SC&A Evaluation of CPP Class 

Definition Requiring Evidence of 

External Dosimetry (1963–1974) 

Bob Barton, Health Physicist

S. Cohen and Associates

Contractor to:

Advisory Board on Radiation and Worker Health/ABRWH

Centers For Disease Control and Prevention

November 10, 2015
Background Reports and Documents

• March 12, 2015: NIOSH releases the Petition Evaluation 

Report (PER) for SEC-00219 Rev. 00, Idaho National Laboratory 

(INL) 

• June 29, 2015: SC&A releases it’s review and evaluation of the 

CPP SEC class definition

• July 21, 2015: NIOSH releases PER for SEC-00219 Rev. 01, INL

• August 21, 2015: NIOSH provides an update with supporting 

information for SEC-00219 Rev. 01 per Advisory Board 

Instruction 

• September 28, 2015: SC&A releases it’s revised review of the 

CPP SEC class definition

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Timeline of SEC Class Definition 

Discussions 

• INL Work Group Discussions

• April 22, 2015 – Clarification and Technical 

Teleconference between the Work Group, NIOSH and 

SC&A (not open to the public)

• July 8, 2015 – Work Group Teleconference 

• November 10, 2015 – Work Group Meeting 

• Advisory Board Discussions

• March 26, 2015 – ABRWH Meeting 104 in Richland, WA

• July 23, 2015 – ABRWH Meeting 105 in Idaho Falls, ID

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Currently Proposed SEC 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 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.”

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Rationale for Original SEC Class 

• Contamination control program was deemed 

ineffective

• Bioassay program was incident-based

• In-vivo program deemed inadequate to detect 

chronic low-level alpha/beta exposures

• Insufficient available air monitoring data

• “The potential for exposures to transuranics that had 

been separated from the mixed fission products 

makes it unlikely that exposures to alpha-emitters can 

be reconstructed from January 1963 through 

December 1974.” (SEC ER, pg. 188)

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Rationale for Revision 01 of Class Definition

• Revision 00 of the SEC Class definition assumed a 

“one badge, one area” dosimetry program at INL

• When a worker leaves one INL area to go to a second 

area, the badge was left in the original area and a new 

badge was issued for the new area

• Any entrance to CPP would have a CPP-specific badge

• Additional documentation indicates a shift to a “one 

badge, multiple area” dosimetry program at INL

• Workers only issued one badge for entire site

• Entrance to CPP possible without CPP-specific badge

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Rationale for Revision 01 (cont.)

• Shift to “one badge, multiple areas” appears to have 

occurred on March 1, 1970

• Shift back to “one badge, one area” in December 1974

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SC&A Revision 01 Evaluation Approach

Purpose/Goal: Evaluate if the revised SEC Class definition 

may unintentionally exclude workers from the SEC Class 

due to current dosimetry requirements.

1. Review all currently available claimants with at least 250 Days 

of covered employment 

• Split original SEC period into two components based on 

dosimetry requirements

• Identify claimants that did not meet dosimetry 

requirements in one or both SEC periods for further 

investigation

2. Investigate claimants who did not meet SEC dosimetry 

requirements to determine the potential for internal exposure 

to alpha-emitting contaminants at CPP

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Overview of Claimant Population (both 

periods) 

• At the time of its review, SC&A identified 898 total 

claimants with covered employment who worked 

in one or both portions of the SEC period.

• 107 claims did not meet the 250-day criteria in either 

the SEC period or the two periods combined (note: 

SC&A still evaluated 61 of these claims).

• 19 claims appear to only have worked at ANL-W and/or 

NRF (i.e. – no evidence of work at INL). 5 of these 

claims also did not have 250 days of employment.

• 2 claims did not have DOE monitoring records, because 

the claims were filed too recently

• 1 claim had been withdrawn prior to receiving DOE 

monitoring records.

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Breakdown by SEC Period: Later Period

(3/1/1970 – 12/31/1974) 

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Later Period (continued)

(3/1/1970 – 12/31/1974) 

SC&A had three observations based on it’s review of 

claimants in the latter portion of the SEC period:

• Observation 1: While the class definition provides the 

example of “at least one film badge or TLD dosimeter,” 

SC&A has assumed that any evidence of monitoring 

during the latter SEC period (3/1/1970–12/31/1974) 

will satisfy the intended criteria.

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Later Period (continued) 

(3/1/1970 – 12/31/1974) 

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Later Period (continued) 

(3/1/1970 – 12/31/1974) 

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Later Period (continued)

(3/1/1970 – 12/31/1974) 

• Observation 2: SC&A identified a single claim that 

contained in-vivo dosimetry related to CPP, but did not 

have related external dosimetry. It is recommended 

that this claim be included with the claims requiring 

additional data capture at INL. 

• Observation 3: Clarification is warranted to establish 

how “temporary” and/or “visitor badges” are utilized in 

the implementation of the class definition during the 

later SEC period (3/1/1970–12/31/1974).

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Breakdown by SEC Period: Earlier Period

(1/1/1963 – 2/28/1970) 

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Earlier Period (continued)

(1/1/1963 – 2/28/1970) 

SC&A had one additional observation related to the 

earlier SEC period:

• Observation 4: Absent additional information to the 

contrary, dosimetry associated with “CADRE” should be 

considered CPP for the purposes of determining SEC 

eligibility. Similar to the CPP dosimetry records, it is 

important to establish that “CADRE” badging records 

have all been captured from INL.

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Earlier Period (continued)

(1/1/1963 – 2/28/1970) 

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NIOSH Cases Identified for Further 

Evaluation with DOE/INL

• NIOSH’s August 21, 2015 Work Group update identified 

10 claims that required follow-up inquiries with INL

• SC&A observed the following rationale for selection of 

these 10 claims (Observation 5):

• Direct evidence of assignment to CPP, such as an entry 

in the Energy Employee’s Location File Card indicating 

assignment to that area

• Anecdotal evidence, such as Computer-Assisted 

Telephone Interview (CATI) statements or information 

contained in the initial DOL application/case file

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Example NIOSH Cases Identified for 

Further Evaluation

• Trades Worker

• External monitoring ends in 1962

• CATI lists CPP as one of five work locations at INL

• Describes incident at CPP in “1963–1966” timeframe

• Radioecologist

• Only career doses available

• Location File Card lists CPP in later SEC period

• CATI with survivor notes “worked all over site”

• Engineer

• Location File Card does not indicate CPP

• Internal and external monitoring at other INL locations

• DOL Initial Case lists ICPP as a work area

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SC&A Cases Recommended for Further 

Evaluation with DOE/INL

• Based on its independent review of the claimant 

population, SC&A identified 23 additional cases 

requiring follow-up

• 2 of 23 were also identified by NIOSH

• 10 of 23 were located in the CPP hardcopy records 

(Routine, Temporary, and Construction Badges)

• Remaining 11 of 23 recommended for follow-up with 

DOE/INL (Observation 6)

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Example SC&A Cases Recommended for 

Further Evaluation

• Trades Worker

• No external monitoring available until 1975

• EE states that badging was intermittent

• CATI describes incident at CPP in “early 1970’s”

• Driver 

• Location File Card and external monitoring for locations other 

than CPP

• In Vivo questionnaire from 1967 indicates previous work area as 

“CPP for 18 months”

• Trades Worker

• In Vivo result for CPP in later SEC period

• External dosimetry ends in 1960

• Energy Employee does NOT have 250 days in the later SEC period

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Summary 

• Several Observations related to clarification of 

the SEC class definition:

• Use of annual/career records as well as other 

records, such as in-vivo results in place of individual 

dosimeters (later SEC period)

• Use of temporary and/or visitor badges

• A combined 21 claims were identified by 

NIOSH and SC&A for further investigation to 

validate the class definition

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Comments and Questions?

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