Hanford

Special Exposure Cohort 

Petition Evaluation Report

Samuel Glover, PhD

Research Health Scientist

National Institute for Occupational Safety and Health

Division of Compensation Analysis and Support

May 2011

St. Louis, MO
Petition Overview

 Petition received on November 10, 2009

 Petitioner proposed class definition:

• All personnel who were internally monitored 

(urine or fecal), who worked at the Plutonium 

Finishing Plant in the 200 Area at the Hanford 

Site, from January 1, 1987 through 

December 31, 1989
Petition Overview—cont. 

 May 3, 2010: Petition qualified for 

evaluation

 Petition basis: Radiation monitoring 

records for members of the proposed class 

have been lost, falsified, or destroyed
Petition Overview—cont. 

 Three existing SEC classes previously enacted 

at Hanford:

1. October 1, 1943 through August 31, 1946, for 

selected areas of Hanford (SEC-00057-1)

2. September 1, 1946 through December 31, 1968, 

for selected areas of Hanford (SEC-00057-2)

3. October 1, 1943 through June 30, 1972, for all 

areas of Hanford (this class subsumed previous 

two classes; SEC-00152)
Petition Overview—cont. 

 SEC-0057 petition requested the SEC class 

be continued through 1990

• Advisory Board and NIOSH continue to review 

post 1972

 The timeframe associated with SEC-0155 

was encompassed by SEC-0057

 SEC-00155 was specific and focused on data 

falsification and was deemed appropriate 

for separate review
Petition Overview—cont.

 The petitioner’s specific evidence of 

accusations by the U.S. EPA of purposeful 

wrong doing by US Testing resulted in NIOSH 

determining that issues regarding quality of 

bioassay data required further investigation 

as a separate issue from the continuing Board 

evaluation of SEC 00057.

 The intent of NIOSH’s separate evaluation of 

SEC-00155 is to ensure that issues identified 

with UST’s non-bioassay analytical programs 

did not also adversely affect the company’s 

bioassay analysis operations in Richland, WA.
Sources of Available Information

 ORAU Team Technical Basis Documents (TBDs)

 ORAU Team Technical Information Bulletins (TIBs) 

and Procedures

 Interviews with eight former employees

 Existing claimant files

 Documentation provided by petitioner

 NIOSH Site Research Database (over 7500 

documents)

 Data captures at Hanford and Office of the 

Inspector General
Interviews

 Eight interviews with former workers

• None of the statements collaborated falsification 

of data from the radiobioassay program
Previous Dose Reconstructions

NIOSH OCAS Claims Tracking System 

Information available as of April 13, 2011

 Hanford claims submitted to NIOSH 4034

 Claims with employment during the period 

evaluated (1987-1989) 1347

 Claims containing internal dosimetry 914

 Claims containing external dosimetry 1310
Periods of NIOSH Evaluation

 NIOSH evaluated the time period requested 

by the petitioner January 1, 1987 through 

December 31, 1989

 While the location was specified as employees 

who worked at the Plutonium Finishing Plant, 

the evaluation was primarily focused on the 

program which applies to all of Hanford
Hanford Operations: 1987-1989

 Evaluation report does not repeat the 

discussions from evaluation reports for 

SEC-00057 and SEC-00152

 Describes activities at the Plutonium Finishing 

Plant during the time period in question

 Focus of the evaluation was data falsification 

and not source-term issues
Plutonium Finishing Plant: 1987-1989

 Weapons grade metal production, Remote 

Mechanical C Line

 Plutonium Reclamation Facility

 Miscellaneous treatment system glovebox 

operations

 Analytical laboratory operation

 Development laboratory operations

 Polycube processing (a polycube is a solid 

mixture of polystyrene and plutonium oxide)
Potential Radiation Exposures 

During the Class Period

 Internal sources of exposure

• Plutonium Finishing Plant contained broad 

spectrum of internal emitters (particularly 

plutonium and americium)

 External sources of exposure

• Not the driving force for this evaluation report

• Photon/beta exposure from the various 

activities at the Plutonium Finishing Plant

• Neutrons were also an exposure potential
Personal Monitoring Data

 Internal monitoring data

• US Testing processed several thousand bioassay 

samples during the period in question

– Urinalysis was the principal plutonium method

– Workers deemed to have a higher risk or those involved 

in potential incident may also have fecal samples

– Americium typically monitored with in-vivo counting 

methods

• Hanford maintained an extensive area monitoring 

program (not the focus of this review)

 External monitoring data

• Extensive monitoring results are available for 

beta/photon and neutron exposures
Background

 US Testing provided radioanalytical services to 

Hanford since 1965 (including bioassay)

 US Testing’s radioanalytical facilities were 

located in Richland, WA

• Richland facility also did non-radiological analyses

 US Testing also had another laboratory in 

Hoboken, NJ

• Performed non-radiological analyses
Background—cont.

 Pacific Northwest National Laboratories 

(PNNL) was responsible for overseeing the 

quality of the data produced by US Testing for 

Hanford from 1979 thru the 1991

• Quality assurance program included blind 

bioassay samples (~250 blanks and quality 

control during 1987 thru 1989)

• Annual reports during the time period of interest 

were reviewed by NIOSH as part of this 

evaluation
Background—cont.

 Additional information on US Testing audits

• PNNL conducted a lengthy procurement process prior 

to the award of the September 1988 contract with US 

Testing

– Included technical and quality assurance/quality control 

evaluations

– PNNL further evaluated the data quality provided by US 

Testing in the fall of 1989 and presented the results to 

Westinghouse Hanford Company, U.S. EPA, and the U.S. DOE, 

and State of Washington

• US Testing participated in on going external quality 

assessment programs conducted by the DOE 

Environmental Measurements Laboratory (EML) and 

the EPA intercomparison quality control programs
Background—cont.

 U.S. EPA suspended US Testing from federal contracts, 

April 25, 1990

• The notice of suspension alleges that the management of US 

Testing "conspired, directed, carried out, and otherwise 

condoned a scheme to defraud the United States Government" 

in its performance at facilities in Richland, Washington and 

Hoboken, New Jersey

• The notice also alleges that this scheme "resulted in the 

submission of false, inaccurate, and unreliable test results and 

data”

• Suspension was related to EPA’s investigation of US Testing as 

related to falsification of environmental (non-radiological) 

sample data

 US Testing admitted wrongdoing and pleaded guilty to a 

felony on April 17, 1991
Evaluations of US Testing

 The U.S. EPA’s suspension of US Testing caused U.S. 

DOE to order PNNL to review US Testing’s data 

quality

 Beginning in May 1990, PNNL conducted two 

separate activities

• Formal audit of past US Testing activities that included 

data traceability

• Three week on-site performance based technical 

oversight of current US Testing practices
Evaluations of US Testing—cont.

 June 1, 1990, PNNL and U.S. DOE announced the 

contract with US Testing was being terminated for 

default

• Termination was based on findings that US Testing had sent 

certain samples to its Hoboken facility without appropriate 

quality assurance as required by the Battelle contract

• US Testing billed the government through Battelle for these 

samples

• Samples were dioxin and total petroleum hydrocarbons 

(non-radiological)

 WHC, U.S. EPA, U.S. DOE and the State of Washington 

performed independent evaluations of US Testing 
Evaluations of US Testing—cont.

 University of Washington (Omenn Report) evaluated 

data from 1983 to 1990 from US Testing, focusing on in 

vitro bioassay data

 In 1992, PNNL summarized the series of reviews as they 

relate to the quality and usability of the US Testing data

 Report concluded that “the data produced under the 

Battelle contract with UST are technically supportable 

for the purposes for which they were collected” and “all 

activities performed to date support the technical 

credibility of the data provided by the UST Richland 

Laboratory.”

 No indication from any evaluation, audit or surveillance 

that the data from the US Testing Richland facility was 

technically compromised
Feasibility of Dose Reconstructions

 NIOSH found no support for an SEC based on 

falsification of data

 NIOSH and the Advisory Board continue to 

evaluate various SEC-related issues in the 1972 

to 1990 period
NIOSH Recommendation

 NIOSH has obtained numerous documents containing 

monitoring results, bioassay program audit reports, 

independent bioassay program data evaluations, as 

well as Hanford process and source-term information. 

• In addition, several individuals with first-hand knowledge of 

the contractor bioassay laboratory issues during the period 

under evaluation have been interviewed. 

• Employee-specific information provided through the EEOICPA 

claims process and Technical Basis Documents written by 

NIOSH have also been available for this evaluation. 

 Based on its analysis of these available resources, 

NIOSH found no part of the class under evaluation for 

which it cannot estimate radiation doses with sufficient 

accuracy.
NIOSH Recommendation—cont. 

Class Feasibility Health Endangerment

January 1, 1987 

to 

December 31, 1989

Yes N/A