Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

A FOCUSED REVIEW OF THE NIOSH SEC-00235 PETITION 

EVALUATION REPORT FOR SANTA SUSANA FIELD 

LABORATORY AREA IV

Contract No. 211-2014-58081 

SCA-TR-2017-SEC011, Revision 0 

Prepared by

Douglas Farver, CHP 

Robert Barton, CHP 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, Virginia, 22201 

November 2017 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

A Focused Review of the NIOSH SEC-00235 Petition Evaluation 

Report for Santa Susana Field Laboratory Area IV

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2017-SEC011 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: November 21, 2017

TASK MANAGER: John Stiver, MS, CHP [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S): John Stiver, MS, CHP [signature on file] 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision 

0 (Draft) 11/21/2017 Initial issue
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TABLE OF CONTENTS

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

1.0 Background and Statement of Purpose ............................................................................... 5

2.0 Description of Santa Susana Field Laboratory Area IV Facilities and Operations............ 6

3.0 Overview of Previous SSFL SEC Petitons and NIOSH’s Evaluation Report for 

SEC-00235 .......................................................................................................................... 7

3.1 Previous Petitions.................................................................................................... 7

3.2 SEC-00235 Petition Evaluation Report .................................................................. 7

3.3 NIOSH Responses to Major Issues Raised in SEC-00235 ..................................... 8

3.3.1 Issue 1: General Covered Employment Status............................................ 8

3.3.2 Issue 2: Area IV of the SSFL Site Profile Concerns ................................... 8

3.3.3 Issue 3: Radiological Incidents ................................................................... 9

3.3.4 Issue 4: Employment Records ..................................................................... 9

3.3.5 Issue 5: Lack of Monitoring ...................................................................... 10

3.3.6 Issue 6: Falsified Documents or Statements ............................................. 10

3.4 SC&A Comments ................................................................................................. 11

4.0 Summary of Dosimetry Data at Santa Susana Field Laboratory Area IV ........................ 12

4.1 Review of External Dosimetry Data ..................................................................... 12

4.1.1 Monitored Workers ................................................................................... 12

4.1.2 Unmonitored Workers ............................................................................... 12

4.1.3 Ambient Environmental External Dose .................................................... 12

4.1.4 Occupational Medical Data ....................................................................... 13

4.1.5 External Dose Reconstruction Feasibility ................................................. 13

4.2 Review of Internal Dosimetry Data at Santa Susana Field Laboratory Area IV .. 13

4.2.1 Air Monitoring Data .................................................................................. 13

4.2.2 Bounding Internal Dose to Unmonitored Workers ................................... 14

4.2.3 Internal Dose Reconstruction Feasibility .................................................. 15

5.0 Summary of Findings ........................................................................................................ 17

6.0 References ......................................................................................................................... 19

Attachment A: SEC Petition 00235 Documents ........................................................................... 22

Attachment B: Overview of Claimant Population........................................................................ 26
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ABBREVIATIONS AND ACRONYMS

Advisory Board or 

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission

CATI computer-assisted telephone interview

CEP Controls for Environmental Pollution

D&D decontamination and decommissioning 

DEEOIC Division of Energy Employees Occupational Illness Compensation 

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

DR dose reconstruction 

EE energy employee

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 

2000 

ER evaluation report 

ETEC Energy Technology Engineering Center 

HHS U.S. Department of Health and Human Services 

LMEC Liquid Metal Engineering Center

MFP mixed fission products 

mrem millirem

NAA North American Aviation

NIOSH National Institute for Occupational Safety and Health

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT technical information bulletin

SEC Special Exposure Cohort 

SNAP Systems for Nuclear Auxiliary Power

SRDB Site Research Database

SRE Sodium Reactor Experiment 

SSFL Santa Susana Field Laboratory
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1.0 BACKGROUND AND STATEMENT OF PURPOSE

On August 9, 2016, the National Institute for Occupational Safety and Health (NIOSH) received 

Special Exposure Cohort (SEC) petition SEC-00235 for workers at the Santa Susana Field 

Laboratory (SSFL) facility. NIOSH qualified the petition on February 1, 2017. The petition 

requested that NIOSH consider the following class: “All employees of North American Aviation, 

to include corporate successors and subcontractors who worked at Area IV of the Santa Susana 

Field Laboratory (SSFL) from December 31, 1964 through the present.” 

The petitioner-requested class included a portion of the class previously evaluated by NIOSH for 

SEC-00234 (NIOSH 2016). Therefore, NIOSH’s qualification assessment considered only the 

period that was not already evaluated: the period from January 1, 1989, through the present.

The petitioner provided information in support of the belief that accurate dose reconstruction 

over time is impossible for the Area IV employees in question. NIOSH concluded that there is 

insufficient documentation to support the petitioner’s assertion that radiation exposures and 

radiation doses were not adequately monitored, either through personal monitoring or area 

monitoring, for the time period as evaluated (1989–present). From August 1991 through 

June 1993, however, bioassay and environmental samples were analyzed by Controls for 

Environmental Pollution (CEP). NIOSH does not accept CEP as a quality supplier of dosimetry 

information and has not used the dosimetry information provided by CEP for dose reconstruction 

of any claims related to this or other sites. NIOSH considers bioassay results from CEP as lost, 

falsified, or destroyed, which is a basis to qualify the petition for evaluation. 

Based on research and data capture efforts related to Area IV of SSFL, NIOSH concluded that it 

has access to bioassay data, external monitoring records, radiological monitoring methods and 

procedures, environmental monitoring reports, and facility characterization records for Area IV 

employees during the period requested by the petitioner. However, NIOSH needed to evaluate if 

the rejection of the CEP data would affect NIOSH’s ability to perform sufficiently accurate dose 

reconstructions. 

NIOSH therefore changed the petitioner-requested class to include only the period during which 

the site contracted CEP as a primary vendor for bioassay sample analysis. NIOSH evaluated the 

following class: “All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at Area IV of the Santa Susana Field Laboratory in 

Ventura County, California, from August 1, 1991 through June 30, 1993.” 

On August 15, 2017, NIOSH presented the results of its SEC-00235 petition evaluation report 

(ER) (NIOSH 2017) at the meeting of the Advisory Board on Radiation and Worker Health 

(hereafter referred to as the “Advisory Board”). After discussion by the Advisory Board, SC&A 

was tasked to review the SEC-00235 petition ER and available documentation, focusing on 

NIOSH’s position that the lack of CEP in vitro data from 1991 to 1993 does not affect NIOSH’s 

ability to perform sufficiently accurate internal dose reconstructions for monitored or 

unmonitored workers. 
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2.0 DESCRIPTION OF SANTA SUSANA FIELD LABORATORY

AREA IV FACILITIES AND OPERATIONS

SSFL is located approximately 30 miles northwest of downtown Los Angeles, California. SSFL 

consists of 2,850 acres in the Simi Hills of Ventura County and is divided into four 

administrative and operational portions based on ownership and operations. U.S. Department of 

Energy (DOE) operations are conducted in Rockwell International-owned and DOE-owned 

facilities in an area designated as Area IV. SSFL was initially established by North American 

Aviation in 1947 as a field test laboratory to static-fire rocket engines. In 1953, Area IV was 

established as a nuclear research and development facility; management by Atomic International 

started in 1955. Atomic International conducted activities in Area IV on development of civilian 

nuclear power and the Liquid Metal Engineering Center (LMEC), which focused on research and 

testing of non-nuclear components to liquid metals. LMEC was renamed the Energy Technology 

Engineering Center (ETEC) in 1978. Through various mergers, SSFL is now managed by 

Boeing.

Between 1954 and 1980, several small nuclear reactors and critical test assemblies were built, 

tested, and operated in Area IV. These research facilities focused on development and operation 

of homogeneous water boiler-type reactors, sodium-cooled graphite-moderated reactors, and 

uranium-zirconium hydride reactors. Starting in 1956 and continuing through 1996, operations 

also supported the manufacture, management, and disassembly of nuclear reactor fuel, as well as 

the operation of nuclear waste management facilities. Fuel manufacturing included the assembly 

of fuel elements for the Sodium Reactor Experiment (SRE), a plutonium fuel manufacturing 

facility, and a uranium carbide fuel pilot plant. 

Most of the nuclear research programs and operations ceased in 1988, and all non-nuclear 

research ended in 1998. However, some support operations, including the Fuel Storage Facility 

and the Radiation Instrument Calibration Laboratory, did not cease until 1996. Beginning in the 

1990s, Area IV activities focused on decontamination and decommissioning (D&D) and 

remediation.
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3.0 OVERVIEW OF PREVIOUS SSFL SEC PETITONS AND NIOSH’S 

EVALUATION REPORT FOR SEC-00235

3.1 PREVIOUS PETITIONS

NIOSH previously evaluated three other petitions for SSFL Area IV. In the petition ER for 

Petition SEC-00093 (NIOSH 2009a), NIOSH determined that it could not estimate internal 

radiation doses with sufficient accuracy for the period from January 1, 1955, through 

December 31, 1958, for employees at SSFL Area IV. NIOSH’s decision was based primarily on 

a lack of internal monitoring data for potentially exposed individuals from January 1, 1955, 

through December 31, 1958. NIOSH also determined that it could reconstruct external dose, 

including occupational medical dose, for the period from January 1, 1955, through December 31, 

1958. In June 2009, the U.S. Department of Health and Human Services (HHS) issued a letter 

designating the January 1, 1955, through December 31, 1958, period for inclusion in the SEC 

(HHS 2009). In October 2009, SC&A issued SCA-SEC-TASK5-0066, Review of the Santa 

Susana Field Laboratory (SSFL) Area IV Special Exposure Cohort (SEC) Petition-00093 and the 

NIOSH SEC Petition Evaluation Report (SC&A 2009). 

In its petition ER for Petition SEC-00156 (NIOSH 2010a), NIOSH determined that it could not 

reconstruct internal radiation doses with sufficient accuracy for the period from January 1, 1959, 

through December 31, 1964, for employees at SSFL Area IV. NIOSH’s decision was based 

primarily on incomplete bioassay, air monitoring, or process and radiological source data from 

January 1, 1959, through December 31, 1964. NIOSH also determined that it could reconstruct 

external dose, including occupational medical dose, for the period from January 1, 1959, through 

December 31, 1964. In April 2010, HHS issued a letter designating the January 1, 1959, through 

December 31, 1964, period for inclusion in the SEC (HHS 2010). 

In its petition ER for Petition SEC-00234 (NIOSH 2016), NIOSH determined that it could not 

reconstruct internal radiation doses with sufficient accuracy for the period from January 1, 1965, 

through December 31, 1988, for employees at SSFL Area IV. NIOSH’s decision was based 

primarily on insufficient internal dosimetry data or air monitoring data available to bound intakes 

of thorium and americium, including their associated progeny, for the period from January 1, 

1965, through December 31, 1988. Consistent with prior determinations, NIOSH also 

determined that it could reconstruct external dose, including occupational medical dose, for the 

period from January 1, 1965, through December 31, 1988. In January 2017, HHS issued a letter 

designating the January 1, 1965, through December 31, 1988, period for inclusion in the SEC 

(HHS 2017). 

3.2 SEC-00235 PETITION EVALUATION REPORT

Although NIOSH has disqualified Area IV in vitro data analyzed by CEP during the period 

August 1991 through June 1993, NIOSH has determined that the lack of CEP in vitro data has 

not affected NIOSH’s ability to perform sufficiently accurate internal dose reconstructions for 

monitored or unmonitored workers. The NIOSH determination is based on the following. 

NIOSH has compared remediation period bioassay data to the operational period data (through 

1988) used to develop the intake rates of ORAUT-OTIB-0080, Revision 00, Internal Coworker 
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Dosimetry Data for Area IV of the Santa Susana Field Laboratory and the De Soto Avenue 

Facility (NIOSH 2014). NIOSH believes the ORAUT-OTIB-0080 intake rates assigned for the 

end of the Area IV operation period (circa 1988) bound the potential remediation period 

exposures for unmonitored workers. 

NIOSH examined the D&D and waste handling operations throughout the remediation period 

(1989–present) to evaluate the exposure conditions before, during, and after the CEP period 

being evaluated in this report. NIOSH’s review indicates that work remained consistent as to 

procedures, personnel protection equipment, and exposure risks. NIOSH has found no major 

radiological project that occurred in the CEP period 1991–1993 that would not have had 

workplace and/or personnel monitoring performed outside the CEP-related period. 

During the August 1991 through June 1993 period with disqualified CEP bioassay results, the 

site was performing routine in vivo whole-body scans for fission products with a different 

contractor, Helgeson Scientific Services (Helgeson 1993). The site reported that the whole-body 

scans showed no measurable exposures (Rockwell 1994). 

3.3 NIOSH RESPONSES TO MAJOR ISSUES RAISED IN SEC-00235 

3.3.1 Issue 1: General Covered Employment Status

The petitioner claimed that the employee’s job location at SSFL cannot be reliably or accurately 

determined for all DOE contracted employees. As such, NIOSH cannot rule out Area IV 

employment among employees of North American Aviation, its divisions, its corporate 

successors, or its subcontractors. 

NIOSH (2017) stated that it does not determine the eligibility for covered employment. NIOSH 

also stated: 

Additionally, worker eligibility by worksite or location at a covered facility is not 

an SEC determining basis. Petitions are qualified for evaluation for inclusion into 

the SEC based on circumstances related to an entire class of employees that 

prevent accurate reconstruction of potential radiation exposure for that class of 

workers. [page 47]

3.3.2 Issue 2: Area IV of the SSFL Site Profile Concerns

The petitioner claimed that the 2006 SSFL site profile lacks information pertinent to additional 

radiological facilities within Area IV and outside Area IV.

NIOSH reviewed the documentation provided by the petitioner and will evaluate the need to 

update the site profile. In the petition ER, NIOSH stated: 

Site profile documents are general working documents that provide guidance 

concerning the preparation of dose reconstructions at particular sites or 

categories of sites. Much of the information provided as additions to the 2006 site 

profile is informational but does not directly support more accurate dose 

reconstruction. Information on broad scope incidents likely to be relevant to dose 
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reconstruction across the site population is generally included in the site profile, 

although smaller-scale incidents are not included in the site profile. When the 

EEOICPA program makes a request for an individual’s dosimetry records for the 

purposes of dose reconstruction, the request includes any incident reports 

involving that individual. Such incident reports become part of the file and the 

specifics of the incident are considered in reconstructing the radiation dose. 

NIOSH routinely evaluates the need to update the site profile and will include 

information provided in this petition package, relevant to performing dose 

reconstructions, during the next update cycle. 

3.3.3 Issue 3: Radiological Incidents 

The petitioner claimed that Boeing’s Incident database contains many incident reports where

workers either not assigned to a radiological location, or not equipped with appropriate radiation 

protection, were involved in an exposure incident. The petitioner further claimed that the 

workers were unauthorized subcontractor employees who had access to radiological locations 

and radioactive materials.

NIOSH reviewed the Incident database and did not find evidence of routine radiological 

processes at non-radiological facilities or incident summaries indicating that “unauthorized 

subcontractor employees” had access to radiological locations and radioactive materials. 

NIOSH stated in the petition ER (page 48): 

NIOSH reviewed the incident summary listing and located a total of 56 incidents 

(once instances of natural radon deposition, procedural violation with no 

potential for exposure, and incidents at non-Area IV locations were screened out) 

for assessment during the period being evaluated. The Area IV facilities in the 

incident summary listing are all known radiological facilities, with the exception 

of a loading dock where a carbon-14 source was improperly controlled. These 

radiological facilities include buildings containing reactors, critical test facilities, 

the Hot Laboratory, the Radioactive Materials Handling Facility, the Fuel 

Storage Facility, the Calibration Laboratory, and the Uranium Carbide Fuel 

Manufacturing Pilot Plant. 

NIOSH also reviewed a Building 4066 incident from October 1966, which the petitioner

provided as an example of a non-radiological location being used for radioactive processes and a 

non-nuclear and unmonitored worker associated with the location and potentially present in 

proximity to radiological materials. NIOSH concluded that the example does not include 

radiological processes, but rather a failure of procedure, allowing an internally contaminated 

piece of equipment to be brought for maintenance without proper assessment and radiological 

controls. 

3.3.4 Issue 4: Employment Records

The petition describes an incident from 1966 as an example of the contractor withholding worker 

records based on the worker being “unmonitored” and presumably not a designated radiation 
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worker. The petitioner further asserted that exposure locations of monitored workers cannot be 

determined because of the loss of the translation key for the building codes used on the visitor 

logs. Commentary from Boeing to the Advisory Board (Boeing 2014) includes discussion of 

employment records for 8,400 employees that contained radiation records that were “blank.” 

NIOSH responded in the petition ER that the administrative policies of Rocketdyne created these 

8,400 empty radiation records. Until the late 1970s, the site policy was to prepare a radiation 

exposure record folder with employee identification information for every new employee in 

anticipation of job conditions that would require a worker to be monitored for radiation 

exposure. This created 14,200 worker radiation dose folders (Lang 1960; Atomics International 

1960, PDF p. 4), of which 5,800 were for monitored radiation workers. The remaining 8,400 

so-called “blank” records were unmonitored non-radiation workers. These records do not 

indicate unmonitored radiation exposure. 

3.3.5 Issue 5: Lack of Monitoring

The petitioner asserted that radiation exposures and radiation doses potentially incurred by 

members of the proposed class that relate to this petition were not monitored, either through 

personal monitoring or through area monitoring. Multiple documents were provided to support 

this claim in support of the F.1 basis. 

NIOSH reviewed all of the documentation and found there was insufficient evidence to support 

the claim of lack of monitoring for Area IV workers. In addition, NIOSH stated that it has access 

to personal monitoring data, work area and breathing zone air monitoring data, contamination 

and radiation survey reports, and bioassay data for Area IV workers, including examples 

throughout the period evaluated, August 1991 through June 1993. 

3.3.6 Issue 6: Falsified Documents or Statements

The petitioner claimed that radiation-monitoring records for members of the proposed class have 

been lost, falsified, or destroyed, and that there is no information about monitoring, source, 

source term, or process from the site where the employees worked. The petitioner attached 

documents to support the claim. 

NIOSH did not find any of the petitioner-supplied documents or information to support the basis 

that monitoring records at SSFL were lost, falsified, or destroyed for the period after 1988. 

However, as noted in Section 1.0, NIOSH considers the bioassay data processed by CEP from 

1991 to 1993 to be unreliable unless the results are also verified. NIOSH qualified the petition 

for evaluation under the basis of lost, falsified, or destroyed dosimeter data due to the site’s use 

of CEP as a contractor providing internal dosimeter data for the period August 1991 to 

June 1993. 
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3.4 SC&A COMMENTS

SC&A reviewed the SEC-00235 petition and NIOSH’s SEC-00235 petition ER. The SEC-00235 

petition included approximately 50 documents submitted by the petitioner, listed in Attachment 

A to this report. 

NIOSH qualified the petition on February 1, 2017, and completed the petition ER on May 11, 

2017. 
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4.0 SUMMARY OF DOSIMETRY DATA AT SANTA SUSANA FIELD 

LABORATORY AREA IV 

4.1 REVIEW OF EXTERNAL DOSIMETRY DATA

4.1.1 Monitored Workers

NIOSH has access to photon, beta, and neutron external dosimetry results, as well as other 

supporting data for the entire period evaluated in this report (available for all years of site 

operation). The policy at SSFL was to assign the applicable dosimetry to anyone with the 

potential for photon, beta, or neutron exposure. Dosimetry was assigned based on job 

assignments that required exposure to radioactive materials (NIOSH 2010b). Summaries of the 

available external monitoring data can be found in the NIOSH petition ER for Petition SEC00093 (NIOSH 2009a). Details about the various analyses used, and the associated minimum 

detectable activities, are presented in ORAUT-TKBS-0038-6, Revision 02, Area IV of the Santa 

Susana Field Laboratory, the Canoga Avenue Facility, the Downey Facility, and the De Soto 

Avenue Facility (sometimes referred to as Energy Technology Engineering Center [ETEC] or 

Atomics International) (NIOSH 2010b). 

The NIOSH external dosimetry database for Area IV of the SSFL contains dosimetry data for

penetrating dose, including gamma and fast neutron dose. 

4.1.2 Unmonitored Workers

Through the course of ongoing dose reconstruction efforts and investigations associated with 

both SEC-00093 and SEC-00156, NIOSH determined that although external monitoring data are 

available for most employees at Area IV, some employees could have received external radiation 

exposures that went unmonitored. To assess potential external dose to unmonitored employees, 

NIOSH developed a coworker dose distribution model, ORAUT-OTIB-0077, Revision 00, 

External Coworker Dosimetry Data for Area IV of the Santa Susana Field Laboratory, the 

Canoga Avenue Facility (Vanowen Building, and the De Soto Avenue Facility (sometimes 

referred to as Energy Technology Engineering Center [ETEC] or Atomics International)

(NIOSH 2009b). This current evaluation of the SEC-00235 petition ER, dealing with the 

disqualification of internal bioassay data, has identified no concerns with the external coworker 

dose distribution models of ORAUT-OTIB-0077. 

In March 2010, SC&A conducted a review of the external dosimetry database used to develop 

the coworker model in ORAUT-OTIB-0077 and issued a white paper on the findings 

(SC&A 2010). 

4.1.3 Ambient Environmental External Dose 

ORAUT-TKBS-0038-4, Revision 02, Area IV of the Santa Susana Field Laboratory, the Canoga 

Avenue Facility, the Downey Facility, and the De Soto Avenue Facility (sometimes referred to as 

Energy Technology Engineering Center [ETEC] or Atomics International) – Occupational 

Environmental Dose (NIOSH 2010c), presents ambient external radiation dose information for 

Area IV of the SSFL for the period 1975 through 1999. During the period under evaluation, 
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lithium-fluoride chips were used. The baseline dose during this period is based on the minimum 

dosimeter sensitivity of 10 mrem/quarter or 40 mrem/year. This minimum sensitivity baseline 

results in a higher annual dose than subtraction of offsite background dose from onsite 

environmental dosimeter results. ORAUT-TKBS-0038-4 presents annual ambient Area IV dose 

rates for assignment for the years under evaluation, 1991 through 1993. This current evaluation 

dealing with the disqualification of internal bioassay data has identified no concerns with the 

assignment of ambient environmental external doses. 

4.1.4 Occupational Medical Data

In its previous SEC class designation for SEC-00234, for the period through December 31, 1988 

(HHS 2017, page 3), HHS stated: 

NIOSH finds that it is feasible to reconstruct occupational medical dose for 

Area IV workers using information and methods in Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures (ORAUT-OTIB-0006) and 

the Area IV site profile documents. 

The SEC-00235 petition ER found no evidence to the contrary for the remediation period (post 

1988) or for the period under evaluation, August 1, 1991, through June 30, 1993. NIOSH 

determined that it is feasible to reconstruct occupational medical dose for Area IV workers for 

the period from August 1, 1991 through June 30, 1993, using information and methods in 

ORAUT-OTIB-0006, Revision 04 (NIOSH 2011), and the Area IV site profile documents 

(ORAUT-TKBS-0038-1,-2, -3, -4, -5, and -6). 

4.1.5 External Dose Reconstruction Feasibility

In its previous SEC-00093 and SEC-00156 class designations, NIOSH found that it has access to 

sufficient employee monitoring and workplace monitoring data to bound potential external 

exposures for employees at Area IV of the SSFL for January 1, 1955, through December 31, 

1958, and January 1, 1959, through December 31, 1964. This petition evaluation found no 

evidence to the contrary for the period from August 1, 1991, through June 30, 1993. SC&A

concurs with NIOSH’s external dose reconstruction feasibility determination. 

4.2 REVIEW OF INTERNAL DOSIMETRY DATA AT SANTA SUSANA FIELD 

LABORATORY AREA IV 

4.2.1 Air Monitoring Data 

NIOSH determined the principal source of internal dose to the workers during the period from 

1991 to 1993 was from airborne radiological particulates generated during D&D activities 

(NIOSH 2017). Air sample results for onsite D&D work, including job-specific breathing-zone 

air sample results and continuous air monitor results for various buildings, are contained in the 

site’s quarterly reports for 1991–1993 (Rockwell 1993). The quarterly reports also describe the 

radiological conditions, radiological activities, and any significant events that occurred during 

the time period. 
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SC&A reviewed the 1991–1993 air monitoring results in Rockwell 1993 and finds them to be 

incomplete. For example, the 1991 quarterly reports provide air sampling information for the 

Systems for Nuclear Auxiliary Power (SNAP) facility, the Hot Laboratory, and the Radiological 

Material Disposal Facility. The Hot Laboratory and the Radiological Material Disposal Facility 

had fixed air monitors, and results are provided. However, the SNAP did not have fixed air 

monitors and only reported job-specific air sample results that were greater than 0.10 of the 

derived air concentration. Also, quarterly reports for 1992 and 1993 are only provided for the 

Hot Laboratory. According to Rockwell 1993, page 176, reports for the SNAP facility and the 

Radiological Material Disposal Facility were not required by regulations and were suspended 

pending the implementation of the DOE Radiological Control Manual. Although the air 

monitoring data are not complete for each facility, SC&A believes the results provide an 

adequate representation of the airborne activity levels of site activities during the evaluated 

period. 

However, given that NIOSH intends to use surrogate bioassay data and associated intakes from 

the operational period to reconstruct internal doses during the evaluated period for SEC-00235, it 

becomes particularly important to establish that radiological conditions during the surrogate 

period are representative and/or bounding of the evaluated period. NIOSH 2017 presents a visual 

comparison of bioassay values during the operational period to limited bioassay identified before 

and after the evaluated period to demonstrate that the magnitude of available monitoring data 

was likely similar to or lower than the operational period. In addition, NIOSH 2017 notes that 

D&D activities were ongoing at SSFL Area IV both before and after the evaluated period and 

also notes there were no major radiological operations identified that might represent a 

significant change in exposure potential. SC&A does not disagree with these assertions. 

Nonetheless, it would be beneficial to perform an analysis of available general area and 

breathing zone air sampling results for the evaluated period in comparison to the operational 

period (i.e., the surrogate data period) to assure that radiological conditions are sufficiently 

similar and/or bounding for use during the evaluated period. This type of analysis would have the 

added benefit of providing a direct link from the internal exposure potential reflected in the 

surrogate data to the exposure potential during the period of interest. 

4.2.2 Bounding Internal Dose to Unmonitored Workers

ORAUT-OTIB-0080 contains derived intake rates for uranium, plutonium, and mixed fission 

products (MFP) through the years 1988, 1986, and 1991, respectively. SC&A’s review of 

ORAUT-OTIB-0080 and associated findings are in SCA-TR-OTIB2014-0080, A Review of 

ORAUT-OTIB-0080, Rev. 00: Internal Coworker Dosimetry Data for Area IV of the Santa 

Susana Field Laboratory and the DeSoto Avenue Facility (SC&A 2014). SC&A’s report 

identified 15 findings and 10 observations that remain unresolved. While some of the findings 

and observations are only relevant for the operational period (e.g., extrapolation of intakes to 

earlier periods of operation), many of these issues relate to the formulation of coworker intakes 

in general. Because those derived intakes are proposed for use during the evaluated period, they 

are relevant to the evaluation of SEC-00235. 
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According to the SEC petition ER (NIOSH 2017, page 43), 

Though there are no available urinalysis data for the August 1991 through 

June 1993 period, due to the invalidation of the CEP-analyzed sample results, 

NIOSH has determined that the data available from before 1991, and following 

1993, are of a similar or reduced value to that in the operational-era coworker 

data for all three coworker-study analytes: uranium, plutonium, and MFP. 

The plutonium intake rates are shown in Tables 5-1 and 5-2 of ORAUT-OTIB-0080 and end in 

1986. Likewise, the uranium intake rates are shown in Tables 5-3 to 5-5, ending in 1988. The 

MFP intake rates are shown in Table 5-6, ending in 1991. ORAUT-OTIB-0080 allows for the 

intake rates to be extended past the end dates as a measure favorable to claimants.

Based on the available pre-1991 and post-1993 data as presented in Figures 7-2, 7-3, and 7-4 of 

the SEC petition ER (NIOSH 2017), SC&A agrees that the intakes indicated by the data before 

1991 and after 1993 are similar or less than those during the operational period. 

4.2.3 Internal Dose Reconstruction Feasibility

Based on NIOSH’s research and the information presented in the SEC petition ER (NIOSH 

2017), NIOSH believes it can estimate radiation doses for all members of the class with 

sufficient accuracy. This class includes all employees who worked at Area IV of SSFL from 

August 1, 1991, through June 30, 1993. NIOSH based its determination on the following key 

items:

• The remediation period bioassay data are not significantly different from the operational 

period data (through 1988) used to develop the intake rates of ORAUT-OTIB-0080. 

NIOSH believes the ORAUT-OTIB-0080 intake rates assigned for the end of the Area IV 

operation period (1988) bound the potential remediation period exposures for 

unmonitored workers. 

• The exposure conditions from D&D and waste handling operations during the 

remediation period (1989–present) did not significantly change before, during, and after 

the CEP period (1991–1993). Also, NIOSH did not find any major radiological project 

that occurred in the CEP period that would not have had workplace and/or personnel 

monitoring performed outside the CEP-related period. 

• During the CEP period, the site was performing routine in vivo whole-body scans with a 

different contractor, and the site had confirmatory in vitro resamples analyzed by the new 

contractor, Teledyne-Brown Engineering. The site reported that these follow-up in vitro

results confirmed no measurable internal exposures (Rockwell 1994). 

Based on our review, SC&A believes that before, during, or after the CEP period of 1991–1993, 

the radiological exposure conditions and the bioassay data did not significantly change. As such, 

the derived intake rates for uranium, plutonium, and MFP in ORAUT-OTIB-0080 would likely 

bound any potential internal exposures for unmonitored workers during the CEP period. 
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However, NIOSH 2017 does not address the potential internal dose to other actinide 

contaminants that would likely be found during D&D activities at the site. As noted in 

Section 3.1 of this report, SEC-00234 was granted on the basis of the inability to reconstruct 

internal exposures to thorium and americium during the operational period. NIOSH should 

address how it intends to reconstruct exposures to these contaminants during the evaluated 

period. 
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5.0 SUMMARY OF FINDINGS 

SC&A was tasked to review the SEC Petition-00235 ER (NIOSH 2017) and available 

documentation focusing on the feasibility of NIOSH performing sufficiently accurate internal 

dose reconstructions for unmonitored workers without using the of CEP in vitro data from 1991 

to 1993. 

SC&A’s focused review of the SEC Petition-00235 ER concluded: 

• There are sufficient employee monitoring and workplace monitoring data to bound 

potential external exposures. 

• The nature of radiological work (namely, D&D activities) does not appear to significantly 

change before, during, or after the 1991–1993 time period. 

• It would be beneficial to compare general air and breathing zone data from the 1991–

1993 period to the operational period (surrogate data period) to assure radiological 

conditions are sufficiently similar or bounding for use in internal dose assessment. 

• The bioassay data obtained during the remediation period did not exceed the bioassay 

data from the operations period (pre-1988). 

• Extending uranium, plutonium, and MFP intake rates in ORAUT-OTIB-0080 would 

likely bound any potential intakes that may have occurred during the CEP period (see 

previous suggestion concerning air sampling comparisons). However, SC&A’s review of 

ORAUT-OTIB-0080 identified several findings and observations that are directly 

relevant to the calculation of intake values proposed for use during the 1991–1993 period. 

These findings and observations have yet to be discussed or resolved. 

• NIOSH has not established how it will reconstruct internal exposures to other actinide 

contaminants, such as americium and thorium, during the evaluated period. Such methods 

should be developed to assure that dose reconstruction is feasible for all radionuclides 

with the potential for exposure. 

In addition, SC&A suggests that example dose reconstructions be provided (whether actual or 

hypothetical) to demonstrate the implementation and application of coworker doses, ambient 

doses, or a combination of the two in an actual dose reconstruction context. Section 7.5 of the 

SEC Petition-00235 ER notes:

As of April 24, 2017, a total of 29 claims have been submitted to NIOSH for 

individuals who worked at Area IV of the SSFL during the period under 

evaluation in this report. Dose reconstructions have been completed for 22 

individuals (~76%).

SC&A has reviewed the available claimant population and provided an overview that includes an 

assessment of available monitoring records, relevant computer-assisted-telephone interview 

(CATI) statements, and the methods used in previous dose reconstructions. Appendix B 
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summarizes this information, which shows that a large portion of previously reconstructed 

claims used ambient, instead of coworker, dose assignment. It has been found in the past that 

providing examples using either real or hypothetical claimants has helped illustrate the intended 

approach to dose reconstruction moving forward. Obviously, such information is beyond 

questions of the general feasibility of dose reconstruction during the evaluated period. 
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6.0 REFERENCES

Atomics International 1960. Special Bioassay Request, Health Physics Procedures, Atomics 

International. July 22, 1960. [SRDB Ref. ID 19053, PDF pp. 4–8] 

Boeing 2014. Commentary on the ABRWH Meeting Redondo Beach, California, November 6, 

2014, The Boeing Company, Santa Susana Field Laboratory. November 18, 2014. [SRDB Ref. 

ID 141323] 

HHS 2009. HHS Designation of Additional Members of the Special Exposure Cohort under the 

Energy Employees Occupational Illness Compensation Program Act of 2000: Designating a 

Class of Employees from Santa Susana Field Laboratory – Area IV, Santa Susana, California, 

U.S. Department of Health and Human Services, Washington, DC. June 18, 2009. [SRDB Ref. 

ID 134474] 

HHS 2010. HHS Designation of Additional Members of the Special Exposure Cohort under the 

Energy Employees Occupational Illness Compensation Program Act of 2000: Designating a 

Class of Employees from Santa Susana Field Laboratory, Santa Susana, California, U.S. 

Department of Health and Human Services, Washington, DC. April 5, 2010. [SRDB Ref. 

ID 134472] 

HHS 2017. U.S. Department of Health and Human Services Designation of Additional Members 

of the Special Exposure Cohort under the Energy Employees Occupational Illness Compensation 

Program Act of 2000: Designating a Class of Employees, Area IV of Santa Susana Field 

Laboratory, Ventura County, California, U.S. Department of Health and Human Services, 

Washington, DC. January 6, 2017. [SRDB Ref. ID 166406] 

Helgeson 1993. Report of In Vivo Counting for Rockwell International Rocketdyne Division, 

6633 Canoga Avenue, Canoga Park, California, Work Performed on September 30 through 

October 1, 1993, Helgeson Scientific Services, Inc. October 13, 1993. [SRDB Ref. ID 39817] 

Lang 1960. Radiological Safety at Atomics International, A Division of North American Aviation 

Inc., J.C. Lang. July 13, 1960. [SRDB Ref. ID 19144] 

NIOSH 2004. Maximum Internal Dose Estimates for Certain DOE Complex Claims, ORAUTOTIB-0002, Revision 01 PC-2, National Institute for Occupational Safety and Health, 

Cincinnati, OH. May 7, 2004. 

NIOSH 2005a. Application of Internal Doses Based on Claimant-Favorable Assumptions for 

Processing as Best Estimates, ORAUT-OTIB-0033, Revision 00, National Institute for 

Occupational Safety and Health, Cincinnati, OH. April 20, 2005. 

NIOSH 2005b. Internal Dose Overestimates for Facilities with Air Sampling Programs, 

ORAUT-OTIB-0018, Revision 01, National Institute for Occupational Safety and Health, 

Cincinnati, OH. August 9, 2005. 
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NIOSH 2009a. SEC Petition Evaluation Report for Petition SEC-00093, Santa Susana Field 

Laboratory-Area IV, National Institute for Occupational Safety and Health, Cincinnati, OH.

April 28, 2009. [SRDB Ref. ID 76961]

NIOSH 2009b. External Coworker Dosimetry Data for Area IV of the Santa Susana Field 

Laboratory, the Canoga Avenue Facility (Vanowen Building, and the De Soto Avenue Facility 

(sometimes referred to as Energy Technology Engineering Center [ETEC] or Atomics 

International), ORAUT-OTIB-0077, Revision 00, National Institute for Occupational Safety and 

Health, Cincinnati, OH. August 3, 2009. [SRDB Ref. ID 72162]

NIOSH 2010a. SEC Petition Evaluation Report for Petition SEC-00156, Area IV of the Santa 

Susana Field Laboratory, National Institute for Occupational Safety and Health, Cincinnati, OH.

January 12, 2010. [SRDB Ref. ID 79567]

NIOSH 2010b. Area IV of the Santa Susana Field Laboratory, the Canoga Avenue Facility, the 

Downey Facility, and the De Soto Avenue Facility (sometimes referred to as Energy Technology 

Engineering Center [ETEC] or Atomics International) – Occupational External Dose, ORAUTTKBS-0038-6, Revision 02, National Institute for Occupational Safety and Health, Cincinnati, 

OH. April 26, 2010. [SRDB Ref. ID 80538]

NIOSH 2010c. Area IV of the Santa Susana Field Laboratory, the Canoga Avenue Facility, the 

Downey Facility, and the De Soto Avenue Facility (sometimes referred to as Energy Technology 

Engineering Center [ETEC] or Atomics International) – Occupational Environmental Dose, 

ORAUT-TKBS-0038-4, Revision 02, National Institute for Occupational Safety and Health, 

Cincinnati, OH. April 26, 2010. [SRDB Ref. ID 80536]

NIOSH 2011. Dose Reconstruction from Occupational Medical X-Ray Procedures, ORAUTOTIB-0006, Revision 04, National Institute for Occupational Safety and Health, Cincinnati, OH. 

June 20, 2011. [SRDB Ref. ID 98147]

NIOSH 2014. Internal Coworker Dosimetry Data for Area IV of the Santa Susana Field 

Laboratory and the De Soto Avenue Facility, ORAUT-OTIB-0080, Revision 00, National 

Institute for Occupational Safety and Health, Cincinnati, OH. March 14, 2014. [SRDB Ref. 

ID 131215]

NIOSH 2016. SEC Petition Evaluation Report for Petition SEC-00234, Area IV of the Santa 

Susana Field Laboratory, National Institute for Occupational Safety and Health, Cincinnati, OH.

October 11, 2016. [SRDB Ref. ID 166405]

NIOSH 2017. SEC Petition Evaluation Report for Petition SEC-00235, Area IV of the Santa 

Susana Field Laboratory, National Institute for Occupational Safety and Health, Cincinnati, OH.

May 11, 2017.

Rockwell 1993. ALARA and Surveillance Quarterly Reports 1991–1993, correspondence,

various authors, Rockwell International. Various dates through 1991–1993. [SRDB Ref.

ID 166444]
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Rockwell 1994. Bioassay Analysis Results—CEP Under Investigation, multiple copies of 

correspondence, Rockwell International, Canoga Park, CA. December 5, 1994. [SRDB Ref. 

ID 166179] 

SC&A 2009. Review of the Santa Susana Field Laboratory (SSFL) Area IV Special Exposure 

Cohort (SEC) Petition-00093 and the NIOSH SEC Petition Evaluation Report, SCA-SECTASK5-0066, Revision 1, SC&A, Inc., Vienna, VA. October 29, 2009. 

SC&A 2010. Review of Database Used to Develop ORAUT-OTIB-0077: External Coworker 

Dosimetry Data for Area IV of the Santa Susana Field Laboratory, White Paper, Revision 1, 

SC&A, Inc., Vienna, VA. March 15, 2010. 

SC&A 2014. A Review of ORAUT-OTIB-0080, Rev. 00: Internal Coworker Dosimetry Data for 

Area IV of the Santa Susana Field Laboratory and the DeSoto Avenue Facility, SCA-TROTIB2014-0080, Revision 0, SC&A, Inc., Vienna, VA. November 24, 2014. 
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ATTACHMENT A: SEC PETITION 00235 DOCUMENTS 

Special Exposure Cohort Petition—Form B, with attachments; received August 9, 2016; DSA 

Ref ID: 127147 

Two Affidavits; signed January 11, 2017; DSA Ref ID: 127726 

Select page from October 1966 Monthly Progress Report; author not specified; November 8, 

1966; DSA Ref ID: 127201 

Press release on NASA contract to develop SNAP power systems; Atomics International; 

May 20, 1963; DSA Ref ID: 127202 

Transfer of Neutron Source; correspondence from A.R. Yarrow; August 21, 1963; DSA Ref ID: 

127203 

Plan of Action for RMDF; correspondence from Jim Harris; December 18, 1975; DSA Ref ID: 

127204 

Transfer of Neutron Source Approval; correspondence from A.R. Yarrow; May 24, 1963; DSA 

Ref ID: 127205 

KEWP Health Physics Log Book; dated September 18, 1959 through April 9, 1963; DSA Ref ID: 

127206 

Accidental Exposure of Film Badges; correspondence from R.R. Garcia; May 18, 1965; DSA Ref 

ID: 127207 

Duty Cycle SNAP 10A Actuators; correspondence from I. Rowe; May 28, 1963; DSA Ref ID: 

127208 

Operational Safety Unit Weekly Newsletter for Week Ending June 1, 1968; correspondence from 

R.E. Alexander; June 6, 1968; DSA Ref ID: 127209 

Steam Accumulator Blowdown Evaluation Rig (SABER) Large Scale Steam Valve Test; author 

not specified; June 29, 1990; DSA Ref ID: 127210 

Approval for More Than 600 MREM Exposure during S8ER Core Vessel Removal and 

Disassembly; correspondence by R.M. Hill; September 27, 1965; DSA Ref ID: 127211 

Health Physics Log Book; dated October 28, 1964 through November 18, 1965; DSA Ref ID: 

127212 

Radiation Safety Unit Weekly Newsletter for the Period Ending July 15, 1967; correspondence 

from R.E. Alexander; July 25, 1967; DSA Ref ID: 127213 

History of the Bowl Area, with descriptions of gasification and propellants for rocket fire tests; 

author not specified; date not specified; DSA Ref ID: 127214 
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Neuron Radiography of S8DR Fuel Elements in STIR Facility; correspondence from 

R.E. Durand; May 4, 1970; DSA Ref ID: 127215 

Accidental Exposure of Atomics International Film Badges during the Latter Part of November 

1962; author not specified; post-November 1962; DSA Ref ID: 127217 

Site Description and Historical Operations of the Bowl Area; author not specified; November 

1992; DSA Ref ID: 127219 

One-Quarter-Ton-Per-Hour Coal Hydropyrolisis Conversion Test Facility; correspondence from 

S.F. Iacobellis; September 15, 1978; DSA Ref ID: 127220 

Presentation: Advanced Single Stage Gasifier Development Program; Pratt & Whitney 

Rocketdyne; October 12, 2005; DSA Ref ID: 127222 

Single sheet showing dosimetry distribution points; author not specified; April 1, 2014; DSA Ref 

ID: 127223 

Advancement of Flash Hydrogasification: Task VIII Performance Testing; A.Y. Falk, 

M.D. Schuman, and D. R. Kahn; June 1986; DSA Ref ID: 127224 

DOE Authority for Release of Certain Facilities at SSFL; correspondence from R.T. Lancet; 

January 11, 1990; DSA Ref ID: 127225 

List of buildings and their status; author not identified; August 9, 1995; DSA Ref ID: 127226 

ETEC Co-generation Equipment; correspondence from R.W. Buckles; January 14, 1986; DSA 

Ref ID: 127227 

Hydrogen Fluoride Chemical Laser Technology; correspondence from J.G. Byrne; June 30, 

1976; DSA Ref ID: 127228 

ETEC Environmental Protection Implementation Plan Pursuant to DOE Order DOE 5400.1; 

Rockwell International Corporation; Revision C; November 9, 1992–November 9, 1993; DSA 

Ref ID: 127230 

Quarterly Report (July through September 1959) of Activity Released to the Atmosphere; 

G. Borg; November 20, 1959; DSA Ref ID: 127231 

Photograph of two drums under a desk that are labeled as radioactive material contaminated 

waste; date not specified; DSA Ref ID: 127232 

Energy Systems Group brochure; Rockwell International; date not specified; DSA Ref ID: 

127234 

Contract Solicitation/Modification for DOE-Boeing; official form extending contract for ETEC 

remediation; December 15, 1998; DSA Ref ID: 127237 
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The Pied Piper—A Historical Overview of the U.S. Space Power Reactor Program; George P. 

Dix and Susan S. Voss; date not specified; DSA Ref ID: 127239 

Presentation: RFI Data Gap Work Plan for Boeing RFI Subarea 1A North B-1, IEL, AILF, and 

Unaffiliated Areas; originally presented at a Santa Susana Field Laboratory technical meeting; 

June 7, 2013; DSA Ref ID: 127240 

Commendation Regarding Uranium Fire at Canoga Facility, May 17, 1967; J.E. Stewart, Jr.; 

May 19, 1967; DSA Ref ID: 127241 

The Gasification of Various Coals in Molten Salts; S.J. Yosim and K.M. Barclay; date not 

specified; DSA Ref ID: 127243 

Preliminary Services for SNAP8 Flight Prototype Test Facility, Building 056 Santa Susana, 

California; Bechtel Corporation; August 1964; DSA Ref ID: 127244 

Radiation Survey of the Downey Facility; approved by P. Rutherford and S. Reeder; release date 

May 7, 2001; DSA Ref ID: 127245 

Health Physics Log Book for Building 12; dated October 12, 1962, through July 27, 1966; DSA 

Ref ID: 127246 

Airborne Radioactive Contamination in SRE High Bay During Reactor Operations; 

correspondence from R.K. Owen; July 17, 1959; DSA Ref ID: 127247 

Atomics International and Energy Technology Engineering Center; correspondence documenting 

DEEOIC finding that any employee of NAA at AEC where operations were conducted was 

potentially eligible under the Act; September 7, 2005; DSA Ref ID: 127248 

Memo with License R-19 authorizing operation of L-47 reactor at Canoga; H.L. Price; issued 

August 1957; DSA Ref ID: 127249 

Memo with License R-40 authorizing operation of L-77 reactor at Canoga; H.L. Price; issued 

May 17, 1958; DSA Ref ID: 127250 

Confirmation of 1958 Termination of License R-19; E.R. Price; June 30, 1958; DSA Ref ID: 

127251 

Amendment to R-40 License; H.L. Price; issued June 28, 1960; DSA Ref ID: 127252 

Rockwell International Site Visit; correspondence from Ross A. Scarano; January 29, 1996; DSA 

Ref ID: 127253 

Photograph of a reactor at Canoga Park; date not specified; DSA Ref ID: 127254 

Photograph of SNAP building complex, with a key specifying building names; date not specified; 

DSA Ref ID: 127255 
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2006 Site Description: Santa Susana Field Laboratory (SSFL) Proposed Corrections to 

Technical Basis Documents 1 and 2, ORAUT-TKBS-0038-1/ORAUT-TKBS-0038-2; CORE 

Advocacy for Nuclear & Aerospace Workers; presented to NIOSH on August 9, 2016; DSA Ref 

ID: 127256 

2016 SSFL Site Description Bibliography; CORE Advocacy for Nuclear & Aerospace Workers; 

presented to NIOSH on August 9, 2016; DSA Ref ID: 127257 

EEOICPA Bulletin No. 10-10 on Designation of SEC Class for Area IV of SSFL from January 1, 

1959 through December 31, 1964; Department of Labor; May 5, 2010; DSA Ref ID: 127389 

Response to the SEC-00235 Consult Call Letter; CORE Advocacy for Nuclear & Aerospace 

Workers; December 21, 2016; DSA Ref ID: 127639 
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ATTACHMENT B: OVERVIEW OF CLAIMANT POPULATION 

As part of its SEC review, SC&A reviewed the affected claimant population to assess the availability of 

monitoring records, relevant statements from the CATI, and characterization of prior dose 

reconstructions/compensation decisions. Table B-4 provides SC&A’s full summary of each claim during 

the evaluated SEC period. NIOSH 2017 also provided an analysis of the claimant population, 

summarized in Table 4-1 (recreated here as Table B-1 for convenience). 

Table B-1. No. of Area IV of the SSFL Claims Submitted Under the Dose Reconstruction Rule 

(Table 4-1 of NIOSH 2017) 

Description Totals 

Total number of claims submitted for dose reconstruction 316

Total number of claims submitted for energy employees who worked 

during the period under evaluation (August 1, 1991 through June 30, 

1993)

29

Total number of claims submitted for energy employees who started their 

employment during the period under evaluation 

6

Number of dose reconstructions completed for energy employees who 

worked during the period under evaluation (i.e., number of such claims 

completed by NIOSH and submitted to the Department of Labor for final 

approval)

22

Number of claims for which internal dosimetry records were obtained for 

the time period in the evaluated class definition

5

Number of claims for which external dosimetry records were obtained 

for the time period in the evaluated class definition 

10

At the time of this review, an additional claim had been filed, bringing the total number of affected 

claims during the evaluation period to 30. It is worth noting that SC&A’s review of this claimant 

population found that 14 individuals had at least some external monitoring records during the evaluation 

period (compared 10 identified by NIOSH), and six individuals had internal monitoring (compared to 

five identified by NIOSH). The source of these discrepancies is not known at this time; however, these 

small differences should not affect the SEC evaluation. 

SC&A examined the available CATI reports for information relevant to the ability to reconstruct doses. 

While SC&A did identify at least one claim that reported an incident that was specifically during the 

evaluation period and involved demolition work, it is not clear from the description of the incident 

whether any radiological hazards were involved as opposed to the more general health and safety 

concerns. SC&A did not find any evidence in the CATI reports of any major changes in radiological 

conditions or exposure potential specific to the 1991–1993 period that might preclude dose 

reconstruction feasibility. 

Several claimant interviews stated they were monitored externally and/or internally; however, no such 

records could be identified in the DOE monitoring records. The identified statements may not 

necessarily be referring to the evaluated period and thus may be referencing earlier monitored periods. 

However, given the absence of temporal specific statements about monitoring practices and/or specific 

information about job type, regular duties, work area, and related exposure potential, it is generally a 

claimant favorable practice to assign unmonitored doses as opposed to ambient doses in many cases. 
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This reinforces the importance of understanding the implementation aspects of assigning unmonitored 

(coworker) internal and external doses to the potentially affected claims at SSFL during the period of 

interest. 

Of the 30 identified claims during the evaluation period, 11 of the 30 would likely require dose 

reconstructions to be performed using the proposed methodology (either partial dose reconstructions if 

SEC-00235 is granted or full dose reconstructions if such reconstructions are deemed feasible). Dose 

reconstructions performed to date include the use of several different methods of reconstructing external 

and internal dose. The chosen dose reconstruction methods identified are summarized in Table B-2 (for 

external exposure) and Table B-3 (for internal exposure). It should be noted that, in many cases, the 

external dose and/or the internal dose was not evaluated for a given claimant. This can be for a variety of 

reasons, such as:

• The probability of causation was determined to be greater than 50% with only a partial dose 

reconstruction. 

• The claim was compensated via one or more established SECs. 

• The claim was pulled by the U.S. Department of Labor subsequent to its transmittal to NIOSH 

for dose reconstruction due to lack of covered employment or a covered illness. 

The observed incidence of external and/or internal dose not being evaluated should not be misconstrued 

as a deficiency in the dose reconstruction, but rather as an efficiency measure to adjudicate claims 

quickly or, in some cases, adherence to the statutory requirements of the Energy Employees 

Occupational Illness Compensation Program Act of 2000 (EEOICPA). 

As seen in Tables B-2 and B-3, a significant portion of the dose reconstructions performed used ambient 

external and internal exposure estimates; SC&A did not identify any dose reconstructions during the 

evaluation period that used the current coworker model data for SSFL. As noted in the concluding 

section of this report, it would be beneficial for the board and/or SC&A to review a subset of sample 

dose reconstructions (whether actual or hypothetical) to assess how the proposed use of coworker intake 

values would be implemented in practice. 

Table B-2. Overview of Methods Used in Prior Dose Reconstructions

External Dose Reconstruction Method

Number of 

Observed Dose 

Reconstructions 

(% of Total)

External dose based on ambient exposures 11 (37%)

External dose based on personal monitoring data 9 (30%)

External dose not evaluated 9 (30%)

External dose based on regulatory standards at the time 1 (3%)
Effective Date:

11/21/2017

Revision No.

0 (Draft)

Document No./Description:

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Page No.

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NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Table B-3. Overview of Methods Used in Prior Dose Reconstructions

External Dose Reconstruction Method

Number 

Observed Dose 

Reconstructions 

(% of Total)

Internal dose not evaluated 12 (40%)

Environmental intake assignment 8* (27%)

OTIB-0002, Maximum Internal Dose Estimates for 

Certain DOE Complex Claims (NIOSH 2004)**

5 (17%)

OTIB-0018, Internal Dose Overestimates for 

Facilities with Air Sampling Programs

(NIOSH 2005b)

5 (17%)

* One claim used whole-body count data in conjunction with ambient intakes. 

** This technical information bulletin is no longer in use.
Effective Date:

11/21/2017

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2017-SEC011

Page No.

29 of 29

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a and has been cleared for 

distribution.

Table B-4: Overview of Claimant Population during SEC Evaluation Period (August 1, 1991–June 30, 1993) 

[Table B-4 on pages 29 to 40 is withheld in its entirety to prevent the disclosure of Privacy Act protected information.]