Table 4. Continued

Job Location/Task Thorium Dust (dpm/M®) [| Thoron* (pCi/Liter)
Production Superintendent 69 48
Assistant Superintendent 75 4.7
Maintenance and Repair Supervisor 6 1.3
Receiving and Shipping 12 1.2
Control Laboratory 12 L9
Labor Crew 92 6.1
mee  inel 6 0.8
case, thoron exposure would not increase the assigned dose to and has not been included.

In addition to the assignment of internal dose based on the thorium dust values, the possibility of
ingestion of this material was also considered.

Details of how these data were applied are addressed in the appropriate sections of the report.

Dose Estimate

External Dose

External dose is received from radiation originating outside the body and is typically measured
by dosimetry worn on the body. Radiation dose measured on a film badge or a thermolumi-
nescent dosimeter (TLD) may have been delivered quickly (acute exposure) or slowly over

the period of time that the employee was exposed (chronic exposure). External dose records
received from the Department of Energy were reviewed and evaluated for the external dose
estimate. ‘The external dose to the brain was determined by using the dose calculated for the
thyroid.

For the purpose of estimating probability of causation, all doses are assumed to be acute.’

Radiation Type, Energy, and Exposure Geometry

Although there were no records indicating that } had ever been monitored, it was
assumed that he was routinely exposed to gamma radiation. The photon energy distribution
assumed for thorium is 25% 30-250 keV and 75% > 250 keV."° The external dose values were
converted to organ dose using a correction factor of 1.44 for 30-250 keV photons’ and 1.0 for
>250 keV photons.

Calculated Dose

It was assumed tha worked a 50-hour workweek, 50 weeks per year for the period
1958-1968. For the years 1969-1989, he was assumed to have worked the average number of
hours per week provided in Table 1, above, for 50 weeks per year.

In the HASL report for Lindsey Light, there are Job Analysis Sheets for each position that
worked. These indicate how much time is spent at different locations during an
8-hour shift. Table 5 below shows these data, which include the doses for both an 8-hour and
10-hour workday.
Table 5. External Exposure Data Used

DRAFT Page 8 of 19



Introduction

The Energy Employees Occupational [ness Compensation Program Act of 2000
(EEOICPA), Executive Order No. 13179, and the Radiation Dose Reconstruction Rule
(42 CFR 82)'

EEOICPA established a compensation program to provide a lump sum payment of $150,000 and
medical benefits as compensation to covered employees suffering from designated illnesses
incurred as a result of their exposure to ionizing radiation, beryllium, or silica while in the
performance of duty for the Department of Energy and certain of its vendors, contractors, and

, subcontractors. This legislation also provided for payment of compensation to certain survivors

of these covered employees.

In Presidential Executive Order No. 13179, the President designated the U.S. Department of
Labor to administer this program for claims by current and former employees of nuclear
weapons production facilities and their survivors who seek compensation for cancers caused by
radiation exposures sustained in the performance of duty. The Executive Order also directed the
Department of Health and Human Services to estimate (reconstruct) the radiation doses received
by these employees. The Department of Labor uses the reconstructed radiation dose in
evaluating whether the employee’s cancer was at least as likely as not related to employment at
the facilities covered by EEOICPA. To fulfill the responsibilities assigned to the Department of
Health and Human Services, the National Institute for Occupational Safety and Health’s
(NIOSH) Office of Compensation Analysis and Support (OCAS) completes dose reconstructions
using the methods described in the Radiation Dose Reconstruction Rule (42 CFR $2)! for the
Department of Labor’s use in making compensation decisions.

The Purpose of: Radiation Dose Reconstruction

A radiation dose reconstruction is used to estimate the radiation dose received by the specific
organ(s) in which a worker developed cancer, particularly when radiation monitoring data are
unavailable, incomplete, or of poor quality. Even in instances when radiation dosimetry data are
available, they rarely specify dose to an organ and often are based on monitoring procedures that
do not meet modern standards.

The basic principle of dose reconstruction is to characterize the occupational radiation
environment to which a worker was exposed using available worker and/or workplace
monitoring information. In cases where radiation exposures in the workplace environment
cannot be fully characterized based on available data, default values based on reasonable
scientific assumptions are used as substitutes.

EEOICPA recognized that the process of estimating radiation doses would require dealing with
uncertainties and limited data and thus required that the government establish methods for
arriving at reasonable estimates of radiation dose received by an individual who was not
monitored or inadequately monitored for exposures to radiation, or for whom exposure records
are missing or incomplete. To the extent that the science and data involve uncertainties, these
uncertainties are typically handled to the advantage, rather than to the detriment, of the claimant.
NIOSH has used the best available science to develop the methods and guidelines for dose

DRAPT Page 2 of 19



reported in Results ot the Indoor Radiological Survey at the W.R. Grace Co., Curtis Bay Site,
Baltimore, Maryland,’ conducted by the Oak Ridge National Laboratory in 1988. This value
was 91.4 microrem/hour, which was converted to annual doses and then divided according to
photon energies, as described above. These doses are provided in Table 6 below.

Table 6. Assigned Annual External Doses

Time Poriad Addressed

Annual Photon Dose

Annual Photon Dose

MTT TTT TTT

30-250 keV (rem) >250 keV (rem)
2.213 4.609
0.081 0.168
0.079 0.165
0.071 0.147
0.075 0.157
0.082 0.170
0.092 0.191
0.092 0.191
0.070 0.146
0.087 0.181
0.090 0.187
0.100 0.209
0.097 0,202
0.103 0.215
0.079 0,165
0.090 0.187
0.084 0.175
0.081 0.169

Table 6. Continued

Time Period Addressed

Annual Photon Dose

Annual Photon Dose

30-250 keV (rem) >250 keV (rem)
0.072 0.151
0.082. 0.171
0.082 0.171
0,082 0.171
9.082 0.171

The external dose assignment is considered claimant favorable for the following reasons:

¢ Lindsey Light and Chemical Company had been operating the site, processing monazite
sand in West Chicago since 1932, and had operated for 19 years at the time of the

DRAFT Page i2 of 19



Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Page 5 of 7

Special Exposure Cohort Petition — Form B
F Basis for Proposing that Records and Information are Inadequate for Individual Dose —
Complete Section F.

Complete at feast one of the following entries in this section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.1 We have attached either documents or statements provided by affidavit that indicate 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.
(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored.
OW Pak S of THE Mosh DPpse Rie CowSytecan
Reo: Mesh Pou CAKE
Tr CveAry Spe) THAT ao RECO) hele
FRO _ TO nGtsy Ar) Ho metus _ bad
bat Re TG Pad Fon J4sr Tae
AB.

F.2 O I/We have attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding monitoring, source, source term, or process
from the site where the employees worked.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have been lost, altered illegally, or destroyed.

Part F is continued on the following page.

Name or Social Security Number of First Petitioner: __



Ball Mill Operator

Task/Location |_ Total Time/Day (min) Dose Rate (mR/hr)
Loading Hopper 200 5
Unload at Discharge 15 5
Work at Dryer 200 2
Lunch and Breaks 45 0.1
Lockers 15 0.1
8-hour Total Dose 24.7 mR
10-hour Total Dose 30.9 mR.

Rotary Dryer

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Loading Buggies 90 5
Loading Dryer 64 2.5
Unloading Dryer 86 2.5
Loading Truck 18 2.5
General Area — Mill/Dryer 162 1.
Lunch and Breaks 47 0.1
Lockers 15 0.1
8-hour Total Dose 17.1 mR
10-hour Total Dose 21.4mR

Thorium Oxide Preparation

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Loading Trays into Furnace 12 15°
Unloading Trays 2 1.5
General Area — Prep Room 406 L4
General Area ~ Building 90 0.7
Lunch and Breaks 44 0.4
Lockers 15 0.1
8-hour Total Dose 11.0 mR.
10-hour Total Dose 13.8 mR

Thorium Sulphate

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
General Area - Press 100 1.2
General Area — Tank Area 200 23.4
General Area — Main Floor 180 1
Lunch and Breaks 44 0.1
Lockers 15 0.1
8-hour Total Dose 28.5 mR
10-hour Total Dose 35.7 mR

Pot Operator

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Dump Sand into Pot 15 2
Unload Sand Hopper 60 1.6
Unload Sand into Acid 30 2

DRAFT Page 9 of 19



Dose from Radiological Incidents
The record of the telephone interview was evaluated carefully by the dose reconstructor. The

telephone interview process did not indicate that there had been any incidents.

Uncertainty

For calculated external doses, point estimates (constant values) were input into the NIOSH-
Interactive RadioEpidemiological Program (NIOSH-IREP). Internal doses were applied as a
lognormal distribution with a geometric standard deviation of 1 245 X-ray doses were applied
as a normal distribution with a geometric standard deviation equal to 30% of the assigned dose.

Possible Overestimate of Radiation Dose

This dose estimate represents an overestimate « rue radiation dose. These
include claimant-favorable dose conversion factors to convert dose to the brain. More realistic
dose conversion factors would result in lower estimated external and medical X-ray doses.
Claimant-favorable assumptions were also used to develop a hypothetical intake. More
realistic assumptions would result in a lower estimated dose to the brain. Estimated missed
doses are likely larger than any doses that were unmonitored or unrecorded.

Summary
may ew meeeeed was exposed to various sources of radiation during his employment and
his estimated dose was rem to the brain. The reported dose is an overestimate
of occupational radiation dose which will support claim determination.

Attachment 1 contains the IREP dose reconstruction summary sheets that will be used
by the Department of Labor to make the final probability of causation determination of
the claim.

References

1. 42 CFR 82, Methods for Radiation Dose Reconstruction Under the Energy Employees
Occupational Iliness Compensation Program Act of 2000; Final Rule, Federal
Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22314, SRDB Reference ID 19392.

2. 42 CFR 81, Guidelines for Determining the Probability of Causation Under the Energy
Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal
Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22296, SRDB Reference ID 19391.

3. NIOSH, (2007) Radiation Exposures Covered for Dose Reconstructions under Part B of
the Energy Employees Occupational Illness Compensation Program Act, Rev 0, OCAS-
IG-003, National Institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio, SRDB Reference ID 35987.

DRAFT Page 15 of 19


45

Lunch and Breaks O41
Lockers 15 0.1
8-hour Total Dose 17.6 mR.
10-hour Total Dose 22.0 mR.
Thorium Nitrate Mold Crusher

Task/Location Total Time/Day (min) Dose Rate (mR/hr)_
Crushing Mold in Hood 216 4
General Area — Cascade Room 204 2.5
Lunch and Breaks 45 0.1
Lockers 15 0.1
8-hour Total Dose 22.8 mR
10-hour Total Dose 28.5 mR.

Hydroxide Dryer

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Unload Hydroxide into Drum 101 12
Load Wet Hydroxide into Pans 146 12
Load Pans into Dryer 38 1.2
Cleanup 6 0.6
General Area ~ Dryer Area 166 0.6
Lunch and Breaks 45 0.4
Lockers 15 0.1
8-hour Total Dose 59.3 mR
10-hour Total Dose 74.1 mR

Thorium Nitrate Crystallization

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Load Mixing Bottle 36 20
General Area — Prep Room 384 L4
Lunch and Breaks 45 04
Lockers 15 0.1
8-hour Total Dose 101.7 mR
10-hour Total Dose 128.0 mR

Rare Earth Rotary Dryer

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Shoveling into Dryer 52 12
Charging Grinding Hopper 224 0.25
Discharging into Drum 24 0.4
General Area — Main Floor 120 0.6
Lunch and Breaks 45 0.1
Lockers 15 0.1
8-hour Total Dose 3.3mR
10-hour Total Dose 4.3 mR

The covered period of employment was 1955-1958. Site records indicate that the thorium-
bearing material was removed and buried in 1957 and 1958. External doses for the remaining
period of employment were based on the mean reported dose for all areas of Building 23, as

DRAFT Page 11 of 19



1

: According to the information contained in the document, Thorium: fis Industrial Hygiene

Aspects,’ the most commonly used process in the United States for the processing ‘of monazite
sand was sulfuric acid digestion. According to the report from HASL,* this appears to

have been the main method employed at Lindsey Light. The job titles fo as
provided in the DOL files, are consistent with those at Lindsey Light. ‘Therefore, the assignment
of doses from the larger more nenductive Lindsey Light facility should provide a claimant-
favorable estimation ¢ dose.

Additional claimant-favorable assumptions were applied. Specific pnt were applied to
calculated doses in order to assign organ dose_based on information in|the External Dose Recon-
struction Implementation Guideline’ and the Internal Dose Reconstruction Implementation
Guideline.’ ORAUT Technical Information Bulletins were also used in this dose reconstruction

(see References). |

In addition to the above information, the record of the computer assisted telephone interview was
reviewed carefully by the dose reconstructor. The information provided was considered in the
dose estimation process. Additional information on the evaluation of ths interview is provided in
subsequent sections of this report, as applicable. |
In the absence of monitoring information fc data were ustd from the HASL report,
based on the job descriptions or work areas provided by DOL. These are provided in Table 2
below.

|

Table 2. Jobs and/or Work Locations |

Ball Mill Operator Rotary Dryer Operator_{ Thoriunh Oxide Preparation
Thorium Sulphate : Pot Operator Dissolving Operator
Thorium Extraction. Press Operator Cascade Operator

Thorium Nitrate Mold Crusher xide Dryer

Rare Earth Rotary Dryer

External gamma doses, based on locations around the various corresponding work locations at
the Lindsey Light facility, have been provided in Table 3 below. \

Table 3. External Doses Based on Plant Locatign”?

Location Gamma Dose (mrem/hr)

Thorium Nitrate Drums - Top 20.0
Thorium Nitrate Drums — Side (6 inches) 20.0
Lanthanum Treating Room (3-foot Level) 14
Center of Furnace Room (Floor Level) 1.5
Center of Furnace Room (3-foot Level) 0.7
Men’s Locker Room, Center (3-foot Level) 0.1
Pot Area, Near Basket (Floor Level) 2.0
Pot Area, Front of Sand Hopper (3-foot Level) 1.6
Pot Area, Bucket of Sand (1 foot) 2.0
Black Mud Press (Floor Level) 9.0

|

| DRAFT Page 6 of 19

i

|

i



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
{ness Compensation Act National institute for Occupational Safety and Health

. OMB Number: 0920-0639 Expires: 09/20/2013
Petitioner Authorization Form Page 2 of 2

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 3 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

The Energy Employees Occupational liiness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 “Occupational Health Epidemiological Studies and EEOICPA Program Records.
HHS/CDC/NIOSH.” These records are treated in a confidential manner, unless otherwise compelled by law.
Disclosures that NIOSH may need to make for the processing of your petition or other purposes are listed
below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations,
(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a
Congressional staff member in response to a verified inquiry.

This notice applies to afl forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of this form is voluntary. Failure to use this form will not result in the denial of any right, benefit, or
privilege to which you may be entitled.

Name or Social Security Number of First Petitioner:


ST ee

‘

ATTACHMENT 1: IREP Input Tables

: : : DRAFT Page 18 of 19
i :


Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
NIness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

Ork Prk Porm pou Coren Tas See
REQ IS THeT Then 15 ANEAOY  PAUHEN,
FOO WR GRACE  Ppatinam on RECO).
SEU AUN , DAG OITA PrAng TO The
Cyime  Bks” fag, on Seartaccg _s¢
RUYR ow Tre S22  bisy Syne
Tas Pnstasir Of RAD AINA PUTA
Rw WAC Or ons.

Baty Pptanty pga Cons TARA hapa “THAT
Asx Te TEM Fatal, OnG bev
biter They Coit eAUUnES ANE
CABO OME) for SEC

[aaa

Attach to Form B if necessary.

Name or Social Security Number of First Petitioner:



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
\liness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 6 of 7

F.3. Q IWehave attached a report from a heaith physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
tadiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation

guidelines.
(Attach report to the back of the petition form.)

F.4 A We have attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (due to either a lack
of monitoring or the destruction or loss of records) for estimating the radiation doses of
employees covered by the petition.

(Attach report to the back of the petition form.)

— —

Go to Part G.

Signature of Person(s) Submitting this Petition —- Complete Section G.

All. ion. A maximum of three persons may sign the petition.
/a//a.Ho
oe Date
Signature Date
Signature Date
Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of

fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true.

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Lr SSS SS SS SSSA
if there are additional petitioners, they must complete the Appendix Forms for additional petitioners.

The Appendix forms are located at the end of this document.

Name or Social Security Number of First Petitioner: _


Table 3. Continued

Location Gamma Dose (mrem/hr) _
Bottom Pan Under Black Mud Press 10.0
Around Second Gray Mud Press (Floor Level) 3.0
Barrel of First Gray Mud — Side (6 inches) 7.0
Red Mud Dissolving Tank — Side (6 inches) 6.5
Between Rare Earth Dryers (3-foot Level) 0.6
Deep Rare Earth Hydrate in Tray 1.2
Front of Feed End, Rare Earth Dryers (Floor Level) 0.25
Discharge End, Rare Earth Dryers (Floor Level) 0.4
Front of Elevator — Balcony (General Area -- 3-foot Level) 1.8
Front of Thorium Nitrate Kettles (3-foot Level) : 4.0
Table at End of Cascade 2.5
Front of Mold Crusher (Floor Level) 4.0
Thorium Extraction Filter Press (Floor Level) 4.0
Ball Mill Discharge — Side 4.5
Mall Mill Charger Hopper 45
Charger Dryer 15

Data for the Daily Weighted Averages of inhaled thorium dust and thoron, based on job location,

are provided in Table 4 below.

Table 4. Daily Weighted Averages of Thorium Dust and Thoron Gas, Based on Job Location’?

Job Location/Task Thorium Dust (dpm/M*) | Thoron* (pCi/Liter)
Ball Mill : 560 64
Rotary Dryer 870 6.4
Pot Operator 2000 7.5
Pot Diggers 330 TS
Press Operator 110 5.2.
Press Foreman 90 3.0
Thorium Oxide Preparation 510 5.9
Thorium Nitrate Crystallization 40 2.8
Rare Earth Rotary Dryer 1300 10.4
Hydroxide Dryer 280 10.5
Thorium Sulphate 110 9.7
Thorium Extraction 180 20.0
Dissolving Operator 220 20.2
Cascade Operator 14 16.0
Thorium Nitrate Mold Crusher 18 15.2
Chemical Operator Foreman 150 14.2
Maintenance and Repair (maximum) 130 10.0
Other Personnel (non-thorium)_ 33 3.9
Plant Gunarintendent 23 2.0

zase, thoron exposure would not increase the assigned dose to’

DRAFT Page 7 of 19

ind has not been included.


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupationat Centers for Disease Contro! and Prevention

ltness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 09/20/2013
Page 1 of 2

Petitioner Authorization Form

lose:

Instructions:

If you wish to petition HHS to consider adding a class of employees to the Special Exposure Cohort and you
ate NOT either a member of that class, a survivor of a member of that class, or a labor organization
representing or having represented members of that class, then 42 CFR Part 83, Section 83.7(c) requires
that you obtain written authorization. You can obtain such authorization from either an employee who is a
member of the class or a survivor of such an employee. You may use this form to obtain such authorization
and submit the completed form to NIOSH with the related petition. Please print legibly.

For Further Information: If you have questions about these instructions, please call the following NIOSH
toll-free phone number and request to speak to someone in the Division of Compensation Analysis and
Support about an SEC petition: 1-877-222-8570.

Authorization for Individual or Entity to Petition HHS on Behalf of a Class of Employees for

Addition to the Special Exposure Cohort

4,
Name of Class Member or Survivor

Street Address of Class Member or Survivor Apt. # P.O. Box

City, State, Zip Code of Class Member or Survivor

Ratdenan af Datitinnar ant. # P.O. Box

City, State and Zip Code ot Petitioner
to petition the Department of Health and Human Services on behalf of a class of employees

ttn ‘

Name of Class Member (employee, not the employee's survivor)

for the addition of the class to the Special Exposure Cohort, under the Energy Employee’s
Occupational iliness Compensation Program Act (42 U.S.C. §§ 7384-7385).

In providing this authorization, | recognize that the petitioner named above will have all the rights
Af a natitinnar oe navidad far under A? CER Part 83.
lahalp

Pata



HASL suryey. Fixed contamination, which would impact the external dose, would be
significantly higher than anything encountered at the Curtis Bay site.

© During the year that the Curtis Bay site processed thorium, less than 1000 tons was
processed, During the period 1932-1973, the West Chicago site processed 136,000 tons,
or an average of more than 3,300 tons per year. The volume of material processed at
Curtis Bay would have resulted in lower external doses,

* The doses assigned for the residual period were based on the highest external dose found
on the first floor of Building 23, where the Ball Mill was located. While on the same
floor, the location was not in the immediate vicinity of the Ball Mill or the Dryer Area.
The actual doses whict would have received would be considerably smaller.

Occupational Medical Dose

In addition to the estimated dose received from site operations, the dose received from diag-
nostic X-ray procedures that were required as a condition of employment was also included in
the overall dose to the brain. Based on information in Table 6.5 of the Technical Information
Bulletin: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures’ and
an assumed annual X-ray procedure each year of. employment through the operational period
(1955-1958), a total X-ray dose of 0.026 rem was assigned. This X-ray dose is considered
claimant favorable as it likely exceeds the true X-ray dose to the brain.

Internal Dose

Radioactive materials taken into the body cause internal dose. A chronic intake of radioactive
material occurs over an extended period (weeks or longer) and an acute intake occurs over a
short period (minutes to hours). Regardless of the rate at which the intake occurs, the internal
dose received from radioactive materials having long half-lives occurs over an extended period
and is considered chronic.

The Integrated Modules for Bioassay Analysis (IMBA) was used to estimate intakes of radio-
active material and annual organ doses. The ICRP 66 lung model (with default aerosol charac-
teristics with the ICRP 68 metabolic models) was used. Intake dates, scenarios, and levels
were based upon mathematical models and do not prove that the intakes occurred on the given
dates. These dates and scenarios provide an acceptable explanation of exposure and dose based
upon the bioassay data provided.'* No records of bioassay monitoring results were found for
Mr. Ellison.

As stated above, dust monitoring information was used to determine internal
dose, The daily weighted average for all the jobs which worked was tabulated and
the mean of 597.308 dpm/cubic meter was established,’ based on a 10-hour workday. All
samples performed by HASL have been subjected to Monte Carlo analysis to determine the
geometric standard deviation (GSD) of 1.24 used in this dose reconstruction. This assessment
is considered claimant favorable based on the following reasons:

e Lindsey Light and Chemical Company had been operating the site, processing monazite
sand in West Chicago since 1932, and had operated for 19 years at the time of the HASL

DRAFT Page 13 of 19



under the Energy Employees Occupational ( Centers for Disease Control and Prevention
IItness Compensation Act National Institute for Occupational Safety and Health

12-2). PMB, Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Pill Reyp Page 1 of 7

Use of this form and disclosure of Social Security Number are voluntary. Failure to use this form or disclose
this number will not result in the denial of any right, benefit, or privilege to which you may be entitled.

Special Exposure Cohort Petition 3 U.S. Department of Health and Human Services

General Instructions on Completing this Form (complete instructions are available in a separate packet):

Except for signatures, please PRINT all information clearly and neatly on the form.
if

Please read each of Parts A — G in this form and complete the parts appropriate to you. If there is more
than one petitioner, then each petitioner should complete those sections of parts A—C of the form that apply
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-

pose. A maximum of three petitioners is allowed.
If you need more space to provide additional information, use the Continuation page provided at the end of
the form and attach the completed continuation page(s) to Form Bi

|
If you have questions about the use of this form, please call the following NIOSH toll-free phone number and
request to speak to someone in the Office of Compensation Analy: is and Support about an SEC petition:

1-877-222-8570.

OA Labor Organization, [. StartatD on Page 3
If you O An Energy Employee (current or former), | Start atC on Page 2
are: QA Survivor (of a former Energy Employee), | Start atB on Page 2
MA Representative (of a current or former Energy Etployee), StartatA on Page 1

Representative Information — Complete Section A if you are authorized by an Employee or
Survivor(s) to petition on behalf of a class.

Are you a contact person for an organization? Q Yes! (Go to A.2) w No (Go to A.3)

A2 Organization Information:

Name of Organization

Position of Contact Person
A.3 Name of Petition Representative:

Mr/Mrs./Ms. First Name Middle Initial Last Name
A4  Addrose:

Ctrant T Ant # P.O. Box

pss ;

City State | Zip Code
A. Telephone Numbe

A6 Email Address:

A7 Check the box at left to indicate you have attached tothe back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in!Parts B or C of this form. An authorization

If you are representing a Survivor, go to Part B; if you are representing an Employee, go to Part C.

Name or Social Security Number of First Petitio: ,
a 4
\



/

4

Page 2 ‘

Once we receive the signed OCAS-1 form from you, we will send the final copy of the dose
reconstruction report to the DOL for adjudication of your claim. We will also send you and the
Department of Energy a copy of the final dose reconstruction report. It is important that you return
the properly signed OCAS-1 form to us within the above-described time frame so that there is no
delay in the adjudication of your claim. We will not forward the dose reconstruction report to DOL
for adjudication without-teceipt of a properly signed OCAS-1 form. If we do not receive the
OCAS-1 form within ‘the time frame described above, we may administratively close the dose
reconstruction and notify DOL of this action. PLEASE USE THE ENCLOSED PRE-
ADDRESSED, POSTAGE-PAID ENVELOPE TO RETURN THE SIGNED OCAS-1 FORM TO US.

If you have any additional questions regarding the revised dose reconstruction report, please
contact our dose reconstruction contractor, Oak Ridge Associated Universities, toll-free at 1-800-
322-0111.

Sincerely yours,

Apkithsth-

Larry J. Elliott
Director
Office of Compensation Analysis and Support

Enclosures

cc:


a

SE DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
NIOSH Tracking Numbe: : National Institute for Occupational
Safety and Health
Robert A. Taft Laboratories
4676 Columbia Parkway

Cincinnati, OH 45226-1998
Phone: 513-533-6800
Fax. 513-633-6817

July 2, 2009

Deai

This ietter is to provide you with information on the status of the dose reconstruction for the claim
yu filed under the Energy Employees Occupational Iliness Compensation Program Act (NIOSH
Tracking Number 5148).

The tional __Institute for cupational fe \d_Health’s (NIOSH) __Office of
Compensation Analysis and Support (0: S_CO! a revi reconstruction of
the radiation dose based upon additional relevant information that NIOSH_has obtained.
Enclosed you will find a copy of a revised Draft NIOSH Report of Dose Reconstruction under the
Energy Employees Occupational Iliness Compensation Program Act (EEOICPA) that supercedes
any previous dose reconstruction reports we have sent you. During the next two weeks, we will
attempt to contact you to schedule a convenient date and time for conducting a new closing
interview with you. The purpose of the closing interview is to review the revised dose
reconstruction results and the basis on which the results were calculated. This will be the final
opportunity during the dose reconstruction process for you to provide additional relevant
information that may affect the dose reconstruction or indicate that you are in the process of
obtaining such information. To facilitate the scheduling of the interview, you can contact us at the
following telephone number 1-800-790-6728 (1-800-790-ORAU). if, after three weeks from the
date of this letter, we have not heard back from you regarding a convenient time to schedule the
interview, then we will assume that you have decided not to participate in the interview.

We have also enclosed a copy of a form (OCAS-1) that should be signed and returned to us
within 60 days. You should sign and return this form even though you may have previously signed

ind returned a similar form after reviewing a previous version of a draft dose reconstruction
report. Your signature on this form certifies that you agree with the following statements: 1) you
are not aware of any additional information that may be relevant to the dose reconstruction; 2) you
have reviewed the revised draft dose reconstruction report and agree that it identifies all of the
relevant information you provided to NIOSH regarding the dose reconstruction; and 3) the revised
dose reconstruction report is ready to be forwarded to the Department of Labor (DOL) for a
determination regarding your claim. Your signature on this form is not an indication that you
agree with the decisions NIOSH made concerning how to use or not use information you provided
for dose reconstruction or that you agree with the findings of the NIOSH dose reconstruction.
DOL’s Office of Workers’ Compensation Programs (OWCP) will notify you of any action that it
may take regarding your claim, and of any rights you may have to raise objections. You will have
an opportunity to raise objections to the final NIOSH Dose Reconstruction Report under
EEOICPA following your receipt of a copy of the recommended decision on your claim from DOL
by following the procedures described in the notice accompanying the recommended decision.



DRAFT Page 19 of 19



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Niness Compensation Act National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 7 of 7

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 300 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information cotlected on this form unless it displays a currently

valid OMB number.

Privacy Act Advisement

{n accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

The Energy Employees Occupational lliness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 “Occupational Health Epidemiological Studies and EEOICPA Program Records.
HHS/CDC/NIOSH.” These records are treated in a confidential manner, unless otherwise compelled by law.
Disclosures that NIOSH may need to make for the processing of your petition or other purposes are listed

below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations;
(e) Federal, state and local agencies for jaw enforcement purposes; and (f) a Member of Congress or a
Congressional staff member in response to a verified inquiry.

This notice applies to all forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these
forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to

provide required information may not be considered by HHS.

Name or Social Security Number of First Petitioner: _ __



‘

General Area — Pot Area 375 1.6
Lunch and Breaks 44 0.1
Lockers 15 0.1
8-hour Total Dose 13.2 mR
10-hour Total Dose 16.5 mR
Dissolving Operator

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
General Area — Stirring Battery 60 4
General Area - Main Floor 210 2
General Area — Balcony 210 1.8
Lunch and Breaks 45 0.1
Lockers 15 01
8-hour Total Dose 17.4 mR
10-hour Total Dose 21.8 mR

Thorium Extraction

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
General Area ~ Press 100 1.2
Cleaning Mud 39 1.2
Load Mud into Drum 6 5.5
General Area -- Main Floor 170 2
General Area — Balcony 165 18
Lunch and Breaks 45 0.1
Lockers 15 0.1
8-hour Total Dose 14.1 mR
10-hour Total Dose 17.8 mR

> Press Operator

Task/Location Total Time/Day (min) Dose Rate (mR/hr)
Cleaning Press — Black Mud 34 10
Loading Black Mud into Drum 8 9
Cleaning Press — 1" Gray Mud 66 3
Loading 1 Gray Mud into Drum 40 7
Cleaning Press — 2"! Gray Mud 24 3
Loading 2TM Gray Mud into Drum 12 7
Cleaning Press — Red Mud 46 7
Loading 2" Gray Mud into Drum 48 6.5
General Area — Press Area 362 3

Press Operator (continued)
General Area — Under Press 200 3
Lunch and Breaks 45 0.4
Lockers 15 0.1
8-hour Total Dose 56.6 mR
10-hour Total Dose 70.8 mR
Cascade Operator

Task/Location Total Time/Day (min) Dose Rate (mR/hr)

General Area — Cascade Room 420 2.5

DRAFT Page 10 of 19



10.

12.

13.

14.

NIOSH, (2007) External Dose Reconstruction Implementation Guideline, Rev 3, OCAS-
1G-001, National Institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio, SRDB Reference ID 38864.

NIOSH, (2002) Internal Dose Reconstruction Implementation Guideline, Rev 0, OCAS-
IG-002, National Institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio, SRDB Reference ID 22402.

ORNL (Oak Ridge National Laboratory), 1989, Results of the Indoor Radiological
Survey at the W.R. Grace Co., Curtis Bay Site, Baltimore, Maryland, ORNL/TM-10439,
Oak Ridge, Tennessee, SRDB Reference ID 7188.

ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0006, Technical
Information Bulletin: Dose Reconstruction from Occupationally Related Diagnostic
X-Ray Procedures, Rev 03 PC-1, December 21, 2005, SRDB Reference ID 20220.

Battelle Memorial Institute, Battelle-TIB-5000/PNWD-3741, Technical Information
Bulletin: Default Assumptions and Methods for Atomic Weapons Employer Dose
Reconstructions, Rev 00, April 2, 2007, SRDB Reference ID 32016.

Albert RE, 1966, Thorium: Its Industrial Hygiene Aspects, Academic Press, New York,
New York, SRDB Reference ID 46367.

Morgan JN, Faust LG, 1964, A Comparison of Theoretical and Measured Dose Rates of
Thorium and Thorium Oxide, HW-83284 (Radiological Development and Calibrations,
Hanford Laboratories), General Electric, Richland, Washington, July 15, SRDB
Reference ID 46086.

ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0005, Technical
Information Bulletin: Internal Dosimetry Organ, External Dosimetry Organ, and IREP
Model Selection by ICD-9 Code, Rev 02 PC-1, February 10, 2006, SRDB Reference

ID 22595,

AEC (U.S, Atomic Energy Commission), 1953, Occupational Exposure to Thorium Dust
and Thoron (Industrial Hygiene Survey — Part I), Lindsey Chemical Company (Health
and Safety Division, Industrial Hygiene Branch), U.S. Atomic Energy Commission,
Washington DC, SRDB Reference ID 9068.

ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0017-6, Technical
Basis Document for the Fernald Environmental Management Project — Occupational
External Dose, Rev 00, April 20, 2004, SRDB Reference ID 19486. .

ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0070, Dose

Reconstruction during Residual Radioactivity Periods at Atomic Weapons Employer
Facilities, Rev 00, March 10, 2008, SRDB Reference ID 41603.

DRAFT Page 16 of 19


Special Exposure Cohort Petition ‘ U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
iiness Compensation Act National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B

Labor Organization information — Complete Section D ONLY if you are a labor organi
D1 Labor Organization mormon

Name of Organization

Position of Contact Person
D.2 Name of Petition! Representative: 4

D3 Address6f Petition Representatwe:

Streét J

City State

employees (if known):

Go to Part E.

Name or Sacial Security Number of First Petitioner:


reconstruction. These methods have been reviewed and commented upon by the public,
including experts in the field of dose reconstruction, and the Presidentially-appointed Advisory
Board on Radiation and Worker Health.

How Radiation Doses Are Reconstructed

NIOSH reconstructs radiation doses by evaluating all available, appropriate data relevant to the
employee’s radiation exposure. Some examples of data that may be included in the dose
reconstruction include, but are not limited to, internal dosimetry (such as results from urinalysis),
external dosimetry data (such as film badge readings), workplace monitoring data (such as air
sample results), workplace characterization data (such as type and amount of radioactive material
processed), and descriptions of the type of work performed at the work location.’

Although the specific methods used for each dose reconstruction may vary, after a claim has
been referred by the Department of Labor to NIOSH for a dose reconstruction, NIOSH typically
requests the worker’s personal radiation monitoring information from the Department of Energy.
Upon receipt of the requested information, at least one voluntary informational interview with
the claimant and/or survivors is conducted and a copy of the interview report is sent for review.
After all of the necessary and available information is gathered, a dose is estimated, using the
methods in the Radiation Dose Reconstruction Rule. After a NIOSH health physicist reviews the
information, methods, and results, the claimant receives a draft copy of the dose reconstruction
report followed by a concluding interview, during which the claimant can add any additional
relevant information that may affect the dose reconstruction. If the claimant certifies that he/she
has completed providing information and that the record for dose reconstruction should be
closed, a final dose reconstruction report is sent to the claimant, the Department of Labor, and
the Department of Energy.

As applied in the EEOICPA, dose reconstructions must rely on information that can be
developed on a timely basis and on carefully stated assumptions. Therefore, the guiding
principle in conducting these dose reconstructions is to ensure that the assumptions used are fair,
consistent, and well-grounded in the best available science, while ensuring that uncertainties in
the science and data are handled to the advantage, rather than to the detriment, of the claim when
feasible. When dose information is not available, is very limited, or the dose of record is very
low, NIOSH may use the highest reasonably possible radiation dose, based on reliable science,
documented experience, and relevant data, to complete a claimant’s dose reconstruction, In
other instances, NIOSH may not need to complete fully a dose reconstruction because a partial
dose reconstruction results in an estimated dose which produces a probability of causation of
50% or greater,

How Radiation Dose Reconstructions Are Used in Final Compensation Determinations
The results of an employee’s dose reconstruction are used by the Department of Labor to
determine the probability that a worker’s cancer was “at least as likely as not” due to his/her
occupational exposure to ionizing radiation during employment at a covered facility. Criteria and
guidelines for making this determination are established by EEOICPA and the Probability of
Causation Guidelines (42 CFR 81).? The dose reconstruction is not the final determination of a
claim, but rather an interim product that is used by the Department of Labor in making its final

DRAFT Page 3 of 19


Information Used

As indicated abov vas employed prior to, throughout, and after the period during
which W.R. Grace and Company was contracted by the Atomic Energy Commission (AEC)
to process monazite sand in order to extract thorium. This dose reconstruction addresses the
operation period (1955 through 1958) and the residual radiation perio.

No records were found to indicat
monitored during his employment. Therefore, during the portion of this dose reconstruction
addressing the operational period, the primary data source was a survey performed by the
Industrial Hygiene Branch, Health and Safety Laboratory GIASL) of the AEC New York
Operations Office, in September 1952 (published in 1953)" at the Lindsey Light Company
in West Chicago, Illinois. This site was the largest of the thorium extraction facilities operated
for the AEC and had been operating as a commercial entity since 1932. The data provided
by Lindsey Light will likely be claimant favorable when compared to the actual operating
conditions which could be expected at the Curtis Bay facility. Another data source used is the
Results of the Indoor Radiological Survey at the W.R. Grace Co., Curtis Bay Site, Baltimore,
Maryland §

‘ DRAFT Page 5 of 19


Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention | +
{iness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B

Proposed Definition of Employee Class Covered by Petition — Complete Section E.
E41  NameofDOE or AWE Facility: (AG euce - 5
£.2 Locations 4 fit the F Facilit fevant to this

SPEG sy y

ON AS PY Liars, Waa Cévtiite
Boliacee V2bI93 Bie f- BLE

E.3 List job titles and/or job duties of employees included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be

included in this class: CWENEA L YE LAT Of
Ball Mill, Por Qheerroe Kata Ler Aacaay Lryer

Lift Macpiees, Marra Mie C5reves, WDE
E.4 EmiSeent Dated AGIA to tne Sette (dares ¢ at, me Wp aree! be.
stat ___ /753_ end _/GHO
Start End
Start End
E.5 Js the petition based on one or moreyunmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: Yes Q No

If yes, provide the date(s) of the incident(s) and a complete description (attach additional pages
as necessary):

ALL Wwoad PRR@D AT THR WR. CRACE
Prauuty, jn Wem BAY MARYA) Beri!
19.52 - fo his Comme bnaet THY oie
OF POSf Meme Badilhtrag 0 At
Momtempy., Diy MAS O08 STMeyh o@ Pruiiieh.

Go to Part F.

Name or Social Security Number of First Petitione’



survey. Fixed contamination (which would impact the external dose) and dust buildup in
and around the equipment (which would impact the internal dose) would be significantly
higher than anything encountered at the Curtis Bay site.

© During the year that the Curtis Bay site processed thorium, less than 1000 tons was
processed, During the period 1932-1973, the West Chicago site processed 136,000 tons,
or an average of more than 3,300 tons per year.

Inhalation intake values were based on an assumed breathing rate of 12 cubic meters per day,’
for 250 working days per year. Ingestion intake values are 20% of the values for the daily
weighted average assumed for inhalation.'* Intake rates for the residual period were based on the
operational period values and adjustment factors from Dose Reconstruction during Residual
Radioactivity Periods at Atomic Weapons Employer Facilities.\*

Table 7. Assigned Annual Internal Intakes of Thorium-232, Thorium 228, and Radium-228

I Time Period | Adjustment Factors Annual Inhalation Annual Ingestion
— ~_|_ for Residual Period!* Intake (dpm/year) Intake (dpm/year)

Not applicable 716769.2 14908.8

0.03 21503.08 447.264

0.007 5017.385 104.3616

0.007 4846.632 100.8099

0.007 4314.951 89.75098

0.007 4590.907 95.49086

0.007 4977.001 103.5216

0.007 5591.771 116.3088

0.007 5591.875 116.311

> 0.007 4271.619 88.84967

0.007 5293.341 110.1015

0.007 5483.061 114.0477

Table 7. Continued

Time Period | Adjustment Factors Annual Inhalation Annual Ingestion
as . for Residual Period'* Intake (dpm/year) Intake (dpm/year)
[ 0.007 6126.784 127.4371
[ 0.007 5904.549 122.8146
r 0.007 6302.393 131.0898
[ 0.007 4819.961 100.2552
[ 0.007 $472,085 113.8194
0,007 5130.276 106.7097
[ 0.007 4944.054 102.8363
i. 0.007 4415.298 91.83821
0.007 5017.385 104.3616
The total internal dose t< was determined to t rem.

DRAFT Page 14 of 19


Special Exposure Cohort Petition ' U.S. Department of Health and Human Services
under the Energy Employees Occupational : Centers for Disease Control and Prevention | «

IIness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 2 of 7

Survivor Information — Complete Section B if you are a Survivor or representing a Survivor.

B.1 Name of Survivor:

Middle Initial Last Name
B.2
B.3
‘Apt # P.O. Box
i State VA Zip Code
B.4 rof Survivor: ) 2
B
B.6 Q Spouse Q Son/Daughter Q Parent
Q Grandparent Q Grandchild
Go to Part C. _

Employee Information — Complete Section C UNLESS you are a labor organization.

C1 Name of Emplc

Mr/Mrs./Ms. First Nafne Middle Initial Last Name
C.2. Former Name of Employee (e.g., maiden name/legal name change/other):

Mr./Mrs./Ms. First Name Micaia tnitint Inet Name

C.3 Social Security Number of Employee: __

C.4 Address of F-ntar--~ 44 hina
Street ~ ~ O. Box
City ~~ State ; Zip Code

C.5 Telephone Number of Employer _
C.6 Email Address of Employee: _

C.7 Employment Information Related to Petition:
C.7a Employee Number (if known):

C.7b Dates of Employment: Start WES End _ A GS: g
C.7c¢ Employer Name: Wk GRACE
C.7d Work Site Location, _Cyeris Bay (MD

C.7e Supervisor's Name:

L _ —— = —
Gunes

Name or Social Security Number of First Petitioner

,


15.

Shleien Bernard, Slaback Jr Lester A, Birky Brian Kent, editors, 1998, Handbook of
Health Physics and Radiological Health, 3 ed, Baltimore: Williams & Wilkins, p 10-15,
10-16, SRDB Reference ID 22737.

DRAFT Page 17 of 19



NIOSH

NIOSH Report of Dose Reconstruction under the
Energy Employees Occupational IlIness Compensation
Program Act (EEOICPA)

OCAS

Cleveland
Energy Employe
Name:
Law, dust Aliddte Daie of Birth
Covered
Employment: W.R. Grace and Company
Curtis Bay, MD
Dates Location
Cancer:
Dp: iD Code" Date‘af Dlagnosis’
Calculations Performed By: Lawrence A. Page, Jr. 5/13/2009
Name Date
Peer Review Completed By: Mutty M. Sharfi, CHP 6/05/2009
Vane Date
Dose Reconstruction Approved By: Vay a
7111/2009

Signature

Peter A. Darnell, CHP, RRPT

Date

Name

DRAFT Page 1 of 19


|
\
|

decision. Final determinations are made by the Department of Labor based on standards
determined by EEOICPA and its implementing regulations,

Dose Reconstruction Overview

The Office of Compensation Analysis and Support has performed a dose reconstruction for
in accordance with the applicable requirements of the Energy Employees Occu-

pational Illness Compensation Program Act. Information provided by the Department of
Labor (DOL) indicates that worked at the W.R. Grace and Company, at Curtis
Bay, Maryland, frot and that he was diagnosed with

W.R. Grace and Company was contracted by the Atomic
Energy Commission (AEC) to process monazite sand in order to extract thorium. The
operational period was 1955 through 1958, with the residual radiation period from 1959
through July, 2006.

radiation exposure was received during employment as a .
according to records received from the Department of Labor and information provided in the
interview process. To process this claim, the radiation dose assigned was overestimated using
efficiency measures. Claimant-favorable assumptions related to radiation exposure and intakes
were applied, based on current science, documented experience, and relevant data. Using this
approach, the dose to the brain was calculated to be The dose was calculated only
for this organ because of the specific type of cancer associated with this claim. Even under
these assumptions, NIOSH has determined that further research and analysis will not produce a
level of radiation dose resulting i in a probability of causation of 50% or greater. In accordance
with 42 CFR § 82.10(k),' NIOSH has determined that sufficient research and analysis have
been conducted to consider this dose reconstruction complete. Per the requirements of 42 CFR
§ 82.10(j),' only the dose incurred up to the point of cancer diagnosis was included in this dose
reconstruction.

If the facts surrounding this dose reconstruction change (e.g., the date of diagnosis is modified,

an additional covered cancer is diagnosed, or additional covered employment is identified), the

efficiency measures used to reconstruct the dose may not be applicable. In this case, if the facts
were to change, the dose reconstructed for the brain could be lower than that reported using the

efficiency process.

dose reconstruction is being revised pursuant to a Remand Order by the Final
Adjudication Board, dated December 22, 2008. The Order requires re-evaluation of the
assigned dose based on additional job descriptions provided after the original dose recon-
struction. Additionally, the Order requires evaluation of the dose received during overtime
hou worked. Payroll records for the yeat have been.
provided to facilitate this. Specific data regarding the number of records per year and the
average hours worked per year are provided in Table 1 below.

DRAFT Page 4 of 19