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SC&A EVALUATION OF IDAHO CHEMICAL PROCESSING 

PLANT CLASS DEFINITION REQUIRING EVIDENCE OF 

EXTERNAL DOSIMETRY (1963–1974) 

Contract Number 211-2014-58081

Prepared by 

Bob Barton 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

June 2015 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

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SC&A Evaluation of Idaho Chemical Processing 

Plant Class Definition Requiring Evidence of 

External Dosimetry (1963–1974)

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Task Manager:

__________________________Date:____________

John Stiver, MS, CHP

Supersedes:

N/A

Project Manager:

__________________________Date:____________

John Stiver, MS, CHP

Reviewer(s):

 John Mauro

 Joseph Fitzgerald

 John Stiver

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 06/29/2015 Initial issue

The Executive Summary for this report has been reviewed for compliance with the Privacy Act 

of 1974 (42 U.S.C. § 7348n(3)(A)) and has been cleared for distribution. However, the body of 

this report is predominantly information protected by the Privacy Act, and therefore not readily 

available for proactive release. Individuals may obtain this document by submitting a document 

request to the Designated Federal Official for the Advisory Board on Radiation and Worker 

Health:

Theodore Katz, Designated Federal Officer, NIOSH, CDC, 1600 Clifton Road, N.E., MS E-20, 

Atlanta, Georgia 30333, telephone: (513)533-6800, toll free: 1-800-CDC-INFO, e-mail:

dcas@cdc.gov.
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

TABLE OF CONTENTS 

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

Executive Summary .........................................................................................................................5
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ACRONYMS AND ABBREVIATIONS 

ABRWH Advisory Board on Radiation and Worker Health 

or Advisory Board 

AEC Atomic Energy Commission 

CDC Centers for Disease Control and Prevention 

CFA Central Facility Area 

CFR Code of Federal Regulations

CPP Chemical Processing Plant 

DCAS Division of Compensation Analysis and Support (formerly Office of 

Compensation Analysis and Support (OCAS) 

DFO Designated Federal Officer 

INL Idaho National Laboratory

MTR Material Test Reactor 

NIOSH National Institute for Occupational Safety and Health 

NOCTS NIOSH OCAS Claims Tracking System 

SC&A S. Cohen & Associates (SC&A, Inc.) 

SEC special exposure cohort 

TLD thermoluminescent dosimeter 
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

EXECUTIVE SUMMARY 

The National Institute for Occupational Health (NIOSH) released the Special Exposure Cohort 

(SEC) Petition Evaluation Report for SEC-000219 for the Idaho National Laboratory (INL) on 

March 12, 2015. On March 25, 2015, NIOSH/Division of Compensation Analysis and Support 

(DCAS) presented the Petition Evaluation Report at the 104th meeting of the Advisory Board on 

Radiation and Worker Health, which took place in Richland, Washington. NIOSH 

recommended the following class definition of workers for inclusion to the SEC class: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at Idaho National Laboratory in 

Scoville, Idaho, and were monitored for external radiation at the Idaho Chemical 

Processing Plant (CPP) (e.g., at least one film badge or TLD dosimeter from 

CPP) between January 1, 1963 and December 31, 1974 for a number of work 

days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established 

for one or more other classes of employees in the Special Exposure Cohort. 

(NIOSH 2015)

At that time, the Advisory Board expressed concern as to the high level of confidence that is 

required to assure that class definition would not inadvertently exclude claimants who may have 

been exposed at the Chemical Processing Plant (CPP), but for whom dosimetry records are not 

available (see ABRWH 2015, pp. 187–210). SC&A was then tasked by the Advisory Board to 

investigate available dosimetry records in order to assess the validity of the class definition, as 

proposed by NIOSH. 

This report presents SC&A’s evaluation of the currently available records in the context of the 

requirements of the SEC class definition. Based on this assessment, SC&A has the following 

two findings and one observation: 

Finding 1: The dosimetry records contained in NIOSH/OCAS Claims Tracking System 

(NOCTS) are not sufficient to accurately determine if a given claimant worked at the CPP (and 

thus qualifies for the SEC) for at least some workers, due to the absence of external dosimetry 

records designating the area worked. 

Finding 2: Based on SC&A’s evaluation of recently captured supplemental dosimetry records,

as well as observed claimants with inadequate NOCTS records, it is apparent that the reviewed 

claimants who worked for the Atomic Energy Commission (AEC) or the prime contractor and 

who have direct evidence of work at CPP have at least one corresponding dosimeter badge 

associated with CPP to allow for SEC determination. However, SC&A could not locate 

corresponding dosimetry in the supplemental records for some claimants who worked as 

subcontractor trades workers and who have direct evidence of being assigned to CPP. Thus, 

SC&A was unable to validate the SEC class definition as proposed by NIOSH. 

Observation 1: SC&A did not find any evidence that work locations provided in available area 

dosimetry cycle reports were contradicted by other work location-specific information contained 
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NOTICE: The Executive Summary for this report has been reviewed for Privacy Act information and has been 

cleared for distribution. However, this report is pre-decisional and has not been reviewed by the Advisory Board on 

Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

in the claimant records. In nearly every instance, the areas specified in the dosimetry records 

comported perfectly with alternate information. The only exceptions were for two sampled 

claimants who submitted bioassay results that indicated “CFA,” while the dosimeter results 

indicated “MTR” (see Appendix C: C.6 and C.11). 

SC&A Recommendation: It is SC&A’s opinion that the probability of a claimant being 

excluded from the SEC class based on absence of dosimetry records when, in fact, they worked 

in CPP is low for AEC and prime contract workers. However, the fact that SC&A was unable to 

locate dosimetry records for 3 of 12 subcontract employee claimants who had insufficient 

NOCTS records, as well as clear evidence of work at CPP, is problematic from an SEC 

implementation standpoint. Accordingly, it is imperative to determine whether reasonable 

evidence exists to mitigate the missing dosimetry record(s) for these and other potential 

claimants. 

Additionally, SC&A believes that it would be instructive to conduct focused interviews with 

intermittent or transient subcontractors and trades workers to help determine if the policy of 

badging individuals entering relevant areas was universal for all workers and periods. Finally, it 

would be pertinent to ascertain what subcontractors supported radiological work activities at CPP 

(company identity and rosters) as a basis for whatever class definition is defined for the SEC. 

The Executive Summary for this report has been reviewed for compliance with the Privacy Act 

of 1974 (42 U.S.C. § 7348n(3)(A)) and has been cleared for distribution. However, the body of 

this report is predominantly information protected by the Privacy Act, and therefore not readily 

available for proactive release. Individuals may obtain this document by submitting a document 

request to the Designated Federal Official for the Advisory Board on Radiation and Worker 

Health:

Theodore Katz, Designated Federal Officer, NIOSH, CDC, 1600 Clifton Road, N.E., MS E-20, 

Atlanta, Georgia 30333, telephone: (513)533-6800, toll free: 1-800-CDC-INFO, e-mail:

dcas@cdc.gov.