Draft

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Evaluation of Claims with Supplemental Dosimetry Requests

Contract No. 211-2014-58081 

SCA-2016-SEC-0074F, Revision 0 

Prepared by 

Bob Barton, CHP 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

January 2016 

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 report 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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S. COHEN & ASSOCIATES: Technical Support for the Advisory Board on Radiation & 

Worker Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: Evaluation of Claims with Supplemental Dosimetry Requests

DOCUMENT NUMBER/

DESCRIPTION:

SCA-2016-SEC-0074F, Revision 00 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: January 12, 2016

TASK MANAGER: John Stiver

PROJECT MANAGER: John Stiver

DOCUMENT 

REVIEWER(S): John Stiver, Joe Fitzgerald

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 1/12/2016 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ..........................................................................................................4

1.0 Background ..........................................................................................................................6

2.0 Evaluation of 18 Claims Requested by SC&A and NIOSH for Follow-up.........................7

2.1 Case #1: Claim ..............................................................................................7

2.2 Case #2: Claim ..............................................................................................9

2.3 Case #3: Claim ............................................................................................12

2.4 Case #4: Claim ............................................................................................13

2.5 Case #5: Claim ..............................................................................................15

2.6 Case #6: Claim ..............................................................................................17

2.7 Case #7: Claim ............................................................................................19

2.8 Case #8: Claim ............................................................................................20

2.9 Case #9: Claim ............................................................................................21

2.10 Case #10: Claim ............................................................................................22

2.11 Case #11: Claim ..........................................................................................22

2.12 Case #12: Claim ............................................................................................24

2.13 Case #13: Claim ..........................................................................................25

2.14 Case #14: Claim ..........................................................................................26

2.15 Case #15: Claim ............................................................................................27

2.16 Case #16: Claim ..........................................................................................27

2.17 Case #17: Claim ..........................................................................................29

2.18 Case #18: Claim ..........................................................................................29

3.0 Summary Recommendation ...............................................................................................30

4.0 References..........................................................................................................................31
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation Worker Health

ANL-W Argonne National Laboratory – West

AX Construction in Test Area North

ATR Advanced Test Reactor

CATI Computer Assisted Telephone Interview

CFA Central Facilities Area

CPP Chemical Processing Plant

CX Construction at CPP

DOE Department of Energy

DOL Department of Labor

EE Energy Employee

EBR Experimental Breeder Reactor

GET/GERT Unknown

HP Health Physics

INEL Idaho National Engineering Laboratory

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Center

LFC Location File Card

LOFT Loss of Fluid Test 

MRF Unknown

MTR Materials Test Reactor

NIOSH National Institute for Occupational Safety and Health

NRF Naval Reactor Facility

NRTS Nuclear Reactor Test Site

OMRE Organically Moderated Reactor Experiment

OX Construction at OMRE

RWMC Radioactive Waste Management Complex

S5G Submarine Platform Reactor, Generation 5, General Electric

SC&A Sanford Cohen and Associates

SEC Special Exposure Cohort

SL-1 Stationary Low-Power Reactor Number 1
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TAN Test Area North

TLD Thermoluminescent Dosimeter

TRA Test Reactor Area

WBC Whole Body Count

WG Work Group
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1.0 BACKGROUND

As a result of discussions undertaken at the July 8, 2015, Idaho National Laboratory (INL) Work 

Group (WG) meeting and the July 23, 2015, Advisory Board on Radiation and Worker Health 

(ABRWH) meeting in Idaho Falls, Idaho, SC&A and the National Institute for Occupational 

Safety and Health (NIOSH) were tasked with continuing to evaluate the proposed Special 

Exposure Cohort (SEC) class definition for the Chemical Processing Plant (CPP) (1963–1974). 

NIOSH transmitted the results of their ongoing evaluation on August 21, 2015 (NIOSH 2015), 

and noted that there were 11 claimants that had been identified as requiring follow-up data 

capture for relevant dosimetry records. In tandem with this effort, SC&A’s evaluation had 

identified 11 additional claimants and requested that they also be forwarded on to INL for 

dosimetry completeness evaluation. 

Data requests were made to INL for NIOSH and SC&A’s identified claimants on October 2, 

2015, and October 21, 2015, respectively. Responses were received from INL as soon as 

information was available on each claim, with the final data request being completed on 

December 30, 2015. At the November 10, 2015, INL WG meeting and again at the November 

18, 2015, ABRWH meeting, NIOSH indicated that they had removed 4 of their 11 claims from 

requiring additional follow-up with INL. Although the reasons for removing these claims were 

not explicitly stated, it appears that the 4 claims were removed from the original 11 NIOSH 

claims for the following reasons: 

• Three of the four claims had evidence of external monitoring during the latter SEC period 

(1970–1974), and thus had met the proposed SEC criteria. 

• The fourth claim did not have 250 days of covered employment in either of the SEC 

periods, and thus would not meet the required employment criteria. 

As such, there were ultimately 7 NIOSH claims and 11 SC&A claims for which additional data 

capture efforts were requested and received from INL. This memo represents SC&A’s review of 

the additional information provided for the 18 total claims identified by NIOSH and SC&A 

As a result of this evaluation, SC&A had the following six observations: 

Observation 1: Five of the 18 claims contained a listing of a “box” and “record number” 

for the relevant claimant dosimetry records. In one of those five claims, it appears that an 

“area exposure report” related to the claimant could not be located. It should be noted that 

NIOSH has undertaken a comparison of monthly Health Physics (HP) reports versus the 

available dosimetry printouts, and NIOSH concluded the records available (at least for 

CPP in the 1963–1970 timeframe) are complete for the purposes of SEC administration.

Observation 2: SC&A identified evidence (specifically an in-vivo record) of a claimant 

entering CPP in 1966 that did not have associated external dosimetry for CPP. 
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Observation 3: Case #3 provides an example where internal monitoring indicates CPP 

during the latter SEC period (1970); however, there is no external monitoring at INL after 

1960. 

Observation 4: Case #4 (and also Case #7) contained dosimetry logbooks that were undated 

and the columns were unlabeled. SC&A was able to determine that these logbooks were not 

associated with CPP and were related to the Stationary Low-Power Reactor Number 1 

(SL-1) incident in January of 1961. SC&A has assumed that this format is exclusively 

associated with the SL-1 incident. 

Observation 5: SC&A noted that in Case #5, the original record transmittal only included 

the career dose totals, which appear to omit the external monitoring that occurred from 

1965 to 1967. While it is possible this is the result of the claimant actually working at the 

Naval Reactor Facility (NRF), it calls into question the use of “career dose totals” for 

establishing monitored periods during the proposed SEC period.

Observation 6: The “annual dose summary” report for Case #6 indicates that the claimant 

was monitored from 1963 to 1966; however, individual dosimetry reports are not available 

to ascertain the exact work location during this time. 

2.0 EVALUATION OF 18 CLAIMS REQUESTED BY SC&A AND 

NIOSH FOR FOLLOW-UP

In this section, a summary profile of each of the 18 claimants is presented and includes the 

following information: 

• Covered SEC Employment 

• Job Title(s)

• Original comments and rationale for selecting the individual claim for supplemental data 

requests

• Relevant information received from the Department of Energy (DOE)/INL as a result of 

these additional data requests

• A discussion regarding the Energy Employee (EE) in relation to the currently proposed 

SEC class definition

The 6 claims for which these observations were made are presented first; the remaining 12 

claims are subsequently presented in random order. 

2.1 CASE #1: CLAIM 

Covered Employment Job Title(s) Start End

/1956 /1992
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Original Comments and Rationale for Selection Claims (SC&A 2015): 

• Location File Card (LFC) only covers up to 1962, but does indicate assignment to CPP 

prior to the proposed SEC period.

• Internal monitoring indicates Central Facilities Area (CFA) during the SEC period.

• Only annual external doses are available.

• Computer-Assisted Telephone Interview (CATI) with EE related to work 

location: “ , MTR, CPP, Central, TAN, 

, went to the site occasionally to work in the .” [Emphasis 

added]

Review Comments based on Supplemental Data Requests:

• No evidence found in complete record set to indicate assignment to CPP during the SEC 

period. 

• Records contained an electronic listing of the “box” and “record number” for the known 

EE’s dosimetry records and indicated one was “Not Found” (see Figure 1). 

Discussion:

While the supplemental data request did not contain any evidence to suggest the EE was 

potentially exposed at CPP during the proposed SEC period, the records did contain an electronic 

listing of the “box” and “record” related to this particular worker (henceforth referred to as the 

“box and record listing”). This is the first time SC&A has seen such a listing included in a 

claimant’s dosimetry record. As seen in Figure 1, a handwritten note suggests that either one of 

the boxes or the particular record (an area exposure report) could not be located. 

SC&A examined each of the 18 targeted claims for a “box and record listing” and found that 

only 5 of 18 contained such a record. However, based on these five claims, SC&A was able to 

determine that only the record shown in Figure 1 was missing and not the whole box.1 Of the 

limited set of five claims, this claim was the only instance where it appears that a record was 

unable to be located. Furthermore, evidence suggests that the missing record was likely from 

either November or December of 1961, based on neighboring records identified in the same box 

for the other four claimants’ records. Therefore the missing record is likely not germane to the 

proposed SEC requirements in this particular case. 

1 SC&A observed that different records from the box in question were present in at least one of the other 

four claim files, and so it appears the handwritten note is in relation to the individual record.

However, since the assurance that dosimetry records are complete and available is of paramount 

importance to the accurate and fair administration of the proposed SEC class, the fact that some 

records may potentially be unavailable is problematic. Because this is the first time SC&A has 

observed a “box and record listing,” the extent to which records may not be able to be located for 

other workers could not be evaluated. 

 
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It should be noted that during the November INL WG and ABRWH meetings, NIOSH presented 

figures comparing the number of reported dosimeters for CPP as listed in the HP summary 

reports versus the number of actual hardcopy records available at this time. Based on those charts 

and the underlying analysis, NIOSH concluded that records for CPP from 1963 to 1970 are 

complete for the purposes of SEC determination. 

Observation 1: Five of the 18 claims contained a listing of a “box” and “record number” 

for the relevant claimant dosimetry records. In one of those five claims, it appears that an 

“area exposure report” related to the claimant could not be located. It should be noted that 

NIOSH has undertaken a comparison of monthly HP reports versus the available 

dosimetry printouts, and NIOSH concluded the records available (at least for CPP in the 

1963–1970 timeframe) are complete for the purposes of SEC administration.

Figure 1. Screenshot of a "Box and Record Listing” Showing One of the 

Records Unavailable 

2.2 CASE #2: CLAIM 

Covered Employment Job Title(s) Start End

/1962 /1967 Draftsman

/1968 /1968 Draftsman

/1969 /1969 Draftsman

/1976 /1976 Draftsman

/1976 /2006 Draftsman
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Original Comments and Rationale for Selection Claims (SC&A 2015): 

• LFC does not indicate a specific work location during the proposed SEC period; 

however, does indicate assignment to CPP during the 1990s. 

• Internal monitoring during the SEC period is related to the CFA. 

• Only the annual dose totals were available for the EE.

• CATI with the survivor indicates: “Central (689), INTEC/CPP, two buildings in town, 

all over the site.” DOL Initial Case lists CFA for SEC period but was “also required to go 

to other facilities.” [emphasis added]

Review Comments based on Supplemental Data Requests:

• Visitor badges were issued for the EE indicating CPP in 1984 and 1985, but not during 

the SEC period.

• A Whole Body Count (WBC) for the EE is labelled as CPP in 1966 (see Figure 2). The 

accompanying WBC questionnaire is shown in Figure 3.

• No “box and record listing” was available for this claimant.

Figure 2. Screenshot of In-Vivo Record from Claim Indicating the Facility was CPP
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Figure 3. Screenshot of the Whole Body Count Questionnaire Accompanying the In-Vivo 

Record in 1966 

Discussion:

As seen in Figure 2, the EE was counted via in-vivo in 1966 at CPP. However, no dosimetry 

badge associated with CPP during the SEC period was identified for this claimant. The Whole 

Body Count Questionnaire shown in Figure 3 indicates that the present work area was CF689, 

which presumably refers to the CFA. Additionally, Figure 3 shows there is a section where the 

worker is to list other work areas at INL.

2

 This section is blank, but also the box indicating the 

EE did not work in “other areas” was not checked. 

2 The form shows “NRTS,” which is an alternate name for INL, standing for “Nuclear Reactor Test Site.”

The CATI report with the EE’s survivor indicated that the claimant worked “all over the site.” 

One possibility is that as a “draftsman,” the claimant would enter different facilities to plan 

modifications to equipment or new construction. If this is the case, the claimant’s main work 

area may have been the CFA; however, the possibility exists that the EE entered CPP to perform 

the duties as a draftsman. Regardless, the evidence suggests that the EE was at CPP in 1966 for 

the in-vivo count and no associated external dosimetry has been identified. As was noted 

previously, there was no “box and record listing” available for this claimant, so it is unknown if 

there is perhaps a missing record, the EE was not badged, or the EE never actually entered CPP. 

Observation 2: SC&A identified evidence (specifically an in-vivo record) of a claimant 

entering CPP in 1966 that did not have associated external dosimetry for CPP. 

 
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2.3 CASE #3: CLAIM 

Covered Employment Job Title(s) Start End

Six Additional Employment Periods Prior to the SEC Period Mason

/1963 /1964 Mason

/1964 /1964 Mason

/1965 /1965 Mason

/1967 /1967 Mason

/1967 /1970 Mason

/1970 1970 Mason

/1970 /1970 Mason

/1972 /1972 Mason

Two Additional Employment Periods After SEC Period Mason

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• Available external dosimetry is restricted to 1960 at INL and does not begin again until 

December of 1988 at Argonne National Laboratory-West (ANL-W) (see Figure 4).

• LFC does not indicate a work area, but states the EE was employed with 

during the SEC period. 

• CATI report with EE does not mention CPP. 

• A urinalysis monitoring result in 1970 indicates CPP (see Figure 5). 

Review Comments based on Supplemental Data Requests:

• Supplemental data requests did not provide any new information. 

• No “box and record listing” is available for this claimant. 

Figure 4. Screenshot of Case #3 External Dose Summary Showing Monitoring at INL 

Only Occurred in 1960
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Figure 5. Screenshot of Bioassay Record for Case #3 Highlighting the Date (July 1970) 

and Location (CPP)

Discussion:

Similar to Case #2, the EE has internal monitoring associated with CPP in 1970, but external 

dosimetry for the individual ended 10 years earlier in 1960. As was noted previously, there was 

no “box and record listing” available for this claimant, so it is unknown if the EE was not badged 

or if there is perhaps a missing record.

Observation 3: Case #3 provides an example where internal monitoring indicates CPP 

during the latter SEC period (1970); however, there is no external monitoring at INL after 

1960. 

2.4 CASE #4: CLAIM 

Covered Employment Job Title(s) Start End

Five Additional Employment Periods Prior to the SEC

/1965 /1965

/1966 /1966

/1966 /1966

/1966 /1966

/1970 /1970

/1970 /1970

/1972 /1972

/1972 /1973

Twenty-Three Additional Employment Periods After the 

Proposed SEC

Electrician

Electrician

Electrician

Electrician

Electrician

Electrician

Electrician

Electrician

Electrician

Electrician

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• Career dose totals end in 1961 and then began again in 1970, though it appears this latter 

monitoring was associated with the NRF. 

• Available dosimetry prior to the proposed SEC indicates work at CPP. 
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• No LFC was available.

• CATI report with EE states:

Areas of contamination were all over the site. They were restricted at first and 

then later they had to work in the areas with no indication that the area was 

cleaned up. CPP was the most contaminated area. There were a lot of 

55-gallon waste drums stored there. They had a lot of spills and evacuations 

which required restriction from the area for 2–3 days at a time. He had to 

evacuate MTR a couple of times while they were building ATR. [Emphasis 

added.] 

Review Comments based on Supplemental Data Requests:

• LFC:

o Employment with in 1970, located at NRF.

o Employment with and in 1972 and 

1973; however, no area was provided. There was no external monitoring during 

these years.

o Assignment to CPP and Test Area North (TAN) in 1978 and 1992.

• There are multiple temporary dosimetry badges at CPP from 1977 to 1980, and again in 

1982.

• File contained multiple dosimetry logs that were undated and the individual columns do 

not contain headers (see Figure 6). SC&A was able to match up the assumed dosimetry 

results column with other records to conclude that these untitled and undated records 

were associated with the SL-1 incident. This was also observed in Case #7. It is assumed 

that all such undated and unlabeled records relate to the SL-1 incident.

• No “box and record listing” is available for this claimant.
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Figure 6. Screenshot from Claim Showing Undated Record with No Column 

Headers

Discussion:

The available monitoring results for this case showed work at CPP both before and after the 

proposed SEC period. Though the CATI report with the worker did indicate work in CPP and 

described the conditions as “the most contaminated area,” it is very possible the EE was referring 

to work outside the proposed SEC. Though the claim file did contain dosimetry records that were 

undated and unlabeled, and thus could have potentially represented CPP exposures, SC&A was 

able to determine that they were from the SL-1 incident by comparing the individual dosimetry 

results from the undated record to other dosimetry logs contained in the file. There was no “box 

and record listing” file provided for the claimant, so it is not possible to determine if any 

particular records could not be located. SC&A did not find direct evidence to suggest the 

claimant was exposed at CPP during the proposed SEC period. 

Observation 4: Case #4 (and also Case #7) contained dosimetry logbooks that were undated 

and the columns were unlabeled. SC&A was able to determine that these logbooks were not 

associated with CPP and were related to the SL-1 incident in January of 1961. SC&A has 

assumed that this format is exclusively associated with the SL-1 incident. 

2.5 CASE #5: CLAIM 

Covered Employment Job Title(s) Start End

Three Additional Employment Periods Prior to SEC period Pipe Insulator

/1965 /1966 Pipe Insulator

/1967 /1967 Pipe Insulator

/1973 /1974 Pipe Insulator

/1974 /1975 Pipe Insulator
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Original Comments and Rationale for Selection Claims (SC&A 2015): 

• LFC entry for /1965– /1966 indicates work at NRF. The other entry ( /73–

/1974) does not list a work area.

• Dosimetry files indicate monitoring ended in 1962.

• CATI with EE indicates the work areas were “S5G, CPP, TAN, LOFT, and EBR-II.” The 

claimant describes an incident at CPP in the 1963–1966 timeframe. 

Review Comments based on Supplemental Data Requests:

• SC&A observed that the “career dose total” (Figure 7) and “annual dose summary” 

(Figure 8) records did not match:

o As seen in the figures, the “career dose total” ends in 1962 and neglects 1965 

through 1967. 

o Specific dosimetry records for 1965–1967 were not available. 

o As noted above, the LFC lists NRF as the work area during the covered 

employment in 1965–1966. The work location for the remaining uncovered 

employment (1967) is unknown.

• Supplemental dosimetry records included a temporary badge for “AX” (construction in 

Test Area North) in 1963, which was outside the covered employment.

• Three temporary badges were issued for the Technical Support Facility in 1973 and 1974.

• No “box and record listing” is available for this claimant.

Figure 7. Screenshot of Career Dose Record for Claim 

Indicating Monitoring Ended in 1962 
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Figure 8. Screenshot of Annual Dose Totals for Case #7 Showing External Monitoring 

Occurred in 1965–1967 

Discussion:

In the CATI report, the claimant describes incidents occurring in the 1963 to 1966 timeframe. 

However, SC&A could not find any evidence of such incidents in the supplemental dosimetry 

files. SC&A noted that in the original record transmittal, the “career dose total” indicated that 

monitoring ended in 1962. Based on the supplemental dosimetry records, which included the 

“annual summary report,” it appears the claimant was also monitored from 1965 to 1967. This 

calls into question the accuracy of the “career dose summary” for establishing monitored periods. 

As was noted, at least part of this period appears to be associated with NRF. This may explain 

why the “career dose totals” did not include these years, but it is not certain without further 

evidence. Since the “box and record listing” was not included in the file, it is not possible to 

determine if all known records for the individual were available. SC&A did not identify any 

direct evidence that the EE was potentially exposed at CPP during the proposed SEC period. 

Observation 5: SC&A noted that in Case #5, the original record transmittal only included 

the career dose totals, which appear to omit the external monitoring that occurred from 

1965 to 1967. While it is possible this is the result of the claimant actually working at NRF, 

it calls into question the use of “career dose totals” for establishing monitored periods 

during the proposed SEC period.

2.6 CASE #6: CLAIM 

Covered Employment Job Title(s) Start End

/1957 /1986

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• LFC does not indicate an assigned work area during the SEC period, and only indicates 

that employment was with the Idaho Nuclear Corp. 

• Claimant was monitored externally at CPP in the 1950s. 

• There were no external monitoring data available in the proposed SEC period. 
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• In-vivo results in the 1963–1965 period were associated with the CFA. 

• CATI report with survivor states: “All over site/ was in TRA and CPP... When 

[The EE] cleaned up reactor spills, [the EE] never wore a dosimeter, so there was no way 

to determine whether [the EE] had reached [the EE’s] radiation limit or to measure how 

much radiation [the EE] was exposed to.” 

Review Comments based on Supplemental Data Requests:

• An in-vivo count questionnaire from 1965 indicates the claimant was in the same area for 

the previous 9 years. However, there are visitor badges associated with CPP (1959) and 

TAN (1961). 

• The EE has visitor badges associated with CPP in 1979 and 1984.

• The “annual exposure summary” report indicates monitoring occurred from 1963 to 1965 

(see Figure 9); however, the actual records (indicating work location) were not included 

in the supplemental dosimetry records. 

• No “box and record listing” is available for this claimant.

Figure 9. Screenshot of “Annual Dose Summary” Report Showing External Monitoring 

from 1963 to 1965 

Discussion:

As noted above, the claimant was monitored at INL from 1963 to 1965 per the “annual dose 

summaries”; however, the individual dosimetry records were not included in the supplemental 

records request and so are assumed not available. Internal records during this period indicate that 

the main work area was “CFA”; however, given that the occupation was “ ,” this is not 

surprising. The CATI with the EE’s survivor states that the itself was in “TRA and 

CPP” and that the EE was involved in cleanup activities. Since the “box and record listing” was 

not included in the file, it is not possible to determine if all known records for the individual 

were available. While SC&A did not find any evidence that the claimant was exposed at CPP 

during the proposed SEC period, the exact work location based on external monitoring results 

from 1963 to 1965 is not available. 
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Observation 6: The “annual dose summary” report for Case #6 indicates that the claimant 

was monitored from 1963 to 1966; however, individual dosimetry reports are not available 

to ascertain the exact work location during this time. 

2.7 CASE #7: CLAIM 

Covered Employment Job Title(s) Start End

/1959 /1963 Health Physicist

/1964 /1964 Health Physicist

/1964 /1965 Health Physicist

/1965 /1966 Health Physicist

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• LFC indicates assignment to Materials Test Reactor (MTR) and NRF during the proposed 

SEC period

• External monitoring results are associated with MTR and CFA.

• One Whole-Body Count Questionnaire indicated that there was no work in any other 

area.

• CATI with the EE mentions incidents at CPP in the 1959–1963 period, although more 

specific dates were not provided. 

Review Comments based on Supplemental Data Requests:

• Part of the supplemental dosimetry file contains logbook entries that are undated and do 

not have column headers. These were determined to be associated with the SL-1 incident 

via comparison with dose totals from alternately formatted dosimetry records (see 

Case #4, Observation 4). 

• Internal dosimetry in 1963 (one of the incident years mentioned) was related to MTR and 

CFA.

• No evidence of an incident was observed in the supplemental dosimetry records, and no 

monitoring was identified at CPP during any period.

• No “box and record listing” is available for this claimant.

Discussion:

Although the claimant mentions incidents at CPP that may have occurred in the first year of the 

proposed SEC period, SC&A could find no indication in the supplementary dosimetry records 

that any incidents were documented involving the EE at that location. Internal and external 

monitoring suggests that the claimant was working in the MTR and CFA areas during the 

proposed SEC period. Since the “box and record listing” was not included in the file, it is not 

possible to determine if all known records for the individual were available. SC&A did not find 

direct evidence to suggest the claimant was exposed at CPP during the proposed SEC period. 
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2.8 CASE #8: CLAIM 

Covered Employment Job Title(s) Start End

Two Additional Employment Periods Prior to the SEC Period Ironworker

/1963 /1963 Ironworker

/1966 /1966 Ironworker

/1969 /1970 Ironworker

/1970 1970 Ironworker

Five Additional Employment Periods After the SEC Period Ironworker

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• CATI with the EE:

o “Argonne, CPP, Westinghouse, EBR I & II, burial grounds, north end, central 

facilities.” 

o Indicates the use of anti-contamination clothing and respirators while working at 

CPP.

o Notes that [the EE] did not wear a film badge, but did use a pencil dosimeter. 

• No LFC was available for the claimant.

Review Comments based on Supplemental Data Requests:

• LFC indicates that parts of 1963 were associated with work at the NRF and “AX” 

(construction at Test Area North).

• Available dosimetry reflects work at “AX” in 1963.

• The annual dose summaries indicate monitoring occurred in 1970 and 1971, though it is 

unknown if this includes NRF employment.

• Three separate employment periods with Arrington Construction are indicated in 1969 

and 1970; however, no area is specified. Starting in August 1970, the LFC indicates 

assignment to NRF.

• Temporary badges were issued for CPP in 1984 and 1985.

• A “Box and Record List” was included in the claimant’s file. All listed records contained 

in the file were also included in the claimant’s dosimetry file.

Discussion:

The claimant describes working at CPP during employment, but does not specify when that work 

may have occurred. Based on the available temporary dosimetry badges, the claimant did work at 

CPP, but not during the SEC period (the temporary badges were in the 1980s). The only 

available monitoring during the proposed SEC period was associated with construction in the 

TAN area. Review of the “box and record list” indicates that all known records for the claimant 
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have been obtained and transmitted to NIOSH. SC&A did not find direct evidence to suggest the 

claimant was exposed at CPP during the proposed SEC period 

2.9 CASE #9: CLAIM 

Covered Employment Job Title(s) Start End

/1962 /1963 Electrical Engineer

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• LFC does not indicate an assigned area or employer. 

• CATI with EE states: “MTR, [Engineering Test Reactor], ATR, reactor sites, sodium 

reactor facility.”

• Internal monitoring data available for MTR and CFA.

• A termination in-vivo questionnaire for MTR indicates “no other areas worked.” 

• From the Department of Labor (DOL) Initial Case: “Worked as an electrical engineer 

performing glove box design, assisting with installation, troubleshooting [sic], 

modifications, etc. during the spent metal reduction program. As an electrical engineer 

spent time with various electrical systems throughout the facility.” 

• Only annual dose summary records area are available.

Review Comments based on Supplemental Data Requests:

• Dosimetry records were provided which show consistent monitoring at MTR during 

1963. 

• One additional visitor badge associated with TAN identified during 1963. 

• No “box and record listing” is available for this claimant.

Discussion:

As noted in the “Original Comments” section, the previously available claimant records did not 

directly indicate work at CPP, nor did the CATI report. However, based on the fact that only 

annual dose summaries were originally available and the statements in the DOL Initial case 

indicated involvement in the spent metal reduction program (location not specified) and that 

electrical work was “all over the site,” it was determined the possibility existed that the EE spent 

at least some time in the CPP. However, specific dosimetry records were received from INL as a 

result of the supplemental data request and they indicated continuous external monitoring at 

MTR, with a single visit to TAN during the 1963 period. Since the “box and record listing” was 

not included in the file, it is not possible to determine if all known records for the individual 

were available. SC&A found no evidence to suggest the EE was potentially exposed at CPP 

during the SEC period. 
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2.10 CASE #10: CLAIM 

Covered Employment Job Title(s) Start End

/1969 /1987 Journeyman Roofer

Nine Additional Employment Periods After the SEC Period Journeyman Roofer

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• CATI report with the EE describes an incident in the early 1970s that took place at CPP 

while working on the roof. 

• Incident Description: “There were two times when they had their clothes and shoes taken 

from them because of contamination being found when they went through the monitoring 

as they exited a job. They also had a truck and other equipment taken to be cleaned up.” 

• Claimant states that external badging was intermittent.

• DOE Response files indicate external monitoring did not begin until 1975. 

Review Comments based on Supplemental Data Requests:

• LFC indicates assignment to CPP for at least 2 days in 1975 (8/25/1975 and 9/3/1975).

• Visitor dosimetry badges for CPP are available for 9/3/1975 and 11/25/1975.

• Regular dosimetry badge reports for CPP are available for cycles ending on 8/31/1975 

and 9/30/1975.

o “HP Request” was indicated under “reason code” for these dosimeters.

o Entries contain a “V” immediately after the area code designation, which likely 

represents that they were “visitor badges.”

• A “Box and Record List” was included in the claimant’s file. All listed records contained 

in the file were also included in the claimant’s dosimetry file.

Discussion:

The claimant does describe an incident in the “early 1970s” which can be assumed to reflect the 

visitor badges issued for the EE in 1975. Additionally, the incident is described as occurring on 

the roof and the actual badges indicate they were associated with CPP construction, which could 

reasonably be envisioned occurring on the roof. Comparison of the “box and record list” against 

the actual records transmitted in the supplemental data request indicates that all known records 

for the claimant were located. Thus, SC&A did not find any direct evidence that exposure may 

have occurred at CPP during the proposed SEC period. 

2.11 CASE #11: CLAIM 

Covered Employment Job Title(s) Start End

/1953 /1967
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Original Comments and Rationale for Selection Claims (SC&A 2015): 

• Claimant has external monitoring records associated with the MTR during the SEC 

period. 

• CATI with survivor did not know the specific work location. 

• In-vivo questionnaire dated 3/31/1967 indicates the EE also worked at CPP for 

18 months, but does not indicate the exact timeframe. Record indicates the contractor was 

“ .”

Review Comments based on Supplemental Data Requests:

• LFC: 

o Indicates assignment to MTR for parts of 1966–1967. 

o Also indicates employment in 1970 and 1971, although no area is given and the 

contractor entry is illegible (security badge records indicate the employers were 

 and ). 

• All external dosimetry during the covered SEC employment period was associated with 

MTR, and the records appear complete and continuous. 

• The EE had the following four external dosimetry records associated with CPP: 

o 3/29/1958: result labelled “not in area”

o 4/5/1958: result labelled “not in area”

o 4/17/1958: positive results listed

o 12/4/1958: record labelled “H.P. Request”

• Dosimetry prior to March 1958 was labelled as “CFA.” 

• A “Box and Record List” was included in the claimant’s file. All listed files (including 

over 400 pages of individual records) contained in the “box and record list” were verified 

as being included in the claimant’s dosimetry file.

Discussion:

The main piece of evidence provided in the original claim review was the whole-body count 

questionnaire from 1967, which indicated the EE spent 18 months at CPP. Unfortunately, the 

questionnaire does not prompt for specific dates to indicate when this employment actually 

occurred. The fact that the claimant was monitored externally at CPP in 1958 could potentially 

explain this unknown 18-month work period at CPP. As was noted, prior to these results, the 

dosimetry was related to CFA. It is not known if the “one badge–one area” badging policy was in 

place prior to 1958. It may be possible that a job title such as “ ” would be badged out 

of CFA, but would occasionally have to enter other areas as needed. All other evidence suggests 

the claimant was monitored continuously at MTR during the period of interest. SC&A’s review 

of over 400 references provided in the “box and record list” indicated that no known records 
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were able to be located. Therefore, SC&A could find no direct evidence that the EE was 

potentially exposed at CPP during the proposed SEC period. 

2.12 CASE #12: CLAIM 

Covered Employment Job Title(s) Start End

Two Additional Employment Periods Prior to the SEC Electrical Workers

/1963 /1963 Electrical Workers

/1965 /1965 Electrical Workers

1965 /1965 Electrical Workers

/1965 /1965 Electrical Workers

/1969 /1969 Electrical Workers

/1970 /1970 Electrical Workers

Seven Additional Employment Periods After the SEC Electrical Workers

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• DOE Response indicates external monitoring ended in 1963. 

• No LFC was available.

• CATI with survivor: "Building/Location: INEL: CPP, RWMC, TAN, MRF, GERT, GET, 

EBR2, NRF: for Power Line Construction, Outside Work, Posting Transmission 

Posts and Stringing the Wire.”

Review Comments based on Supplemental Data Requests:

• LFC:

o Indicates assignment to TAN construction during parts of 1963. 

o Hire dates in 1969 and 1970 were indicated, but no external dosimetry and/or 

termination dates were provided. 

o Employer during these latter years is listed as “Miscellaneous Contractors.”

• Monitoring began again in 1986 and lists “INT” as one of the areas. This could 

potentially represent “INTEC” or the Idaho Nuclear Technology and Engineering Center 

(formerly the CPP).

• No “box and record listing” is available for this claimant.

Discussion:

The main reason for requesting follow-up data capture for this claimant was that there was no 

LFC available and no individual dosimeter results for 1963. Supplemental data request provided 

a single dosimetry sheet associated with construction in the TAN area. The CATI with the EE’s 

survivor did list CPP among several other facilities located at the INL site; however, no dates 

were provided. One possibility is that the latter dosimetry records beginning in the mid-1980s 

actually represent INTEC, or the current name of the CPP. There was no “box and record listing” 
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file provided for the claimant, so it is not possible to determine if any particular records could not 

be located. SC&A found no direct evidence of exposure at CPP during the proposed SEC period. 

2.13 CASE #13: CLAIM 

Covered Employment Job Title(s) Start End

/1967 /1967 Teamster/Warehouseman

/1972 /1972 Teamster/Warehouseman

7 Additional Employment Periods After SEC-Period Teamster/Warehouseman

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• DOE Response indicates monitoring did not begin until 1986. 

• CATI with EE: 

o “Building/Location: CPP (chemical processing plant) 698... Routine job duties:

Went into areas to pick up safe work permits. Shipping and receiving supplies.” 

o States that no badges were worn, but the EE was routinely frisked and area 

surveys were undertaken. 

• LFC does not contain information until 1986 when CPP is listed. 

Review Comments based on Supplemental Data Requests:

• Employment in the earlier two periods was established based on security badges issued 

by Arrington Construction and the Kellog Co. 

• Temporary film badges for CPP in 19823

 and 1985. 

3 Area designation on 1982 temporary badge has some legibility issues; SC&A has assumed it is also for 

CPP, based on what is available.

• Dosimetry printouts beginning in 1986 indicate dual badging at TRA and “INT” 

(assumed to represent INTEC).

• A “Box and Record List” was included in the claimant’s file. All listed records contained 

in the file were also included in the claimant’s dosimetry file.

Discussion:

Although the claimant states in the CATI report that the sole work location was at CPP, no actual 

dates were provided. Evidence suggests that the EE was monitored as a visitor and then on a 

regular basis at CPP during the 1980s. No evidence of work location or radiation monitoring 

(external or internal) during the brief period of covered employment in 1967 and 1972 was 

identified. Based on the “box and record listing,” it appears that all known records involving the 

EE were able to be located. Therefore, SC&A found no evidence that the claimant was exposed 

at CPP during the proposed SEC period. 

 
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2.14 CASE #14: CLAIM 

Covered Employment Job Title(s) Start End

/1953 /1954 Carpenter

/1963 /1963 Carpenter

/1963 /1963 Carpenter

1964 1964 Carpenter

/1964 /1964 Carpenter

/1973 /1976 Carpenter

Four Additional Employment Periods After SEC Period Carpenter

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• DOE Response indicates the claimant was not monitored at INL.

• No LFC could be located for the EE. 

• CATI with survivor: 

o Work Location: “Test Reactor Area, Chemical Processing Plant, Experimental 

Breeder Reactor, Test Area North.”

o “Exposure depended on which building [the EE] was in; however, [the EE]

mostly worked in radiation zones and had to be monitored on [the EE’s] way out 

of the zone... and building scaffolding, worked in pipe tunnels, and [the EE]

worked around pool areas where they kept radiated fuel.” 

Review Comments based on Supplemental Data Requests:

• Supplemental data requests provided two visitor badges for the EE in 1975 for the 

Radioactive Waste Management Complex (RWMC). 

• Additional visitor badge labelled as “Area 2014

” in 1978. 

4 Assumed to be EBR-II based on a handwritten note contained in the margin of the scanned visitor badge.

• No other dosimetry or LFC were provided. 

• No “box and record listing” is available for this claimant.

Discussion:

As noted above, the survivor of the EE listed CPP as one of the work areas that the claimant was 

located during the covered employment. However, aside from three visitor badges found in the 

1970s (after the proposed SEC period), there is no evidence to indicate the EE’s work area at 

INL. There was no “box and record listing” file provided for the claimant, so it is not possible to 

determine if any particular records could not be located. SC&A has found no direct evidence that 

the claimant was exposed at CPP either during or outside the proposed SEC period. 

 
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2.15 CASE #15: CLAIM 

Covered Employment Job Title(s) Start End

/1972 /1993

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• Only a career dose was available for this claimant.

• LFC indicates assignment to CPP for the period of 8/10/1972 to 5/6/1975 and also 

indicates “TLD” during this period. 

• CATI with survivor: “Building/Location: CFA-690 (Central Facility) and throughout the 

INEL Site as required.”

Review Comments based on Supplemental Data Requests:

• Regular monitoring began with a cycle for July 1972 and continued through the relevant 

proposed SEC period; all badges were associated with CFA.

• Claim has one regular area exposure report for CPP ending in May 1975.

• Claim has a visitor badge at CPP in November 1973.

• No “box and record listing” is available for this claimant.

Discussion:

Although there is direct evidence of the claimant being assigned to CPP during the relevant 

covered employment during the SEC and only a single visitor badge for the area, this is not 

unexpected, since the site policies at the time had switched from “one badge–one area” to “one 

badge–multiple areas.” Therefore, it is assumed the claimant simply took the applicable CFA 

badge and was able to enter CPP without obtaining a new badge. There was no “box and record 

listing” file provided for the claimant, so it is not possible to determine if any particular records 

could not be located. SC&A did not find evidence to suggest that the claimant was exposed at 

CPP and would be inadvertently excluded by the currently proposed SEC class definition 

requirements.

2.16 CASE #16: CLAIM 

Covered Employment Job Title(s) Start End

/1951 /1951 Insulator , Asbestos Worker

/1964 /1964 Insulator , Asbestos Worker

/1964 /1964 Insulator , Asbestos Worker

/1974 /1974 Insulator , Asbestos Worker

/1974 /1977 Insulator , Asbestos Worker

/1977 /1977 Insulator , Asbestos Worker

/1977 /1979 Insulator , Asbestos Worker
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Original Comments and Rationale for Selection Claims (SC&A 2015): 

• LFC: 

o Only indicates assignment to NRF during the SEC period, although there are 

several entries that do not indicate a specific work area.

o Assigned to CPP in 1975. 

• CATI report with survivors mentions CPP in an incident involving the EE, although the 

date of the incident was only given as “1961–1979” 

• Dosimetry result for “OX” (construction near the Organically Moderated Reactor 

Experiment (OMRE)) in January of 1963. Covered employment in this year is attributed 

to ANL-W.

Review Comments based on Supplemental Data Requests:

• Five visitor badges were found in the 1967 and 1968 timeframe with no area specified. 

These badging periods match up with assignments to NRF found on the LFC.

• Positive external exposure observed in 1974 was associated with a brief visit to TRA.

• Regular dosimetry records found for the EE in 1975 for CPP.

• Additional visitor badges for CPP in 1975, 1977 and 1978.

• No “box and record listing” is available for this claimant.

Discussion:

The CATI report with the survivors indicated there was an incident that occurred at CPP during 

the 1961–1979 time period. The LFC as well as regular/visitor badging indicates the EE was 

potentially exposed at CPP beginning in 1975. Evidence prior to this year indicates work areas 

such as construction at the OMRE area, a single visit to TRA, and multiple visits to NRF. There 

was no “box and record listing” file provided for the claimant, so it is not possible to determine if 

any particular records could not be located. SC&A did not find evidence to suggest that the 

claimant was potentially exposed at CPP during the proposed SEC period. 
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2.17 CASE #17: CLAIM 

Covered Employment Job Title(s) Start End

/1964 /1964 Plumber/Pipefitter

/1964 /1964 Plumber/Pipefitter

/1966 /1967 Plumber/Pipefitter

/1968 /1968 Plumber/Pipefitter

/1968 /1969 Plumber/Pipefitter

/1969 /1970 Plumber/Pipefitter

/1973 /1973 Plumber/Pipefitter

/1973 /1973 Plumber/Pipefitter

/1974 /1975 Plumber/Pipefitter

12 Additional Employment Periods After the SEC Period Plumber/Pipefitter

Original Comments and Rationale for Selection Claims (SC&A 2015): 

• Career dose totals indicate work from 1963 to 1970 was actually at ANL-W.

• LFC indicates several employment periods without a location specified (the only entries 

that specified a location were for ANL-W).

• Claimant was monitored at CPP during the latter SEC period (1970–1974), but did not 

have 250 days of covered employment. 

• CATI with survivor did not know the EE’s work location. 

Review Comments based on Supplemental Data Requests:

• No additional information was identified to indicate a specific work location for 

employment periods (1963–1970) that were not specifically labelled as “ANL-W.” 

• No “box and record listing” is available for this claimant.

Discussion:

Since no additional information was identified in the supplemental data request, SC&A has 

found no evidence, direct or anecdotal, that the claimant was potentially exposed at CPP during 

the earlier SEC period (1963–1970). The EE was monitored at CPP during the latter SEC period; 

however, the EE did not meet the 250-day SEC requirement. There was no “box and record 

listing” file provided for the claimant, so it is not possible to determine if any particular records 

could not be located. 

2.18 CASE #18: CLAIM 

Covered Employment Job Title(s) Start End

/1963 /1963 Painter

/1963 /1963 Painter

Three Additional Employment Periods After the SEC Period Painter
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Original Comments and Rationale for Selection Claims (SC&A 2015): 

• DOE Response indicates the claimant was not monitored at INL. 

• CATI with EE states that the work location was “Breeder reactor bldg., INTEC” (Idaho 

Nuclear Technology and Engineering Complex).

Review Comments based on Supplemental Data Requests:

• Supplemental data request affirms that the claimant was not monitored at INL.

• Security records do not list an employer for the covered employment periods during the 

proposed SEC period. 

• No “box and record listing” is available for this claimant.

Discussion:

The CATI report with the EE indicated that one of the work locations was INTEC (Idaho 

Nuclear Technology and Engineering Complex), which is the current name for the CPP. 

Supplemental data requests affirmed that the EE was not monitored at INL at any time. There 

was no “box and record listing” file provided for the claimant; however, this would be expected 

for an EE who was not monitored at any time at INL. SC&A found no evidence that the claimant 

was potentially exposed at CPP during the proposed SEC period. 

3.0 SUMMARY RECOMMENDATION

Based on our exhaustive review of dosimetry and worker placement data for the INL claimant 

population, SC&A believes that the probability of incorrectly excluding a claimant from the 

proposed SEC class based on the current external dosimetry requirements remains small but real.

Based on SC&A’s review of the 18 total claims jointly identified by NIOSH and SC&A, there 

remains some uncertainty regarding the efficacy of the class definition. For example, one of the 

18 claims exhibited evidence that at least one of the records related to the EE could not be 

located (see Observation 1). In two other examples, internal monitoring (specifically in vivo) 

indicated entrance into CPP, though the required external dosimetry was not provided and/or 

available (see Observations 2 and 3). Finally, one of the 18 claims indicated external monitoring 

for some years during the SEC for which individual dosimeter logs, which would allow for 

placement of the worker in a given area, were not provided and/or available (see Observation 6). 

Therefore, at this time SC&A is unable to validate the efficacy of the currently proposed class 

definition, despite the substantial effort put forth in the entirety of the INL SEC studies.
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4.0 REFERENCES

NIOSH 2015. NIOSH CPP and CX Dosimetry Evaluation - Follow-up. National Institute for 

Occupational Safety and Health - Email communication from Tim Taulbee to the INL Work 

Group. Sent: August 21, 2015

SC&A 2015. Evaluation of the Revised SEC Class Definition for the Idaho National Laboratory 

Chemical Processing Plant (1963-1974). Sanford Cohen and Associates, Vienna, VA.

September 28, 2015.