SEC-00219: Idaho National 

Laboratory – Chemical 

Processing Plant – Verification 

and Validation of Class Definition 

(1963–1970) 

Presented by: 

Bob Barton, SC&A, Inc.

Meeting of the Advisory Board on Radiation and Worker Health

Pittsburgh, PA

April 17, 2019
Introduction and Background SEC Petition-00219 

 July 23, 2015: NIOSH releases Revision 1 of the SEC-00219 Evaluation 

Report regarding dose reconstruction feasibility at the Chemical Processing 

Plant (CPP) for the period from 1963–1974. (Revision 02 of the SEC-00219 

ER was released in February 2017 with the class definition remaining 

unchanged.)

 Revised class definition effectively split into two periods:

 January 1, 1963–February 28, 1970

 March 1, 1970–December 31, 1974

 Revised class definition:

“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.” [Emphasis added.]

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Introduction and Background SEC Petition-00219 (cont.) 

 March 24, 2016: Advisory Board recommended acceptance of the second 

part of the class definition (March 1, 1970–December 31, 1974), which only 

required evidence of external monitoring at INL.

 Concerns remained regarding the requirement of external monitoring specific 

to CPP for the first part of the class definition.

 Preliminary investigations determined that temporary/visitor badges were not 

appropriately attributed to the energy employees (EEs) and were not included 

in the individual dosimetry files.

 INL/DOE began a significant coding effort to migrate the temporary/visitor 

badge information into the INL Dosimetry Index.

 Once the badges were appropriately coded and indexed, they should be correctly 

attributed to each individual EE.

 If individual claimant dosimetry files are now complete, then SEC determinations 

based on CPP-specific external monitoring should not inadvertently omit a 

qualifying claim.

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Introduction and Background SEC Petition-00219 (cont.) 

 INL/ANL-W Work Group concerns remained about the 

implementation and effectiveness of the coding and indexing 

effort of the temporary badges/visitor cards.

 Visitor cards are handwritten on small index cards (roughly the 

area of a matchbook), which might pose the following potential 

issues:

 Legibility issues with original cards

 Name misspellings or variations (e.g., use of nicknames or middle 

initials used in place of first initial)

 Human error during the transfer of information to the INL 

Dosimetry Indexing system

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Introduction and Background SEC Petition-00219 (cont.) 

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Introduction and Background SEC Petition-00219 (cont.) 

 Work Group tasked SC&A with developing and executing 

a verification and validation (V&V) study to determine the 

effectiveness of the coding/indexing effort.

 SC&A delivered its “proof of principle” V&V approach in 

September 2016, which was discussed during the May 2017 

Work Group meeting.

 Full V&V proposal was completed and discussed with the Work 

Group in August 2017:

 Full V&V proposal included 228 potential candidates that covered nearly 

1,800 temporary badges.

 Work Group elected to begin the V&V process with the 30 claims 

categorized by SC&A as most beneficial to the study (larger number of 

temporary badges, diversity of employers and job types).

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Introduction and Background SEC Petition-00219 (cont.) 

 NIOSH began submitting requests to INL for the group of 30 

claims during Fall 2017 with the following language included in 

the request cover letter:

“This case is part of a group of 30 cases that are being reviewed in order to 

evaluate a concern raised by the Advisory Board on Radiation Worker Health 

(ABRWH). Although INL previously provided dosimetry responses for this 

EE, we are requesting that INL perform a new records search and provide a 

full radiological record for this EE...

In order to completed [sic] address the ABRWH concern, it would be 

extremely helpful if the full dosimetry/radiological record were provided”

 Based on the first few claimant dosimetry records received 

from DOE, it was evident that indexing/coding process had still 

not been correctly implemented.

 DOE/INL was notified of the issue and a second records 

request was made in Spring 2018.

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Introduction and Background SEC Petition-00219 (cont.) 

 July 2018: SC&A provided a status evaluation of 18 of 30 

claimant dosimetry records that had been provided to 

date.

 Evident from 2 of the 18 preliminary evaluations that the 

indexing/coding system was still not functioning properly: 

 1 case was missing all 31 identified visitor badges

 1 case only contained 6 of 49 identified visitor badges (~12%)

 NIOSH resubmitted records requests for a third time for 

these two claims, along with the remaining 12 of 30 claims 

for which records had not yet been received.

 Updated dosimetry records for all 30 claims were provided 

by DOE/INL by mid-October 2018.

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V&V Results for SEC Petition-00219: Overall Results

 671 total badges were associated with the group of 30 

claims (not including potential name variations)

 634 were correctly included in the updated individual 

dosimetry files (94.5%)

 15 of the 30 claims had 100% of their identified visitor 

badges correctly included in the update dosimetry records

 Update for the two cases resubmitted for the third time:

 1 case improved from 0% (0/31 badges included) to 97% (30/31 

badges included) 

 1 case improved from 12% (6/49 badges included) to 96% (47/49 

badges included)

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V&V Results for SEC Petition-00219: Name Variations

 SC&A identified potential name variations among 15 of the 30 V&V 

claimants (51 total badges).

 Only 15 of the 51 identified badges with name variations were 

found in the updated dosimetry files (29%).

 SC&A also reviewed the updated dosimetry files for name 

variations that had not been identified by SC&A during formulation 

of the V&V proposal.

 Review included records other than CPP temporary badges (e.g., 

temporary badges from other locations)

 Additional name variations found for 22 of 30 V&V claims (66 

name variations in total)

 Name variations identified include examples of temporary 

badges with identical name variations in which some were 

correctly included and others were incorrectly excluded.

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SC&A Summary Conclusions

 94.5% (634/671) identified badges were correctly included in the updated 

dosimetry file (observed name variations not included). 

 The average among the 30 V&V claims was 94.3% of identified badges 

correctly included.

 15 of 30 V&V claims had 100% inclusion of identified temporary badges.

 Two identified cases with significant issues identified in July 2018 improved 

from 12% to 96% and 0% to 97%.

 Separate analysis of name variations identified by SC&A showed that 29.4% 

(15 of 51 temporary badges) were included in updated dosimetry file.

 66 additional name variations not identified by SC&A (covering 21 of 30 V&V 

claims) were found in the updated dosimetry file.

 All 30 V&V cases had at least one CPP badge during the period of interest 

(1963–February 1970).

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Work Group Recommendations and/or Path Forward

 INL/ANL-W Work Group met via teleconference on 

March 25, 2019.

 NIOSH determined that early issues with the INL 

Dosimetry Indexing system implementation were related 

to staffing turnover at the time and lack of clarity on what 

was requested rather than a systemic problem.

 Determined that the chance to miss a monitored worker at 

CPP who also spent 250 days of covered employment 

inside the facility is “very unlikely.”

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Work Group Recommendations and/or Path Forward

 Work Group recommends the Advisory Board accept part 

(a) of NIOSH’s proposed class definition for SEC-00219:

“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.” [Emphasis added.]

 Note: Part (b) of the definition has already been accepted.

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Questions?

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