Draft

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

REVIEW OF EXTERNAL DOSIMETRY RECORDS FOR 

THE CHEMICAL PROCESSING PLANT 83.14 SEC 

PERIOD (1975–1980)

Contract No. 211-2014-58081 

SCA-TR-2018-SEC002, Revision 0 

Prepared by 

Robert Barton, CHP 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, VA 22201-3324 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 2018 

DISCLAIMER 

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues.

NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and 

Worker Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: Review of External Dosimetry Records for the Chemical 

Processing Plant 83.14 SEC Period (1975–1980)

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2018-SEC002

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: February 20, 2018

TASK MANAGER John Stiver, MS, CHP [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S):

John Stiver, MS, CHP [signature on file]

Joe Fitzgerald, MS, MPH [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date

Description of Revision

0 (Draft) 2/20/2018 Initial issue
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TABLE OF CONTENTS

List of Tables .................................................................................................................................. 4

List of Figures ................................................................................................................................. 4

Abbreviations and Acronyms ......................................................................................................... 5

1 Introduction and Background ................................................................................................. 6

2 Completeness of Area Exposure and Construction Exposure Reports ................................... 7

3 Review and Discussion of Available Temporary Badging Records ..................................... 17

4 Identification of Verification and Validation Cases ............................................................. 19

5 Multiple Badges for Multiple Areas – Claimant Study ........................................................ 22

6 Summary and Conclusions ................................................................................................... 26

7 References............................................................................................................................. 27
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LIST OF TABLES

Table 1. Comparison of Reported Total Regular Dosimeters Processed to SC&A’s Tabulation of 

Dosimeter Entries for Months in which No Completeness Analysis Was Possible in NIOSH 

2017b............................................................................................................................................. 15

Table 2. Comparison of Reported Total Construction Dosimeters Processed to SC&A’s 

Tabulation of Dosimeter Entries for Months in which No Completeness Analysis Was Possible 

in NIOSH 2017b ........................................................................................................................... 16

Table 3. Comparison of SC&A and NIOSH Totals of Monitored Workers during Period with 

Duplicate Records Observed ......................................................................................................... 17

Table 4. Description of 11 Candidate Entries Identified in Limited Temporary Badge Records 21

Table 5. Description of Seven Candidate Entries Identified as “Visitors” in Area Exposure 

Reports .......................................................................................................................................... 22

Table 6. Summary of Job Title Analysis of Multiple Badging in Multiple Areas ........................ 25

LIST OF FIGURES

Figure 1. Example of an Area Exposure Report ............................................................................. 8

Figure 2. Example of a Dosimetry Branch Activity Report for the Month of July 1975 ............... 9

Figure 3. A Comparison of the Number of Regular Monitored Workers Found in the Area 

Exposure Reports versus the Expected Number of Monitored Workers Reported in INL 

Dosimetry Branch Monthly Summaries ....................................................................................... 11

Figure 4. A Comparison of the Percentage of Regular Monitored Workers Found in the Area 

Exposure Reports versus the Expected Number of Monitored Workers Reported in INL 

Dosimetry Branch Monthly Summaries ....................................................................................... 12

Figure 5. A Comparison of the Difference in the Number of Monitored Construction Workers 

Found in the Area Exposure Reports versus the Expected Number of Monitored Workers 

Reported in INL Dosimetry Branch Monthly Summaries ............................................................ 13

Figure 6. A Comparison of the Percentage of Monitored Construction Workers in the Area 

Exposure Reports versus the Expected Number of Monitored Workers Reported in INL 

Dosimetry Branch Monthly Summaries ....................................................................................... 14

Figure 7. Example of Monthly Area Exposure Report Summary Cover Page ............................. 18

Figure 8. Example of a Temporary Badge Report for CPP from March 1975 ............................. 19

Figure 9. Distribution of Generic Job Types Included in the Claimant Sampling ....................... 24

Figure 10. Percentage of Sampled Claims with Multiple Badges for Multiple Areas by Month . 26
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ABBREVIATIONS AND ACRONYMS

Advisory Board or 

ABRWH Advisory Board on Radiation and Worker Health 

ANL-W Argonne National Laboratory-West

CPP Chemical Processing Plant

EE energy employee 

EBR-II Experimental Breeder Reactor-II

HP Health Physics 

INL Idaho National Laboratory

NIOSH National Institute for Occupational Safety and Health

NRF Naval Reactors Facility

ORAUT Oak Ridge Associated Universities Team

SEC Special Exposure Cohort 

SRDB Site Research Database

TLD thermoluminescent dosimeter

V&V verification and validation
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1 INTRODUCTION AND BACKGROUND

Based on its evaluation of Special Exposure Cohort (SEC) Petition 00219 for the Idaho National 

Laboratory (INL), the National Institute for Occupational Safety and Health (NIOSH) proposed 

that the following class be added to the SEC: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Idaho National Laboratory 

(INL) in Scoville, Idaho, and (a) who were monitored for external radiation at the 

Idaho Chemical Processing Plant (CPP) (e.g., at least one film badge or TLD 

dosimeter from CPP) between January 1, 1963 and February 28, 1970; or (b) 

who were monitored for external radiation at INL (e.g., at least one film badge or 

TLD dosimeter) between March 1, 1970 and December 31, 1974 for a number of 

work days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established 

for one or more other classes of employees in the Special Exposure Cohort. 

[NIOSH 2017a, page 1]

Although the end date for the recommended class was December 31, 1974, NIOSH indicated 

they were continuing to evaluate dose reconstruction feasibility for the period after 1974 at CPP

via the 83.14 petition process. On July 20, 2017, NIOSH issued its evaluation of Petition-00238 

(NIOSH 2017b) and recommended an additional class: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Idaho National Laboratory 

(INL) in Scoville, Idaho, and who were monitored for external radiation at the 

Idaho Chemical Processing Plant (CPP) (e.g., at least one film badge or TLD 

dosimeter from CPP) between January 1, 1975 and December 31, 1980 for a 

number of work days aggregating at least 250 work days, occurring solely under 

this employment, or in combination with work days within the parameters 

established for one or more other classes of employees in the Special Exposure 

Cohort. [page 1]

This petition was presented to the Advisory Board on Radiation Worker Health (ABRWH) 

during Meeting Number 118 held on August 23, 2017, in Santa Fe, NM (ABRWH 2017). Based 

on previous deliberations concerning SEC-00219, NIOSH determined that some external 

dosimetry records (namely, temporary or visitor badges) had not been appropriately indexed and 

entered into the INL electronic dosimetry system. Consequently, these records were not properly 

included in individual dosimetry files and thus were not available for potential SEC 

determinations. An effort to properly code these additional dosimetry records is currently 

underway by the INL site. 

In response to the coding effort undertaken by the site, the Advisory Board asked SC&A to 

evaluate the completeness of available dosimetry records and also propose potential test cases to 

validate that dosimetry records are being appropriately included in individual claimant files. This 

report presents SC&A’s evaluation of the completeness of dosimetry records for the Chemical 
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Processing Plant (1975–1980) in the context of individual SEC determinations. SC&A’s review 

is separated into four main areas of investigation: 

• Evaluation of the completeness and availability of routine area exposure reports and 

construction exposure reports (see Section 2).

• Evaluation of the completeness and availability of temporary/visitor badges (see 

Section 3).

• Identification of claimants who could be used to verify and validate that dosimetry 

records have been correctly coded and identified with the individual worker to allow for 

SEC determinations (see Section 4).

• Review of a subset of claimant files to assess the practice of requiring a separate 

dosimetry badge for each area entered during a single monitoring cycle during the period 

of interest. This practice is often referred to as “multiple badges for multiple areas” (see 

Section 5).

The analysis in Sections 2 and 3 are to determine whether the currently available dosimetry 

records at INL are complete or, alternately, if it is apparent that there are missing records that

may call the SEC badging requirement into question. Section 4 deals strictly with the issue 

related to whether the available records are being properly indexed and included in individual 

dosimetry requests. Finally, Section 5 investigates the important facet of the proposed definition 

in which it assumed that if you entered CPP, you received a CPP badge. Alternately, if one were 

allowed to enter CPP with a dosimetry badge obtained in another area (e.g., Test Area North, 

Central Facilities Area, Argonne National Laboratory-West), the class definition requirements 

would likely have to be expanded. Section 6 provides a brief overview of the findings and 

observations for each of these four areas of review and includes SC&A’s summary conclusions.

2 COMPLETENESS OF AREA EXPOSURE AND CONSTRUCTION 

EXPOSURE REPORTS

Dosimetry records for CPP most often come in a format known as “Area Exposure Reports” for 

most monitored workers;1

1 “Construction Exposure Reports” are identical in format but were compiled separately for those workers strictly 

involved in construction projects. 

these reports contain an electronic printout by site area and are 

sometimes organized by individual contractor. Characteristics and information contained on the 

area exposure reports include the following: 

• Individual Health Physics badge number 

• Name of individual 

• Contractor

• Site area designation 

• End date of exposure period

 
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• Reason for dosimeter (e.g., routine, Health Physics request, recovered lost badge, 

termination)

• Irregularity code (i.e., the reason a particular badge was not read, such as it was not 

available or was damaged) 

• Deep and shallow dosimeter results for the monitoring period (generally monthly)

• Totals for the quarter, year, and entire career at INL

• “PSN”2

 number (sequential number assigned to each dosimeter in official record)

2 The exact meaning of the acronym “PSN” is not known at this time; one possibility is “Personal Sequential 

Number.” 

In addition, area exposure reports indicate when a particular badge represents a temporary/visitor 

badge. Figure 1 shows an example of an area exposure report, with various characteristics circled 

and labeled. 

Figure 1. Example of an Area Exposure Report 

To assess the completeness of available dosimetry records, the SEC-00238 evaluation report 

(NIOSH 2017b) compared the number of monitored employees by badging cycle listed in the 

area/construction exposure reports to the number of monitored workers reported in sitewide 

Dosimetry Branch activity reports (this latter total is referred to as the “expected” number of 

monitored workers in this report). Figure 2 shows an example of a Dosimetry Branch activity 

report showing the expected number of monitored workers at CPP. 

 
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Figure 2. Example of a Dosimetry Branch Activity Report for the Month of July 1975 

NIOSH presented its comparison of the expected number of monitored workers contained in the 

summary reports to the available dosimetry logs in Figures 5-1 and 5-2 of the SEC-00238 

evaluation report (NIOSH 2017b). These exact figures are not recreated here; however, SC&A 

obtained the data used in the comparison and reanalyzed it to show the numerical difference 

between the expected number of workers reported to have been monitored by month and the 

actual available records. In addition, SC&A presented the observed differences in the expected 

report totals and available records totals as a percentage of the expected report total per month. 

This analysis was done for both the regularly monitored workers contained in the area exposure 

reports (see Figures 3 and 4) and workers designated as construction workers found in the 

construction exposure reports (see Figures 5 and 6). 

As can be seen in Figures 4 and 6, report summaries detailing the number of monitored workers 

by month were available for 49 of the 72 months of interest (68.1%). The largest observed 

temporal gap occurred from October 1975 to September 1976 (11 months total), with the 

remaining temporal gaps spanning 3 months or less. These gaps are specifically discussed later 

in this section.

Observation 1: A comparison of the expected number of monitored workers listed in the 

Dosimetry Branch activity reports to those tabulated in the available dosimetry logbooks 

contained in area and construction exposure reports was only available for 49 of the 72 months 

of interest (~68%). The largest temporal gap observed was 11 months; all others were 3 months 

or less. 

For the majority of months for which data are available for comparison, there are more 

monitored workers observed in the area/construction exposure report logbooks than were 

indicated in the corresponding Dosimetry Branch activity report totals (see Figures 3 and 5 for 

regular and construction workers, respectively). Some notable exceptions include August 1978 
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for regularly monitored workers (20 additional workers were indicated to have been monitored 

than were found in the dosimetry lists). For workers designated as construction workers, the 

periods in August and September of 1978 as well as July 1979 indicated between 17 and 31 

additional workers were monitored who were not located in the Construction Exposure Report 

listings. 

Figures 4 and 6 put the observed differences in total workers into a percentage of the total 

expected monitored workforce as indicated by the Dosimetry Branch activity reports. For

example, if the Dosimetry Branch activity reports indicated 100 workers were monitored 

externally and 90 were observed in the corresponding area exposure reports, then the available 

dosimetry records would represent 90% of the expected monitored workforce. Conversely, if 

there were 110 workers observed in the area exposure reports, then the available dosimetry 

records would represent 110% of the expected monitored workforce. 

For the regular (non-construction) workers at CPP, the percent of the total monitored workforce 

found in available area exposure report logbooks generally fluctuated within ±1% of the 

expected total (this occurred in 39 of 49 months analyzed). As indicated in Figure 3, records 

indicate 20 additional workers were monitored in August 1978 than could be found in the area 

exposure reports. This indicates that 98.1% of the expected monitoring total was found in the 

dosimetry listings. 

For construction workers at CPP, the fluctuations in total percentage were more pronounced, 

with only approximately 25% of the evaluated months falling within 1% of the expected total. 

The range of percentages ranged from a low of 85.3% in August 1978 to a high of 118.5% in 

November 1980. 
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Figure 3. A Comparison of the Number of Regular Monitored Workers Found in the Area 

Exposure Reports versus the Expected Number of Monitored Workers Reported in INL 

Dosimetry Branch Monthly Summaries
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Figure 4. A Comparison of the Percentage of Regular Monitored Workers Found in the 

Area Exposure Reports versus the Expected Number of Monitored Workers Reported in 

INL Dosimetry Branch Monthly Summaries
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Figure 5. A Comparison of the Difference in the Number of Monitored Construction 

Workers Found in the Area Exposure Reports versus the Expected Number of Monitored 

Workers Reported in INL Dosimetry Branch Monthly Summaries
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Figure 6. A Comparison of the Percentage of Monitored Construction Workers in the Area 

Exposure Reports versus the Expected Number of Monitored Workers Reported in INL 

Dosimetry Branch Monthly Summaries

As noted in Observation 1, direct comparisons between expected number of monitored workers 

and the actual number of monitored workers located in the area exposure report logbooks were 

available for 49 of 72 months during the period of interest. In addition, the largest observed gap 

in available comparisons was 11 months from October 1975 to September 1976. Although not as 

useful as comparing the number of monitored workers in a given period, comparing the total 

number of dosimeters reported to have been processed to the number available in the dosimetry 

logs would provide some indication of the completeness of available records during those 

months in which the total number of monitored workers is unknown. Accompanying the area 

exposure reports for each monthly monitoring cycle is a summary cover page listing the total 

number of badges serviced in a given period. An example of a summary cover page can be seen 

in Figure 7 in the next section (Section 3) for the badging period from January 1, 1975, to 

January 31, 1975. 

Analyzing the number of dosimeters per period requires some additional considerations, such as:

• Is the dosimeter entry actually during the period of interest or some earlier period?

• Was the dosimeter actually processed and numerical results provided?

• Is the dosimeter actually from CPP or another area, such as the Experimental Breeder 

Reactor-II (EBR-II)? 
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In addition, SC&A observed that some records were duplicated in the references cited in NIOSH 

2017b and could result in double counting. The occurrence of duplicate records might also affect 

the comparisons of the total number of monitored workers presented above and is discussed later 

in this section. 

The comparison between SC&A’s tabulation of total dosimeters per period and the number of 

dosimeters reported to have been processed is shown in Tables 1 and 2 for regular workers and 

construction workers, respectively. As seen in these tables, the comparison between SC&A’s 

manual tabulation and the number of dosimeters reported to have been processed generally 

showed reasonable agreement. Based on SC&A’s analysis, 19 of the 24 analyzed monitoring 

periods either matched or showed a higher total than the number of reported badges processed 

for both regular and construction dosimeters. 

Table 1. Comparison of Reported Total Regular Dosimeters Processed to SC&A’s 

Tabulation of Dosimeter Entries for Months in which No Completeness Analysis Was 

Possible in NIOSH 2017b 

Monitoring 

Period

SC&A Total 

Dosimeters*

Reported 

Number of 

Dosimeters 

Processed

Differential (Reported 

Total – SC&A Total)

January 1975 288 286 -2

February 1975 317 317 0

March 1975 312 309 -3

May 1975 289 288 -1

August 1975 604 599 -5

October 1975 610 610 0

November 1975 618 621 3

December 1975 678 675 -3

January 1976 810 808 -2

February 1976 921 921 0

March 1976 1,083 1,085 2

April 1976 1,033 1,034 1

May 1976 825 818 -7

June 1976 841 834 -7

July 1976 894 889 -5

August 1976 817 815 -2

October 1976 884 882 -2

December 1976 1,063 1,066 3

January 1978 1,154 1,142 -12

October 1978 1,172 1,157 -15

November 1978 1,081 1,078 -3

January 1979 1,069 1,066 -3

April 1979 1,211 1,200 -11

*Total includes only dosimeters that have numerical results reported, were in period, and identified as from CPP. 
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Table 2. Comparison of Reported Total Construction Dosimeters Processed to SC&A’s 

Tabulation of Dosimeter Entries for Months in which No Completeness Analysis Was 

Possible in NIOSH 2017b 

Monitoring 

Period

SC&A Total 

Dosimeters*

Reported 

Number of 

Dosimeters 

Processed

Differential 

(Reported Total – 

SC&A Total)

January 1975 74 72 -2

February 1975 49 49 0

March 1975 28 28 0

May 1975 11 9 -2

August 1975 15 14 -1

October 1975 6 3 -3

November 1975 7 4 -3

December 1975 10 10 0

January 1976 38 38 0

February 1976 63 62 -1

March 1976 139 145 6

April 1976 112 92 -20

May 1976 67 76 9

June 1976 109 95 -14

July 1976 95 102 7

August 1976 139 133 -6

October 1976 167 175 8

December 1976 313 311 -2

January 1978 121 107 -14

October 1978 304 299 -5

November 1978 144 138 -6

January 1979 142 141 -1

April 1979 205 201 -4

*Total includes only dosimeters that have numerical results reported, were in period, and identified as from CPP. 

Observation 2: SC&A’s analysis of the total number of dosimeters in available records 

compared to the total number of dosimeters that were reported to have been processed during the 

observed temporal gaps showed reasonable agreement for both regular badges and construction 

badges. SC&A found no indication that available dosimetry logbooks for regular and 

construction badges are incomplete during these periods. 

As stated previously, SC&A’s review of the area/construction exposure reports noted that 

duplicate dosimetry results were included in the captured references for some monitoring 

periods. Specifically, a given dosimetry entry would appear in separate logbook locations but 

contained an identical name, date, result and sequential number (PSN number). This would be a 

cause for concern if not properly accounted for, as it would artificially inflate the total number of 

observed monitored workers used in comparison to the expected monitoring totals. SC&A 

identified duplicate records for the following monitoring periods: 

• November 1975 

• February–September 1976 
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• April and October 1977 

• January, February, April, and May 1980 

SC&A independently tabulated the number of monitored workers in these months and accounted 

for any duplicate records (the exceptions are November 1975 and February through July of 

19763

3 These periods were omitted because no comparisons between the reported total of monitored workers and the 

number of monitored workers contained in the available records were possible, as noted in NIOSH 2017b. However, 

duplicate records were accounted for in the previous analysis comparing the number of dosimeters listed in the 

referenced logbooks to the number of dosimeters reported to have been processed.

). SC&A’s total compared very well with NIOSH’s total, as shown in Table 3. Although 

the SC&A and NIOSH totals do not match exactly, it is clear that proper adjustments were made 

to account for duplicate records contained in the available references.

Table 3. Comparison of SC&A and NIOSH Totals of Monitored Workers during Period 

with Duplicate Records Observed 

Monitoring Period Total 

Duplicate 

Records 

Observed

Number of 

Monitored 

Workers 

(SC&A)

Number of 

Monitored 

Workers 

(NIOSH)

September 1976 173 787 786

April 1977 218 879 875

October 1977 136 893 895

January 1980 31 1,156 1,152

February 1980 204 1,167 1,167

April 1980 46 1,155 1,160

May 1980 256 1,183 1,181

Observation 3: SC&A noted that the available area exposure reports often contained duplicate 

entries for the same dosimetry badge entry, which would have the potential to artificially inflate

the total number of monitored workers identified during a given period. However, SC&A’s 

independent analysis of those periods with duplicate records showed excellent agreement with 

NIOSH’s reported totals; therefore, it is evident that NIOSH had made appropriate adjustments 

to account for duplicate records. 

3 REVIEW AND DISCUSSION OF AVAILABLE TEMPORARY 

BADGING RECORDS

The previous section concentrated on the area and construction exposure reports that were cited 

and analyzed in the SEC-00238 petition evaluation report (NIOSH 2017b). Figure 7 shows an 

example screenshot of the summary page from an area exposure report. Of particular note is the 

fact that Figure 7 indicates that zero “temporary badges” were processed during this period.

However, as seen in Figure 1 (Section 2), there were badges designated with a “V” to indicate a 

visitor, so it is apparent that at least some temporary/visitor badges are included in the 

area/construction exposure reports. These visitor badges are likely included in the “special pulls” 

total shown in Figure 7. However, it is important to note that all summary cover pages for 

 
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reports during the period of interest (1975–1980) indicate that zero “temporary badges” were 

processed during their respective badging cycles. 

Figure 7. Example of Monthly Area Exposure Report Summary Cover Page 

SC&A identified a set of temporary badge reports for the period of interest 1975–1980 (INL 

various dates-a, -b). However, it was apparent that the available captured temporary badge 

reports were likely not complete. SC&A requested clarification as to the disposition of any 

remaining temporary badge reports that might still be available at INL. NIOSH/Oak Ridge 

Associated Universities Team (ORAUT) indicated that those reports are likely available but had 

not been captured due to the focus of previous data capture efforts (Findley 2017). 

Finding 1: SC&A located temporary badge reports during the period of interest; however, it is 

apparent that the currently available records are incomplete. Additional temporary badge reports 

are likely available at the site but have not been captured due to the focus of previous data 

capture efforts. It would be beneficial that such reports be obtained and reviewed to assure 

completeness of dosimetry records for use in potential SEC adjudication. Furthermore, capture of 

these records would allow for the expansion of available candidates for verification and 

validation reviews discussed in Section 4 of this report. 

Figure 8 shows an example of a temporary badge report (names have been redacted). Note that 

this style of report also contains an entry column for a “Permanent Badge No.,” also known as an 

HP badge number. In the example report shown in Figure 8, the Permanent Badge No. entries are 

blank. To assess the extent to which the entries on the identified temporary badge reports are 

reflected in the official area exposure reports described in Section 2, SC&A compiled all 

temporary badge entries with zero recorded dose.4

4 As discussed previously, badges with zero recorded dose were selected due to previously identified problems with 

the coding of zero-dose visitor/temporary badges in the official INL dosimetry system. 

SC&A identified 258 temporary badges in the 

available temporary badge reports that indicated zero recorded dose for the energy employee 

(EE). SC&A then compared these zero dose entries to the area/construction exposure reports 

covering the same time period to determine if these badging records had been appropriately 

included in the official dosimetry records. Of those 258 temporary badges reviewed, 219 (~85%) 

 
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could not be located in the corresponding area exposure reports. All of the remaining temporary 

badges (39 of 219) that had been migrated to the area/construction exposure reports had a 

“Permanent Badge No.” indicated on the original temporary badge report. This indicates that 

temporary badges indicating zero accrued dose were likely only migrated to CPP’s official 

dosimetry record if the EE already had a Health Physics badge number assigned. 

Figure 8. Example of a Temporary Badge Report for CPP from March 1975 

Finding 2: Based on a review of the limited available temporary badge reports from 1975 and 

1980, workers who accrued zero measured dose and did not have a permanent Health Physics 

badge indicated in the temporary badge report do not appear to be consistently migrated into the 

official area exposure reports for CPP. This does not necessarily indicate that such temporary 

badge entries are unavailable for dose reconstruction and/or SEC adjudication. However, it does 

indicate that determinations of the completeness of records using area exposure reports are likely 

based on incomplete data and information. 

4 IDENTIFICATION OF VERIFICATION AND VALIDATION CASES

As discussed in the previous section, concerns remain for workers who were assigned temporary 

badges that did not measure a positive external dose and who had not been previously assigned a 

Health Physics number. While the site retained these temporary/visitor badges, the results do not 

appear to have been consistently migrated into the electronic dosimetry system used by the INL 

Dosimetry Branch. Current efforts are underway by INL to capture and code these additional 

data so they can be accurately and easily retrieved during records requests for an individual EE. 

Verification that this coding and indexing effort is effective is important for all dose 

reconstructions performed by NIOSH, but it is especially important in the context of the 

proposed SEC because of the specific dosimetry requirements of the currently recommended 

definition. Previously, SC&A proposed a verification and validation approach to address an 

earlier SEC during the period 1963–1970 at CPP (SEC-00219). That proposal identified a subset 

of claimants that were identified in captured temporary badge records but whose previously 

transmitted monitoring files had not contained those temporary badges. Ideally, once the coding 

and indexing effort is completed by INL, any new records requests for these individuals would 

correctly include these temporary badges. The proposal for the earlier SEC period is detailed in 
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the SC&A memorandum, Update on Validation and Verification of INL CPP Temporary Badge 

Database – Expansion of Claimant Pool (1963–1970) (SC&A 2017). As part of that effort, 

SC&A focused only on claimants who would still require a dose reconstruction because the 

individual either would not qualify for the SEC or would require adjudication of medical benefits 

for non-SEC cancers.

However, because only a portion of temporary badge records had previously been captured for 

the period of interest in this report (1975–1980), there were simply not enough data to focus only 

on claimants who would require a dose reconstruction. Therefore, SC&A considered any 

claimants included in the captured temporary badges as candidates for potential verification 

activities. Additionally, SC&A reviewed any “visitor” entries in the main area/construction 

exposure reports to potentially expand the pool of verification and validation (V&V) candidates. 

SC&A’s examination of these records identified the following dosimetry entries for further 

comparison with current claimant monitoring records: 

1. Available Temporary Badge Reports: any claimant with a dosimeter reading of zero 

(22 claims identified covering 23 total badges) 

2. Area Exposure Reports: any claimant with the “visitor” designation associated with their 

dosimetry entry (44 claims identified covering 63 total badges5) 

5

 To try to expand the group of available claimants, SC&A considered both zero and positive dosimeter readings.

From the first group of identified claimants (temporary badges), 11 of the badges were already 

contained in the claimant monitoring record, 11 were not currently contained in the claimant 

record, and 1 was unknown at this time.6

6 The U.S. Department of Energy had not yet responded to a records request for this individual 

.

From the second group of identified claims (“visitors” 

in the area/construction exposure records), 56 of 63 records were already contained in the 

claimant monitoring file, 4 were not found, and 3 claimant files only contained annual 

summaries of external doses. Therefore, a total of 18 samples (11 temporary badges and 7 visitor 

badges) were identified as candidates for V&V records requests. These 18 candidates are 

described in Tables 4 and 5 for temporary badges and visitor entries, respectively.

 
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Table 4. Description of 11 Candidate Entries Identified in Limited Temporary Badge 

Records

[Redacted] End Date 

of Record

Employer 

on 

Record* 

Dose 

Reconst. 

Required?

Additional Comments

[Redacted] 1/17/1975 ANL-W Yes

The claimant files did contain two other CPP 

temporary badges during the period of interest 

(August and July 1975).

[Redacted] 4/1/1976 ANL-W Yes — 

[Redacted] 4/14/1976 ANL-W Yes The claimant had a positive CPP visitor badge 

included in their monitoring file from July 1976.

[Redacted] 4/27/1976 ANL-W Yes — 

[Redacted] 11/4/1976 ANL-W Yes

The claimant would currently require a dose 

reconstruction because covered employment at 

INL ends in 1962.

[Redacted] 11/4/1976 ANL-W Yes

The claimant would currently require a dose 

reconstruction because there is no covered 

employment currently identified at INL. 

[Redacted] 11/16/1976 ANL-W No

The claimant has extensive dosimetry associated 

with CPP beginning in 1977 currently contained in 

their monitoring record.

12/1/1976 ANL-W Yes — 

[Redacted] 3/18/1977

Allied 

Chemical 

Co.

No

The EE had a permanent badge number entered on 

temporary badge records ( ).

[Redacted] 3/31/1977

Allied 

Chemical 

Co.

No

The Location File Card contained in the claimant 

monitoring record is reflective of visiting CPP 

during March 1977, but the temporary badge was 

not found.

[Redacted] 11/11/1977 ANL-W Yes

Though covered employment does not begin until 

1989 for this claimant, evidence in Department of 

Labor files suggests the EE may have been 

employed at during the period of interest. 

*ANL-W = Argonne National Laboratory-West.

[Redacted] [redacted]
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Table 5. Description of Seven Candidate Entries Identified as “Visitors” in Area Exposure 

Reports

End Date 

of Record

Employer 

on 

Record

Dose 

Reconst. 

Required?

Additional Comments

7/15/1976

Aerojet 

Nuclear 

Co.

No

The available claimant file only contains annual 

summaries covering this visitor badge.

1/15/1975

Aerojet 

Nuclear 

Co.

Yes

The available claimant file only contains annual 

summaries covering 1975. In addition to the 

visitor badge, 8 regular badges associated with 

CPP were also issued during 1975.

1/9/1975

Aerojet 

Nuclear 

Co.

No

The claimant had 7 different visitor badges at 

CPP during 1975; 5 of the 7 were already 

contained in the claimant’s monitoring record.

1/29/1975

Aerojet 

Nuclear 

Co.

No

—

9/29/1975

Aerojet 

Nuclear 

Co.

Yes

—

1/21/1976

Aerojet 

Nuclear 

Co.

No

Note: this claimant was also included in the 

temporary badge records described in Table 4.

2/16/1976

Aerojet 

Nuclear 

Co.

No

Note: this claimant was also included in the 

temporary badge records described in Table 4.

Observation 4: Based on its review of limited temporary badges and dosimetry entries 

designated as “visitor” in the main area/construction exposure reports, SC&A was able to 

identify just 18 external dosimetry entries from the claimant population that could be used for 

future verification and validation review. However, if the full set of temporary badge reports is 

captured at INL, the available population of V&V candidates would likely increase markedly. 

5 MULTIPLE BADGES FOR MULTIPLE AREAS – CLAIMANT STUDY

In addition to establishing the completeness of available dosimetry records and validating that 

they are correctly coded to the INL dosimetry system, another significant facet of the 83.14 class 

definition is the notion that the INL site transitioned from a “one badge-multiple area” policy to a 

“multiple badge-multiple area” policy. In the former situation, workers were able to take a badge 

from one major site area and use that badge for entrance into another area. In the latter situation, 

monitored workers would leave an area-specific badge when exiting that area and would be 

assigned a second badge if entering another area. This is especially important in the current 

83.14 SEC class definition because it requires that a “CPP-specific” dosimetry badge be in 

evidence to prove potential exposure in the plant. 

To assess the extent to which the site used a “multiple badge-multiple area” policy during the 

period of interest (January 1, 1975–December 31, 1980), SC&A examined a random sample of 

claimants and compiled data related to the number of different area badges observed for an 

individual during a given monthly badging cycle. At the time of its review, SC&A determined 

[redacted]

[redacted]

[redacted]

[redacted]

[redacted]

[redacted]

[redacted

[redacted]
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that there were 462 claimants with verified employment during the 83.14 SEC period. The goal 

of the study was to compile information on one quarter (~25% or 115 claimants) out of that 

group. However, during the random sampling of the 462 total claims, it became evident that 

several claims were not germane to the study and so were rejected as part of the reviewed subset 

of claimants. SC&A rejected claims from the study for the following reasons: 

• General Lack of Monitoring: the claimants were not monitored at INL or were monitored 

outside the period of interest (36 randomly selected claims rejected).

• Quality of Monitoring Records: only annual or career summaries are available, making it 

impossible to determine individual badging practices (nine randomly selected claims 

rejected).

• Limited Work Duration: the EE only worked for a few weeks or months during the 

period of interest (five randomly selected claims rejected).

• Job Title/Description: the type of work performed would not likely pose the potential for 

movement among different areas (four randomly selected claims rejected, which included 

two workers, a instructor, and an ). 

The rejected claims were replaced with additional randomly selected claimants. SC&A 

categorized each of the 115 claims used in the sampling analysis into nine generic job types, as 

shown in Figure 9. As seen in the figure, 40% of the sampled claimant population was classified 

as “Construction Trades/Maintenance” and 23% was classified as “Engineers/Technicians.” The 

remaining seven job categories individually contributed less than 10% of the total. 
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Figure 9. Distribution of Generic Job Types Included in the Claimant Sampling

Table 6 summarizes the results of the job-specific analysis of multiple badging for multiple 

areas. Approximately 48% of the “Construction Trades/Maintenance” claims contained at least 

one badging cycle that included dosimeter results for multiple areas. On average, approximately 

13% of the monitored dosimeter cycles per claim for this job category contained multiple 

badges. The average number of area badges per dosimeter cycle for this group was 1.27, which 

was only eclipsed by the 1.41 area badges per cycle for the five “Managerial/Administrative” 

claims surveyed. The highest number of area badges observed in a single cycle for any job 

category was six, which occurred for a “Construction Trades/Maintenance” worker.7

 

7 The claim had observed area badges in December 1975 at the 

.
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Table 6. Summary of Job Title Analysis of Multiple Badging in Multiple Areas

SC&A Work 

Designation

Total

Claims

Sampled

Percentage 

of Claims 

with 

Evidence 

of 

Multiple 

Badges

Average 

Percentage of 

Multiple Badge 

Cycles per 

Claim

Maximum 

Percentage of 

Multiple 

Badge Cycles 

per Claim

Average 

Number of 

Observed 

Badges per 

Cycle

Maximum 

Number of 

Badges per 

Cycle

Construction 

Trades/ 

Maintenance

46 47.8% 13.3% 87.5% 1.27 6 

Engineers/ 

Technicians 27 40.7% 10.4% 100.0% 1.03 3 

Scientists 10 20.0% 0.7% 4.3% 1.01 2

Security/Custodial/ 

Fire 10 40.0% 16.9% 100.0% 1.20 5 

Operations 9 33.3% 2.8% 12.1% 1.04 3

HP/Rad Techs 6 50.0% 16.2% 50.0% 1.10 4 

Managerial/ 

Administrative 5 40.0% 24.4% 100.0% 1.41 3 

2 0.0% 0.0% 0.0% 1.00 1

Observation 5: With the exception of two , all sampled job categories showed 

evidence of multiple area badges during a single dosimetry cycle. The maximum number of 

observed area badges during a single dosimetry cycle was six, which occurred for a 

“Construction Trades/Maintenance” worker in December 1975. 

In addition to the job-specific analysis, SC&A analyzed the sampled claimant population by 

monitoring cycle. The purpose of the temporal analysis was to identify any time periods in which 

the policy of multiple badges for multiple areas may not have been applied. Figure 10 shows the 

percentage of sampled claims who had multiple badges during a single dosimetry cycle by 

month. As seen in the figure, the percentage generally fluctuates between 5 and 20%, with a

maximum of 31.1% in December 1975. The average for the entire period was 11%. There was 

no month in which instances of multiple badges for multiple areas was not observed. Finally, 

there does not appear to be a discernable temporal trend in the percentage of claims with multiple 

badges per dosimetry cycle during the period of interest. 

[redacted]
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Figure 10. Percentage of Sampled Claims with Multiple Badges for Multiple Areas by 

Month

Observation 6: The practice of multiple area badges during a single dosimetry cycle was 

observed for at least some sampled claims during every month during the period of interest. 

Furthermore, there does not appear to be a discernable temporal trend in the percentage of claims 

exhibiting multiple area badges per dosimetry cycle; thus, the use of multiple area badges

appears to be a consistent policy. The percentage of sampled claims with multiple badges per 

dosimetry cycle generally fluctuated from 5 to 20%. 

6 SUMMARY AND CONCLUSIONS

As stated in Section 1, SC&A’s review of the 83.14 class definition included four main facets: 

evaluation of completeness of main area/construction exposure reports, review of available 

temporary badge reports, identification of potential verification and validation claims, and 

confirmation of the “multiple badges for multiple areas” policy at INL. 

As detailed in Section 2, SC&A found no substantive reason to believe that the captured area and 

construction exposure reports are incomplete. Although there were temporal gaps in the ability to 

assess the completeness of these records by analyzing the number of monitored workers, 

comparisons of the total number of processed dosimeters do not indicate that completeness of the 

area/construction dosimetry logs is of concern. Furthermore, SC&A’s analysis established that 

appropriate adjustments had been made in NIOSH’s original completeness analysis to account 

for the existence of duplicate records in the captured references.
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SC&A’s examination of the available temporary badge records in Section 3 indicated that 

worker dosimetry results with zero accrued dose, and for which no permanent Health Physics 

badge had been previously assigned, were not generally migrated into the official 

area/construction exposure records. Additionally, SC&A determined that the captured temporary 

badge records available for analysis are currently incomplete. Evidence suggests that additional 

temporary badge records are available at the site. It would be beneficial to capture these 

additional temporary badge records, in particular when considering the limited number of V&V

cases that were identified in Section 4 (18 total cases). 

Finally, SC&A’s review of a substantial portion of the claimant population indicated that the 

practice of “multiple badges for multiple areas” was evident throughout the period of interest 

(January 1975 to December 1980). As expected, the analysis by job category indicated that more 

transient jobs, such as construction/maintenance workers, had the highest prevalence of multiple 

area badges during a given monitoring period. Additionally, temporal analysis of the multiple 

badging practice indicated no significant changes or gaps in policy. 

7 REFERENCES

ABRWH 2017. Transcript: 118th Meeting of the Advisory Board on Radiation and Worker 

Health, Santa Fe, NM. August 23, 2017.

Findley 2017. Email from Mitch Findley, ORAUT, to Bob Barton, SC&A, Subject: 83.14 RFI. 

November 8, 2017.

INL various dates-a. CPP Temporary Badge and Special Badge Reports and HP Requests 

November 11, 1974 – December 31, 1976, Idaho National Laboratory. Various dates. [SRDB 

Ref. ID 143029]

INL various dates-b. CPP Temporary Badge and Special Badge Reports December 1, 1976 –

December 31, 1980, Idaho National Laboratory. Various dates. [SRDB Ref. ID 143017]

NIOSH 2017a. SEC Petition Evaluation Report Petition SEC-00219 Idaho National Laboratory,

Revision 2, National Institute for Occupational Safety and Health, Cincinnati, OH. February 22, 

2017. 

NIOSH 2017b. SEC Petition Evaluation Report Petition SEC-00238 Idaho National Laboratory,

Revision 0, National Institute for Occupational Safety and Health, Cincinnati, OH. July 20, 2017.

SC&A 2017. Memorandum: Update on Validation and Verification of INL CPP Temporary 

Badge Database – Expansion of Claimant Pool (1963–1970), SC&A, Inc., Arlington, VA. 

August 3, 2017.