HHS Special Exposure Cohort Determination: 

Grand Junction Facilities, Grand Junction, Colorado [SEC 00175]

U.S. Department of Health and Human Services Determination Concerning a 

Petition to Add Members to the Special Exposure Cohort

under the 

Energy Employees Occupational Illness Compensation Program Act of 2000 

Determination Concerning a Petition for Certain Employees from 

Grand Junction Facilities 

Grand Junction, Colorado
HHS Special Exposure Cohort Determination: 

Grand Junction, Grand Junction, Colorado [SEC 00175]

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I. Determination 

I, Alex M. Azar II, Secretary of Health and Human Services (Secretary) (HHS), have 

determined that the employees defined in Section II of this report do not meet the statutory 

criteria for addition to the Special Exposure Cohort (SEC), as authorized under the Energy 

Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA), 42 U.S.C. 

§ 7384q. 

June 21, 2018 [Signature on File] 

Date Alex M. Azar II, Secretary

 

II. Employee Class Definition

All employees who worked in any area of the Grand Junction Facilities in Grand 

Junction, Colorado, from January 1, 1986, through July 31, 2010. 

III. Decision Criteria and Recommendations

Pursuant to 42 U.S.C. § 7384q, to designate a class for addition to the SEC, the Secretary 

must determine, upon recommendation of the Advisory Board on Radiation and Worker 

Health (Board), that

(1) It is not feasible to estimate with sufficient accuracy the radiation dose that the class 

received; and

(2) There is a reasonable likelihood that such radiation dose may have endangered the 

health of members of the class.

The SEC final rule states in 42 C.F.R. § 83.13(c)(1) that it is feasible in two situations to 

estimate the radiation dose that the class received with sufficient accuracy. First, the rule 

states that radiation doses may be estimated with sufficient accuracy if the National Institute 

for Occupational Safety and Health (NIOSH) has established that it has access to sufficient 

information to estimate the maximum radiation dose for every type of cancer for which 

radiation doses are reconstructed that could have been incurred under plausible 

circumstances by any member of the class. Alternatively, radiation doses may be estimated 

with sufficient accuracy if NIOSH has established that it has access to sufficient information 

to estimate the radiation doses of members of the class more precisely than a maximum dose 

estimate.

In a letter dated October 25, 2017, the Board, pursuant to 42 U.S.C. § 7384q, agreed with the 

following NIOSH findings, effectively advising the Secretary that radiation doses can be 

reconstructed with sufficient accuracy for certain employees at the Grand Junction Facilities 

(GJF) in accordance with provisions of EEOICPA and the SEC final rule. 
HHS Special Exposure Cohort Determination: 

Grand Junction, Grand Junction, Colorado [SEC 00175]

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IV. Determination Findings

Feasibility of Estimating Radiation Doses with Sufficient Accuracy

The Secretary established the feasibility determination for the class of employees covered by 

this report based upon the findings summarized below: 

• The principle sources of internal radiation exposure during the post-1985 period were 

exposure to alpha emitting radionuclides, including radon, from source materials handled 

at the site. 

• NIOSH can estimate a bounding dose for GJF workers for the years 1986 through 1990, 

based on the regulatory limit for workplace airborne radioactivity. NIOSH obtained 

sufficient information about the site and sufficient air sampling and bioassay results to 

allow it to conclude that internal exposures during this time were bounded by exposure to 

the workplace limit on radioactive airborne concentration (called the maximum 

permissible concentration). 

• NIOSH concluded it will use personal bioassay results to reconstruct doses for claims 

where personal bioassay data existed, and can bound doses using 10 percent of the 

workplace limit on radioactive airborne contamination (called the derived Air 

concentration at that time) for claims that did not have personal bioassay data for the 

years 1991 through July 31, 2010. 

• The principle sources of external radiation exposure in the post-1985 period were photon 

and beta radiation from source material handled at the site. Neutron sources used by 

some workers at the site were also sources of exposure. 

• NIOSH has access to a compilation of external radiation dosimetry data for 1960 and 

later that NIOSH obtained during its research into GJF. NIOSH can use that data to 

prepare a coworker model for external doses and can use that model, when needed, to 

reconstruct external radiation doses for the period January 1, 1986, through July 31, 

2010. 

• NIOSH has established that it has access to sufficient information to: (1) estimate the 

maximum radiation dose, for every type of cancer for which radiation doses are 

reconstructed, that could have been incurred in plausible circumstances by any member 

of the class; or (2) estimate radiation doses more precisely than an estimate of maximum 

dose. Information in available resources is sufficient to estimate the maximum internal 

and external potential exposure to members of the evaluated class under plausible 

circumstances during the specified period, January 1, 1986, through July 31, 2010. 

• The Board concurred with NIOSH's determination that dose reconstruction is feasible for 

the evaluated class of GJF workers during the period from January 1, 1986, through July 

31, 2010, and therefore should not be added to the SEC. 
HHS Special Exposure Cohort Determination: 

Grand Junction, Grand Junction, Colorado [SEC 00175]

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Health Endangerment

Because the Secretary established that it is feasible to estimate with sufficient accuracy the

radiation doses encountered by GJF employees as specified in this class, a determination of 

health endangerment is not required. 

V. Effect of the Determination

Members of the class of employees covered by this determination and their survivors 

continue to be eligible to submit claims for compensation under EEOICPA. As required for 

cancer claims covering other Department of Energy and Atomic Weapons Employer 

employees (or Atomic Weapons Employees) not included in the SEC, qualified cancer 

claims under Part B of EEOICPA for members of this class will be adjudicated by the 

Department of Labor, in part, on the basis of radiation dose reconstructions, which will be 

conducted by NIOSH. 

VI. Administrative Review of Determination

The determination provided in this report may be subject to an administrative review within 

HHS, pursuant to 42 C.F.R. § 83.18(a). On the basis of such a review, if the Secretary 

decides to designate the class of employees covered by this determination, in part or in 

whole, as an addition to the SEC, the Secretary will transmit a new report to Congress 

providing the designation and the criteria and findings on which the decision was based.