these families are hurting so bad for information,”
Pace said in a recent interview, referring to former workers and their families. “It’s a very important thing to
me. I’m up in my 70s, and I’d like to get all these things documented so there are more true stories ~— truer
stories —- instead of some of the speculation.”

Pace has lived for the past 16 years in Rexburg, Idaho, with his wife, Geneva, whom he married in the
summer of the meltdown.

He acknowledges his accounts are limited to what he witnessed and heard as he helped scrub radiation from
walls with soap and water, among other tasks during the summer and fall of 1959. The passage of time has
muted his recollection of some details, but other images and conversations are etched into his memory.

It’s true, Pace said, that workers from Rocketdyne, Atomics International’s sister division that conducted
rocket engine tests at the lab, were brought over to help with the cleanup. To record exposure to radiation,
they wore film badges that were checked every night. Once they reached a certain level, the worker was
banned from the reactor site for 30 days.

SRE workers were often told not to wear their badges, he said.

An improvised cleanup

It’s also true, Pace said of a story that seems more lore than fact, that women’s sanitary napkins were used
to wipe down contaminated surfaces with cleansers gathered from around the 2,850-acre Field Laboratory

after the meltdown. The absorbent material was more effective and longer lasting than sponges. A secretary
suggested using them, he said.

“It was brilliant,” Pace said. “When we were done we’d throw it in a plastic bag and throw it out back.”

It’s likewise true, Pace said, that radioactive gases were released. The night of the surge, the men — dressed
in nothing more protective than cotton coveralls — worried about venting “hot” gases into the air.

“The big thing on their mind was which way the wind was blowing,” Pace said. “They released that (gas)
and it went out over the San Fernando Valley where all their children and families were, and they couldn’t

say a thing about it because it was top secret.”
For decades, the partial meltdown was shrouded in secrecy, its details first revealed in internal company

documents unearthed in 1979 by UCLA students in the wake of the meltdown at the Three Mile Island
nuclear power plant near Middleton, Pa., in March of that year. ‘The same year, Rocketdyne, which outlived

mhtmtfile;//C:\Documents and Settings\Vernon\Desktop\Corhort Petition\'59 nucle... 7/23/2009


MAY-16-01 WED 15:47 NRO R IV FAX NO. 8608188 P.02

tawn®

gst Meu, UNITED STATES
Oy get NUGLEAR REGULATORY COMMISSION
3 dg) REGION Iv 1
oA 617 RYAN PLAZA DAIVE, SUITE 40, 7
Gy, Na ARLINGTON, TEXAS 76077-8064 ° EG E
——_

|

danuary 29, 1996 |

MEMORANDUM TO: Michael F. Weber, Chief
Low-Level Waste and Decommissioning Projects Branch
Division of Waste Management /NMSS 7

FROM: Ross A. Scarano, Director fort baare

Division of Nuclear Materfals Safety
SUBJECT: ROCKWELL INTERNATIONAL SITE VISIT

As you are aware, Oak Ridge Associated Universities (ORAU) recently reviewed
59 terminated rasearch and test reactor license docket files. ORAU concluded
that 30 files did not contain sufficient decommissioning and disposition
information. One of the 30 files was Docket 50-50, License R-19,

License R-19 was issued to Atomics International, a Division of North American
Aviation, for the 1-47 reactor. This reictor operated between 1957-1958 at a
Atomics International facility located in Canoga ‘Park, California. The
facility is now controlled by Rockwell International.

In an attempt to gather more information about tha reactor, a member of our

staff, Mr. Robert Evans, visited Rockwell International on’ November 15-16,

1995, In summary, the where-abouts of the reactor were not identified

although disposition information was located for some of the reactor fuel.
0, the former ‘oom was visited and surveyed for radioactive

contamination and none was identified.

Records obtained during the site visit consist mainly of documents related to
the license application and early operational records. Little disposition or
decommissioning information was identified for this reactor although some
Tretotogical and environmental records were found for the building that houged
the reactor, .

In addition, several individuals (including W. L.-Fisher, former NRC Region IV
Branch Chief) who worked with the reactor were interviewed and none could
recall] what happened to the reactor, .

Atomics International and its predecessors operated many unigue reactors for
decades in and around Panoga Park. The facility had a well-defined waste
disposal program. The reactor was most likely properly disposed of in the

‘ late 1950°s through Atomic International’s normal waste processing and

disposal programs.

Attachment 1 provides additional information about the history of the reactor
and the site visit. Affixed to Attachments 2 through 4 are copies of
documentation that were found in Rockwell’s files. Attachment & is a copy of
the ORAU review of Docket File 50-50. We recommend that the information be

added to the NRC’s archive file for Docket No. 50-50.


lEffective Date: FRevision No. [Document No. Page No.
January 30, 2009 SCA-SEC-TASK5-0066, Page 30 of 54

Page 17 (Urinalysis for period 1975-1988):
The following analytical methods were taken from a series of annual reports...
The measurement “type” in parentheses appears in many personnel bioassay
records. The detection limits should have improved over the years. However, a
listing was not found. ... [Emphasis added.]

Page 18 (On the method for analyzing mixed fission products):

Mixed fission Products were precipitated from a basic oxalate media. ... Alkali
metals such as '°7Cs did not precipitate. In addition, volatile fission pr roducts
such as 1-131 were lost. ... [Emphasis added.}

Page 19 (On in-vitro methods for individual radionuclides):

Although fecal sampling was mentioned as both a routine and a special bioassay
method in site documents, little detail has been found about the analytical
methods used. ... [Emphasis added.]

Page 20 (On the use of whole-body counting for monitoring workers):

.. whole-body counting for fission or activation products was apparently not part
of the routine bioassay program at ETEC. Between 1975 and 1988, only 25
counts on 25 individuals were summarized in annual reports. ...All WBCs were
reported positive for 37Cs. Ten counts were performed in 1977 and 15 were
performed in 1979. [Emphasis added.]

Page 20/21 (On the use of chest counting):

Jn 1967, the first chest (lung) counts for uranium using a medical | system were
performed at UCLA. The 186-keV gamma ray from the decay of ??U was used to
quantify the amount of EU in the lung ... Calibration of this system was crude;...
[Emphasis added.]

Starting in 1968, Helgeson Nuclear Services esprovided lung counting services. ...
The results were reported in milligrams of? U £2 sigma...

By 1977, two 5-in.-diameter, thin-window phoswich detectors were used, ... [to
detect U-235]

(SC&A notes that all chest measurements only quantified the amount or the
activity of U-235. Without a firm understanding of the level of enrichment, the
more important contribution of U-234 to total alpha activity cannot be
determined.)

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: Revision No, |Document No. iPage No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 36 of 54

“radiation workers”, were not internally monitored while all radiation workers were externally
monitored.” If these radiation workers did indeed work in the SRE area, the lack of internal
monitoring would be a concern, given the program was supposed to be fully functional in 1959.

Atomics International prepared two reports on this incident; a report titled SRE Fuel Element
Damage, An Interim Report (NAA-SR-4488)—November 15, 1959 (AL 1959), and a second
report titled, SRE Fuel Element Damage, Final Report (NAA-SR-4488 (suppl)—-1961 (AI 1961).

The interim report (AI 1959) contains important information related to this incident that is not in
the site profile. Examples of this information include the following:

¢ During this occasion, specifically, in October 1958, the maximum radiation
levels in the general area of the moderator coolant pump were reported to be
about 50 Mr/hr (October 14). Below shield blocks | and 2, the radiation level
was about 21 mr/hr (on October 11). (p. I1V-C-9)

* Radiation levels measured on April 18, 1959 varied from 50 to 420 mr/hr.
... Additional measurements made 5 days later (a total of 17 days after
shutdown) indicated no significant decay. (p.{V-C-10) [Table IV-C-6
includes radiation levels in the Gamma Facility on various dates in August,
September, and October of 1959. The measured radiation levels peaked on
August 12 (2.9 r/hr) and decreased to 0.7 r/hr on October 5.]

¢ Cold trapping was started during run 14. However, radiation measurements
could not start until August 8 (due to the radiation hazard from the high
radiation levels of Na’), at which time the dose rate, extrapolated to near the
surface, was about 70 r/hr. It is possible that initial cold-trap dose rates, had
they been measured, would have yielded significantly higher values. (p. 1V-C-
12) [The radiation rates at the cold trap, shown in Table IV-C-7, range from
63 r/hr on August 8, 1959, to 50 r/hr, with a peak of 81 r/hr on August 13.]

« Following the termination of run 14, the fuel handling cask was used to
inspect the fuel elements in the reactor. ... Operations directed towards
removal of these slugs resulted in occasional radiation levels as high as
1000 r/hr at 1 ft. from the slugs. However, the maximum total exposure
received by operations personnel during these cask operations did not exceed
1 rem ina single week. (p. 1V-C-22). [The basis for this last statement was
not provided in the report, and the number of personnel exposed was also not
presented.]

The final report (AI 1961) also contains information related to potential worker exposure.
Examples of this information include the following:

¢ This report discusses the distribution and management of the fission products
during the recovery operations. During the recovery effort the objectives

2 Percentages rather than absolute numbers have been provided given Privacy Act concerns.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area [TV —Canoga Facility site

is unlikely that new or additional monitoring would have begun at Vanowen, with a move
out of the building being eminent.

(d) A letter from the Atomic Energy Commission, dated June 28, 1960 (Ref 5), grants
North American Aviation permission to move the L-77 reactor from the Vanowen
building to the DeSoto site. Since the L-77 reactor could not be moved without this
permit, this “License” dates the earliest date for the removal of the L-77 reactor from the
Vanowen building, and thus the conclusion of nuclear operations at the Vanowen
building, prior to decontamination and clean-up. This date for the “license” to move the
L-77 reactor out of the Vanowen building, granted June 28, 1960 has been used to
establish the concluding date for this Petition for a Special Exposure Cohort for the
SSFL/Area IV ~ Canoga Facility site.

Some anomalies exist (re: Ref 7, Attachment 1) regarding the disposition of the L-47 reactor,
that was operated in the Vanowen building at the SSFL/Area IV - Canoga Facility site. On
Nov. 15-16, 1995, representatives of the United States Nuclear Regulatory Commission
toured the Vanowen building. Records regarding the date of disposition of the L-47 reactor,
and the location to which it was moved, were limited. Only ten percent (10%) of the reactor
fuel purchased for the L-47 could be accounted for. The building site was surveyed on the
above, Nov. 15, 1995 date for radioactive contamination (approx 35 years after nuclear
operation were removed from the building), The report states that no contamination was
identified. That report further states that “The former reactor room was found to free of
radioactive materials which indicated that the area had been successfully remediated by
either Atomics International or Rockwell International.” The question of at what date this
occurred, and what contamination existed prior to the remediation, was not addressed. No
comments were included in the report regarding the material handling, machining and
nuclear processing facilities that were in the Vanowen building in the 1950s, prior to the
move to the DeSoto building 101.

Attachment A — F.3/F.4 Section F-3 Requests that attached report(s)
from a health physicists or other individual...... , and Section F-4 Requests attached
technical report(s), issued by an agency of the Executive Branch of Government
(re; NIOSH),----be employed in order to
“provide a basis for proposing that records and information are inadequate for
individual dose (reconstruction)”

The basis for this Petition that dose reconstructions can not be performed for North
American Aviation employees at the SSDL/Area IV - Canoga Facility site, from November

15, 1955 through June 28, 1960 is derived, in part, from the NIOSH prepared Ref 2 report,
“SEC Petition Evaluation Report, Petition, SEC-0093, dated February 6, 2008 which
addresses the SSFL/Area IV site. The basis for this Petition is that the same dose monitoring
deficiencies that existed at the SSFL/Area IV site also existed at the SSFL/Area IV ~ Canoga
Facility site. Specifically regarding these deficiencies NIOSH states in the Ref 2 report, on
page 3, the following---

13



‘59 nuclear reactor accident remains vivid for former Santa Susana Field Laboratory w... Page 4 of 6

Pace returned to the Field Laboratory last winter for the first time in more than 49 years, accompanied by
Dempsey, local activists and a Boeing representative.

In an area that now is mostly open field, Pace described where buildings once stood. He pinpointed the
slope where the old weather equipment once sat. It was his job to gather weather data and determine which
way the wind was blowing.

Standing on the slope’s crest, Pace looked at Simi Valley and Moorpark and saw that the once-small towns
surrounded by open fields and citrus groves were now full-grown cities spreading across the valley floor.

“It was a little spooky going back there,” Pace said later. “Up at the hill I could remember where I used to
walk around. Spooky because there was supposed to be more there. I could see it in my mind and see what it
was. It was like looking at a ghost.” '

New program, an eager apprentice

Construction on the Sodium Reactor Experiment began in April 1955. The reactor was part of a program by
Atomics International and the U.S. Atomic Energy Commission to develop a sodium-cooled reactor that
could be employed for civilian uses. It also was used in experiments.

“It was different,” Pace said. “It wasn’t like going to a reactor today that is set for making electricity. Each
day I went to work it was a different experiment or they were trying different types of fuel, seeing what type
of fuel would work the best under different circumstances.”

Pace, who grew up in Northridge and graduated from Reseda High School, had moved to Moorpark with his
family in 1958. He’d grown up around his father’s auto body and paint business and was well-versed in
mechanics.

Newly engaged, he applied for the trainee position at Atomics International with the help of a family friend
and started work in March 1959. He and Geneva married several months later and bought a house in
Thousand Oaks. He was laid off in November of that year.

“I enjoyed what I was doing,” Pace said. “It was quite an honor to work there in those days, for somebody at
my age to have that kind of work there, especially if you didn’t have an education.”

Pace called the period “a different time.” The Korean conflict had ended, but the Cold War persisted as
Soviet leader Nikita Khrushchev threatened nuclear war and the United States honed its nuclear defense.

Calm without, trouble within

Security was tight at the Field Laboratory. Driving up Black Canyon Road on July 13, 1959, everything
appeared to be in its place. The guard at the lab’s front gate gave no indication anything was amiss, Pace
said.

For the next four months, work revolved around the power surge and meltdown. Without precedent to set
their course, SRE officials proceeded to diagnose and fix problems through trial and error.

The damage was caused when a chemical used to cool the pumps that pushed the heat-absorbing sodium
around the fuel bundles leaked into the sodium. The mix caused a gummy substance that blocked the
sodium flow, causing the fuel to run hot and meld with the steel tubes that encased it. Similar leaks had

previously occurred.

mhtmib-file://C:\Documents and Settings\Vernon\Desktop\Corhort Petition\'59 nucle... 7/23/2009



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
. Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

This conclusion is amplified in several selected comments extracted from the Ref 2 report,
SEC-00093. These are as follows----

In Section 6.1.1 Internal Urinalysis Data, on page 33, of Ref 2----

“NIOSH has identified only limited amounts of internal personnel monitoring data for
pre-1959 exposures; this is consistent with its findings that a SSFL routine bioassay
program was not initiated until August 1958 (Kellehar, 1966). Therefore, NIOSH has
concluded that pre-1959 workers will generally not have bioassay data prior to August

1958 (except in rare cases).”

And in Ref 2, Section 6.1.2 Lung, Whole-Body, and Other Types of Internal or Bioassay
Data

“Routine lung-counting, using equipment and techniques specifically developed to
measure lung deposits of uranium, did not start until 1968 (outside of the timeframe

evaluated in this report).” (underling added)
And in Ref 2, Section 7.1.1 Internal Monitoring Data Review

“The routine in vitro bioassay program was established in August 1958 (Kellehar, 1966).
The practice at SSFL was to collect urine samples based on job assignments that
required exposure to radioactive materials. Prior to August 1958, NIOSH has found only
limited personnel bioassay data or associated internal monitoring-related information
for the worker class being evaluated in this report. However, NIOSH does have access to
original urinalysis results and other supporting program data for the period after the
initiation of a bioassay program in August 1958.” (underling added)

And in Ref 2, Section 7.2 Internal Radiation Doses at SSFL-Area IV

“Workers were potentially exposed to these radionuclides during reactor operations as
well as during shutdowns, modifications, and refueling. Dust containing radionuclides
could be inhaled by individuals and then deposited in the respiratory tract. The dust
would also settle on surfaces and become resuspended in the air, where it could again be
inhaled or ingested by transfer from contaminated surfaces via hand-to-mouth. The
majority of the exposures over the history of SSFL-Area IV operations are considered to
be chronic in nature.

and
“In addition to particulate matter, reactor operations also produced some short-lived

gaseous (xenon- 133 and krypton-85) and volatile fission products (radioiodine).
Workers could have inhaled this material, although generally there were systems
designed to confine or absorb this material until it decayed or was disposed of as waste

(Sapere Consulting, 2005).”

18



[Effective Date: [Revision No. |Document No. age No.
January 30, 2009 i) SCA-SEC-TASKS5-0066 Page 15 of 54

were inadvertently contaminated. The site profile states that both areas have been remediated
and that no residual contamination has been detected.

2.5 OTHER RELEVANT FACILITIES

There are three other operations that are addressed in the site profile; the Downey facility, the
Canoga Park facility, and the De Soto facility. Each of these facilities is described below.
NIOSH considers these facilities as individual covered areas and does not include them in SEC
Petition-00093. This issue will be further reviewed below.

2.5.1 Downey

The Downey facility, located in Downey, California, included AEC-funded activities performed
in a small portion of a large building from 1947-1955. The AEC activities included mainly
paper studies, R&D, and engineering studies, The R&D activities involved the use of a 2-MeV
Van de Graaff generator, a small-scale radiochemical laboratory, a neutron counting room, and a
construction area with a small 0.5 W teaching reactor.

2.5.2 Canoga Park

Activities at the Canoga Park, California, facility occurred in the Vanowen Building from
approximately 1954-1960. Activities that had been performed at the Downey facility were
moved to the Canoga Park facility at the end of 1955. The primary activities performed at the
Vanowen Building included design, development, and operation of small aqueous fuel reactors;
fuel development; and radiochemistry, and beryllium machining is believed to have occurred.

2.5.3 De Soto

Radiological operations occurred at the De Soto facility from 1959 to the mid-1990s. Nuclear
fuel material and other radioactive materials were used in Buildings 101 and 104 (referred to as
001 and 004, respectively, prior to 1984) from 1959-1983, Building 104 was used at a much-
reduced level until the mid-1990s. The nuclear operations conducted in these buildings included
the Advanced Test Reactor (ATR) fuel fabrication and supporting activities; a Gamma Radiation
Facility; and a mass spectroscopy (Helium Laboratory).

2.6 RADIONUCLIDES OF CONCERN

Workers at SSFL were engaged in many process operations and maintenance activities that had
the potential for external and internal exposures to a host of radionuclides shown in Table 2-3 of
TBD-2.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



a.

b.

=36

Operating Restrictions
(1) North American Aviation, Inc., shall operate the facility
in accordance with the application.
(2) North American Aviation, Inc., shall not operate the reactor
at a power level in excesé of 10 watts (thermal)
(3) Materials having a reactivity value in excess of 0.5% may
not be inserted into the exposure tubes.
Records
In addition to those otherwise required under this license and
applicable regulations, North American Aviation, Inc., shall
keep the following records: ~
(1) Reactor operating records, including power levels,
(2) Records showing radioactivity released or discharged
into the air or water beyond the effective control of CS
North American Aviation, Inc., as measured at the point’ _
of such release or discharge
(3) Records ,of emergency scrams, including reasons for
emergency shutdowns
Reporte
North American Aviation, Ine., shall immediately report to the

Commission any indication or occurrence of a possible unsafe
t

condition relating to the operation of the reactor.

5. This license is effective as of the date of issuance and shall. expire

at midnight May 16, 1978.

FOR THE ATOMIC ENERGY COMMISSION
.

WAL rise” =

Date of Issuance: jin 28 1960 Breton

Dbviston of Licensing & Regutation



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

These statements suggest that (1) all personnel records currently exist in hardcopy form
only, and (2) records may be of poor quality, difficult to interpret, and incomplete.
SC&A concludes that the use of these records for dose reconstruction will require a
comprehensive assessment regarding the quality and completeness of records contained
in the 170 file cabinets, and requires guidance to dose reconstructors for their
interpretation/use.

Section 4.3.10 Use of SSFL Site Survey Data/Source Term cannot be Regarded as
Useful Surrogate Data for Bioassay Data in Dose Reconstruction

In the In the absence of an individual’s in-vitro/in-vivo bioassay data, the TBD provides
the following information and guidance to dose reconstructors:

If bioassay data are not adequate to evaluate an individual's internal

doses, dose reconstructors can use workplace monitoring data (NIOSH

2002). The following types of workplace data might be available for

ETEC: breathing zone air samples, general area air samples, and surface

contamination surveys. However, these data are not likely to be in

individual exposure records. Data on respirator use are not likely to be

available ... resuspension factors are not likely to be available. [Emphasis

added.]
Section 5.12 (page 30):

Without bioassay or air sample data, the last resort is determination of

airborne concentrations using source term evaluations (NIOSH 2002, p.

19). Data on the amount of dispersible material available does not appear

to be available for ETEC. [Emphasis added.]
This “guidance” is deficient and places an unrealistic responsibility on the dose
reconstructor because, at a minimum, the dose reconstructor will need to make judgments
regarding (1) how to use general air sampling data when breathing zone data are not
available or limited, and (2) what resuspension factors should be assigned. It is important
that additional guidance be

Section 5.0 CONCLUSIONS

After a thorough review of SEC Petition-00093 and the large number of relevant/support
documents, it is still unclear as to which of the four facilities should be covered in the
petition and the initial year of coverage, which is dependent on whether all four facilities
are covered in the petition or if it is just Area IV of SSFL that is covered. The list of
covered sites in the DOE database is not consistent with the list of covered sites identified
in the August 23, 2004, Federal Register. If only Area IV of SSFL is covered in the
petition, it is not clear whether the initial date of coverage is 1953, 1954, or 1955. Ifit is
determined that all four facilities will be included in the SEC Petition, the initial coverage
date will need to be changed to 1947 or 1948. NIOSH and DOE should make this
decision, based on further research.

30



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV —Canoga Facility site

“NIOSH cannot estimate internal exposures with sufficient accuracy during the period
from 1955 through 1958 (which is a period with limited internal monitoring data). This
includes the time from the beginning of Area IV radiological activities in 1955, to late
1958 (selected as December 31, 1958 for SEC evaluation purposes). This timeframe
corresponds with the date after which an established bioassay program existed at SSFL
and after which sufficient internal monitoring has been identified.”

Some aspects of this basis for this Petition, as detailed by NIOSH in Ref 2,, that amplify and
detail this above statement have been presented previously in Attachment A - E-2, in the
presentation regarding the facilities (i.e., the site description) that are included in this
Petition.

Additional supporting documents and statements follow-- through page 20-- of this Petition
attachment. The radiation monitoring data collected by Atomics International, a Division of
North American Aviation, as reported in Ref 6-a through 6-h, include both the SSFL/Area
IV site and SSFL/Area IV - Canoga Facility site. These reports provide similar types of
measured radiation data (or lack thereof) for both sites. It is inconceivable to believe that a
site, such as the Vanowen building in the SSFL/Area IV - Canoga Facilities site (or other
buildings at this site), would be monitored differently than the SSFL/Area IV site, or that
monitoring data would have been collected, recorded or maintained differently

A review of the three NIOSH-prepared documents (for North American Aviation site
locations at: SSFL/Area IV, Downey, Canoga Park Vanowen building, and DeSoto) that
address radiation doses support the above statements. The three NIOSH documents (Ref 1-d,
1-e, 1-f, and 1-g) address Occupational Environmental Dose, Occupational Internal Dose and
Occupational External Dose, respectively.

Nothing is found in these three documents to suggest that the radiation monitoring programs,
in any aspect, for the SSFL/Area IV site and Canoga Park Vanowen building site were
conducted differently, or had different objectives, or used differing technologies, or were
recorded differently. To the contrary, most of the statements in the three documents tied the
monitoring programs at the SSFL/Area IV site and the Canoga Park Vanowen building site,
together.

Statements in Ref 1-d, Occupational Environmental Dose, in Section 4.5 (page 8), Section
4.5.4 (page 10) and Section 4.6.5 (page 15): and in Ref 1-e, Occupational Internal Dose in
Section 5.3.1.1 (page 13) and Section 5.3.3 (19): and in Ref I-g, Occupational External Dose,
in Section 6.2 (page 6) address radiation monitoring (or lack thereof) and available
monitoring data (or lack thereof) for the SSFL/Area IV and Canoga Park Vanowen sites,
together, with similar comments applied.

However, throughout the above referred Sections are statements such as found in: Ref 1-d,
Section 4.5.4, referring to Stack Effluent Concentrations before 1959 “No data are available

14



[Effective Date: [Revision No. |Document No. age No.
January 30, 2009 i) SCA-SEC-TASKS-0066, Page 26 of 54

Given the above, we believe NIOSH should re-assess the time periods of interest to the SEC
Petition.

4.3 ADEQUACY OF THE INTERNAL MONITORING PROGRAM
4.3.1 Overview of Internal Monitoring Program

SC&A evaluated internal monitoring data from 136 claimant files with dose reconstruction
overviews. Our evaluation included identifying the number of workers that were monitored in a
given year. The results of this evaluation are presented graphically below. The percentage of
workers monitored and the total number monitored are shown in Figures 4.3.1-1 and 4.3.1-2 for
the period of 1955-1995 and 1956~1966, respectively.’ The conclusions we have drawn in
evaluating this information are presented below.

% Workers Internally Monitored

1955 1960 1965, 1970 1975 1980 1985 1990 1995
Year

Figure 4.3.1-1: Percentage of Workers Monitored, 1955-1995

1 Figures showing the actual number of workers internally monitored were redacted given Privacy Act
concerns,

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Attachment A
Amplification of the statements made on the Special Exposure Cohort Petition -
Form B: for the
Santa Susanna Field Laboratory (SSFL)/Area IV ~Canoga Facility site

Attachment A-C.7b —_ Dates of Employment

My employment began on | a (North American Aviation--employer), and
continued with successor Corporations (North American Rockwell and subsequently,
Rockwell International) unti 1990. Emplo tinued at R a ft
International facilities as a subcontract employee fro: 1990 throu; 005.

Employment for the period addressed in this Petition is from Nov 15, 1955 through June 28,
1960. During this period I was employed by North American Aviation. (Note: North
American was the Corporation for such identities listed as Atomics International,
Rocketdyne, Canoga facility, Vanowen Building, DeSoto facility, Santa Susanna Field
Laboratory, SSFL, ETEC, and Area IV. None of these identities were ever corporations, or
ever held a contract directly with any agency of the United States Government, but rather
“names” for divisions, subdivisions or groups within the Corporation’s structure.)

Attachment A - C.7c Employer Name
The name of the Corporation was North American Aviation (until Sept, 1967), subsequently
North American Rockwell (until Feb. 1973) and after that date, Rockwell International.

Attachment A ~ C.7d Work Site Location

During the period addressed in this Petition, from Nov 15, 1955 through June 28, 1960, I
worked at the SSFL/Area IV - Canoga Facility site, located at 6633 Canoga Ave., Canoga
Park, CA. (From | 1955 a 1955 I worked at the Corporation’s Downey and
Slausen facilities in central Los Angeles.)

The SSFL/Area IV - Canoga Facility site is shown in the circa 1950’s photograph in Figure
A. The aerial view is looking south. The site is bounded by Canoga Ave. (parallel to the
railroad tracks) on the east side; on the west by Owensmouth St.; on the north by Vanowen
Blvd; and on the south by Victory Blvd: all located in Canoga Park, CA. Within these
boundaries at the SSFL/Area IV - Canoga Facility site are the Main Building (001) on the
southern part of the site, the Vanowen Building (038) in the north-west, and the Engineering
Annex (004) on the north-east. A small building (043) was constructed between the
Vanowen building and Engineering Annex building in the late 1950’s or early 1960’s, and
originally was used a cafeteria/lunch room. Several small buildings and a water tank facing
Owensmouth Blvd are also on the site. The site includes a building (009) on the south-side
of Canoga Ave., directly across the street from the Main building (038); this building was
used for material receiving and inspection, and for material storage in the 1950’s and early
1960’s, and was later enlarged for added manufacturing and assembly operations.

During this period I also was assigned numerous work tasks, and days, on temporary
assignments at the Corporation’s Santa Susanna Field Laboratory. 1 worked at all areas in
the SSFL site, including Area IV. (The SSFL was, at the time period specified in this
Petition located in an unincorporated area in the Post Office code of Santa Susanna, CA;
Simi, CA is now the address for the SSFL).



UNITED STATES

ATOMIC ENERGY COMMISSION
WASHINGTON 25, D.C.

NORTH AMERICAN AVIATION, INC .
DOCKET NO. 50-94
AMENDMENT. TO UTILIZATION FACILITY LICENSE eo

License No, R-40
Amendment No. 1
License No. R-40 is revised in its entirety to read as follows:
1, The Atomic Energy Commission (hereinafter "the Commission") finds
that:

A. The solution-type 10 watt nuclear research reactor authorized
for construction by Construction Permit CPRR-54 issued to North
American Aviation, Inc., has been constructed in accordance with
the specifications contained in the application;

B, There is reasonable assurance that the reactor can be operated
without endangering the health and safety of the public;

C. North American Aviation, Inc., is technically and financially
qualified to operate the reactor;

D, Issuance of a license. to possess and operate the reactor will
not be inimical to the common defense and security or te the
health and safety of the public;

E. North American Aviation, Inc., has submitted proof of financial
protection which satisfies the requirements of Commission regu-
lations which are currently in effect.

2. Subject to the conditions and requirements incorporated herein, the Com-

mission hereby licenses North American Aviation, Inc:


Effective Date: Revision No. |Document No. Page No.
January 30, 2009 0 SCA-SEC-TASKS-0066 Page 3 of 54

TABLE OF CONTENT

Abbreviations and Acronyms .. soseveanecesegensseese

1.0 — Introduction.............
1.1. Scope and Purpose of SEC Review
1.2 Technical Approach and Review Criteri:
1.3. Organization of the Report.

2.0 Key Information and Data Presented in the SSFL Site Profile
2.1 Principal Operations..............
2.2 Development and Testing of Nuclear Reactors

2.2.1 Homogeneous Water Boiler Reactors...

2.2.2 Sodium-Cooled Graphite-Moderated Reactors

2.2.3 Systems for Nuclear Auxiliary Power Reactors .

2.3 Critical Test Facilities...
2.4 Nuclear Support Operations.
2.4.1 Reactor Fuel Manufacturing

2.4.2 Disassembly and Examination of Reactors and Used Reactor Fuel
Assemblies

2.4.3 Fabrication, Use, and Storage of Radioactive Source:

2.4.4 Preparation of Radioactive Material for Disposal ..

2.4.5 Research on Reprocessing Used Reactor Fuel

2.4.6 Operation of Particle Accelerators.

2.4.7 Research Using Radioisotopes.

2.4.8 Miscellaneous Operations

2.5 Other Relevant Facilities.
2.5.1 Downey..

2.5.2 Canoga Park

2.5.3 Dé Soto...

2.6 Radionuclides of Concern,

3.0 Overview of the SEC Petition-00093 and NIOSH’s Evaluation Report

3.1. SEC Petition-00093
3.2. SEC Petition Evaluation Repo!
3.3. | NIOSH’s Response to Major Issues Raised in SEC-00093

3.3.1 Responses to Six Issues Identified in the SEC Petition and During

3.4. NIOSH’s Conclusion

4.0 Preliminary Findings Associated with the SEC Petition .
4.1 Overview.

4.2 Areas Considered in the SEC Petition

4.2.1 Areas Addressed by Petition.

4.2.2 Coverage Dates............

4,3 Adequacy of the Internal Monitoring Program

4.3.1 Overview of Internal Monitoring Program

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CER 82.



‘59 nuclear reactor accident remains vivid for former Santa Susana Field Laboratory w... Page 5 of 6

‘The sodium in the reactor was drained and removed in large drums and taken to an open-air burn pit, Pace
said.

Laura Rainey, a senior engineering geologist with the state Department of Toxic Substances Control, was
struck by Pace’s description of the types of waste and debris generated by the meltdown and its aftermath.

“That was a very important day,” Rainey said about meeting Pace during his December visit. “The thing I
value most is he brings the human side to the history.”

Wrong button uncovers the danger

Removing the damaged rods, some of which were stuck in place, proved daunting. By Aug. 2, six of the fuel
elements had been removed from the subterranean reactor floor, according to Atomics International reports.

On that day, a protective cask was lowered into the reactor to encircle and remove another damaged rod. As
the cask was pulled up, the fuel rod broke apart. A portion remained in the reactor core, the other half
lodged in the cask. :

“It was such a shock to the operator, he panicked,” Pace said. “He pushed the wrong button to stop it to see
what had happened.”

Pushing the wrong button, he added, “lifted the lead shield off the floor that protected against radiation
leaking out of the reactor core.”

With the shield up, the whole building was contaminated. The panicked worker ran and “signaled with the
alarm for everyone to get out of the building,” Pace said, adding that another worker volunteered to re-enter
the reactor room to lower the shield.

The building and surrounding area were off-limits for two weeks.

Pace acknowledges he did not observe that event, and learned of it from his supervisor, who instructed Pace
not to come to work. Workers were let back in two weeks later, and Pace helped clean up the contamination,
washing down walls and floors and throwing out office equipment.

The reports do not mention the shield being opened but mention high levels of contamination and note that
some time was spent refining another cask and testing it. A test run took place on Sept. 22.

Containing the problem brings risk

Another fuel rod also broke off in a cask on a day when Pace was present, as he watched workers raise and
lower the transporter trying to pull the fuel rod into the protective cask, he said.

‘Workers peered under the lead shield to sce if the fuel rod had cleared the top of the subterranean reactor.
Every time the lead shield was up, the reactor room was exposed, Pace said.

In one of the most recognizable photographs from the SRE incident, Pace is pictured peering into a hole. He
said he is not looking to the reactor core but rather looking into a piece of equipment used to remove broken
pieces of fuel, to see if it was properly aligned.

In another photo, Pace and other workers are turning a giant spoked circle atop the reactor core. The men
were trying to rotate the reactor lid so a large lead plug could be positioned over fuel rods so they could be

mhtmkfile://C:\Documents and Settings\Vernon\Desktop\Corhort Petition\'59 nucle... 7/23/2009



Effective Date: [Revision No. [Document No. Page No.
January 30, 2009 0 SCA-SEC-TASK5-0066 Page 6 of 54

MDA Minimum Detectable Activity

MDL Minimum Detection Limit

MeV Mega Electron Volt

MFP Mixed Fission Product

mL Milliliter

MPBB Maximum Possible Body Burden

Mr Millirem

NAA North American Aviation

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH OCAS Claims Tracking System

NSEC Nuclear Science and Engineering Corporation

NTA Neutron Track Emulsion Type A

OCAS Office of Compensation Analysis and Support

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

pci pico Curie

Tr Rem

R&D Research and Development

REIRS Radiation Exposure Information Reporting System

Rem roentgen equivalent man

RI Rockwell International

RMDF Radioactive Materia) Disposal Facility

RSRMS Radiation Safety Records Management System

SC&A, Inc, §. Cohen and Associates

SEC Special Exposure Cohort

SRDB Site Research Database

SRE Sodium Reactor Experiment

SNAP Systems for Nuclear Auxiliary Power

SSFL Santa Susana Field Laboratory

TBD Technical Basis Document

UCLA University of California Los Angeles

UF Uranium Fluoride

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.