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 

Center For Disease Control and Prevention 

July 8, 2015
Background 

• March 12, 2015: NIOSH releases Petition Evaluation 

Report for SEC-00219, Idaho National Laboratory (INL) 

• March 26, 2015: 

• NIOSH presents the Evaluation Report to the ABRWH 

• SC&A is tasked with evaluating the proposed class 

definition with a focus on available dosimetry records 

at the Chemical Processing Plant (CPP) 

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

class definition 

2 
NIOSH Class Definition 

“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.” 

3 
Rationale for 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. 187)

4 
SC&A Investigative Approach 

1. Assessment of available interviews with 

former workers 

2. Evaluate claimant records to assess the 

dosimetry program in the context of the 

current class definition 

5 
Summary of Interview Assessment 

• 50 Sets of worker interview summaries 

• Interviews conducted by the Board, NIOSH, and SC&A in 

June, September, and November of 2014 

• Not all of the worker interview summaries have been 

finalized 

• Available summaries affirm universal badging of CPP 

personnel entering radiological areas 

• Recommendations: 

• Continue line of inquiry with future interviews and a focus 

on badging policies 

• Evaluate interviews that are not yet available 

6 
Goals of SC&A Claimant Evaluation 

1. Characterize the external dosimetry program for the 

completeness/availability of records 

2. Determine the extent to which “gaps” exist and 

explore potential explanations: 

• Not monitored, but not likely exposed 

• Not monitored, but likely should have been 

• Moved to another location on site or likely not 

employed at INL 

3. Evaluate if the class definition captures all relevant 

workers 

7 
SC&A Approach and Methods 

• Analyze a subset of claimants and relevant 

records/information 

• Available dosimetry records 

• Department of Labor (DOL) case files 

• Computer-Assisted Telephone Interview (CATI) 

• Iterative process used in selection of claimants for 

focused review 

• Sampling is NOT a representative cross-section of the 

claimant population! 

8 
SC&A Approach and Methods (cont.) 

• Initial group of claimants chosen to cover several 

different job types (security, engineers, operators, 

laborers, maintenance, construction, instrument techs, 

HP techs, firemen, etc.) 

• Based on initial assessment, review focused on 

subcontract trades workers with intermittent 

employment 

• 30 total claims characterized (initial group + 

focused group) 

9 
SC&A Approach and Methods (cont.) 

Final Spread of Job Types Among 30 Claims 

10
Available Work Location Information 

• Area Dosimetry “Cycle” Reports (routine monitoring)

• Temporary and/or Visitor Badges 

• Internal Monitoring (in vivo, urinalysis) 

• Incident Reports (generally medical, not radiological) 

• CATI and/or other Interview Statements 

• Location File Cards 

• Master Security File Card 

11
Example: Area Dosimetry Cycle Report 

12
Example: Location File Card 

13
Example: Master Security File Card 

14
Results of 30 Claim Reviews 

• SC&A developed five “categories” of claimants based on 

the available dosimetry: 

• Category 1: No gaps observed in dosimetry records 

• Category 2: Gaps appear to exist, but records are likely 

complete based on “PSN number”

• Category 3: Gaps exist in monitoring records, but no 

evidence of exposure during unmonitored periods identified 

• Category 4: Gaps exist in monitoring records, but there is 

some indication of potential exposure during unmonitored 

periods 

• Category 5: Only annual dosimetry summaries available 

15
Example of Category 1 

16
Example of Category 2 

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Example of Category 3 

18
Notes on Category 3 Example 

• In 1964, there are area dosimetry cycle reports, but no dose 

is recorded and record indicates “not in area”

• External Dosimetry from June 1967–September 1969 is a 

combination of CPP and material test reactor (MTR) areas 

• July 1970 to January 1971, the Energy Employee (EE) worked 

for “H.S. Wright,” but no location information is available

• No bioassay or in vivo samples were submitted during the 

Special Exposure Cohort (SEC) period 

• CATI report with survivor: “specific [work] locations are 

unknown.”

19
Example 1 of Category 4 

20
Notes on Category 4, Example 1 

• Claimant provides a detailed incident description in 

the CATI report (see Section D.4 for details): 

• Type of work performed 

• Specific external doses accrued 

• Actions taken as a result of the incident 

• The exact dates of the incident are unknown 

• Based on available information (available dosimetry, 

bioassay monitoring, employment dates) it is possible 

the incident occurred outside of the available 

badging period 

21
Example 2 of Category 4 

22
Notes on Category 4, Example 2 

• Location file card only indicates employer, not location, during SEC 

• From CATI Report 

• Building/Location: “At CPP, LOFT project, SL-1”

• Frequency of Badge Worn: “Daily”

• Badge Exchange Frequency: “Several times a week”

• “Area of contamination were all over the site... 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 a time.”

• “CPP a lot of years. This was a very contaminated area because of the 

stack emissions. Worked on the calciner project.”

• Location file card indicates a brief assignment (~2 months) to CPP 

in 1978 (no dosimetry badge found) 

23
Category 5 

• No dosimetry cycle reports or temporary/visitor 

badges in NIOSH/OCAS Claims Tracking System (NOCTS) 

• Only annual summary record available (see below) 

24
Category 5 (cont.)

• Without the individual dosimetry reports, it is not 

possible to ascertain where the worker was badged.

• Prompted SC&A to investigate how many claims fit the 

Category 5 criteria:

• SC&A identified 144 Category 5 claims out of 796 claims 

who worked during the SEC period.

• Of those 144 Category 5 claims, 39 had DIRECT 

evidence of assignment to CPP during the SEC (i.e., 

location file card indicates CPP).

• 12 of the 39 were subcontract workers.

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Finding 1

The dosimetry records contained in 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. 

26
Supplemental Records Captured

• Technical Call between NIOSH, SC&A, and the Work 

Group took place on April 22, 2015

• NIOSH informed SC&A that significant additional 

dosimetry records had been captured at INL and 

uploaded to the Site Research Database (SRDB)

• Subsequent to that meeting, NIOSH provided SC&A 

with a listing of SRDB ID numbers to quickly access the 

records

• Uploaded files include over 7,200 pages of CPP-related 

dosimetry files, including Routine Area Cycle Reports 

and Visitor/Temporary Badge reports

27
Supplemental Records Captured (cont.)

• SC&A had identified 39 claimants with insufficient NOCTS 

records AND direct evidence of assignment to CPP.

• 12 of these 39 claims were employed by subcontractors at 

INL.

• SC&A carefully searched the supplemental records for 

these claims.

• SC&A was able to identify “at least one” dosimeter badge 

for these claimants for 36 out of the 39 cases.

• Remaining three cases could not be located in the 

supplemental records.

28
Case 1

• Construction worker and Equipment Operator with 

Arrington Construction

• SEC employment ~1.5 months

• Location File Card indicates “CPP Cx Quarterly” under 

area code; handwritten notation “TF” also likely 

indicates “temporary film”

• The claimant had positive external doses during 1974 

(per the annual summary card)

29
Case 1 (cont.)

• From CATI

• “said he thinks he may have had a badge at one time but then the badges 

were taken away. He does not remember if he wore a dosimeter badge.”

• “[The EE] cleaned up materials that leaked out of the stack... loaded the 

materials into 55 gallon plastic line drums.”

• “it is his understanding that the facility had to bury the backhoe he used to 

clean up materials that leaked from the stack because it was so 

contaminated.”

• “He said there was a trailer that had a monitored [sic] attached to it and a 

man walked around with a Geiger counter as he worked. He does not 

recall how many days the project lasted but it was at least a couple.”

• What precautions were taken to protect you: “Coveralls (he had to change 

into fresh coveralls every two hours”

• “said they walked through some form of arc to be checked for radiation”

30
Case 2

• Claimant worked as a construction laborer for H.S. Wright 

(~5.5 years in SEC period)

• Conflicting Information on Badging Policies

• CATI indicates no badging took place

• DOL Initial Case forms do indicate badging

• Annual summary indicates external monitoring during year when 

Location File Card indicates CPP

• Location File Card indicates “CPP-Cx Quarterly” for the area 

code designation

• From CATI:

• Work Location: “Unknown, 3–4 miles northwest of central”

• “Cleanup work, shovel work, and whatever needed to be done as 

laborer... they were called to do a clean-up at Wrights, just over the 

fence. They were pulled out because they said it was ‘too hot’”

31
Case 3

• Claimant worked as a Heavy Equipment Operator for H.S. Wright 

for five separate periods totaling ~4 years of SEC employment.

• Location file card contains three separate periods of assignment at 

CPP indicating “CPP-Cx Construction” and “CPP-Cx Monthly.”

• Location file card also indicates dual assignment at MTR during 

two of the three periods.

• Claimant registered positive penetrating dose during these two 

periods (per annual exposure summaries). Third period had 

recorded dose of zero.

• CATI report was performed with the survivor.

32
Finding 2

Based on SC&A’s evaluation of recently captured supplemental 

dosimetry records, as well as observed claimants with 

inadequate NOCTS records, it is apparent that the reviewed 

claimants who worked for the Atomic Energy Commission (AEC) 

or the prime contractor and who have direct evidence of work 

at CPP have at least one corresponding dosimeter badge 

associated with CPP to allow for SEC determination. However, 

SC&A could not locate corresponding dosimetry in the 

supplemental records for some claimants who worked as 

subcontractor trades workers and who have direct evidence of 

being assigned to CPP. Thus, SC&A was unable to validate the 

SEC class definition as proposed by NIOSH.

33
SC&A Summary Conclusions

• It is SC&A’s opinion that the probability of incorrect 

exclusion of AEC and/or prime contract employees from 

the SEC based on the absence of dosimetry records is low.

• SC&A was unable to locate supplementary dosimetry 

records for 3 of the 12 subcontract workers who were 

identified as having insufficient NOCTS records and direct 

evidence of assignment to the CPP. This suggests a 

problem with how construction trades workers were 

badged and/or how their company records were retained.

34
SC&A Recommendations

• To the extent feasible, determine whether reasonable 

evidence exists to mitigate the missing dosimetry record(s) 

for the identified subcontract claims and other potential 

affected claimants.

• Instructive to conduct focused interviews with intermittent 

or transient subcontractors and trades workers to assure 

that the badging of individuals entering relevant areas was 

universal.

• Ascertain what subcontractors supported radiological work 

activities at CPP, and potentially obtain rosters of workers 

who were involved in such activities.

35