Alliance of Nuclear Worker Advocacy Groups--Letter to the Radiation Safety Journal from Dr. Daniel

Dr. Daniel W. Mckeel, Joseph C. Rattz Jr, Md

Informations

• Publié par: Feduh
• Nombre de lectures: 95
• Langue: English

Extrait

Alliance of Nuclear Worker Advocacy Groups

Coalition for a Healthy Environment, Oak Ridge, TN

Harry Williams 865-693-7249, Janine Anderson 865-984-0786

Janet Michel 865-966-5918

Grassroots Organization of Sick Workers, Craig, CO

Terrie Barrie 970-824-2260, Kay Barker 970-887-3558

Tri-Valley CAREs, Livermore, CA

Robert Schwartz 925-443-7148

New Mexico Alliance of Nuclear Worker Advocates

Dr. Maureen Merritt 505-455-0550

Southern Illinois Nuclear Workers

Dr. Dan McKeel 573-323-8897

July 24, 2008

Michael T. Ryan, Editor

Health Physics – The Radiation Safety Journal

402 Corey Boulevard

Summerville, SC

29483

Dear Mr. Ryan:

The Alliance of Nuclear Worker Advocacy Groups (ANWAG) has been involved with the

Energy Employee Occupational Illness Compensation Program Act (EEOICPA) since its

inception.

Our members have monitored the implementation of the law by the responsible

agencies, attended and spoke at public meetings, and have offered our concerns to those

agencies, Congress, the Part E Ombudsman, and the press.

We have recently reviewed the July 2008 edition of the Health Physics Radiation Journal which

is dedicated to the National Institute of Occupational Safety and Health Office of Compensation

Analysis Support’s (NIOSH) scientific papers on their dose reconstruction program and wish to

offer a few observations.

ANWAG finds it odd that the Journal did not present any opposing views, as one would expect

to find. At the very least, you might have recruited a guest editorialist, as many other journals do

in a similar situation, to balance the opposing points of view of NIOSH and its critics with

respect to dose reconstruction methodology.

That editorialist could have reviewed other systems

of dose reconstruction such as those employed the Defense Threat Reduction Agency (DTRA)

for the Atomic Veterans since the early 1990s.

ORAU is the major contractor for both NIOSH

and DTRA dose reconstruction programs [REF 1a].

Yet, NIOSH and DTRA have had major

issues with each other scientific methodology [REF 1b,c] and your readers would benefit from

knowing about that major interagency controversy within our government.

Instead, your

portrayal of the NIOSH dose reconstruction program is very one-sided.

One misconception we also see is that NIOSH and its contractor Oak Ridge Associated

Universities (ORAU) developed the methodology alone.

The authors of the papers recognized

that they had input from the interested stakeholders and advocates, yet the submissions to your

journal appear that NIOSH and ORAU alone were responsible for the procedures.

This portrayal

is not quite accurate.

While Dr. Paul Zeimer, Chairman of the Advisory Board on Radiation and

Worker Health (the Board), acknowledged that the Board has a contractor to assist them,

ANWAG feels it is important to note the invaluable contribution made by that contractor,

Sanford Cohen and Associates (SC & A).

At the direction of the Board, SC & A reviewed the

site profiles NIOSH and their contractor issued and reported several deficiencies. In fact, SC &

A found and reported in their November 10, 2006 report 33 deficiencies in the Feed Materials

Production Center (Fernald) site profile.

SC & A also made significant contributions to many of the scientific methodologies published

and used by NIOSH.

At the direction of the Board, SC & A would work with NIOSH and their

contractor, ORAU, in developing the scientific calculations necessary to reconstruct dose.

The advocates and claimants often do not agree with the assumptions. However, we do feel it is

necessary that SC & A be acknowledged for their participation.

The process of developing the site profiles and scientific methodology has been long and arduous

and too long for the stakeholders.

We have seen a protracted battle to have NIOSH accept

documentation or oral histories from the workers and advocates.

A case in point is the Special

Exposure cohort petition for the Rocky Flats facility.

A petitioner stated in the petition that

NIOSH was using an incorrect particle size for plutonium. NIOSH, after two years of debate

with the petitioners, the Board and the Board’s contractor, SC & A, finally agreed that the

petitioners’ claim was correct and revised their methodology, as evidenced in their technical

bulletin, ORAUT-OTIB-0049.

Another example of the length of time it takes NIOSH and its contractor to agree to a

stakeholder’s assertion is the conflict of interest policy. The paper written by Judson L. Kenoyer,

Edward D. Scalsky and Timothy D. Taulbee, employees of ORAU contractor, Dade Moeller and

Associates, states, “However, care must be exercised to avoid selecting a Document Owner – or

any other team member – who has worked at the specific site in the past; otherwise he or she will

be considered by third-party reviewers as having a potential conflict of interest.”

For the Rocky

Flats facility, NIOSH and the Board were advised of the conflict with the author of the site

profile by claimants and advocates in 2003.

The author was not removed as an author until

2006.

A similar conflict was presented to the Board and NIOSH concerning the Neutron Dose

Reconstruction Project for the Rocky Flats plant.

Unfortunately, that concern of the

advocates

with this conflict was ignored.

ANWAG appreciates the opportunity to submit our observations and experience with the dose

reconstruction and Special Exposure Cohort processes.

Sincerely,

Dr. Daniel W. McKeel, Jr, MD

For ANWAG members

Southern Illinois Nuclear Workers (SINEW)

Phone: [phone]

Fax: [phone]

e-mail: [e-mail]

Mail: PO Box 15, Van Buren, MO 63965

[REF 1a]

www.orau.org/busops/oews/

dtra

.htm

[REF 1b]

www.cdc.gov/

NIOSH

/ocas/pdfs/sec/ppg/

dtra

.pdf

[REF 1c]

www.cdc.gov/

niosh

/ocas/pdfs/sec/ppg/evalsupp.pdf