Idaho National Laboratory 

SEC Petition-00238 Status 

Update

Presented by: 

Bob Barton, SC&A, Inc.

Meeting of the Advisory Board on Radiation and Worker Health 

Providence, Rhode Island

August 22–23, 2018
INL SEC Petition-00238

 July 20, 2017: NIOSH Petition-00238 Evaluation Report is released 

as part of the 83.14 process

 NIOSH recommends an addition to the SEC Class for workers at the 

CPP for the period 1975–1980:

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.

 August 23, 2017: Advisory Board discusses proposed class during 

regular meeting in Santa Fe, New Mexico

 ABRWH votes to accept the proposed 83.14 class definition

 SC&A tasked with performing an evaluation of CPP dosimetry 

completeness for this period (1975–1980)

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SC&A Approach to Completeness Evaluation of SEC-00238

 SC&A Review Item 1: Evaluation of the completeness and 

availability of routine area exposure reports and construction 

exposure reports.

 SC&A Review Item 2: Evaluation of the completeness and 

availability of temporary/visitor badges. 

 SC&A Review Item 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. 

 SC&A Review Item 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.” 

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SC&A Evaluation of SEC-00238: Review Item 1 –

Completeness of Routine Dosimetry Records

 Completeness of dosimetry records established by comparing the number of monitored 

workers per badging cycle reported by INL to the actual dosimetry records captured by 

NIOSH.

 SC&A 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 months in which the number of monitored workers reported per badging cycle was 

not available, SC&A compared the total number of dosimeters processed against the 

actual dosimetry records captured by NIOSH.

 SC&A 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. 

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SC&A Evaluation of SEC-00238: Review Item 2 –

Completeness of Temporary/Visitor Badges

 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 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. 

 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. 

 August 2018 Path Forward on Findings 1 and 2: NIOSH to perform additional data 

capture at INL to obtain the full set of temporary badges for completeness evaluation. 

SC&A to participate in data capture efforts with NIOSH as appropriate.

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SC&A Evaluation of SEC-00238: Review Item 3 –

Identification of Verification and Validation Cases

 SC&A evaluated the potential for verification and validation 

(V&V) cases among the claimant population to assure 

temporary/visitor badges are included with current DOEsupplied monitoring records for individual energy employees.

 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 V&V review. However, 

when the full set of temporary badge reports is captured at INL, 

the available population of V&V candidates would likely 

increase markedly. 

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SC&A Evaluation of SEC-00238: Review Item 4 –

Multiple Badging for Multiple Area Policy

 SC&A reviewed a semi-random set of the claimant population comprising 

~25% of the relevant claimant population (115 claims in total).

 Review consisted of examination of a sufficient cross section of job titles and 

time periods to determine if separate dosimetry badges were required for 

separate INL site areas. 

 SC&A Observation 5: With the exception of one job category, 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 (i.e., the energy employee was badged in six 

separate areas at INL during the same time period). 

 SC&A 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. 

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SC&A Evaluation of SEC-00238: Conclusions and Path 

Forward

 Evidence strongly suggests that routine badging records for regular 

CPP employees as well as CPP employees designated as 

construction workers are complete and available (Review Item 1).

 All available temporary/visitor badges have not yet been captured by 

NIOSH; therefore, determinations related to the completeness of 

temporary/visitor badges and potential V&V evaluations are not 

currently feasible (Review Items 2 and 3).

 SC&A’s analysis of a significant portion of the INL claimant population 

concluded that workers were required to obtain area-specific badges 

when moving among the major site locations at INL (Review Item 4).

 August 2018 Work Group Path Forward: NIOSH to perform 

additional data capture at INL to obtain the full set of temporary 

badges for completeness evaluation. SC&A to participate in data 

capture efforts with NIOSH as appropriate.

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Questions?

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