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.

MEMORANDUM

TO: Idaho National Laboratory Work Group 

FROM: SC&A, Inc.

DATE: September 29, 2016 

SUBJECT: Verification and Validation (V&V) Plan for Temporary Badges at CPP (1963–1970) 

Introduction and Background

The Special Exposure Cohort (SEC) evaluation report for the Idaho National Laboratory (INL) was 

initially finalized in March 2015 and recommended a class of all workers located at the Chemical 

Processing Plant (CPP) and who were monitored externally at CPP from 1963 to 1974. Since that time, 

both the National Institute of Occupational Safety and Health (NIOSH) and SC&A have performed 

multiple assessments using available claimant files to evaluate the appropriateness and validity of the 

dosimetry requirement. Some of the main discoveries as a result of those assessments and additional 

research are as follows:

• Efficiency measures were applied to some claims resulting in only annual dose summaries being 

transmitted by the U.S. Department of Energy (DOE). This was resolved in the fall of 2015, with 

DOE agreeing to send complete radiological monitoring histories instead of summaries.

• Some record formats for construction workers had not been previously identified as associated 

with CPP work and exposure. These records have subsequently been captured and will be 

included in worker exposure records as appropriate. 

• Beginning in early 1970, INL workers were allowed to use their badge from their primary areas 

of work to enter other locations at the site. This resulted in a revision to the class definition that

changed the criteria from a CPP-specific badge to any INL dosimetry badge for the period 

March 1, 1970, to December 31, 1974.1

1 The earlier portion of the SEC period (January 1, 1963–February 28, 1970) still required a CPP-specific dosimetry 

badge. The Advisory Board voted to accept the latter SEC period (March 1, 1970–December 31, 1974). 

• For some portions of the SEC period, temporary badges or visitor cards had not been officially 

entered into the INL dosimetry system if the exposure on the badge was zero. Although the 

visitor cards were not entered into the dosimetry system, the original visitor cards were kept by 

the site.

For the last bullet, DOE is currently undertaking an extensive coding and indexing effort to assure that 

all temporary badges/visitor cards are correctly entered into the dosimetry system and that worker 

dosimetry records are complete. One of the main concerns expressed at the March 2016 INL Work 

 
Memo – Proposed V&V of CPP Temporary Badges 2 SC&A – September 29, 2016

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

Group meeting involved the completeness of relevant temporary/visitor dosimetry records, as well as 

potential issues related to the implementation of these dosimetry records once they had been coded and 

indexed. 

On the issue of data completeness, NIOSH compared monthly health physics reports detailing the 

number of badges issued for CPP against the actual number of captured badges in NIOSH’s possession. 

NIOSH presented the results of that comparison on August 2, 2016; therefore, this issue is not discussed 

further.

On the issue of implementation, the Work Group asked SC&A to investigate and propose a method to 

verify and validate that the complete set of visitor records is being implemented correctly on an 

individual basis. This memo provides an overview of SC&A’s proposed approach and methodology to 

evaluate the implementation process for temporary badges/visitor cards. 

Description of Proposed Methodology 

As described in the previous section, it was INL site policy not to enter visitor badges into the main 

dosimetry system if the exposure incurred by the worker was zero. Since this policy was discovered, 

DOE has undertaken a massive coding and indexing effort of all visitor badges to assure that all 

dosimetry for the site is included in their database and thus available to the U.S. Department of Labor 

(DOL) for SEC determinations and to NIOSH for accurate dose reconstruction. 

During data capture efforts at INL, NIOSH captured all of the visitor cards and temporary badge reports 

for CPP from 1963 to 1974.2

2 Verified via email exchange with Tim Taulbee, NIOSH, on August 18, 2016.

 While the records have been captured, they are not coded or searchable in 

any meaningful way. However, by manually examining these captured visitor cards, analysts can 

identify individual claimants by name and security number. This sample of claimant visitor cards 

provides a comparative set of data that can be used to verify that temporary badges are correctly 

included in the records provided by DOE to NIOSH. Claimant visitor cards included in the verification 

and validation (V&V) sample would have to meet the following criteria:

• The claimant requires an updated dose reconstruction and was employed in the period from 1963 

to 1974. These would include claims that do not currently qualify for the designated SEC 

(March 1, 1970–December 31, 1974), or who require partial dose reconstructions for non-SEC 

cancers.

• The individual visitor card associated with the claimant is not already included in available 

monitoring records from DOE. 

• The claimant can be directly associated with the individual visitor card by security number. 

This last criterion will necessarily limit the pool of available claimants for V&V sampling; however, it is 

deemed appropriate to avoid uncertainty when only the name is available to identify the claimant. 

 
Memo – Proposed V&V of CPP Temporary Badges 3 SC&A – September 29, 2016

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

Proof of Principle

In order to assure that identification of a sample of claimants that satisfy the above criteria (see the 

previous section, “Description of Proposed Methodology”) within the captured visitor cards is feasible, 

SC&A examined the CPP visitor cards captured by NIOSH for portions of 1968–1970; the Site 

Research Database (SRDB) references that were reviewed are shown in Table 1. Based on its review of 

these references, SC&A was able to identify 32 claimants who satisfy the criteria described in the 

previous section. Among the 32 claims, a total of 53 visitor cards were identified that could be used for 

the V&V study. These claims are summarized in Attachment 1. 

As stated previously, it is SC&A’s understanding that NIOSH has captured the visitor cards and 

temporary badge reports for each year under consideration at CPP. Therefore, it would be important to 

examine records for the years 1963–1967, as well as any additional reports from 1968 to 1970, to 

establish a sufficient sample set for use in potential V&V studies.

Table 1. References Used as a Proof of Principle for V&V Sampling

SRDB 

Ref. ID Title Page 

143032 CPP Area Visitor Badges July 6, 1967–December 4, 1970 221

143040 CPP Area Visitor Badges May 22, 1968–December 31, 1969 223

143045 CPP Area Visitor Badges June 19, 1967–December 31, 1968 219

151596 CPP Visitor Exchange Cards January 2–February 4, 1969 and 

June 2–7, 1969 275 

151598 CPP Visitor Exchange Cards September 9–December 31, 1968 787

151601 CPP Visitor Exchange Cards January 3–June 30, 1969 1,051

151602 CPP Visitor Exchange Cards March 31–August 26, 1969 and 

November 6–December 12, 1996 1,089 

151627 CPP Visitor Exchange and Construction Cards May 8–22, 1968 and 

August 6–December 14, 1968 1,041 

Conclusion 

SC&A examined possible methods for performing a V&V study on the implementation of visitor 

cards/temporary badges that are currently being coded and indexed by DOE. By using currently 

captured “hardcopy” records of individual visitor badges and temporary badge reports to identify 

claimants, a sample of records can be developed to check against radiological dose records received 

subsequent to the completion of the DOE database. SC&A examined several visitor card records from 

the 1968-to-early-1970 timeframe and found 32 claimants (representing 53 visitor badges) that met the 

criteria discussed above in “Description of Proposed Methodology.” 

It should be noted that at least two of these claimants had visitor cards with a name spelling that 

complicated the ability to match a visitor entry with a specific worker based purely on name (see 

Claims and ). In addition, one claim contained a visitor card that had transposed two digits 

of the five-digit security code (see Claim ). These types of discrepancies were of concern to the 

implementation of the proposed SEC class, and so examination of these specific cases will help 

understand the validity and potential difficulties of DOE’s complex coding and indexing effort. It is 
Memo – Proposed V&V of CPP Temporary Badges 4 SC&A – September 29, 2016

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

expected that examination of visitor and temporary badges in other years will yield more examples such 

as the three discussed above.
Memo – Proposed V&V of CPP Temporary Badges 5 SC&A – September 29, 2016

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distribution.

Attachment 1: Overview of 32 Claimants (53 Total Visitor Badges) Identified by SC&A for V&V Sampling

Claim 

ID

Relevant Employment 

Dates Job Title(s) Illness(s)

# Visitor 

Cards 

Identified

Additional Comments

/1955– /1992 Laborer, 2 

Neither of the visitor cards are reflected in the DOE_Response files 

currently available for the claimant. The energy employee (EE) was 

consistently monitored externally from 1963 to 1970; however, none of 

the badges were associated with CPP. The EE has many badges at CPP 

starting in 1970 (during the approved SEC period).

/1960– /1975

Administrative 

Assistant 4 

The EE has 250 days of employment and external monitoring in the 

approved SEC period.

 which 

had been observed by SC&A in other cases. 

According to the DOE_Response records, there is a gap in external 

monitoring from 1961 to 1970. The identified visitor cards were from 

May 1968 and February and June 1969.

/1951– /1978

Machinist, 

1 DOE_Response files indicate a gap in external monitoring from 1963 to

1970. Identified visitor card was from December 1968.

/1961– /1963

/1965– /1966

/1966– /1967

/1968– /1979

Welder, 1 

Two other visitor cards were identified; however, they were included in 

the claimant’s monitoring records (positive exposures). The EE had 

several additional visitor cards contained in their DOE_Response files, 

and all showed positive exposures.

The identified visitor card contained a zero exposure and was from 

December 1968. 

/1961– /1995

Maintenance, 

1 DOE_Response files indicate a gap in external monitoring from 1967 to 

1970. The identified visitor card was in April 1969.

/1955– /1969 Maintenance, 1 The last observed external monitoring result in the DOE_Response files 

was in 1967. The identified visitor card was in December 1968.
Memo – Proposed V&V of CPP Temporary Badges 6 SC&A – September 29, 2016

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distribution.

Claim 

ID

Relevant Employment 

Dates Job Title(s) Illness(s)

# Visitor 

Cards 

Identified

Additional Comments

/1952– /1986

Security, 

1 

The claim file contains one visitor card from October 1969 that

recorded a positive exposure. The identified visitor card is from 

December 1969.

/1956– /1986

Mechanic

1 

There appears to be a gap in external monitoring records contained in 

the DOE_Response files from 1962 to1970. The identified visitor 

badge is from December 1968.

/1956– /1969 2 No external dosimetry was observed for the EE after 1965. The 

identified visitor badges were for October 1968 and April 1969. 

/1951– /1980 Pipefitter 4 

While the four visitor cards did not appear in the DOE_Response files, 

the dates of the visitor cards overlap with “CX Area Exposure 

Dosimetry” reports that are available for the claim. 

/1957– /1969 Technician 1 

The only indication of assignment to CPP is an in vivo record 

questionnaire from 1964. The identified visitor card was from 

May 1968.

/1962– /1966

/1968– /1972

/1972– /1972

Laborer, 

1 External monitoring for the claimant appears to end in 1966. The 

identified visitor card was in January 1969.

/1967– /1984 Operator 2 

There is no indication in the DOE_Response files that the EE was 

assigned to CPP from 1963 to 1974. The security # for the EE is ; 

however, on one of the two visitor cards the security # appears as 

.

/1958– /1995 1 

External dosimetry was observed in the DOE_Response files for 1964–

1965, and again in 1987. The identified visitor badge was in 

August 1968.

/1957– /1974

Laborer, 

1 

An additional visitor badge was identified and was located in the 

DOE_Response files for the claimant (positive exposure).

The time periods of both visitor badges are covered by routine area 

exposure monitoring at CPP. 
Memo – Proposed V&V of CPP Temporary Badges 7 SC&A – September 29, 2016

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distribution.

Claim 

ID

Relevant Employment 

Dates Job Title(s) Illness(s)

# Visitor 

Cards 

Identified

Additional Comments

/1968– /1969

/1970– /1976 Pipefitter 5 

All five badges were not contained in the available DOE_Response 

files. The EE did have one CX Area Exposure entry, but it is not related 

to the visitor badges.

/1960– /1963

/1963– /1965

/1965– /1968

/1968– /1971

/1971– /1971

Laborer 1 

According to currently available DOE monitoring records, external 

monitoring ended in 1964 for the claimant. NIOSH amended an 

external dosimetry record for 1985. The identified visitor card was in 

September 1968. 

The claimant’s . The manner in which the 

middle was written on the visitor card could be interpreted as 

; however, the security numbers match. 

/1968– /1970 Laborer 1 

Three other visitor badges were also identified; however, they had 

positive exposure readings and were included in the current 

DOE_Response files for the claimant.

/1954– /1990

Clerk

1 

While the EE was monitored externally during the approved SEC 

period and was 

, the diagnosis date was less than 5 years from the first 

exposure.

The identified visitor badge was not found in currently available 

DOE_Response files. 

/1967– /1971

/1974– /1974 Operator

2 

The EE has many area exposure reports for “CX”; however, neither of 

the identified visitor badges were found in the available 

DOE_Response files.

/1951– /1980 Chemist 1 The EE appears to have a gap in external monitoring from 1964 to

1980.

11 distinct employment 

periods from 1963 to

1974 Laborer

3 

An additional six visitor badges were identified for the claimant;

however, they each contained positive doses and so were included in 

the currently available dosimetry record for the EE.
Memo – Proposed V&V of CPP Temporary Badges 8 SC&A – September 29, 2016

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distribution.

Claim 

ID

Relevant Employment 

Dates Job Title(s) Illness(s)

# Visitor 

Cards 

Identified

Additional Comments

/1963– /1964

/1967– /1968

/1968– /1968

/1969– /1971

/1971– /1971

/1973– /1993

Pipefitter 2 

The claimant’s ; however, the two visitor 

cards identified by matching security # show the 

The dates of the visitor cards are subsumed into “CX Dosimetry - Area 

Exposure Reports” available for the claimant; however, the individual 

visitor cards were not included.

A third visitor card was found for an ; however, the 

security # did not match the claimant.

/1963– /1986 2 

Two visitor cards are not reflected in DOE_Response files.

A third visitor card was also identified; however, it reported a positive 

dose and was found in the EE’s monitoring records.

/1955– /1985

Technician

2 Neither visitor card was found in the EE’s monitoring records.

/1967– /1968

/1968– /1969

/1969– /1969 Machinist

2 

Two visitor cards were not reflected in DOE_Response files.

A third visitor card was also identified; however, it reported a positive 

dose and was found in the EE’s monitoring records.

/1956– /1969

/1969– /1971

/1971– /1976 Engineer

2 

The EE likely qualifies for the approved SEC based on the 

; however, it is assumed that a partial dose 

reconstruction will also be required for the . 

The visitor badges identified prior to the approved SEC period do not 

appear in the claimant’s DOE_Response files.

/1958– /1980 Welder 1 No evidence of work at CPP is observed in DOE_Response files.

/1958– /1995

Janitor

1 Available external monitoring was not observed until 1970 in the 

DOE_Response file. 

12 distinct employment 

periods from 1963 to

1974 Operator

1 EE was monitored at CPP during the approved SEC period. The visitor 

badge was in June 1969 and was not included in the records.
Memo – Proposed V&V of CPP Temporary Badges 9 SC&A – September 29, 2016

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distribution.

Claim 

ID

Relevant Employment 

Dates Job Title(s) Illness(s)

# Visitor 

Cards 

Identified

Additional Comments

/1962– /1987 1 

DOL Initial Case states that the EE was responsible for 

 at CPP, with occasional mechanical 

work. The EE was consistently monitored at from 

1963 to 1970. Beginning in 1970, the EE has multiple internal and 

external monitoring results associated with CPP.

/1961– /1963

/1963– /1963

/1963– /1964

/1965– /1967

/1967– /1968

/1969– /1970

Operator

1 

The EE has monitoring data associated with CPP during the relevant 

employment dates; however, the identified visitor card is not included 

in the DOE_Response files.