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

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

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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 ...

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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: 573-323-8897
Fax: 573-323-0043
e-mail: danmckeel2@aol.com
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