Cowered Emnlovee NIOSH ID# Sociat Security #

feconstruction. ‘thes: 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 wre .
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
Teconstruction 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 ali 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

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” [Effective Date: ision No. "No. No.

June 10, 2005 Draft SCA-TR-TASK 1-0004 13 of 221

SC&A has identified a number of issues. These issues are sorted into the following categories,
in accordance with SC&A’s review procedures:

(1) Completeness of-data sources
(2) Technical accuracy

(3) Adequacy of data

(4) Consistency among site profiles
(5) Regulatory compliance

Following the introduction and a description of the criteria and methods employed to perform the
review, the report discusses the strengths of the TBD, followed by a description of the major
issues identified during our review. The issues were carefully reviewed with respect to the five
review criteria. Several of the issues were designated-as findings because they represent
deficiencies in the TBDs that need to be corrected, and which have the potential to substantially
impact at least some dose reconstructions.

L1 SUMMARY OF STRENGTHS

For the purpose of reconstructing internal doses based on historical operations, NIOSH compiled
an enormous amount of data describing the radioactive materials and operations at the various

. facilities and their associated processes.

Attachment D.3 of the intemal dosimetry TBD includes a series of: eight tbles that provide - -
guidance to dose reconstructors for assigning inhalation intakes of various radionuclides when
the results of urinalysis are below the MDA. The intakes, in units of dpm/d, are normalized to an
MDA of | dpm/d (based on a 24-hour urine sample). The tables also list cumulative intakes, in
both dpm and pCi, based on exposure durations of 1 to 50 years. A second set of 11 tables
provides similar guidance for whole body counters, normalized to an MDA of 1 nCi. These
tables are helpful for dose reconstructions for claimants who worked at the Hanford Site, and are
Gartied ut to 50 years. According 'to the internal dosimetry TBD, plutonium ‘urinalysis started in
September 1946 (page 13), reliable uranium urinalysis started sometime in 1948 (page 24), and
routine fission product urinalysis started in January 1947 (page 27). These urinalysis data were
available in the late 1940s and generally provide a better means than air sampling data for the
dose reconstructors to determine daily and cumulative intakes. However, some limitations of the
data, discussed below, need to be factored in.

The use of the hypothetical intake described in ORAUT-OTIB-0002 (Rollins 2004) by NIOSH
likely overestimates the dose to nonradiological workers and minimally exposed workers. For
sites with reactors, such as Hanford, each claimant is assigned 28 radionuclides considered
representative of potential sources of intake.

In compiling the atmospheric source terms for deriving outdoor occupational exposures, NIOSH
made a concerted effort to compile the source term data needed to reconstruct the doses to
unmonitored workers. This applies especially to the early period, prior to 1968.



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WASHINGTON SCENCE, AND
"TRANSPORTATION
1717 Hart SenaTe Ornce BULDNG ENERGY AND NATURAL

- JURCES:
eam United Strtes Senate mone AAs
WASHINGTON, DC 20510-4705
February 15, 2006

Dear

Thank you for contacting my office regarding your request for the executive summary of the
audit regarding Hanford EEOICP cases. I appreciate hearing from you about this, and have
enclosed informational material on this matter.

hope you find this information useful in resolving your concems. Should you need any further
assistance on this or any other matter, please do not hesitate to contact my office in the future.

Sincerely,
a“ awe
Maria Cantwell
United States Senator
e
Enel 33

Pease Repty To:

DUS. Feverat Courthouse 1D Jackson Feverat BULDING (0 Mansnaut House: 1D 825 Japean AVENUE D 2830 Wenwore Avenue Gi 960 Pacinc Avenue
‘West 920 Rirverswwe, Sure 687 915 2no Avenve, Sure 3206 1313 Ormcers’ Row CHA ‘Sune 98 ‘Sure 615
‘SPOKANE, WA 99201 ‘Searmes, WA 88174-1008 First FLoor. RICHLAND, WA $3352 Evenert, WA $8201 Tacoma, WA $8402
(903) 353-2507 (206) 220-6400 VANCOUVER, WA 38661 (509} 946-8106 (425) 303-0114 (2839 572-2281
Fae (509) 353-2567 Tout FREE: +-888-648-7328 (360) 696-7838 Fax (509) 946-9377, Fax (426) 303-8251 Fx (253) 572-5873

Faxc (206) 220-6404 FAX (360) 696-7846
‘Web: httpzicantwell.senate.gov





Covered Employee ‘NIOSH TD# ‘Social Security #

based on a hypothetical intake. This assumed intake included each of the radionuclides likely to
result in significant internal dose at the Hanford Site.

Applying the hypothetical intake to the coton (which is a maximizing assumption) and calculat-
ing organ dose. in accordance.with.the Technical Information Bulletin: Maximanr Internal Dose ~~
Estimates for Certain Complex Claims,’ a total intemal dose of 8.256 rem was assigned. This
assigned dose is an overestimate of the actual intemal doses received.

Dose from Radiological Incidents ’
The record of the telephone interview was evaluated carefully by the dose reconstructor. It was
mentioned in the interview that the employee was involved in an incident while working at the
Hanford Site; he was restricted because his dose was over the allowable limit several times. He
teceived urine and fecal monitoring for a long time after the incidents. It was also mentioned
that there was concem with the validity of DOE’s records, based on local perceptions. Along
with the available monitoring records, the claimant-favorable assumptions applied in this dose
Teconstruction would take into account dose associated with any radiological work activities and
any potential radiation doses received during an incident.

Uni

Except for missed dose, point estimates (constant values) were used for organ dose input into the
NIOSH-Interactive RadioEpidemiological Program (NIOSH-IREP). Missed doses were divided
by-2-and a lognormal distribution was applied in accordance with the NIOSH Extemal Dose
Reconstruction Implementation Guideline?

Possible Overestimate of Radiation Dose
There are a number of reasons to believe that this dose estimate Tepresents a larger dose than

true radiation dose received while working at the Hanford Site. The most important
teasons for this include:

* Claimant-favorable dose conversion factors were used to convert potential whole body
dose to dose to-the colon. Had more realistic dose conversion factors béen used, the
estimated dose to the colon would have been smaller.

¢ Internal doses were estimated by using claimant-favorable assumptions regarding a hypo-
thetical intake that was unlikely to have occurred. The actual intemal doses received by
would have been considerably smaller than those calculated using these
assumptions.

* The actual doses to the colon from occupational medical X-ray procedures are likely to
be smaller than were calculated based on the maximizing assumptions used in this dose
reconstruction. .

* The external on-site ambient doses estimated fr - likely much larger than
any ambient doses that were unmonitored or unrecorded.

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Effective Date: Revision No. [Document No. Page No.

June 10, 2005 Draft SCA-TR-TASK1-0004 14 of 221

12 SUMMARY OF FINDINGS
Finding i: The NIOSH-derived neutron-to-photon dose ratios for use in pre-1972 neutron dose

“ recohstruction are technically deficient and based oii noncdnsériative assiriaptions; making them

claimant unfavorable for use in dose reconstruction. For many Hanford workers, neutron.
exposure contributed a large fraction of the total dose derived from external radiation. In fact,
when they are adjusted to account for the current International Commission on Radiological
Protection (ICRP) neutron-weighting factor, neutron doses at the Hanford 200 and 300 Area
plutonium facilities dominate the external dose. SC&A found various combinations of
deficiencies that include: (1) the use of inappropriate data, (2) the use of incomplete or
insufficient data, (3) the use of unconfirmed assumptions, and (4) the failure to account for
critical variables, which limits the use of extrapolated date over time. It is also clear that historic
neutron exposures to reactor workers in many areas are not adequately characterized.

Finding 2: The lack of bioassay data during the early period makes it difficult to properly
quantify internal doses during that period. It is particularly a problem when dealing with the
potentially high exposures that occurred during that time. Plutonium bioassay did not begin until
September 1946; uranium bioassay did not begin until the first half of 1948. Fission product
urinalysis data are unreliable until 1948. Uncertainties in the actual bioassay techniques and
instruments used to quantify internal dose and the MDAs used in the years following 1946 need
to be more thoroughly evaluated. Use of air monitoring data as a surrogate for worker intake
during this early period is insufficiently substantiated, particularly given the lack of a basis for
the assumed statistical distributions.

Finding 3: No guidance or direction for the dose reconstructor is provided regarding how
adjustments aré to be made or uncertainty factors calculated based on film badge and
thermoluminescent dosimeter (TLD) error data provided in the TBD. In fact, no adjustments are
recommended in recorded penetrating or gamma dose, with the exception of penetrating dose
recorded for the two-clement dosimeter used prior.to 1957.for workers in the 200 Area. .
Likewise, adjustment factors are lacking for the large variety of exposure geometries
experienced by workers at Hanford.

Finding 4: There is a significant potential for missed internal dose at Hanford that is
insufficiently addressed in the TBD. Issues not adequately addressed include estimation of
uncertainties for bioassay measurements prior to 1981, uncertainty corrections for whole-body
counting prior to 1986 (and even default radionuclides until 1993), and potential contribution of
radioactive contaminants in recycled uranium. The uncertainties in the case of plutonium in vivo
counts are especially large. While the TBD recognizes the problem, the approach for dealing
with them is not scientifically persuasive and does not appear to be consistently claimant
favorable.

Finding 5: Modeling of occupational exposures due to Hanford environmental releases is not as
claimant favorable as it should be, because the RACHET puff advection model is apparently not
being applied to daily episodic airborne releases. Given that there were a number of relatively

large short-term, ground-level, and elevated atmospheric releases at Hanford, it is important that
these are modeled as hourly, not continuous annual releases, as indicated by Tables A-1 through
A-21 of the TBD (Scalsky 2003). Lack of adequate parametric modeling of episodic releases

also presents a significant potential for missed dose if releases are treated as continuous releases,



i

Special Exposure Cohort Petition U.S. Department of Health and Human Services|
under the Energy Employees Occupational Centers for Disease Controt and Prevention
{liness Compensation Act National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B .

Basis for Proposing that Records and Information are Inadequate for Individual Dose —
Complete Section F.

Complete at least one of the following entries in this section by checking the appropriate box and providing
thie required infoimation related to thé Séledlion. YOti aré not required to complete more than One entry. ~

Fa 4 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.

ty). LA ft rom ax
There are 10y tars ith no moni ‘ring

g LAS SLE, attacked Lora dca ra ent with

enelosur és.

F.2 # 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, alter. ~ ystroyed.
20 years worked at Hantord
n itor iv vols for onty ha

* Part Fis.continued on the following page.

a eyo:
t

Name or Social Security Number of First Petitioner:



| remember coming home from school two other times when our father was home
because he had been overexposed. The family took weekend trips to Whidbey
Island to relieve’ _ 2's anxiely at these times. These were easily remembered
trips during my childhood. 1 remember my parents planning to start a construction
business in order to get 6 _ away from the hazardous work environment.
They were anxious times a child easily remembers.

Therefore, | assert the records have been falsified.

Our father talked at the dinner table about working atthe” . — nwhere they
were making concrete forms to pour more concrete around Jeaking radioactive
tanks. They worked under pouring water in special suits for 20 minute intervals.

C. The employment records from DOE were in error. On Farm AEC-1, PERSONNEL
SECURITY QUESTIONNAIRE, ° listed alt his employment and periods
of unemployment from school in 1931 to June 1960. DOE’s records do not match.
After strenuous objections, | received a letter from DOL, dated April 1, 2005, copy
enclosed, with “corrected” employment dates.

Therefore, | assert that the records are in error and incomplete.

STATE OF TEXAS)

COUNTYOF ARRANSAS)

On February 28, 2006, personally appeared before me, a Notary Public.
vho acknowledged to me that she executed the foregoing

instrument.

} s. DAPHNE KIRCHHARR ¢
ret NOTARY PUBLIC
Bi

EY

State of Texas
Comm. Exp. 04-05-2008



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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

“ “1 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 M- worked at the Hanford Site from 343, through
1951, and intermittently from , 1955, through . 1961. He was diagnosed
with colon cancer in 1961. .

The majority of Mr. adiation exposure was received during employment as a carpenter.
Mr. *s dose reconstructed under the Energy Employees Occupational Illness Compensation
Program Act of 2000 was 36.045 rem to the colon. The dose was calculated only for this organ
because of the specific type of cancer associated with this claim.

For the purposes of this dose reconstruction, was given an overestimate of radiation
dose using claimant-favorable assumptions related to radiation exposure and intake, based on
current science, documented experience, and relevant data. Even under these assumptions,
NIOSH has determined that further research and analysis will not produce a level of radiation
dosevesulting 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 82.104j),' only the dose incurred up to the point of cancer diagnosis was included in this
dose reconstruction.

Information Used

During this dose reconstruction, the primary data source was the dosimetry records obtained
from the Departitierit of Energy (DOE). ‘In addition, specific parameters were applied to the
dosimetry records in order to assign organ dose based on information in the Extemal Dose Re-
construction Implementation Guideline” and the Internal Dose Reconstruction Implementation
Guideline.‘ ORAU Technical Information Bulletins and Technical Basis Documents were also
used in this dose reconstruction (see References). In instances in which specific information was
lacking, parameters were selected that maximized the dose estimate.

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 the interview is provided in
subsequent sections of this report.

Page 4 of 10



_ Covered Employee NIOSH ID# Social Security #

f

stalsig gles)

a ie eres
S 7358 ron
ee ee ee
es iid ‘eens
65, 3957 chee
er 1558 chen
8 880, , | eons
s a eee
2 i erm _
. ria er “17 See .
so n Hs, same
eee ee 7
. 7 Bee soe
7 1955, som
Bi er =e
ta 8 a4
2 ‘ie
cs ise :
a 1945 teenie
et ore
si even
a er ae Seems __
= 7
rene
rene
rove
een
teen
en
‘ere

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Page 10 of 10



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Covered Emptoves , NIOSH IDF Social Security #

provided in the Hanford Site External Dosimetry Technical Basis Document, this results in a
maximum potential missed dose fr 3.960 rem from photons and 18.682 rem from
neutrons. Per the requirements of the External Dose Reconstruction Implementation Guideline,’
this value was used as the 95" percentile of a + lognormal distribution for the Purpose of caleu-
lating probability ofeausation. — -

On-Site Ambient Dose

Although vas monitored for ionizing radiation doses periodically during his employ-
ment at the Hanford Site, on-site ambient doses were assessed as part of this dose reconstruction
for ali years of employment. This accounts for any doses from stack releases or other radiation
sources that may inadvertently have been subtracted from the dosimeter readings. The on-site
ambient doses assigned were based on the maximum annual on-site ambient external doses
reported for any area of the site (as described in Attachment E of the External Dose Recon-
struction procedure’) and an assumed average of 50 hours worked per week throughout the
employment period,” up to the date of cancer diagnosis. The total on-site ambient dose assigned
was 3.483 rem.

Occupational Medical Dose

In addition to the estimated dose received from site operations, the dose received from diagnostic
X-ray procedures that were required as a condition of employment was also included in the over-
all dose to the colon, as modeled by that ‘organ. Based on information in Attachment E of the
External Dose Reconstruction procedure® and an assumed annual X- Tay procedure each year of
employment, up to the date of cancer diagnosis, a total X-ray dose of 4.226 rem was assigned.
This X-ray dose is. considered claimant favorable as it likely. exceeds the true X-ray dose to the
colon. Also, a multiplication factor of 1.3 has been applied to ensure claimant favorability and
account for uncertainty.

Internal Dose

Internal dose is caused by radioactive materials that are taken into the body. A chronic intake is
an intake of radioactive material that occurs over an extended period of time (typically weeks or
longer). Arracute intake is an intake of radioactive material that 6écurs over a short period of
time (typically minutes to hours). Regardless of the rate at which the intake occurs, the intemal
dose received from radioactive materials having long half-lives occurs over an extended period
of time and is, therefore, considered chronic. The intemal dose to the colon was determined by
using the model for that organ.®

Assigned internal doses are based on the information provided in the Technical Information
Bulletin: Maximum Intemal Dose Estimates for Certain Complex Claims.” Although part of Mr.
employment period is outside of the applicable dates as specified in this Technical
Information Bulletin, the methodology applies because of 's low external radiation dose

results and his low potential for internal exposure as an carpenter.

Internal dose monitoring records for radionuclides other than tritium were reviewed. All
measurement results for non-naturally occurring radionuclides showed an activity less than the
level of detection for the given radionuclides and bioassay method. However, to account for any
incidental dose that may have been received but not documented, internal dose was assigned

Page 6 of 10



AFFIDAVIT
SPECIAL EXPOSURE COHORT
HANFORD SITE
RICHLAND, WASHINGTON

- : 4: “* do Swear that:

a. | remember specimen containers from Hanford routinely on our front porch. These containers
were on many porches in Richland and the surrounding area. | was familiar as to what they were.
J also remember something in the refrigerator that was related to the specimen samples.

NIOSH requested the dose reconstruction information from the Department of Energy (DOE).
They received a computer summary from Hanford Radiological Exposure Reporting System
(REX). REX did not contain any internal dose monitoring. | requested a complete copy of the file
from the Department of Labor (DOL). There were no intemal exposure data.

| made a Freedom of Information Act (FOIA) request of the DOE for alt dosimetry data, all
documents and supporting documents related to his employment, all handwritten calculations, all
yearly dose sheets, all punch cards, all personal radiation exposure history forms, and any and ail
other information regarding my father. There was intemal dose information, though very jimited.
Therefore, | assert that most internal dosimetry records have been lost or misplaced. There were
nine years of employment at Hanford for which there were no records of radiation dose
monitoring of any kind. | assert that the radiation monitoring records are in error and incomplete.

wee tney emeeneny seme yo eee -~4, Clearly remembers that « was already home when she
came home from school one day. He was in the back yard and distraught and crying because he
had been over exposed. | have heard about this incident the whole time | was growin

None of the information provided indicates an over exposure that we can determine.

described the back yard incident in each interview regarding this claim. We have asked this or
the health physicists that interviewed us as part of the close-out interview process. He did not
see any incidents of over exposure, nor were there any interna! dose records for him to review.
Therefore, | assert the records have been falsified.

” /Date: 3-E- ob
STATE OF oneldh )
COUNTY OF HOOD RIVER)
On March 8, 2006, personally appeared before me, a Notary Public, vho

acknowledged to me that she executed the forgoing instrument.

OFFICIAL SEAL “ .
BRAD RYHLICK Hefo 6
NOTARY PUBLIC-OREGON
COMMISSION NO. 382760
MY COMMISSION EXPIRES JULY 18, 2008

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NIOSH OCAS

NIOSH Report of Dose Reconstruction under.the |
Energy Employees Occupational Illness Compensation

Program Act (EEOICPA)
STENT TERETE gE RTE
NIOSH ID: Social Security No. DOL District Office
Seattle
Energy Employee ~~ 7
Name: bot Furs Mitdl Dave of Bint
Covered
Employment: Hanford Site
- Richland, WA.
= Lovation
Cancer:
Colon 153.0 -. 1961
Tipe, ICD Conde Date of Diagnosis
Calculations Performed By: Lo Alfred W. Steedley 11/17/2004-
- Name Date
Peer Review Completed By: Mickey M. Hunacek HA 72004
Nome ae
Dose Reconstruction Approved By:
A¥.. BHD 11/23/2004
Senate Dat

LaVon B. Rutherford, CHP

Verte

Page 1 of 10



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Part F2. continued

long. There was also a badge incident. There was a random check after the bus
tide back’ from N ‘Area. count was so high they were angry he had
been on the buss exposing other people for the entire ride. The ride from N
Area was quite long. We asked if there were any abnonmalities in the dose
records that showed these two incidents. He said no, he could see nothing in the
records that would indicate these incidents, no abnormalities at all which was

wrong because... _ a remembers other incidents too. After this,! i
and | informed him we were formally stating and we wanted him to note we
alleged falsification of records. ‘ ~ stated he understood. He heard itona
daily basis from this site.

Affidavits from ~ and .---~,tare also submitted.
Supporting documents:

Enclosure 6, NIOSH Letter
Enclosure 7, HW-4.209, Hanford Engineer Works Inter-Department Transfer or
Change of Job Classification, listing some Areas worked

Enclosure 8, HW-4.209, Hanford Engineer Works Inter-Department Transfer or
Change of Job Classification, listing change of job classification.

Enclosure 9, Letter from PNNL, March 20, 2003

Enclosure 10, Notes from Ciose-Out Interview, December 10, 2004

Enclosure 11, Affidavit from ’
Enclosure 12, Affidavit from [.

Part F4

We petition on the basis of a technical report by S. Cohen and Associates
(SC&A) for the NIOSH Advisory Board, enclosure 13. The Summary of Findings
was especially relevant.

A news release, enclosure 14, from Senator Cantwell’s office, dated November
17, 2005: Cantwell urged the agency's Advisory Board to review the status of
former Hanford workers following an audit suggesting that a possible deficiency
in data on worker radiation exposure between 1944 and 1968 may lead officials
to underestimate exposure levels.....and found several instances where
thousands of workers may be eligible for Special Exposure Cohort (SEC) status.
Supporting documents:

Enclosure 13, Executive Summary with cover letter from Sen. Cantwell
Enclosure 14, News release, Sen. Cantwell's office

Page3 of 3



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played poker. “enough money to buy a set of china and silverware for his wife. We
know many of the records were falsified. ] _ xxplained that her former sister-in-law had
worked at Hanford in the 80s. The sister-in-law said the badge information was rutinaly
falsified. Chris stated he heard those stories daily toc _ . - ated we, we aad

_. were formally stating we know there was falsification of records and information.

_ Chris stated he understood, He hears it on a daily basis from this site and others, We asked what

could be done about it. He recommended if the claim was denied, send in the OCAS form and
appeal the denial. The denial could not be appealed with out the OCAS form. The case could be
administratively closed if we did not respond and sign the form. However we were not to sign
the form until we had submitted the additional information to the DOL. He stated we would need
a new dose reconstruction report and a new OCAS form since we now had additiona}
employment time. The case is currently in a "pending" state due to our questions.

Chris stated there were about 12 pages of dose reconstruction from 1944. There were no bio
information, no urine or fecal samples. He said it was unfortunate that due to cost restraints thev
did not monitor everybody. .  4Mstated there had to have been bio records! Both =,

f y temember seeing the sample boxes on our front porch all the time. There was
medicine in the refrigerator he had to drink. Again, many records destroyed or falsified.

_ ~~ Fememberec ring a mole removed-from his neck. I examined
thyroi: _ —-lremembers neck being swollen from his thyroid. However, there is no
mention of thyroid in the records. Chris told us to inform the DOL we thought ~ ~ had thyroid
cancer also. We looked through the records from?

Under MICROSCOPIC: The skin tumor consists of shallow, papillary-folds. The epidermis in
this region is thin and shows hyperpigmentation of the basal layer. The sinus tract is lined by
chronic granulation tissue. The lymph node is hyperplastic and shows prominent germinal
centers. No evidence of tumor tissue is apparent.

Under PATHOLOGIC DIAGNOSIS: Lymphoid hyperplasia of lymph node.

Abdoruinal sinus tract.
- Basal cell papilloma of the skin.
As a physician, Chris interpreted the records to show tha! aad two additional primary

cancers. He said the statement under MICROSCOPIC "No evidence of tumor tissue is apparent"
meant there was no evidence of metastic tumor tissue from the colon. The record did not say
benign. The lymphoid hyperplasia and the basal cell papilloma were two additional primary

cancers.

Chris explained the REM meant radiation exposure in man. RAD meant radiation exposure in
any other entity. We discussed thyroid cancers and diseases as *
have thyroid problems.

Jn summary, Chris again advised us to contact the DOL since there was a. additional employment
time and b. additional primary cancers. He instructed us to request a new dose reconstruction and
case review.



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Y PRIVATE

la
+t
YJ
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Ir

DATE:
TO:
prow: SSeS COMPLETE

SUBJECT: PRIORITY NIOSH #
EEOICP Claim #-

The Hanford Radiological Exposure Records have been searched for all radiological exposure material
relating to “his information has been copied and is attached. As in the past, we have not
sanitized the documes but have indicated those needing attention with a “flag” on the right-hand side of the

page.
Per your request, | have attached the following items relating to

‘History,
3) Hanford Occupational Lifetime Totals by Year, and
~4) Bioassay Results and In Vivo Record.

‘Due to a reevaluation + + *= -t¢¢s, there were dose corrections made. All radiation dose adjustment
sheets are attached. _

The x-ray dose recorded in 1959 shows 59 for each month. This fs assumed to be a programming error, and
Js really a print-out of the year. tn 1959 k was Hanford practice to report Whole Body (penetrating) Dose as
the sum of the gamma dose plus the neutron dose and 35% of the x-ray dose. ‘The value printed for the
calendar year gamma total is actually @ total of gamma dose plus 35% of the x-ray dose. ‘The skin dose
(derma) was calculated as the sum of the whole body dose and the remaining 65% of the x-ray dose. The x-
ray dose total for 1959 should be 0 mrem.

- K review of our tecords shows rio Indication that . vas monitored for radiation exposure at Hanford

during 1955.

According to our records no intemal doses were recorded for this individual while employed or visiting
Hanford. -

ifyou need additional information, please give me a call o os

xe Personal Exposure File

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09/98/2008J9:41,, 381250575 AN Ee Er pas 0676
Special Exposure Cohort Patition US. Department of Health and Human Sarvices
under the Energy Enigloyees Ooeupadans! or Dasase Concent
‘Compensation Act National insttute for Occupations Sufety and Health
‘OMB Number: 0620-0639 Expires: 06/31/2007
Cohort Petition — Form B Baas Sot?

H F.3 (2 lWe have atteched # report from a health physicist or other Indtidual with expertiea in
; radiation dese reconstruction documartting the limitations of existing DOE or AWE recorts on
H radiation exposures at the facility, a8 relevant to ihe petition. The report specifies the besla for
. . these documented fi ‘compiation of dose reconstructions for

members of the class under 42 CFR Part 82 and related NIOSH technical implementation

{Attach report to the buck of the petition form.) 1
| Pa . (We have attached a sclentific or tachnical report, nsued by a government agancy of the
Executive Branch Regulatory

of Government or the Genaral Accounting Office, the Nuclear
Commission, or the Gefense Nuclear Facilities Safety Board, or published in a peer-reviewed
Journal, that identines dosimetry and related information that ate unavailable (due to either @ lack
i of monttoring or the destruction: or logs of records) for estimating the radiation doses of
i employees covered by the patition.

(Attach report to the back of the patition form,

; All Petitionors should sign and date the petition A maximum of theee persons may elgn the petition.

. . — S320
Aeegye . Bete
cone 3-J-0b
Siinatire 1” VauGursr OF 7 >
_ UBILE f
a — cnt an

Notion: Any person who knowingly makes any false statement, misrepresentation, conceatnant of
fact or any other act of fraud So obizin compensation as provided under EECICPA or who
knowingly accepts compensation to which that person is not entitled Is subject to elvil ar
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by s fine or Imprisonment or both. | affirm that the information

provided on this form is eccurate and true,
! : Send this form to: SEC Pettion .
| Office of ‘Compensation Analysis and Support
4876 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Name or Social Securty Number of First Petitioner.



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—4 Raanloyee NIOSH ID# Social Security #

Introduction

The Energy Employees Occupational Illness Compensation Program Act of 2000
{EEOICPA), Executive Order No. 13179 and the Radiation Dose Reconstruction Rule

442-CFR82)'.. -

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 inthe Radiation Dose Reconstruction Rule (42 CER 82)! 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 modem 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

Page 2 of 10



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Part F2.

We petition on the basis that records for employees at Hanford were lost or
destroyed and falsified.

The other way td account for the ten yéars of missing dose monitoting records is
that the records existed at one time, but have either been lost or destroyed. We
believe there also should have been more intemal dose monitoring records.

We petition on the bases that records were falsified.

NIOSH was obviously given faulty information on which to base the dose
reconstruction. NIOSH letter dated March 15, 2005, enclosure 6 states, “Mr.

8 assigned to various facilities within the 100 and 300 Area while
employed at the Hanford Site. As a carpenter, his duties included building
additions to storage tanks and building concrete forms.” HW-4.209, Hanford
Engineer Works Inter-Department Transfer or Change of Job Classification,
effective date -, 1948 shows he worked not only in 100 and 300 Areas,
but also in 700-1000 Areas as well, enclosure 7, HW-4.208, Hanford Engineer
Works inter-Department Transfer or Change of Job Classification, effective date
April 11, 1949 shows he worked not only as a carpenter, but as a maintenance
méchanic, enclosure 8. Again, | point out the records are incomplete; therefore
he may have worked in other job classifications and other Areas at the Hanford
site.

Letter from PNNL dated March 20, 2003, Subject: Priority NIOSH #¥

EEOICP Claim # enclosure 9,
states:
“A review of our records shows no‘indication that ... was monitored for

radiation exposure at Hanford during 1955.” and “According to our records no
internal doses were recorded for this individual while employed or visiting
Hanford.”

There are no records for nine years in addition to 1955 which shows the above
statement to be false. That there were no internal doses recorded for this
individual is also false, yet we were told repeatedly there were no internal dose
records.

During the Close-Out Interview with Chris W., a licensed health physicist and
physician, board certified in radiology, on December 10, 2004, enclosure 10,

. stated our concer about falsification of records. There was in
incident where M a was left in a hot area too long. When f ncame
home from school, «was already home from work. She remembers him
being horribly upset and explaining he had been intentionally left exposed too

Page 2 of 3



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Summary
: was exposed to various sources of radiation during his employment at the Hanford
Site. The estimated dose to 0 8 5 364 045 rem.
The reported dose i isa significant o overestimate te of M. _—__. » occupational radiation dose which
will support claim determination.

Attachment I 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 CER 82, Methods for Radiation Dose Reconstruction Under the Energy Employees
Occupational Illness Compensation Program Act of 2000; Final Rule, Federal
Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22314, °

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

3. NIOSH, (2002) External Dose Reconstruction Implementation Guideline, Rev 1,
OCAS-IG-001, National Institute for Occupational Safety and Health, Office of
Compensation Analysis and Support, Cincinnati, Ohio.

4. 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.

5. ORAU Team, ORAUT-TKBS-0006-6, Technical Basis Document for the Hanford
Site ~ Occupational External Dosimetry, Rev 01, January 9, 2004.

6. ORAU Team, ORAUT-PROC-0006, External Dose Reconstruction, Rev 00,
June 27, 2003.

7. ORAU Team, ORAUT-OTIB-0002, Technical Information Bulletin: Maximum Internal
Dose Estimates for Certain DOE Complex Claims, Rev 01, January 10, 2004.

8. ORAU Team, ORAUT-OTIB-0005, Technical Information Bulletin: IMBA Organ,
External Dosimetry Organ, and IREP Model Selection by ICD-9 Code, Rev 01,
January 23, 2004.

Page 8 of 10



Special Exposure Cohort Petition US. Department of Health and Human Services
under the Energy Employees Occupational Cénters for Disease Control and Prevention
Iiiness Compensation Act National Institute for Occupational Safety and Health

. OMB Number: 0920-0638 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 1 of 7|

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

|General t Instructions on Completing this Form (complete | instructions are available i in a separate packet):
Except for ‘Signatures, please PRINT ail information clearly and neatly on the form.

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.

Ifyou 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 B.

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 Analysis and Support about an SEC petition:
1-800-356-4674.

QA Labor Organization, StartatD on Page3

Ifyou G An Energy Employee (current or former), StartatC on Page 2
are; 101A Survivor (of a former Energy Employee), Start atB on Page 2
G A Representative (ofa current or former Energy Employee), StartatA on Page 1

omplete Section A if you are authorized by an Employee or

A.1__ Are you a contact person for an organization? 0) Yes (Go to A.2) OQ No (Go to A.3)
A.2 Organization Information:

Name of Organization

Position of Contact Person
A.23 Name of Petition Representative:

MrJ/Mrs./Ms. First Name Middle fnitial Last Name

A4 Address:
Street Apt # P.O. Box
City State Zip Code

A5 Telephone Number: ¢ 2 -
A6 Email Address:

AZ i Check the box at left to indicate you have attached fo the 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.

p

Name or Social Security Number of First Petitioner:

a



if you have any questions, please contact our office toll-free at 1-888-805-3401 or in
writing at the above address.

Enclosure: SSA-581, Social Security Administration Form
EE-4, Employment History Affidavit



Aprit 1, 2005

Dear Mrs.

This letter is with regard to the status of your claim filed under Part B of the

Employees Occupational Iliness Compensation Program Act of 2000 (EEOICPA) following
receipt of the radiation dose reconstruction from the National Institute of Occupational
Safety and Health (NIOSH). The probability of causation (PoC) that your father's colon -
ponies was related o his employment ite

‘As we discussed Ge Kgtowe indy a teow of Ses to indicates that your -
fe roonesy past Hero! te br Dont oa size SA an Ket
Engineers 1155); Based oral of the available 3

The complete employment history information reported, for coneidortion ofa possible
“rework” of the dose reconstruction, is as follows:

Hanford
Hanford
Hanford
Hanford
Hanford

Enclosed is the Social Security Administration Form SSA-581 to complete and teturn to

this office, if you choose. This authorization will only be, used to request Sogial Security

records in the event that we feed to supplement the employment information previously

submitted fo establish Govered employment. Social Secarly Administaion-secorde sre
fs of employa ly provide :the.name’of the:


Page 1 of 2

From: Castellano, isaac (Cantwell) [lsaac_Castellano@cantwell.senate.gov]

Sent: — Friday, November 18, 2005 4:06 PM
To:
‘Subject: FW: Cantwell Wins Review of Hanfofd Worker Benefits Status

Isaac Castellano

Office of U.S. Senator Maria Cantwelt

State Outreach Assistant/Constituent Services Representative
206-220-6400

206-220-6404 Fax

Every Monday, Maria provides a brief outline about her work in the Senate and issues of importance to
Washington state. If you are interested in subscribing to this update, please visit her website

at: http://gp1d.senate.gov/mailman/ listinfo/cantwell-weekly-update .

U.S. SENATOR MARIA CANTWELL
WASHINGTON

FOR IMMEDIATE RELEASE CONTACT: CHARLA NEUMAN
NOVEMBER 17, 2005 (202) 224-3441

Cantwell Wins Review of Former Hanford
Worker Benefits Status

WASHINGTON, DC — Thursday, U.S. Senator Maria Cantwell (D-WA) applauded the National
Institute for Occupational Safety and Health (NIOSH) for their decision to review the benefits available
to former Hanford workers. Cantwell requested the review in a letter sent to NIOSH on October 3 after
reading an audit of available radiation exposure data. In a letter to Cantwell, NIOSH committed to
discussing the audit’s findings and re-evaluating the benefits status of former Hanford workers at their
January meeting in Oak Ridge, Tennessee.

“This is the right decision,” said Cantwell. “Right now, we don’t know the full extent of workers’
exposure to toxins. We need to review the situation to make sure all former Hanford employees
get the help they need. Some of these workers have waited years for help. Without this review, we
might wrongly deny worker's compensation to thousands of deserving individuals who have
already waited too long.”

Cantwell urged the agency’s Advisory Board to review the status of former Hanford workers following
an audit suggesting that a possible deficiency in data on worker radiation exposure between 1944 and
1968 may lead officials to underestimate exposure levels. The audit, prepared by S. Cohen &

Enel y

11/18/2005



i

Close out interview with Chris W., 10 December 2004, 1100 to 1300

Ciiris gave his credentials including licensed health physicist and physician, board certified in
radiology.

The first item we discussed was the time frame of Aug 1942 to May 1943. This time frame was
not included in the dose reconstruction. He went through the computer records and found the
Personnel Security Questionnaire which listed the date and name of. employment. The first date

worked at Hanford was 8/42 to 5/43 for DuPont as a carpenter at Hanford. The second
date is 5/43 to 4/51 for DuPont and General Electric as a carpenter at Hanford. Chris
recommended we contact the Department of Labor (DOL) to notify them of the additional time
and request another dose reconstruction.

In the first interview with Brad, we had asked for 42 CFR 81 and 82. Chris directed us to the
CDC web site to access that information.

. . Joth requested copies of the close out interviews. Chris explained that
the interviews were not taped. We could request copies of the phone logs through the Freedom of
Information Act to David Sundin of OCAS at email ocas@cdc.gov. We would need to identify
ourselves, exactly which documents we were requesting and a return address or email address.
We should also included our social security number and the NIOSH case number

‘The next question was what amount of REM would equal 50 percent or greater. There were so
many factors for probability of causation: time, age, latency, target organ, race of claimant,
gender, Hispanic, Indian, African American, etc. Then we discussed the fact that . . was

Chris recommended we ask the DOL if this would be a factor. Chris also said the
dose reconstruction people were right next door. He stated that cancer and REM are
noncorralative factors.

We discussed diagnostic procedures and how they differed today from the 1960s. For instance
‘cancer was simply listed as colon cancer. It did not state transverse, ascending,

descending etc. We discussed the numbers and types of cases and claims filed. He explained the

differences between a case and claims. The case was the employee, the claims were survivors.

He stated the dose reconstruction report was preliminary only! It was developed from assumptive
information based on available records. Then they make a threshold for which cases would be 50
Percent above or below. None of the claims that have been approved so far have gone through
NIOSH. There are 25 plus types of cancers that are accepted case would not have
made it to the current point if the type of cancer he had was not an accepted cancer.

Discussed dose reconstruction. Chris referred us to page seven. Again} ” aud
expressed concem about falsification of records. There was the incident where? was left
in a hot area too long. When -came home from schoo] * ~ —_ was extremely upset.

She remembers him being horribly upset and explaining he had but intentionally ieft exposed
too long. There was also a badge incident. There was a random check after the bus ride back
from ~~ wT “3 Count was so high they were angry he had been on the buss exposing
o other people tor the entire ride. The ride from N area was quite long. Some of the employees

Bact 10

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corey ee ee

Page 2

FOIA #2002-0004 Summary was processed on October 17, 2001. . . 7
An EEOICP Claim was completed on April 18, 2002.

Priority NIC ‘as processed on March 20, 2003.

if you have any questions regarding Mi * * records, please contact me at <

4

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SPECIAL EXPOSURE COHORT PETITION
Part F1.

* We are petitioning on the basis that ceitain peridds of tiivié were not monifored, *
and that there were periods of time when there was no monitoring of internal
doses.

worked at Hanford for various contractors from

see enclosure 1. He was terminated inf._._...... ... . when he could not pass
his physical for work. We know this only by a brief mention in the medical notes
requested from. _ __. . Hospital written by one of the doctors who treated him for
cancer. He died ag. —>f colon cancer. Mrs. + _ his wife died in
teens My sister, ’ eo 0 andi ft .yi’ are his only
survivors. Our EEOICP claim, number _ is still going through the

process. All supporting documentation of birth certificates, marriage certificates
and death certificates has been submitted with the claim. It has been denied
twice because the dose reconstruction could not support the 50% as likely as not
causation standard. made a FOIA request of the Department of
Energy for all employment records, dose records, hand written notes,
calculations and any other information. After reviewing the records

realized why the claim can’t seem to support the 50% standard. There are very
limited dose records in the file. There are ten years with no dose monitoring
records at all see enclosure 2. The years that are covered, often do not have
information for every month, see enclosure 3. In each and every interview my
sister and | related the memory of sample canisters on our front porch, yet we
were repeatedly told there were no records of internat dose monitoring.
However, in reviewing the records, there were two sheets showing internal dose
monitoring. ‘The only records for internat dese; Plutonium Inventory Report-with -
Fission Products Inventory Report using the same samples, are for four samples
in 1959, enclosure 4, two samples in 1960, and one in 1961, enclosure 5.

The ten years for which there are no dose monitoring records of any type are:
1942, 1943, 1946, 1949, 1950, 1951, 1952, 1953, 1954, and 1955. This
information constituted new evidence and a request to rework the dose
reconstruction was sent.

Supporting documents:

Enclosure 1, Letter from DOL, dated April 1, 2005 listing dates of employment.
Enclosure 2, REXER77, Radiological Exposure individual Dosimeter History
Enclosure 3, Hanford Dose Records for . .--61, note only six months
Enclosure 4, intemal dose records 1959

Enclosure 5, intemal dose records 1960 and 1961

Page 1 of 3



Covered Emptoyee NIOSH ID# Social Security #

Dose Estimate

External Dose

Extemal dose is received from radiation originating outside the body and is typically measured
by dosimetry worn on the body.” Radiation dégé meastitéd on a film badge or a thérmolimi-
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 found to be sufficient for the
external dose teconstruction, The external dose to the colon was calculated using the model
for that organ ®

vas assigned to various facilities within the 100 and 300 Areas while employed at the
Hanford Site. As a carnenter, his duties included building additions to storage tanks and building
concrete forms. . _. --a was exposed to photon radiation and potentially exposed to neutron
radiation while working in these areas.

For the purpose of estimating probability of causation, all photon doses, except on-site ambient,
are assumed to be acute and all neutron doses are assumed to be chronic, as this maximizes
probability of causation.’ On-site ambient doses are assumed to be chronic.

Radiation Type, Energy, and Exposure Geometry
For-the purposes of this dose reconstruction, the distribution of 4s exposure geometry
and radiation energies was selected to maximize dose. This exposuré assumes 100% Anterior-
Posterior ‘geometry. In accordance with the Extemal Dose Reconstruction Implementation
ideline,” dose conversion factors were used to calculate the colon dose from exposure to
wooo and neutron radiation. For photon radiation, 100% 30-250 keV energy range with a
claimant-favorable organ dose conversion factor of 1.000 was applied. For neutron tadiation, a
100% 100 keV ~2 MeV energy range, with a claimant-favorable organ dose conversion factor
of 1.000 and an ICRP correction factor of 1.91, was applied in accordance with the Technical
Basis Document for the Hanford Site - Occupational Extemal Dosimetry.”

Dosimeter Dose

Individual dosimeter results were used to reconsmnict se. Corrections to the
reported doses were applied as described above in accordance with the Technical Basis
Document for the Hanford Site — Occupational External Dosimetry

Missed Dose

In accordance with the External Dose Reconstruction Implementation Guideline,’ a potential
missed dose was assigned to each zero dosimeter reading to maximize the potential external
doses received by . A missed dose represents the dose that could have been received
but may not have been recorded due to the dosimeter detection limits or site reporting practices.

Throughout his employment at the Hanford Sit: $ typically on a varying dosimeter
change-out schedule. The total number of zero dosimeter readings assigned was 99 for photons
and 99 for neutrons. These numbers were maximized to ensure that all possible instances of a
zero badge reading were accounted for in this dose reconstruction. Based on information

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five Date: ision No. Document No. No.
June 10, 2005 Draft SCA-TR-TASK1-0004 11 of 221

methods as well as descriptions of facilities and processes that resulted in the worker exposures.
The site profile also provides direction for assigning internal and external doses to monitored and
unmonitored workers.
Hanford was and remains a complex operation involved in numerous missions, each of which
has its own unique exposure hazards. Occupational risks of exposure to ionizing radiation are
generally defined by Hanford’s past and current missions:

(1) Production of nuclear weapons materials and nuclear energy research and development
(1943-1990)

(2) Environmental restoration, waste management, nuclear material stabilization, and facility
decontamination and decommissioning for permanent site closure (1990-2033)!

In the context of these missions, facilities of concern include:

* “Nine graphite-moderated, light-water cooled reactors were constructed near the
Columbia River in the Hanford 100 Areas over a period of 20 years commencing in 1943
(Carlisle 1996). The production reactors were used to produce plutonium by irradiating
metallic uranium fuel elements with neutrons during the fission reaction in the reactor
core. Other defense-related radionuclides that were experirnented with included:
“ irradiation of thorium to produce “°U, irradiation of ‘depleted uranium to produce py,
‘+ irradiation of neptunium targets to produce **Pu, and irradiation of americium to produce -
. medical grade **Pu.” Radiological hazards included external photon, beta, and neutron.
exposure from fission products and neutron radiation, and internal exposure to fission and
activation products? ae .

+ Seven physical testing, research, and demonstration reactors.

+ - Five chemical separation plants and associated ‘furél separation facilities, including the T ”
and B plants, the REDOX plant, the PUREX plant, and U Plant, where radiological
hazards included potential for internal and external exposure to a variety of
radionuclides.*

* “Three facilities for fuel fabrication, i.e., the Uranium Metal Fuels Fabrication facility,
the Uranium Metal Extrusion facility, and the Fuel Cladding facility. There were also two

"U.S. Department of Energy, Performance Management Plan for the Accelerated Cleanup of the Hanford
‘Site, DOE/RL-2002-47, Rev. D., page ii.

? Selby, J, Technical Basis Document for Hanford Site - Site Description, ORAUT-TKBS-0006-2,
Revision 00, PC-1, Oak Ridge Associated Universities, Oak Ridge, TN, December 29, 2004.

3 U.S, Department of Energy, Hanford Site Waste Management Units Report, DOE/RL-80-30, Revision 12,
Janmary 2003.

“ Chemical separation activities included: (1) Bismuth Phosphate (BiP04) Process (1944-1956), (2)
REDOX Process (1952-67); (3) Solvent uranium extraction from waste tanks (1952-1958); (4) PUREX Process
(1956-1972, 1983-1990); and (5) Radiocesium and radiostrontium solvent extraction from high-level tank wastes
(1968-1985).



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Effective Date: Revision No. Document No. Page No.
June 10, 2005 Draft SCA-TR-TASK1-0004 of 221

support facilities; the Uranium Storage and Oxide Burner facility and the Reactor Fuel
Manufacturing Pilot Plant.”°

+ “Pwo plutonium finishing ficilitiés, 231-Z (Piutoniuit Isotation Builditig) and 234:5Z
(Plutonium 18 Finishing Plant Complex) operated at Hanford from 1945 to present. The
latter is still involved in 19 plutonium stabilization efforts as a part of the Hanford
cleanup program. Both of these complexes are located in the 200-W Area.”

* Twenty-one research, development, and testing facilities where a variety of exposures to
radioisotopes occurred.

+ Waste handling and storage facilities, one in each of the 200-W and 200-E areas, a trench
facility, a settling tank area, an evaporator facility, chemical separations exhaust filtration
facilities, and three liquid waste handling buildings, all providing a potential for external
and internal exposure, as well as exposures via the environmental transport pathway.

* Some 2,710 waste disposal sites and burial grounds in the 100, 200, 300, and 1100 Areas,
currently being characterized and remediated.’ The preponderance of these sites poses
radiation exposure risks.

+~ High-level radioactive waste (HLW) storage in 177, large underground tanks.® High-level
. tadioactive tank waste stabilization and removal from underground tanks, scheduled for
. + ‘processing and disposal over the next 30 years, pose ongoing risks of exposure to
radionuclides. ee re

+ Anestimated 2,750 surplus facilities, many of which are contaminated with
radionuclides, are either scheduled or are now undergoing deactivation, decontamination,
and decommissioning?

ithas not been possible within the time and resouices available for this review to examine all
aspects of the site profile in detail due to the immense complexity and long history of the
Hanford facilities, and the many changes that have occurred over the decades. SC&A has
selected certain issues for detailed discussion because they may significantly affect dose
reconstruction.

Based upon a review process, which included not only a review of the TBDs and supporting
TIBs and documentation, but also interviews with the authors of the documents and site experts,

5 Scalsky, E. D., Technical Basis Document for the Hanford Site Introduction, ORAUT-TKBS-0006-1,
Rev. 01, January 9, 2004, page 5.

6 Selby, J., Technical Basis Document for Hanford Site Site Description, ORAUT-TKBS-0006-2, Rev.
00, October 2, 2003, page 14,

Tus. Department of Energy, Hanford Site Waste Management Units Report, DOE/RL-80-30, Revision 12,
January 2003.

® Between 1944 and 1988, some 530 million gallons of high-level wastes containing more than 800
amegacuries (uncorrected for decay) were generated at Hanford. High-level wastes stored at Hanford currently
contain approximately 194 megacuries in 54 million gallons or 204,000 cubic meters.

U.S. Department of Energy, Office of Environmental Management, Linking Legacies, Chapter Five,

Surplus Facilities, htp:/Mlegacystory apps.em.doe.gov/text/link/link5 htm.



w= 209

HANFORD ENGINEER WORKS
inter-Departnent Transfer or Change of Job Classification

“Hon-Exonpt_Eaployeee

Send Original fo: Weekly Payroll Division

Send Copy To: Personnel Division
a. ome
Nane >= Payroll No. — Age <5
(Nene in fall)

Effective Date of Change June 13, 21949

Payroll No. Department Job Classi fication Rate
Present _ _. - Sqmmmity Public Works Carpenter “B" $78.00
Rew Commmity Publis Works Carpenter “s* $76.00

Reason for Change: Comploston of temporary work neer 100-F Area,

1
__anf retuming to foli time employment 700-1200 Ares,
2. Present Duties: Carentan ~ Comunity Public Wore
3, New Duties: Carpenter - Commmity Public Works
4. Continuous Service Date: Mey 12, 2943
5. Length of Time on Present Classification: years and 20 months
____ RECORD OF EMPLOYMENT CLEARANCES
Quality | Very Good - ve ical acai 7
Quantity: _# | Good - - 6 Stores :
atfendance_- fair - - F
Cooperation. @ = | Poor - ~ P
Reliability FF.
eran alae

os

Approved

SUNG 3 194g

i 2S 4, TAGAN
Date: - Approved ee

WORKS MANAGER OR
ASSISTANT WORKS MARAGER

Enel 7



E3

E4

E5

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: 0920-0638 Expires: 05/31/2007
Page 4 of 7

Name of DOE or AWE Facility: _idanfo
Locations at the Facit relevant to this petition:

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 ct
neluded in ins CESS It Qecords are uncom phate do not k.nour all
Classes marker) -

Employment Dates relevant to this petition:

Start End eee 7
Stat | | End - a —
Stat | End

Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored 0 or
recorded exposure incidents?: iYes No

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

Name or Social Security Number of First Petitioner: _



Page 2 of 2

Associates (SC&A, Inc.) for the NIOSH Advisory Board and released in June, reviewed the Hanford site
profile, a case history of activities at the Hanford nuclear facility, and found several instances where
thousands of workers may be eligible for Special Exposure Cohort (SEC) status. SEC status would
make former employees automatically eligible for workers’ compensation.

Specifically, the June report by SC&A, Inc. found potentially significant exposures of reactor workers to
‘unmeasured neutrons and unplanned airbome-releases-of radionuclides. The repert also noted -
inconsistencies over time in recording worker radiation exposure, and insufficient measurements taken
for internal exposure to recycled uranium. Insufficient or inconsistent data could make it impossible to
determine the actual exposure level of former workers through dose reconstruction. Without dose
reconstruction, SEC status would be former workers’ only hope of compensation for their work related
injuries or illnesses.

HEH

11/18/2005



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DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service

NIOSH Tracking Number: National institute for Occupational

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

March 15, 2005

Dear

This letter is to provide you with information on the status of the claim you filed under the Energy
Employees Occupationat Illness Compensation Program Act (NIOSH Tracking Number 3374).

The National Institute for Occupational Safety and Health’s (NIOSH) Office of Compensation
Analysis and Support (OCAS) has completed a reconstruction of the radiation dose for your claim,
conducted a closing interview with you, and received a properly signed OCAS-1 form. Enclosed
you will find a copy of the final NIOSH Report of Dose Reconstruction under the Energy
Employees Occupational illness Compensation Program Act (EEOICPA).

We -have forwarded a copy of the enclosed final dose reconstruction report to the appropriate
Department of Labor (DOL) District Office of the Office of Workers’ Compensation Programs for
their use in adjudicating your claim. We have also sent a copy of this report to the Department of
Energy.

If you have any additional questions regarding your claim, please feel free to contact us toll-free at
1-800-35-NIOSH (1-800-356-4674), You can also email us at ocas@cdc. gov or contact our office
directly at (513) 533-6800. Additional information on OGAS can also be-found-on our Web site at
http:/www.cdc.gov/niosh.

Sincerely yours,

j
1
\
|
|
|

Larry J. Elliott, MSPH, CiH
Director
Office of Compensation Analysis and Support

Enclosures

co: File



D2

DS

D4
D5
D6

D7

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

Centers for Disease Control and Prevention.
National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
30f7

Labor Organization information:

Namie ‘of Organization

Position of Contact Person
Name of Petition Representative:

Address of Petition Representative:

Street Apt# P.O. Box
City State Zip Code
Telephone Number of Petition Representative: ) -

Email Address of Petition Representative:

Period during which labor organization represented employees ¢ Covered by this petition
(please attach documentation): Start

Identity of other labor organizations that may represent or have vprasented this class of
employees (if known):

Name or Social Security Number of First Petitioner: _



iffective Date: ision No. Posument ‘No. Page No.
June 10, 2005 Draft SCA-TR-TASK1-0004 10 of 221

1.0 EXECUTIVE SUMMARY

S. Cohen and Associates (SC&A, Inc.) evaluated the followi documents related to historical

* occupational exposures af the Haniford Site: ORAUT-TKBS-0006-1, Technical Basis Document
for the Hanford Site — Introduction (Scalsky 2004ba); ORAUT-TKBS-0006-2, Technical Basis
Document for the Hanford Site — Site Description (Selby 2004); ORAUT-TKBS-0006-3,
Technical Basis Document for the Hanford Site - Occupational Medical Dose (Scalsky 2003);
ORAUT-TKBS-0006-4, Technical Basis Document for the Hanford Site Occupational
Environmental Dose (Savignac 2003); ORAUT-TKBS-0006-5, Technical Basis Document ‘for
the Hanford Site — Occupational internal Dose (Bihl 2004y, and ORAUT-TKBS-0006-6,
Technical Basis Document for the Hanford Site — Occupational External Dosimetry (Fix 2004).
The evaluations focused on the completeness, technical accuracy, adequacy of data, and
compliance with stated objectives, as stipulated in the SC&A Standard Operating Procedure for
Performing Site Profile Reviews (SC&A 2004) approved by the Advisory Board on Radiation
and Worker Health (Advisory Board) on March 18, 2004. (A fifth objective, “consistency
among various site profiles,” was limited to a comparison with the Savannah River Site Profile.)
Although SC&A is aware that there was a recent Rev. 01 to ORAUT-TKBS-0006-4 in April
2005, this Rev. 01 has not been evaluated in this report. :

In addition, SC&A evaluated and made use Of technical information bulletins (TIBs) that relate
to the Hanford Site Profile: . woe .

© ORAUT-OTIB-0002, Technical Information Bulletin -~ Maximizing Internal Dose
Estimates for Certain DOE Complex Claims. (Rollins 2004)

* « ORAUT-OTIB-0007, Technical Information Bulletin -— Occupational Dose from Elevated
Ambient Levels of External Radiation -(Strome 2003)

The National Institute for Occupational Safety and Health (NIOSH) Technical Basis Documents

ae (TBD8), Which together constitute the NIOSH site profiles for specific U.S. Department of

Energy (DOE) and Atomic Weapons Employer sites, are designed to support the conduct of
individual dose reconstructions under the Energy Employees Occupational Illness Compensation
Program Act of 2000 (EEOICPA). This is accomplished by compiling and analyzing data such
as those related to facility operations and processes over time, radiological source term
characterization, chemical and physical forms of the radionuclides, historic workplace conditions
and practices, and incidents and accidents involving potential exposures. As the support
contractor to Advisory Board, SC&A has been charged with independently evaluating the
approach taken in NIOSH site profiles (encompassing TBDs and supporting TISs) to gauge their
adequacy, completeness, and validity. This information will be used by the Advisory Board to
advise the Secretary of Health and Human Services on the scientific validity and quality of dose
reconstruction efforts performed,

These TBDs are used by NIOSH, along with individual dose data provided by DOE and
information gathered in interviews with claimants, to reconstruct doses for Hanford employees
{including contractor and subcontractor employees). This review is designed to fulfill the
objectives set by the Advisory Board for assessing the accuracy and adequacy of the Hanford
Site Profile to serve as the main set of TBD documents that informs dose reconstruction for
claimants. For instance, it provides the data on the limits of detection of radiation monitoring



#

‘Social,
‘Calo.

5951
Wa

Page 9 of 10

it

ss 3
EEE

NIOSH ID#
ATTACHMENT 1: REP Input Tables

i toa “cea earned Geis ~~ eR —
TOMICER AGHIOS ~
a a

i 8, is i ai) falas)
t : 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
lines Compensation Act National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Page 2 of 7
Survivor information — Complete Section B if you are a Survivor or representing a Survivor.

B.1 Name of Survivor:

‘Writs INS. FirstName Middl Initial ~ ~ Lasthame
B.2 Social Security Number of Survive
B.3 Address of Survivor:

Sifeet Aptt P.O. Box

uny ~ State Zip Code
B.4 Telephone Number of Survive
B.5 Email Address of Survivor:

v 2
B.6 ‘Relationship to Employee: Q Spouse ¥ Son/Daughter OQ Parent
Q Grandparent Q Grandchild

: wo t

Cc Employee Information — Complete Section C UNLESS you are a labor orga
C1. Name of Employee:

. ‘MrJNirs/Ms. First Name Middle Initial Last Name
C.2 Former Name rh Employee (e.g., maiden name/legal name change/other):
Nie
Mr/MrsJMs. First Name Middle Initial Last Name |

C.3 Social SecurityNumber of Employee: _ =
C4 Address of Employee (f living):

NA
Street Apt P.O. Box

City State Zip Code
C5 Telephone Number of Employee: ¢ d
C.6 Email Address of Employee:
C.7 Employment Information Related to Petition:

C.7a_ Employee Number (if known): Ome. number —
C.7b Dates of Employment: Stat _ . —_— End
C.7e Employer Name: DuPont, GE. Hanford Dpevat tony, Kaiser Eng JS-AUones
C.7d Work Site Location: Ail 4 ra - i
PAs » FEEO YS In k

C.7e Supervisors Name: Unknown

Go to Part E.

Name or Social Security Number of First Petitioner:__



AFFIDAVIT
SPECIAL EXPOSURE COHORT
HANFORD SITE
RICHLAND, WASHINGTON = 2 . -

_. --, do swear that:

a. | remember specimen containers from Hanford routinely on our front porch.
These containers were on many porches in Richland and the surrounding area. |
was familiar as to what they were. | also remember something in the refrigerator
that was related to the specimen samples.

NIOSH requested the dose reconstruction information from the Department of
Energy (DOE). They received a computer summary from Hanford Radiological
Exposure Reporting System (REX). REX did not contain any intemal dose
monitoring. My: ° ” _ requested a complete copy of the file from the
Department of Labor (DOL). There was no internal exposure data.

way Made a Freedom of Information Act (FOIA) request of the DOE for all
dosimetry data, all documents and supporting documents related to his employment,
all handwritten calculations, all yearly dose sheets, all punch cards, all personal
radiation exposure history forms, and any and all other information regarding my
: _-eived erriployment records and badge dosimetry records, insurance
records and Inter Department records showing changes in job classifications and
transfers to different Areas at the Hanford site. There were also internat dose
information, though only for 1959, 1960 and 1961. There was a letter dated March
20. 2003, the letter states, “A review of our records shows no indication that
_-~u WaS monitored for radiation exposure at Hanford during 1955.” There are nine
~-years-with no dose records; not just 1955. < . Workéd at Hanford from
1942 to 1961.

Therefore, | assert that most intemal dosimetry records have been fost or misplaced.
{ also assert that the radiation monitoring records are in error and incomplete.

b. | clearly remember one event, : vas already home when | came home
from school. He was in the back yard, screaming and crying because he had been
over exposed, The incident was discussed many times while | was growing up.

None of the information provided indicates an over exposure that we can determine.
\ described the back yard incident in each interview regarding this claim. We (my
sister ~ ae) have asked for information about this specific incident of
the health physicists that interviewed us as part of the investigative process. They
did not see any incidents of over exposure in any of the records at their disposal.

Kacl i]



five Date: Revision ‘No. [Document No. age No.
June 10, 2005 Draft SCA-TR-TASK1-0004 15 of 22)

©.g., plutonium releases from the T and B reprocessing plants, '*Ru and }Ru releases from the
REDOX plant, and fission product releases as part of the Green Run and other operational
release episodes.

Finding 6: The Tank Farm characterization in the TBD (Bih! 2004) is inadequate for dose
reconstruction guidance in several respects. The list of radionuclides cited in the TBDs is
incomplete, increasing the potential for missed dose. The site profile relies primarily on
ORIGEN calculations to identify radionuclides that occur in large quantities and has not
consulted field characterization data to verify the calculations (see Attachment 2 of this report),
The TBD also does not reflect a complete description and characterization of past and current
environmental restoration and waste management operations from which radiation exposure is
likely to result.

Finding 7: Hanford was involved in both minor and major special campaigns, most notably
those involving production of thorium and polonium. NIOSH needs to provide a detailed
revision in the Hanford Occupational Internal and External Dosimetry TBDs to properly account
for doses from the production of °U in the 100, 200 and 300 Areas, particularly in the 1960s to
1970s during peak production of *U. For workers exposed to thorium in the 1950s and 1960s,
NIOSH needs to confirm such thorium exposures by urinalysis data for individual claimants, and
dose revonstructors should carefully review potential doses in the 1960s and 1970s from

__ irradiated thorium.

Finding 8: The TBD is incomplete with réspect to remediation and disposal sites, Although
NIOSH has included descriptions of key production and storage facilities, they have not. .

- addressed the numerous environmental waste streams and cribs that have been cleaned up‘in the

past at Hanford disposal sites (¢.g., ERDF). These areas pose radiological risks to those workers
involved-in the remediation and disposal process. Also, as these areas continue to age, the
radionuclides of concern may be different from those in the original operations. Dose .
Teconstructors need to take into account the risks associated with these areas at the Hanford site
and the variability in radionuclide concentrations.

Finding 9: The method of locating, evaluating, and integrating incident data into the dose
reconstruction is not clear in the Hanford TBDs. The Hanford occupational internal dose TDB
@ihi 2004) gives no specific information as to the spread of contamination in the reactor
building, 231-Z Plutonium Isolation Facility, concentrator buildings, and uranium metal
fabrication shops during the period 1943-1946. NIOSH should search for records that can
provide additional information on doses resulting from accidents and incidents.

13 OPPORTUNITIES FOR IMPROVEMENT

Oro-Nasal Breathing: NIOSH should take into account oro-nasal breathing in the estimation of
inhalation and ingestion doses. The dose conversion factors for light and heavy breathing should

* take account of the fact that many workers switch from nasal to oro-nasal breathing as the work
becomes heavier. An upward adjustment to the percentage of heavy exercise and the
consideration of oro-nasal breathing would ultimately increase the total uptake of radioactive
material and be more claimant favorable given the uncertainties involved.



HANFORD ENGINEER WORKS

~ . tnter-Department Transfer or Change of Job Classification
' ° Non-Exempt Employees .
. SPECIAL CHANGE-OVER FORM °
. S
Send’Original To: Weebly Payroll Division +
Send Copy To: Personnel Division *
Name Payroll No. Age

“Wise in Bel

Effective Dete of Change APRIL 11, 199

Payroll No. Department Job Classification
Present Maint. Meek
New. Cosp Den.

1. Reeson for Change: CHANGE OF CJIASSIFICATION AND/
BATE OF PAY IN At

CHANGE OF WAGE RATE SYSTEK

2. Present Duties:

3. New Duties:

4, Continuous Service Date:

S. Length of Time on Present Classification: yeare and months
RECORD OF ENPLOYMERT CLEARANCES

Quality Very Good - VG

Quantity. Good = - 6

Attendance. Fair - + F

Cooperation Poor - - P

Reliability

Approved ‘SUPERINTENDENT OR
ASSISTANT SUPERINTEXOERT

Date: Approved

Approved oc. TA



REXER77 RADIOLOGICAL EXPOSURE Page 1

Individual Dosimeter History 0171306
Hid: SSN: Rex Id:
s

: Pay
cc Ta Nc Begin DE Erid_Dt oc_ ‘Shalt Deep Nevt “Ring Bye Per End Dt
tT 01/03/1961 22/31/1961 360 2150 0 QO O 12/31/1961
7 01/01/1960 12/31/2960 $80 300 0 0) 0 12/31/1960

01/01/1959 12/31/1959 750 390 o ° Q 12/31/1959
TT 01/01/1958 12/31/1958 460 460 0 i) 0 12/31/1958
TT 01/01/1957 12/32/1957 70 30 9 ° OQ 12/31/1957
xX 94/01/1957 12/31/1957 QO Oo oO ° ® 12/31/1957
XX 01/01/1956 12/31/1956 8 9 0 £3) 0 12/32/1956
xX 01/01/1948 12/31/1948 0 ° ° 0 o 12/31/3948
xx 1/01/1947 12/31/1947 330 130 f) ° 0 12/31/1947
xx 01/01/1945 12/31/1945 40 10 0 0) 0 12/31/1945
xXx 01/02/1944 12/32/1944 60 . 6 0 oO © 12/31/1944

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