Draft

SC&A EVALUATION OF IDAHO CHEMICAL PROCESSING 

PLANT CLASS DEFINITION REQUIRING EVIDENCE OF 

EXTERNAL DOSIMETRY (1963–1974) 

Contract Number 211-2014-58081

Revision 1 

Prepared by 

Bob Barton 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

July 2015 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Effective Date:

July 15, 2015

Revision No.:

1 (Draft)

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Evaluation of CPP Class Definition

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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

Document No.: 

S. COHEN & ASSOCIATES: Evaluation of CPP Class Definition 

Technical Support for the Advisory Board on Effective Date: 

Radiation & Worker Health Review of Draft – July 15, 2015

NIOSH Dose Reconstruction Program Revision No. 

01 (Draft) 

SC&A Evaluation of Idaho Chemical Processing 

Plant Class Definition Requiring Evidence of Page 2 of 7

External Dosimetry (1963–1974)

Task Manager: Supersedes: 

__________________________Date:____________ Rev, 0 

John Stiver, MS, CHP 

Project Manager: Reviewer(s):

 John Mauro

__________________________Date:____________ Joseph Fitzgerald 

John Stiver, MS, CHP John Stiver 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 06/29/2015 Initial issue

1 (Draft) 07/15/2015 Report has been revised to reflect new information on recently discovered 

supplemental dosimetry records for the Chemical Processing Plant and the revised 

class definition as presented by NIOSH on July 8, 2015.

The Executive Summary for this report has been reviewed for compliance with the Privacy Act 

of 1974 (42 U.S.C. § 7348n(3)(A)) and has been cleared for distribution. However, the body of 

this report is predominantly information protected by the Privacy Act, and therefore not readily 

available for proactive release. Individuals may obtain this document by submitting a document 

request to the Designated Federal Official for the Advisory Board on Radiation and Worker 

Health:

Theodore Katz, Designated Federal Officer, NIOSH, CDC, 1600 Clifton Road, N.E., MS E-20, 

Atlanta, Georgia 30333, telephone: (513)533-6800, toll free: 1-800-CDC-INFO, e-mail:

dcas@cdc.gov.
Effective Date:

July 15, 2015

Revision No.:

1 (Draft)

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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

TABLE OF CONTENTS 

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

Executive Summary .........................................................................................................................5
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ACRONYMS AND ABBREVIATIONS 

ABRWH Advisory Board on Radiation and Worker Health 

or Advisory Board 

AEC Atomic Energy Commission 

CDC Centers for Disease Control and Prevention 

CFA Central Facility Area 

CFR Code of Federal Regulations

CPP Chemical Processing Plant 

DCAS Division of Compensation Analysis and Support (formerly Office of 

Compensation Analysis and Support (OCAS) 

DFO Designated Federal Officer 

INL Idaho National Laboratory 

MTR Material Test Reactor 

NIOSH National Institute for Occupational Safety and Health 

NOCTS NIOSH OCAS Claims Tracking System 

SC&A S. Cohen & Associates (SC&A, Inc.) 

SEC special exposure cohort 

TLD thermoluminescent dosimeter 
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

EXECUTIVE SUMMARY 

The National Institute for Occupational Safety and Health (NIOSH) released the Special 

Exposure Cohort (SEC) Petition Evaluation Report for SEC-000219 for the Idaho National 

Laboratory (INL) on March 12, 2015. On March 25, 2015, NIOSH/Division of Compensation 

Analysis and Support (DCAS) presented the Petition Evaluation Report at the 104th meeting of 

the Advisory Board on Radiation and Worker Health, which took place in Richland, Washington. 

NIOSH recommended the following class definition of workers for inclusion to the SEC class: 

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

contractors and subcontractors who worked at Idaho National Laboratory in 

Scoville, Idaho, and 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 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 2015a)

At that time, the Advisory Board expressed concern as to the high level of confidence that is 

required to assure that class definition would not inadvertently exclude claimants who may have 

been exposed at the Chemical Processing Plant (CPP), but for whom dosimetry records are not 

available (see ABRWH 2015, pp. 187–210). SC&A was then tasked by the Advisory Board to 

investigate available dosimetry records in order to assess the validity of the class definition, as 

proposed by NIOSH. SC&A released their review of the class definition on June 29 (SC&A 

2015) and presented their findings to the Work Group on July 8, 2015. At that meeting, NIOSH 

revised their proposed class definition as follows: 

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 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 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 2015b) 

Additionally, NIOSH presented new information recently obtained from the Department of 

Energy (DOE) regarding dosimetry records at the CPP, which had recently been discovered. 

These records represent a significant increase in the available monitoring data for CPP workers 

and affected revisions in the Finding 2 from Rev. 0; however, at the July 8, 2015, INL Work 

Group meeting, NIOSH indicated that it does not expect to receive the full data set for several 

weeks. Thus, this report is an interim update to Rev. 0, which was delivered to the Work Group 
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

on June 29, 2015, and is prepared principally to inform the Advisory Board at the July 23, 2015, 

meeting in Idaho Falls, Idaho. It presents an update to SC&A’s original evaluation (SC&A 

2015) of the available records in the context of the requirements of the SEC class definition. 

After the new data are available and SC&A has reviewed them, we will prepare a final revision 

(Rev. 2) to this report. 

Based on our original review and our assessment of the new data that NIOSH presented at the 

July 8, 2015, Work Group meeting, SC&A has the following two findings and one observation. 

Finding 1: The dosimetry records contained in the NIOSH/OCAS Claims Tracking System 

(NOCTS) are not sufficient to accurately determine if a given claimant worked at the CPP (and 

thus qualifies for the SEC) for at least some workers, due to the absence of external dosimetry 

records designating the area worked. 

Finding 2: Based on the evaluation of available claimant records, a portion of the 

supplementary dosimetry records, and claimant-specific dosimetry recently provided by DOE, 

SC&A was able to find “at least one” dosimetry badge for all claimants reviewed who had direct 

evidence of work at the CPP. However, SC&A is not able to evaluate the completeness of the 

full set of supplemental records until such a time as all CPP-related external monitoring (January 

1, 1963–February 28, 1970) and INL external monitoring (March 1, 1970–December 31, 1974) 

is provided to NIOSH and the Board. 

Observation 1: SC&A did not find any evidence that work locations provided in available area 

dosimetry cycle reports were contradicted by other work location-specific information contained 

in the claimant records. In nearly every instance, the areas specified in the dosimetry records 

comported perfectly with alternate information. The only exceptions were for two sampled 

claimants who submitted bioassay results that indicated “CFA,” while the dosimeter results 

indicated “MTR” (see Appendix C: C.6 and C.11).

SC&A Recommendation: It is SC&A’s opinion that the probability of a claimant being 

excluded from the SEC class based on absence of dosimetry records when, in fact, they worked 

in CPP is low. This is particularly true for Atomic Energy Commission (AEC) and prime 

contractor employees. However, the complete set of dosimetry records for subcontract and/or 

construction trades workers has not yet been received from INL. An evaluation of the 

completeness of these supplemental dosimetry records would appear to be warranted when they 

become available. 

SC&A believes that it would be instructive to conduct focused interviews with intermittent or 

transient subcontractors and trades workers to help determine if the policy of badging individuals 

entering relevant areas was universal for all workers and periods. Additionally, it would be 

pertinent to ascertain what subcontractors supported radiological work activities at CPP 

(company identity and rosters) as a basis for whatever class definition is defined for the SEC. 

Finally, it will be important to validate the DOE records search process through appropriate 

focused searches of CPP workers who appear to be lacking primary and supplemental records in 
Effective Date:

July 15, 2015

Revision No.:

1 (Draft)

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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

the current dataset. This will help assure that all relevant claimants are correctly identified 

should the full set of dosimetry records be deemed complete.

The Executive Summary for this report has been reviewed for compliance with the Privacy Act 

of 1974 (42 U.S.C. § 7348n(3)(A)) and has been cleared for distribution. However, the body of 

this report is predominantly information protected by the Privacy Act, and therefore not readily 

available for proactive release. Individuals may obtain this document by submitting a document 

request to the Designated Federal Official for the Advisory Board on Radiation and Worker 

Health:

Theodore Katz, Designated Federal Officer, NIOSH, CDC, 1600 Clifton Road, N.E., MS E-20, 

Atlanta, Georgia 30333, telephone: (513)533-6800, toll free: 1-800-CDC-INFO, e-mail:

dcas@cdc.gov.