SEC Petition Evaluation Report

Petition SEC-00238

Report Rev Number: 0

Report Submittal Date: July 20, 2017

Subject Expert(s): Mitch Findley

Site Expert(s): None

Petition Administrative Summary

Petition Under Evaluation

Petition Number: SEC-00238

Petition Type: 83.14

Petition A Receipt Date: March 16, 2017

DOE/AWE Facility Name: Idaho National Laboratory

Petition Class

NIOSH-Proposed Class Definition: All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Idaho National Laboratory 

(INL) in Scoville, Idaho, and who 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, 1975 and December 31, 1980 for a 

number of work days aggregating at least 250 work days, occurring 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. 

Related Petition Summary Information

SEC Petition Tracking Number(s): SEC-00219

Petition Type: 83.13

DOE/AWE Facility Name: Idaho National Laboratory

Petition Status: Class added to the SEC: March 1, 1970 through December 31, 1974.

(January 1, 1963 through February 28, 1970 to be determined.) 

Related Evaluation Report Information 

Report Title: SEC Petition Evaluation Report for Petition SEC-00219

DOE/AWE Facility Name: Idaho National Laboratory

ORAU Preparation and Review

ORAU Lead Technical Evaluator: Mitch Findley

ORAU Peer Review Completed By: Dan Stempfley
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DCAS Review and Approval

Peer Review Completed By:

[Signature on File]

Timothy D. Taulbee 

July 20, 2017

SEC Petition Evaluation Reviewed By:

[Signature on File]

James W. Neton 

July 20, 2017

SEC Petition Evaluation Reviewed By:

[Signature on File]

Stuart L. Hinnefeld 

July 20, 2017 
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Evaluation Report Summary: SEC-00238, Idaho National Laboratory

The National Institute for Occupational Safety and Health (NIOSH) prepared this evaluation report in 

response to a petition to add a class of workers at the Idaho National Laboratory to the Special 

Exposure Cohort (SEC). The Energy Employees Occupational Illness Compensation Program Act of 

2000, as amended, (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of 

Employees as Members of the Special Exposure Cohort under the Energy Employees Occupational 

Illness Compensation Program Act of 2000, describe the process for adding new classes to the SEC.

NIOSH-Proposed Class Definition to be Added to the SEC 

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

subcontractors who worked at the Idaho National Laboratory (INL) in Scoville, Idaho, and who 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, 1975 and December 31, 1980 for a number of 

work days aggregating at least 250 work days, occurring 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. 

Feasibility of Dose Reconstruction Findings 

NIOSH lacks sufficient information, which includes biological monitoring data and air monitoring 

data, to allow it to estimate with sufficient accuracy the potential internal exposures to transuranic 

radionuclides to which the proposed class may have been subjected. NIOSH finds that it has 

sufficient information to reconstruct other potential internal exposures, external exposures, and 

occupational medical dose for CPP employees at INL with sufficient accuracy.

The NIOSH dose reconstruction feasibility findings are based on the following: 

• NIOSH has determined that the internal dose potential at CPP during the period under evaluation 

was related to its primary function of processing spent fuel elements containing enriched uranium 

in order to recover un-fissioned uranium. The uranium was separated from fission products by a 

continuous liquid-liquid extraction process. Although much of the processing equipment was 

heavily-shielded and remotely operated, the plant design was based on a direct-contact 

maintenance philosophy. Principal sources of internal radiation for members of the proposed clas

may have included exposures to uranium, mixed fission and activation products (MFP/MAP), 

exotic radionuclides (produced from, or as a result of, reactor neutron irradiation), and transuranic 

radionuclides. Potential exposures would likely be from inhalation and ingestion during 

processing operations. 

s

• NIOSH has determined that there are insufficient internal dosimetry data or air monitoring data 

available to bound intakes of transuranic radionuclides for the period from January 1, 1975 

through December 31, 1980. 
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• NIOSH has determined that a routine bioassay program for transuranic radionuclides was 

established at CPP in 1981. NIOSH has not found any data that indicate significant operational 

transuranic exposures after 1980 that cannot be bounded. Therefore, NIOSH has established an 

end date of December 31, 1980 for this SEC class.

• NIOSH has determined that the beta-gamma external dose potential at CPP during the period 

under evaluation was associated with the handling and storage of spent fuel, fuel reprocessing, 

laboratory analyses of product streams, and disposal of process wastes. The neutron external dose 

potential at CPP during the period under evaluation was associated primarily with the handling of 

transuranic radionuclides and spontaneous fission of radionuclides. Principal sources of external 

exposure for members of the proposed class included exposures to beta, photon, and neutron 

radiation. Monitoring data are available for CPP in the form of individual dosimetry records and 

area exposure reports. 

• Consistent with the findings in its SEC-00219 INL evaluation report, NIOSH finds that it is able to 

reconstruct external and medical X-ray dose for all INL employees for all periods at the site. This 

includes CPP employees from January 1, 1975 through December 31, 1980. 

• Pursuant to 42 C.F.R. § 83.13(c) (1), NIOSH determined that there is insufficient information to 

either: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred under plausible circumstances by any 

member of the class; or (2) estimate the radiation doses of members of the class more precisely 

than a maximum dose estimate.

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

CPP during the period from January 1, 1975 through December 31, 1980, but who do not qualify for 

inclusion in the SEC, may be performed using these data as appropriate. 

Health Endangerment Determination

The NIOSH evaluation did not identify any evidence supplied by the petitioners or from other 

resources that would establish that the class was exposed to radiation during a discrete incident likely 

to have involved exceptionally high-level exposures. However, the evidence reviewed in this 

evaluation indicates that some employees in the class may have accumulated chronic radiation 

exposures through episodic intakes of radionuclides and from direct exposure to radioactive materials. 

Therefore, 42 C.F.R. § 83.13(c) (3) (ii) requires NIOSH to specify that health may have been

endangered for those employees covered by this evaluation who were employed for a number of work 

days aggregating at least 250 work days within the parameters established for this class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC.
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Table of Contents

1.0 Purpose and Scope ....................................................................................................................... 9

2.0 Introduction ................................................................................................................................. 9

3.0 NIOSH-Proposed Class Definition and Petition Basis .............................................................. 10

4.0 Radiological Operations Relevant to the Proposed Class ......................................................... 10

4.1 Operations Description ..................................................................................................... 11

4.2 Radiation Exposure Potential from Operations ................................................................ 18

4.3 Time Period Associated with Radiological Operations .................................................... 18

4.4 Site Locations Associated with Radiological Operations ................................................ 19

4.5 Job Descriptions Affected by Radiological Operations ................................................... 19

5.0 Summary of Available Monitoring Data for the Proposed Class .............................................. 19

5.1 Data Capture Efforts and Sources Reviewed ................................................................... 20

5.2 Previous Dose Reconstructions ........................................................................................ 20

5.3 Employee Interviews ........................................................................................................ 21

5.4 Incidents ........................................................................................................................... 23

5.5 Internal Monitoring Data .................................................................................................. 24

5.6 External Monitoring Data ................................................................................................. 27

5.7 Workplace Monitoring Data ............................................................................................. 31

5.8 Radiological Source Term Data ....................................................................................... 35

6.0 Feasibility of Dose Reconstruction for the Proposed Class ...................................................... 36

6.1 Feasibility of Estimating Internal Exposures ................................................................... 37

6.2 Feasibility of Estimating External Exposures .................................................................. 38

6.3 Class Parameters Associated with Infeasibility ................................................................ 39

7.0 Summary of Feasibility Findings for Petition SEC-00238 ........................................................ 40

8.0 Evaluation of Health Endangerment for Petition SEC-00238 ................................................... 40

9.0 NIOSH-Proposed Class for Petition SEC-00238 ...................................................................... 41

10.0 Evaluation of Second Similar Class .......................................................................................... 41

11.0 References ................................................................................................................................. 43

Attachment One: Data Capture Synopsis .............................................................................................. 51
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Tables 

Table 4-1: INL Site Population (1975-1980) ........................................................................................ 12

Table 4-2: Descriptions of Key CPP Process and Support Buildings ................................................... 14

Table 4-3: Chronology of CPP Processing Runs (1975-1980) ............................................................. 15

Table 4-4: Chronology of Waste Calcining Facility Campaigns (1975–1980) ..................................... 16

Table 5-1: No. of INL Claims Submitted Under the Dose Reconstruction Rule .................................. 20

Table 5-2: Plutonium In-vitro Bioassay Analyses by Year for CPP (1970-1988) ................................ 26

Table 5-3: Plutonium In-vitro Bioassay Analyses by Month for CPP in 1981 ..................................... 27

Table 5-4: Relative Hazard in CPP Fuels by Radionuclide in 1980 ..................................................... 36

Table 6-1: CPP Shift Lab Alpha Contamination Reported Between June 1, 1979 to Aug., 16, 1979 .. 38

Table A1-1: Summary of Holdings in the SRDB for Idaho National Laboratory ................................ 51

Figures 

Figure 4-1: Location of CPP on the INL Reservation ........................................................................... 11

Figure 4-2: CPP Fuel Reprocessing Schematic ..................................................................................... 13

Figure 4-3: Schematic of CPP Buildings in March 1974 ...................................................................... 14

Figure 4-4: Laboratory Bench in the Shift Lab in 1977 ........................................................................ 16

Figure 5-1: Comparison of Number of Personnel Monitored on Monthly CPP Area Exposure Reports 

vs. Dosimetry Branch Monthly Reports for 1975-1980 ........................................................................ 29

Figure 5-2: Comparison of Number of Personnel Monitored on Monthly CX Area Exposure Reports 

vs. Dosimetry Branch Monthly Reports for 1975-1980 ........................................................................ 30

Figure 5-3: Example of Contamination Survey of CPP-602 Lab 211 in 1977 ..................................... 32

Figure 5-4: Example of Contamination Survey of CPP-602 Lab 211 in 1981 ..................................... 33

Figure 5-5: Radiological Hazards Checklist from CPP Procedure, Control and Handling of 

Radioactive Materials (1982) ................................................................................................................ 34
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Acronyms

ABRWH Advisory Board on Radiation and Worker Health

ACC Allied Chemical Corporation

ADAMS Agency-wide Documents Access and Management (NRC database)

AEC Atomic Energy Commission

ALARA As Low As Reasonably Achievable

ANC Aerojet Nuclear Company

ANL-W Argonne National Laboratory-West

APPR Army Package Power Reactor

ATLAS Automatic Thermoluminescence Analyses System

ATR Advanced Test Reactor

ATR-XA Advanced Test Reactor – XA (re: fuel element type)

AWE Atomic Weapons Employer

BML Battelle Memorial Laboratory (re: fission disc)

BMI Battelle Memorial Institute (re: reactor in Columbus, Ohio)

Co Cobalt

CP-5 Chicago Pile No. 5

CPP Chemical Processing Plant (INL)

Cs Cesium

CX CPP Construction Code

D&D Decontamination and Decommissioning

DBFE Design Basis Fuel Element

DCAS Division of Compensation Analysis and Support

DD&D Deactivation, Decommissioning, and Demolition

DHHS Department of Health & Human Services

DOE Department of Energy

DOL Department of Labor

EBR-II Experimental Breeder Reactor No. 2

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000

ERDA Energy Research and Development Administration

ETR Engineering Test Reactor

ETRC Engineering Test Reactor Critical Facility

GETR General Electric Test Reactor

HEPA High Efficiency Particulate Air (filter)

HHS Health & Human Services (Department of)

HP Health Physics or Health Physicist

HSL Health Services Laboratory

HTGR High Temperature Gas-Cooled Reactors

HTRE Heat Transfer Reactor Experiments

ICPP Idaho Chemical Processing Plant

INEEL Idaho National Engineering and Environmental Laboratory

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Center

JMTR Japan Materials Test Reactor

JRR Japanese Research Reactor

KUR Kyoto University Research Reactor

LiF Lithium Fluoride
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LPT Low Power Test

LPTR Livermore Pool Type Reactor 

MFP/MAP Mixed Fission and Activation Products 

Mn Manganese

MPC Maximum Permissible Concentration

mrem millirem

MTR Materials Test Reactor

NASA National Aeronautics and Space Administration

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH DCAS Claims Tracking System

NRC Nuclear Regulatory Commission

NRF Naval Reactor Facility

OMRE Organic Moderated Reactor Experiment 

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

ORNL Oak Ridge National Laboratory 

OSTI Office of Scientific and Technical Information (DOE)

OWR Omega West Reactor (Los Alamos)

PBF Power Burst Facility

PIF Process Improvement Facility (also known as the Low-Bay Laboratory)

Pu Plutonium 

PWR Pressurized Water Reactor

R Roentgen equivalent man (Rem)

RCG Radiation Control Guides 

RESL Radiological and Environmental Sciences Laboratory 

SC&A Sanford Cohen & Associates 

SEC Special Exposure Cohort 

SER Sandia Engineering Reactor 

SOP Standard Operating Procedure 

SPERT Special Power Excursion Reactor Tests

Sr Strontium 

STIR Shielding Tests Irradiation Reactor

TLD Thermoluminescent Dosimeter

TRA Test Reactor Area

TRU Transuranic Radionuclides 

UCLA-MTR University of California Los Angeles–Materials Test Reactor

Zr zirconium 
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SEC Petition Evaluation Report for SEC-00238

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: Mitch 

Findley, MJW Corporation. The rationales for all conclusions in this document are explained in the 

associated text.

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for employees who worked at the Idaho 

Chemical Processing Plant at the Idaho National Laboratory (referred to as CPP throughout the 

remainder of this report) from 1975 through 1980. It provides information and analysis germane to 

considering a petition for adding a class of employees to the Congressionally-created SEC.

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report.

This evaluation, in which NIOSH provides its findings both on the feasibility of estimating radiation 

doses of members of this class with sufficient accuracy and on health endangerment, was conducted in 

accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services add a class of employees to the SEC. The evaluation is 

intended to provide a fair, science-based determination of whether it is feasible to estimate, with 

sufficient accuracy, the radiation doses of the proposed class of employees through NIOSH dose 

reconstructions.1

 

1 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available on the NIOSH Radiation Dose Reconstruction Program page. 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioners and the 

Advisory Board on Radiation and Worker Health. The Board will consider the NIOSH evaluation 

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, to make recommendations to the Secretary of HHS on whether or not to 
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add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this final decision process, the 

petitioner(s) may seek a review of certain types of final decisions issued by the Secretary of HHS.

2

 

2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available on the NIOSH Radiation Dose Reconstruction Program page.

3.0 NIOSH-Proposed Class Definition and Petition Basis

In Rev. 2 of the SEC-00219 Petition Evaluation Report for INL (NIOSH, 2017), NIOSH determined 

that it could not estimate radiation doses with sufficient accuracy for CPP employees for the period 

from January 1, 1963 through December 31, 1974. NIOSH’s decision was primarily based on a lack 

of internal monitoring data for individuals potentially exposed to transuranic radionuclides without 

mixed fission products present. However, NIOSH determined that it could reconstruct external dose, 

including occupational medical dose, for the period from January 1, 1949 through December 31, 1970. 

In June 2016, the Department of Health and Human Services (DHHS) issued a letter designating the 

March 1, 1970 through December 31, 1974 period for inclusion in the SEC. The period from January 

1, 1963 through February 28, 1970 is still under active review by the Advisory Board on Radiation 

and Worker Health. 

This evaluation responds to Petition SEC-00238, which was submitted by an EEOICPA claimant 

whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient 

dosimetry-related information. NIOSH’s determination that it is unable to complete a dose 

reconstruction for an EEOICPA claimant is a qualified basis for submitting an SEC petition pursuant 

to 42 C.F.R. § 83.9(b). 

For this evaluation, the NIOSH-proposed class includes all employees of the Department of Energy, 

its predecessor agencies, and their contractors and subcontractors who worked at the Idaho National 

Laboratory (INL) in Scoville, Idaho, and who 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, 1975 and December 31, 1980 for a number of work days aggregating at least 250 work 

days, occurring 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. 

During this period, employees were involved in the handling and storage of spent fuel, fuel 

reprocessing, laboratory analyses of product streams, and disposal of process wastes in order to 

support the primary mission of CPP in recovering enriched uranium from spent reactor fuels. 

4.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize radiological operations at CPP from January 1, 1975 through 

December 31, 1980 and the information available to NIOSH to characterize particular processes and 

radioactive source materials. Using available sources, NIOSH has attempted to gather process and 

source descriptions, information regarding the identity and quantities of radionuclides of concern, and 
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information describing processes through which the radiation exposures of concern may have 

occurred and the physical environment in which they may have occurred. The information included 

within this evaluation report is meant only to be a summary of the available information. 

4.1 Operations Description

The Idaho National Laboratory was known by several names throughout its history [i.e., National 

Reactor Testing Station (1949–1973), Idaho National Engineering Laboratory (1974–1996), Idaho 

National Engineering and Environmental Laboratory (1997–2004), and Idaho National Laboratory 

(2005–Present)]. Throughout the rest of this evaluation report, the site will be referred to as the Idaho 

National Laboratory or INL (with the exception of source document titles). 

The Idaho National Laboratory is an 890-square-mile complex located in the high desert of eastern Idaho, 

west-northwest of the city of Idaho Falls. While other facilities at INL conducted various reactor 

research and development activities, the primary purpose of CPP was to reprocess spent nuclear fuel 

from naval propulsion, test, and research reactors to recover enriched uranium for reuse in nuclear fuel 

and nuclear weapons production. Figure 4.1 shows the location of CPP on the INL reservation. 

Figure 4-1: Location of CPP on the INL Reservation
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The years 1975 through 1980 marked a period of change in regulatory bodies at INL and also a 

change of prime contractor at CPP. The Energy Research and Development Administration (ERDA) 

replaced the Atomic Energy Commission (AEC) as the INL regulatory body between 1975 and 1977 

before the Department of Energy (DOE) was created as a cabinet-level department of the federal 

government in 1977. DOE has remained as the INL regulatory body to the present. Allied Chemical 

took over CPP operations from the Phillips Petroleum Company in 1971. Allied ran CPP operations 

until it completed its contract in late 1979 and was replaced by Exxon Nuclear Idaho (Occupational 

Exposure History, 1993, PDF p. 53). 

In contrast to the years prior to 1974, NIOSH has concluded that definitive historical site population 

numbers are quite good for the years 1975 through 1980 (Occupational Exposure History, 1993, PDF 

p. 43). This is largely due to the data compiled for the annual reports on radiation exposure reports for 

ERDA and its contractor employees and DOE and its contractor employees for the years 1975 through 

1980 (Occupational Exposure History, 1993, PDF p. 82). Table 4-1 lists the site population numbers 

for the 1975-1980 period under evaluation. The numbers presented in the table are inclusive of 

AEC/DOE and contractor personnel engaged only on contracts administered by the Idaho operations 

office; they do not include visitors or personnel employed on contracts administered by other AEC 

operations offices. These counts do not appear to include workers employed by minor subcontractors 

(e.g., construction subcontractors), which only appear to be included when visitors are counted. 

Counting visitors likely would greatly expand the population count. For the period under evaluation, 

the CPP workforce population can be determined by external dosimetry use because external 

dosimetry was required for entry into the CPP fenced area. Section 5.6 of this report provides the 

monthly external dosimetry usage for CPP and CX (the CPP construction code). 

Table 4-1: INL Site Population (1975-1980)

Year INL Site Population

1975 6,338

1976 6,762

1977 7,748

1978 8,935

1979 9,471

1980 9,930

Source: Occupational Exposure History, 1993, PDF p. 82

CPP was a multipurpose plant designed specifically to recover uranium from a wide variety of 

highly-enriched uranium spent nuclear reactor fuels (20 to 93% U-235). In addition to fuel from 

INL’s test and research reactors, CPP received fuels from the U.S. Navy’s ship propulsion reactors at 

the Naval Reactor Facility (NRF), foreign research reactors, and civilian power reactors (CPP Safety 

Review, 1974, PDF p. 14). Fuels to be processed were received in the CPP-603 Fuel Storage Facility, 

where they were stored for months or years until enough fuel of a particular type was accumulated to 

make a processing run economical. Nuclear reactor fuel processed at CPP consisted of uranium clad 

in aluminum, zirconium, and stainless steel alloys. These fuels were dissolved in the main processing 
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building, CPP-601, by headend3

3 Headend is the first process step of fuel reprocessing. The headend comprises all process stages of mechanical sectioning 

of fuel elements up to chemical dissolution of the spent fuel in order to prepare extraction. It is the stage in which spent 

fuel is received and a dissolved product solution of standard composition is produced. The headend process does not 

produce a final product; it provides the feeds for the next process stages.

 methods involving dissolution in nitric or hydrofluoric acid or by an 

electrolytic aqueous process. CPP-601 was a large rectangular building with its primary operations 

carried out in 25 shielded cells which housed the process equipment. Figure 4-2 provides a general 

schematic diagram of fuel reprocessing steps at CPP. 

Figure 4-2: CPP Fuel Reprocessing Schematic

Source: CPP Safety Review, 1974, PDF p. 17

The work at CPP required a variety of support facilities. Attached to CPP-601 were buildings 

containing offices, multiple analytical laboratories, and maintenance shops. Ventilation ducts 

connected these buildings to waste treatment buildings which contained ventilating exhaust fans and 

filters for discharging waste gases to a 250-foot-high stack. There was a tank farm for interim storage 

of high-level radioactive liquid wastes from the spent-fuel processing. During periodic “campaigns” 

to reduce the quantities, these liquid wastes would be converted to more stable solid granules at the 

Waste Calcining Facility (CPP-633). Calcining resulted in an eight-fold reduction in waste volume 

with the resultant calcine stored in stainless steel bins in underground concrete vaults (NIOSH, 2005, 

PDF p. 247). 

In addition to fuel reprocessing and support facilities, CPP had a number of facilities dedicated to 

process testing and improvement. The CPP-620 Chemical Engineering/High-Bay Laboratory was a 

chemical engineering laboratory facility used primarily for non-radioactive testing of plant processes, 

and for the development and improvement of new processes. Process support and pilot plant studies 

were also carried out in the labs of the Process Improvement Facility (PIF, also known as the LowBay Laboratory). CPP-640, originally known as the Hot Pilot Plant, was renamed the Headend 

Processing Plant in 1973. It was used to test new equipment and chemical flowsheets in support of 

 
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the fuel-processing operations in CPP-601. A shielded Mechanical Handling Cave was added in 

CPP-640’s process-makeup area in the late 1970s for processing graphite fuels. 

Figure 4-3 shows the location of the major CPP buildings. Table 4-2 lists CPP key process and 

support buildings with a brief description of each building’s function. 

Figure 4-3: Schematic of CPP Buildings in March 1974

Source: CPP Safety Review, 1974, PDF p. 16

Table 4-2: Descriptions of Key CPP Process and Support Buildings

Bldg. No. Building Name First 

Used

Last 

Used Building Function

CPP-601 Main Processing 

Building

1953 1992 A five-story building, with four stories underground, where spent reactor 

fuel was reprocessed. The dissolution of spent fuel and recovery of 

enriched uranium was performed in various steps by equipment housed 

in shielded cells. 

CPP-602 Laboratory 1952 2009 Attached to CPP-601 building; contained a series of laboratories to 

provide analytical support.

CPP-603 Fuel Storage 

Building

1953 Present Designed to receive and store irradiated fuel elements. Located one-third 

of a mile away from the CPP-601 Building. The fuel elements were 

moved to CPP-601 via shield cask, truck, or rail car.

CPP604/605 Waste Disposal 

Building and Rare 

Gas Plant 

1953 ND A building dedicated to processing liquid and gaseous wastes. Liquid 

wastes were evaporated and then sent to the liquid waste tank for storage. 

Gaseous waste were processed in the CPP-605 building which had the 

ability to recover krypton and xenon, if desired.

CPP-620 Chemical 

Engineering 

Laboratory

1968 ND Primarily used for non-radioactive testing of plant processes and for 

development and improvement of new processes.
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Bldg. No. Building Name First 

Used

Last 

Used Building Function

CPP-627 Remote Analytical 

Facility and MultiCurie Cell

1955 1997 Supplied continuous analytical services in support of the CPP-601 and 

CPP-633 buildings. Primary constituents were two lines of shielded cells 

as well the Shift Lab, which provided a bench and hood.

CPP-630 Mass Spectrometry 

Facility

1956 2009 Primarily used to perform mass measurements on final product samples. 

CPP-633 Waste Calcining 

Facility

1963 1981 Converted aqueous nuclear fuel reprocessing waste into granular calcine 

solids. 

CPP-637 Process 

Improvement 

Facility

1959 ND Support facility using a chemical engineering laboratory for testing of 

plant processes with non-radioactive materials and un-irradiated 

uranium.

CPP-640 Hot Pilot 

Plant/Headend 

Process Plant

1963 1981 Support facility for testing new equipment and chemical flowsheets in 

support of the spent reactor fuel processing operations in CPP-601.

CPP-709 Eastside Service 

Waste Monitoring 

Station

1952 1990 Wastewater from floor drains, steam-condensate lines, equipmentcooling jackets, and the process-equipment-waste evaporator were routed 

through the basin of this building and pumped to an injection well.

CPP-734 Westside Service 

Waste Monitoring 

Station 

1960 1989 The normally-uncontaminated wastewater from steam condensate and 

equipment-cooling lines was routed to the basin of this building for 

monitoring and then flowed by gravity into an injection well.

Section 5.1.2 in Rev. 2 of the SEC-00219 INL Evaluation Report contains detailed information on 

CPP buildings and operations (NIOSH, 2017). The following discussion addresses facility operations 

and modifications of interest for this evaluation. 

By 1975, CPP had been operating for almost 25 years as a full-scale fuel-reprocessing facility with 

increased production requirements that resulted in almost continuous plant operations. In 1975, a 

campaign (Run #30) to co-process zirconium and aluminum fuels to recover uranium was completed, 

as well as a second electrolytic-processing campaign to convert recovered and purified uranyl nitrate 

solution to UO3 (Idaho Chemical Programs, 1976, PDF p. 3). Table 4-3 provides details of processing 

runs at CPP from 1975 through 1980 (Stacy, 2000, PDF pp. 285-286). Four operating periods of the 

Rare Gas Plant to recover Kr-85 and xenon isotopes were also successfully completed that year. 

These recoveries from the off-gas produced from dissolution of aluminum-clad fuel took place in 

specialized equipment located within the CPP-604 Waste Disposal Building (Fuel Reprocessing 

Complex, 2006, PDF p. 42). 

Table 4-3: Chronology of CPP Processing Runs (1975-1980) 

Run # Process Period Fuel Type

30 2/74 to 1/75 Zr, GETR, ATR, MTR, MTR 20%, TRA scrap, JRR, ETR, CP-5, OWR, JMTR, 

Juggernaut, KUR, Um, SER, LPTR, EBR-II Vycor glass, G.G.A.Thermionic, ETRC 

plates, University of Wyoming UO2SO4, Atomics International fission disc, HTRE scrap, 

Walter Reed Army Hospital, Nuclear Test Gauge/Split Table Reactor, HTGR secondary 

burner ash leaching, BMLfission disc

31 2/75 to 5/75 EBR-II, APPR cold fuel scrap

32 5/76 to 9/76 Zr, PWR

33 3/77 to 6/77 Godiva reactor fuel, HTRE, ATR, MTR, LPT, ETR, GETR

34 8/77 to 9/77 EBR-II, OMRE, SPERT, ORNL-17-1, BMI, Kinglet, Sandia (Godiva reactors), PBF 

metallurgical samples

35 7/78 to 3/79 Zr, custom

36 9/80 to 3/81 Zr, Rocky Flats U3O8, GETR, OWR, STIR, LPTR, UCLA-MTR, ATR, ETR, ATR-XA
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After a lengthy maintenance and decontamination period, the Waste Calcining Facility resumed 

operations in May 1975. Calcining a fluoride waste stream had not been considered in the original 

facility design. The processing of zirconium fluoride waste solutions amplified a condition of 

increased radioactive contamination depositing on the scratched and pitted surfaces of metal vessels 

and pipes (INEEL, 1997, PDF p. 48). Decontamination became steadily more difficult and residual 

radiation rates continued to rise over time (Decontamination, 1978, PDF p. 34). Also in 1975, funds 

to design a new calcining facility were authorized; the new facility was completed in 1982. Table 4-4 

provides details of the campaign runs at the Waste Calcining Facility from 1975 through 1980 

(INEEL, 1997, PDF p. 64). 

Table 4-4: Chronology of Waste Calcining Facility Campaigns (1975–1980)

Campaign No. Campaign Dates Waste Solution Calcined Liquid Waste Calcined (Gallons)

7 May 1975 – Jan 1977 Zirconium Fluoride 375,300

8 Aug 1977 – Sep 1978 Zirconium Fluoride 267,500

8 Aug 1977 – Sep 1978 Sodium Bearing 193,400

9 Jun 1979 – Mar 1981 Zirconium Fluoride 454,600

9 Jun 1979 – Mar 1981 Sodium Bearing 22,300

The CPP analytical laboratories had been a source of contamination issues at CPP due to the nature of 

the work performed (primarily analysis of process samples) as well as poor housekeeping. 

Contamination incidents were fairly common occurrences, especially in the Shift Lab (see Figure 4-4) 

in the Remote and Service Analytical Laboratory (CPP-627) (Norman, 1979). 

Figure 4-4: Laboratory Bench in the Shift Lab in 1977

Source: CPP Safety Review, 1977, PDF p. 46
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As a result of the ongoing contamination issues, plus an extended production outage in 1978 due to a 

small criticality in H-Cell of CPP-601, modifications were made in many of the CPP analytical 

laboratories. Modifications included the following (Dykes, 1981, PDF p. 2):

CPP-602: 

• Locker room modified and cafeteria relocated (1977) 

• Old exhaust HEPA filter boxes replaced with new bag-out type housings (1979) 

CPP-627: 

• New lab benches installed in the West End of the Shift Lab (1978) 

• Isolation room built for warm work in the East End of the Shift Lab (1980) 

• Lab benches in the East End of the Shift Lab replaced by open-front boxes (1980) 

• Prototype master/slave manipulators installed in an isolation box (1980) 

• System compatible with CPP Operations procedures installed to receive hot samples directly into 

the Remote Analytical and Service Laboratory (1980) 

The initial phase of compiling the ICPP Decontamination Manual4

 

4 ICCP stands for Idaho Chemical Processing Plant. CPP stands for Chemical Processing Plant. Both acronyms were used 

interchangeably at the site and are employed within this report as well, depending on the source document.

was completed in 1975. The 

manual contained 12 sections, each dealing with a specific group of plant vessels and equipment 

having a common contamination history. The sections covered all equipment used in fuel 

reprocessing and radioactive material handling that was subject to decontamination and contact 

maintenance (Idaho Chemical Programs, 1976, PDF p. 4). The importance of the effort to reduce 

radiation and contamination problems at CPP was evidenced in the decontamination and 

decommissioning (D&D) of process cells A, B, C, D, and L in the CPP-601 Main Processing Facility. 

These five process cells contained process equipment previously used for fuel reprocessing but 

categorized as surplus in 1978. The D&D operations began in July 1980 and were completed in June 

1984. The radioactive waste volume generated included 1024 ft3 of transuranic waste and 16,180 ft3

of non-compactible low-level waste (Process Cells, 1984, PDF p. 7).

Major decontamination efforts were also performed in other CPP buildings, including the CPP-603 

Fuel Storage Building. The facility had a number of contamination-control issues, including excess 

basin contamination levels, elevated general area radiation rates, and frequent personnel 

contamination incidents, including visitors (Rich, 1974a, PDF pp. 2-3). While the clean-up efforts 

were ongoing, it was not until 1977 that substantial results were realized after priority attention was 

given to reducing the radioactivity levels in the basin and improving the chemical make-up of the 

basin water (CPP Rad Controls, 1977, PDF pp. 2-3).

Beginning in 1978, a portion of the Hot Pilot Plant (CPP-640) was modified to support headend 

processing of graphite-based fuel. The name of the building was changed to the Headend Process 

Plant. Much of the fuel for this work came from a joint AEC and National Aeronautics and Space 

Administration (NASA) Rover project for developing a nuclear-powered rocket. When the project 

was abandoned, fuel was sent to ICPP for processing; however, graphite-based fuel processing did not 

begin until 1983 (Fuel Reprocessing Complex, 2006, PDF p. 39). 
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4.2 Radiation Exposure Potential from Operations

Based on the site operations outlined in Section 4.1, sources of external exposure at CPP were 

primarily attributed to photon and beta radiation. Neutron radiation was present due to spontaneous 

fissions and alpha-neutron reactions, but only at insignificant levels during the period under 

evaluation (Szulinski, 1980, PDF pp. 7 and 14). The potential for external radiation dose was 

primarily due to the presence of mixed fission and activation products from the reactor fuels processed 

at CPP. The majority of radioactivity in process raffinate solutions and calcined wastes were from the 

long and medium half-life fission products. In addition to the products present in the reactor fuels, 

activation of fuel cladding and structural materials (e.g., Mn-54 and Co-60) would also be present, but 

would vary depending on the type of fuel processed. Beta emissions would be present because most 

fission products are initially rich in neutrons and undergo beta decay to dissipate energy.

The primary sources of internal radiation exposure at CPP were related to its primary function of 

processing spent fuel elements containing enriched uranium in order to recover un-fissioned uranium. 

While the reprocessing itself was performed remotely in heavily-shielded cells, maintenance for the 

entire plant was performed via direct contact (CPP Safety Review, 1974). In addition, there was a 

large process sampling program that took raffinate samples from all three cycle extractions for

laboratory analysis. Another potential source of internal radiation exposure was during wastecalcining operations where liquid wastes were converted into solid granules for long-term storage. 

The primary radionuclides likely present throughout most CPP facilities during the period under 

evaluation would include uranium, mixed fission and activation products, radioactive noble gases, 

radioiodines, plutonium, and neptunium.

4.3 Time Period Associated with Radiological Operations

The first year of CPP radiological operations was 1951. CPP was used for reprocessing of spent 

nuclear fuel until 1992, when the Department of Energy (DOE) announced that the CPP reprocessing 

function would be phased out (Wagner, 1999, PDF p. 9). CPP was re-tasked with a mission focused 

on fuel-storage technologies and waste management. CPP was renamed the Idaho Nuclear 

Technology and Engineering Center (INTEC) in 1998 when the fuel reprocessing mission was 

officially over. At that time, DOE identified the Main Processing Building (CPP-601) for removal, 

along with the Fuel Storage Building (CPP-603), and several support structures. In 2005, DOE 

identified the remaining ICPP structures as obsolete; deactivation, decommissioning, and demolition 

(DD&D) of its buildings and structures began, including those associated with spent fuel reprocessing

(Fuel Reprocessing Complex, 2006, PDF pp. 11 and 58). 

As presented in Section 3.0 of this report, DHHS has already included CPP employees in the SEC for 

the period from March 1, 1970 through December 31, 1974 due to the lack of transuranic bioassay 

monitoring. The period from January 1, 1963 through February 28, 1970 is still under active review 

by the Advisory Board on Radiation and Worker Health. Further evaluation has revealed that it was 

not until 1981 that CPP implemented a routine transuranic bioassay program. Due to the date of this 

monitoring change, NIOSH has since determined that it cannot estimate internal radiation doses from 

exposures to transuranic radionuclides separated from mixed fission products with sufficient accuracy 

for employees who worked in any area of CPP from January 1, 1975 through December 31, 1980. 
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4.4 Site Locations Associated with Radiological Operations

NIOSH has determined that CPP-specific and claimant-specific data available for the period from 

January 1, 1975 through December 31, 1980 allow NIOSH to identify workers entering the CPP 

fenced area, but not worker movement within CPP. Although transuranic materials without mixed 

fission products present were located only in a few specific areas at CPP (primarily in the processing 

facility hot cells, the Multi-Curie Cell, and the analytical laboratories), there is no way to determine 

which CPP workers accessed those areas. NIOSH is therefore unable to define individual employee

exposure scenarios based on specific work locations within CPP during the period under evaluation. 

4.5 Job Descriptions Affected by Radiological Operations

NIOSH has determined that the site-specific and claimant-specific data available for CPP for the time 

period under evaluation (January 1, 1975 – December 31, 1980) are insufficient to allow NIOSH to 

determine that any specific work group was not potentially exposed to radioactive material releases or 

possible subsequent contamination. 

NIOSH has insufficient information associating job titles and/or job assignments with specific

radiological operations or conditions. Without such information, NIOSH is unable to define potential 

radiation exposure conditions based on employee job descriptions. 

5.0 Summary of Available Monitoring Data for the Proposed Class

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring are unavailable, internal 

exposures can sometimes be estimated using more general area monitoring, process information, and 

information characterizing and quantifying the source term.

This same hierarchy is used for determining the external exposures to the cancer site. Personal 

monitoring data from film badges or thermoluminescent dosimeters (TLDs) are the primary data used 

to determine such external exposures. If there are no personal monitoring data, then area and 

environmental dosimeter data, exposure rate surveys, process knowledge, and source term modeling 

can be used to reconstruct the potential exposure. 

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available on the Radiation 

Dose Reconstruction Program (DR) page. 
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5.1 Data Capture Efforts and Sources Reviewed 

As a standard practice, NIOSH completed an extensive database and Internet search for information 

regarding Idaho National Laboratory. The database search included the DOE Legacy Management 

Considered Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, 

the Energy Citations database, and the Hanford Declassified Document Retrieval System. In addition 

to general Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, 

OSTI Information Bridge Fielded searches, Nuclear Regulatory Commission (NRC) Agency-wide 

Documents Access and Management (ADAMS) web searches, the DOE Office of Human Radiation 

Experiments website, and the DOE-National Nuclear Security Administration-Nevada Site Officesearch. Attachment One contains a summary of Idaho National Laboratory documents. The summary 

specifically identifies data capture details and general descriptions of the documents retrieved.

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH.

5.2 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH DCAS Claims Tracking System (referred to as NOCTS) to locate 

EEOICPA-related dose reconstructions that might provide information relevant to the petition 

evaluation. Table 5-1 summarizes the results of this review. (NOCTS data available as of June 5, 

2017). 

Table 5-1: No. of INL Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 1928

Total number of claims submitted for energy employees who worked during the period under 

evaluation (January 1, 1975 through December 31, 1980). 1015

Number of dose reconstructions completed for energy employees who worked during the period 

under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 957

Total number of claims submitted for energy employees who started their employment during the 

period under evaluation (January 1, 1975 through December 31, 1980) 567

Number of claims for which internal dosimetry records were obtained for the identified years in 

the evaluated class definition 308

Number of claims for which external dosimetry records were obtained for the identified years in 

the evaluated class definition 605
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5.3 Employee Interviews

To obtain additional information about INL, NIOSH interviewed a large number of current and former 

INL employees during the SEC-00219 INL evaluation. Those interviews included both in-person and 

telephone interviews. An additional joint interview (2016a below) was conducted with two former 

INL employees for the specific purpose of supporting this SEC-00238 evaluation because these 

individuals were considered likely to have new information on the CPP for the period under 

evaluation. A review of all SEC-00219 interviews identified the following 21 interviews as germane 

to the CPP focus in this SEC-00238 evaluation. 

• Personal Communication, 2014a, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

ABRWH, and SC&A; June 24, 2014; SRDB Ref ID: 142401

• Personal Communication, 2014b, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS and SC&A; 

June 24, 2014; SRDB Ref ID: 142397

• Personal Communication, 2014c, Personal Communication with former Department of EnergyIdaho Office [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ABRWH, 

and SC&A; June 24, 2014; SRDB Ref ID: 142359

• Personal Communication, 2014d, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

ABRWH, and SC&A; June 25, 2014; SRDB Ref ID: 142404

• Personal Communication, 2014e, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by ORAU Team, 

ABRWH, and SC&A; June 25, 2014; SRDB Ref ID: 142364

• Personal Communication, 2014f, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

ABRWH, and SC&A; June 25, 2014; SRDB Ref ID: 142387 

• Personal Communication, 2014g, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU 

Team, ABRWH and SC&A; June 26 2014; SRDB Ref ID: 142362

• Personal Communication, 2014h, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

ABRWH, and SC&A; September 10, 2014; SRDB Ref ID: 142398

• Personal Communication, 2014i, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH and SC&A; 

November, 2014; SRDB Ref ID: 141472

• Personal Communication, 2014j, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

ABRWH, and SC&A; November 17, 2014; SRDB Ref ID: 159717
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• Personal Communication, 2014k, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU 

Team, ABRWH, and SC&A; November 18, 2014; SRDB Ref ID: 141477

• Personal Communication, 2014l, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU 

Team, ABRWH, and SC&A; November 18, 2014; SRDB Ref ID: 141478

• Personal Communication, 2014m, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU 

Team, ABRWH and SC&A; November 18, 2014; SRDB Ref ID: 142363

• Personal Communication, 2014n, Personal Communication with current Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH and SC&A; 

November 18, 2014; SRDB Ref ID: 141480

• Personal Communication, 2014o, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU 

Team and SC&A; November 19, 2014; SRDB Ref ID: 142360

• Personal Communication, 2014p, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

and SC&A; November 19, 2014; SRDB Ref ID: 142405

• Personal Communication, 2014q, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, 

ABRWH, and SC&A; November 19, 2014; SRDB Ref ID: 159715

• Personal Communication, 2014r, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH and ORAU 

Team; December 11, 2014; SRDB Ref ID: 141471 

• Personal Communication, 2016a, Personal Communication with former Idaho National 

Laboratory [job title redacted]and a DOE Idaho Operations [job title redacted]; In-person 

interview at Idaho Falls, Idaho by ORAUT and DCAS; January 27, 2016; SRDB Ref ID: 167245

• Personal Communication, 2016b, Personal Communication with former Idaho National 

Laboratory [job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ABRWH, 

and SC&A; January 27, 2016; SRDB Ref ID: 159731

• Personal Communication, 2016c, Personal Communication with former Idaho National 

Laboratory [job title redacted]; Phone interview by ABRWH, and SC&A; February 16, 2016; 

SRDB Ref ID: 159716

• Personal Communication, 2016d, Personal Communication with former Idaho National 

Laboratory [job title redacted]; Phone interview by DCAS, ABRWH, and SC&A; April 5, 2016; 

SRDB Ref ID: 159718
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5.4 Incidents

The CPP was especially designed for the dissolution of a wide variety of spent reactor fuels for the 

principal purpose of recovering enriched uranium. Because its primary activities involved the 

handling and storage of spent fuel, chemical separation, and disposal of process wastes, radiological 

incidents did occur. However, during the period under evaluation (1975-1980), most of these 

incidents were minor in nature (CPP West Gate, 1975; Contamination Incidents, 1978). INL’s 

monitoring and analytical programs were designed to initiate an investigation of any potential internal 

intake that was indicated by off-normal workplace indicators, such as personnel contamination or 

positive air sampling. NIOSH found extensive personal monitoring data for mixed fission and 

activation products (beta/gamma); therefore, only two external radiation events of interest plus the 

criticality in H-Cell in 1978 are discussed below. 

• Plutonium Spill in CPP-602 (February 1975): A plutonium spill occurred in CPP-602, Room 703.

No detectable personnel exposures (Condotta, 1981).

• Exposure Limit Exceeded During CPP-603 Basin Filters Change-Out (June 16-21, 1976):

Exposures to [number redacted] CPP operations personnel during basin filter backwashing

operations at the CPP-603 Fuel Storage Building resulted in exceeding the quarterly skin exposure

limit of 5 rem for second quarter 1976 (Exposures, 1973, PDF p. 182). The basin wash filters

were originally supplied with an automatic backwashing system but this was abandoned after

problems were encountered. Subsequently, a manual system was adopted even though it was

known that higher personnel exposures would result. The overexposure was primarily the result

of not reviewing exposure histories prior to work. The overexposures also pointed out the need

for the much-needed basin filtration system which was in the process of being installed at the time

of the incident.

• Radiation Incident at CPP-603 (November 27, 1976): During routine duties at the CPP-603 Fuel 

Storage Building, it was reported that a canister of material was floating on the surface of the basin 

water (Storms, 1976, PDF p. 2). Radiological measurements indicated a 3 R/hr direct radiation 

dose rate but no airborne activity. Personnel exposures from the dosimeters of [number redacted] 

workers in the affected area indicated a maximum whole body dose of 70 mrem. The incident was 

another indicator of needed operational safety upgrades to the CPP-603 facility.

• Criticality Accident (October 17, 1978): The accident occurred in a shielded operation of the firstcycle solvent-extraction columns in CPP-601, which were designed to remove fission products 

from dissolved irradiated reactor fuel in order to recover enriched uranium. The criticality 

occurred in the H-100 column (in the H Cell) after a dilute solution containing increased uranium 

levels (due to a leaking water valve on a make-up tank) caused an increase in the uranium

inventory of the column until the excursion occurred (1979 CPP Criticality, 2000, PDF p. 59).

Radiation alarms alerted CPP workers to the increased radiation rates resulting from the criticality.

The extraction columns were shut down and the plant evacuated. Forty five operations personnel

and 35 construction personnel were evacuated. Personnel and the environment were monitored to

determine the extent of radiation exposure and contamination. [Number redacted] construction

workers and 11 operations personnel received whole-body counts as follow-up bioassay. The

results showed no internal deposition of radioactive material due to the accident. Personnel

radiation dosimeters were pulled and processed. The maximum whole-body dose to any
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individual was less than 130 mrem (Note: This dose also included the previous two weeks 

exposure accumulated on the dosimeter) (DOE, 1978, PDF p. 43). No contamination attributable 

to the incident was found on or near the CPP site or in the environment. There were no significant 

personnel exposures and no damage to process equipment as a result of the criticality. However, 

as a direct result of this event, the plant entered an “extended and expensive” shutdown (1979 CPP 

Criticality, 2000, PDF p. 59). 

• CPP Shift Lab (1981): Although there was not a contamination event of dosimetric consequence 

during the period under evaluation, there were a series of contamination control problems in the 

CPP Shift Lab, sometimes involving alpha-emitting radionuclides. In 1981, this culminated in the 

identification (via routine in-vivo bioassay) of uranium and plutonium intakes for a number of 

Shift Lab radioanalysts. 

5.5 Internal Monitoring Data

A class of CPP workers was added to the SEC as a result of the SEC-00219 evaluation that discovered 

a lack of transuranic bioassay data from 1963 through 1974 despite new activities that involved 

separating certain transuranic radionuclides from the mixed fission products. The October 1974 report 

entitled Preliminary ICPP Health Physics Upgrade Program stated that an improved bioassay 

program was necessary due to the increase in routinely encountered alpha activity plausibly 

attributable to plutonium (ICPP HP Upgrade, 1971-1980). At the time of the report, CPP workers 

were only required to have a whole-body count every four years with urinalysis required, as deemed 

necessary by CPP Health Physics, depending on radiological conditions. This monitoring program 

was inadequate for transuranic materials such as plutonium. In an effort to rectify this deficiency, a 

routine in-vitro bioassay program was planned. Also planned were upgrades to the existing chestcounting program to “state of the art detection capabilities believed to be essential for plutonium lung 

counting support of the ICPP internal dosimetry program” (ICPP HP Upgrade, 1971-1980, PDF p.

113). Endeavors to improve calibration methods and lower the in-vivo detection limit for transuranic 

radionuclides of interest were undertaken. A systematic investigation into uncertainties associated 

with chest-counting, such as chest-wall thickness, calibration uncertainty, and subject background was 

also undertaken so that the propagated uncertainty with chest-counting for transuranic materials could 

be better understood. 

The upgrades in the CPP bioassay program were slow to be implemented. In February 1975, an initial 

request was made to the Health Services Laboratory (HSL) for support of a routine CPP bioassay 

program that would include in-vitro (urine and feces) and in-vivo bioassay. It was requested that 

plutonium, uranium, and strontium-90 analyses be performed on 150-200 urine samples, with a like 

number of plutonium analyses performed on fecal samples. There is an indication that the substantial 

workload resulting from such a large number of time-consuming analyses could not be supported at 

that time (Anderson, 1975, PDF pp. 3-4). 
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While the requested analytical services were not implemented for CPP in 1975, the Analytical 

Chemistry Branch of the HSL performed some investigatory work on plutonium analyses of feces. 

This work indicated that this type of analysis would be the preferred matrix for plutonium bioassay. 

Additional work was done on screening fecal samples to determine the severity of a potential 

inhalation intake of insoluble plutonium. As a result of this work, the HSL offered (in 1977) to 

provide support for 50 fecal analyses for plutonium, 50 fecal analyses for gamma-emitters and 

strontium-89/90, 50 urinalyses for gamma-emitters and strontium-89/90, 50 urinalyses for isotopic 

uranium, and 50 urinalyses for natural uranium (Williamson, 1976, PDF pp. 2-3). 

The beginnings of the routine bioassay program were implemented in 1978. The sampling program 

was limited, but it indicated that low-level plutonium exposures were occurring at CPP. The initial 

bioassay program focused on chemists, analysts, operations personnel, decontamination technicians, 

and instrumentation personnel (Bioassay, 1978, PDF p. 2). In November 1980, a planned substantial 

upgrade in the “ICPP Internal Dose Monitoring Program” was announced. The upgrade involved an 

increase in the number of in-vivo and in-vitro bioassays, including plutonium, uranium, and strontium 

in-vitro analyses. The program consisted of a staggered schedule of annual in-vitro bioassay and 

annual or semi-annual in-vivo bioassay for selected organizations or groups of employees deemed to 

have the highest internal exposure potential. Supervisors were required to provide lists of employees 

scheduled for in-vivo bioassay to the Radiological and Environmental Sciences Laboratory (RESL)5

 

5 Health Services Laboratory was renamed the Radiological and Environmental Sciences Laboratory in 1978.

a 

month in advance. Likewise, a list of employees scheduled to submit in-vitro bioassay samples was 

generated with notices provided to affected workers a month in advance. Instructions on sample 

collection and sample collection kits were distributed by the CPP Dispensary (CPP Program Upgrade, 

1980, PDF pp. 2-3).
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The gradual implementation of a routine bioassay program for plutonium analysis is reflected in the 

in-vitro bioassay data in the possession of NIOSH. Table 5-2 provides the annual number of 

plutonium bioassays performed in both urine and fecal matrices from 1970 through 1986. The limited 

analyses in 1978 and the full implementation of a plutonium in-vitro bioassay program in January 

1981, as described in INL documentation, are reflected in these data.

Table 5-2: Plutonium In-vitro Bioassay Analyses by Year for CPP (1970-1988) 

Year Urine Fecal

1970* 1 0

1971* 0 0

1972* 86 0

1973* 55 0

1974* 29 0

1975* 7 0

1976 0 0

1977 0 0

1978 3 8

1979 14 11

1980 36 1

1981 214 278

1982 180 226

1983 220 357

1984 209 314

1985 369 300

1986 137 324

Source: Bioassay, 1958-1986

Note: * means that values for that year are from NIOSH, 2017, Table 7-6 

The plutonium in-vitro analyses performed by month in 1981 were reviewed to ensure that the routine 

program was fully implemented at the beginning of the year as indicated. Table 5-3 presents these 

data. The substantial increase in analyses beginning in July 1981 are the result of follow-up 

monitoring of personnel after a routine positive bioassay for a Shift Lab radioanalyst detected an 

intake in May 1981 (Shift Lab Intakes, 1981). The analyses per month remain elevated until returning 

to routine levels in October 1981. 
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Table 5-3: Plutonium In-vitro Bioassay Analyses by Month for CPP in 1981

Month/Year Urine Fecal

Jan-1981 4 0

Feb-1981 18 3

Mar-1981 9 2

Apr-1981 7 2

May-1981 17 1

Jun-1981 10 15

Jul-1981 80 166

Aug-1981 23 56

Sep-1981 16 25

Oct-1981 10 6

Nov-1981 10 2

Dec-1981 10 0

Total 214 278

Source: Bioassay, 1958-1986

5.6 External Monitoring Data

In January 1975, INL returned to a “one badge, one area” policy for external dosimetry. The appeal 

for returning to this policy is captured in the following memo excerpt from the Director of the INL 

Security Division in November 1974: 

It is the desire of the ID Health Services Laboratory, Aerojet Nuclear Company, and Allied 

Chemical Corporation to return to the original concept of one badge for one area. The present 

multi-area badge system was initiated in 1969 on a recommendation by [name redacted] then of 

Idaho Nuclear Corporation, at a time when INC controlled all of the areas concerned. Now that 

the area responsibilities are divided between ANC and ACC, and because of the frequent 

interchange of personnel between the areas, the multi-area badge system is no longer adequate 

for the necessary radiation exposure control and the identification of the location of the radiation 

source. These capabilities are extremely important now due to the inception of the "as low as 

practicable" concept in personnel radiation exposure. (Dosimetry, 1972-1981, PDF p. 145)

The implementation of the ALARA (As Low As Reasonably Achievable) concept to reduce radiation 

exposures was led by the Health Physics Group at the Idaho Nuclear Corporation, which introduced 

new administrative controls in 1974. Each branch manager was required to set annual exposure goals 

below 3 rem per year for each radiation worker who had received an annual exposure greater than 0.5 

rem for the previous year. These controls resulted in the use of added shielding in operating areas and 

hot cells, a clean-up of plant areas having elevated radiation levels, and a more even distribution of 

exposures among people in the same maintenance crafts. Each succeeding year, the exposure 

experience was reviewed by branch management and efforts were made to lower the exposure goal for 

each individual (Occupational Exposure History, 1993, PDF p. 54). 
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ALARA was especially important in the mid- to late-1970s. In 1975, CPP had a low plant collective 

dose of about 340 person-rem because almost continuous fuel reprocessing allowed only for minimal 

direct maintenance. However, the following year extensive upgrading and expansion of the plant and 

construction staffs resulted in a near doubling of the collective dose. By 1978, due to a 

comprehensive facility clean-up, CPP comprised about 70% of the total INL collective exposure 

(Occupational Exposure History, 1993, PDF p. 53). 

In February 1974, a locally researched and developed dosimetry system was implemented for all INL 

areas except for the Naval Reactor Facility. This system, called ATLAS (Automatic 

Thermoluminescence Analyses System), used lithium fluoride (LiF) in a Teflon matrix that was the

identical shape and size as the film packet it was to replace. However, the ATLAS system proved to 

be problematic for use in a large occupational dosimetry program due to the inconsistent and 

unpredictable nature of its TLD response. The variations observed in comparison tests between the 

ATLAS dosimeters and direct-reading dosimeters demonstrated the ATLAS system “exceeded

tolerable limits for use in our radiation protection program” according to a December 1974 memo 

from the Director of the INL Safety Division (Dosimetry, 1972-1981, PDF p. 277). 

In December 1974, the CPP dosimetry program began an upgrade to a two-chip LiF dosimeter by 

having a small group of workers wear the LiF chip dosimeter, the ATLAS LiF Teflon dosimeter, and 

a Savannah River Site dosimeter that had been requested for testing (Dosimetry, 1972-1981, PDF p.

38). The two-chip LiF dosimeter was selected and a Harshaw Model 2000 TLD system was 

implemented at INL. By May 1975, all INL areas were using the Harshaw TLDs (Dosimetry Branch 

Changes, 1978, PDF p. 3). 

Other changes to the INL external dosimetry program that are of interest for the period under 

evaluation included a change to TLD-700 chips for use as extremity dosimeters. The TLD disc that 

had been in use delivered an erratic response to high-energy beta fields and also reduced manual 

dexterity. The change to TLD-700 chips led to increased usage by INL personnel (Dosimetry 

Program, 1974, PDF p. 41; Dosimetry Branch Changes, 1978, PDF p. 5). In October 1976, INL 

began testing a new albedo neutron dosimeter. This dosimeter consisted of an outer cadmium case 

and an inner polyethylene shield with TLD-700 and TLD-600 chips; this dosimeter replaced the NTA 

neutron film badges in 1977 (Aoki, 1979, PDF p. 4). 

Access to the CPP operating area was controlled by an outer security fence and security-controlled 

gates. In addition, all personnel entering the CPP operating area were required to be monitored for 

external dose via a dosimeter (i.e., by film badge or TLD). Due to this entry requirement, individuals 

who entered the CPP operating area can be identified by their external dosimetry, which also indicates 

when they were there. In an effort to provide a review of the completeness of the CPP area external 

dosimetry records for 1975 through 1980, the CPP and CX (CPP Construction) area exposure reports, 

which contain individual dosimeter results, were compared to the dosimeter processing numbers 

reported in the INL Dosimetry Branch monthly reports. Not all of the Dosimetry Branch monthly 

reports during the evaluation period were found. 
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Figure 5-1 provides a comparison of the monthly totals reported in the Dosimetry Branch monthly 

reports that were found and the monthly CPP area exposure reports. NOTE: The bars for 1975 also 

represent data from CPP 55 printouts and CPP 55 monthly reports (see Table 5-1 Note). 

Figure 5-1: Comparison of Number of Personnel Monitored on Monthly CPP Area Exposure Reports vs. 

Dosimetry Branch Monthly Reports for 1975-1980

Source: Exposure Reports, 1975; CPP Area Exposures, 1976; CPP Area Exposures, 1977; CPP Area Exposures, 1978; CPP 

Area Exposures, 1979; CPP Area Exposures, 1980; DOE Idaho Summaries, 1975; DOE Idaho Summaries, 1978; DOE Idaho 

Summaries, 1979; DOE Idaho Summaries, 1980; ERDA Idaho Summaries 1976; ERDA Idaho Summaries 1977

NOTE: CPP 55 was the code used to designate annual TLD exchange. 
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Figure 5-2 provides a comparison of the monthly totals reported in the Dosimetry Branch monthly 

reports that were found and the monthly CX area exposure reports. NOTE: The bars for 1975 also 

represent data from EPFCON printouts and EPFCON monthly reports (see Table 5-2 Note). 

Figure 5-2: Comparison of Number of Personnel Monitored on Monthly CX Area Exposure Reports vs. Dosimetry 

Branch Monthly Reports for 1975-1980

Source: CXM Area Exposures, 1975; CXM Area Exposures, 1976; CXM Area Exposures, 1977; CXM Area Exposures, 

1978; CXM Area Exposures, 1979; CXM Area Exposures, 1980; DOE Idaho Summaries, 1975; DOE Idaho Summaries, 

1978; DOE Idaho Summaries, 1979; DOE Idaho Summaries, 1980; ERDA Idaho Summaries 1976; ERDA Idaho Summaries 

1977

NOTE: NIOSH has been unable to confirm the full definition of the acronym “EPFCON.” However, it has been confirmed 

that “CON” refers to construction. EPFCON was the designator used for a series of exposure reports that broke out exposures 

both by construction company and by area. It appears that INL generated these reports only in 1974 and 1975.
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5.7 Workplace Monitoring Data

NIOSH has access to workplace air, surface, and environmental monitoring data for CPP. The CPP 

Health Physics program records include limited air sample data for alpha-emitters but more complete 

records for beta/gamma-emitters. This difference is primarily due to the widely-held belief that 

beta/gamma-emitters would always be present as an indicator of contamination. In 1975, CPP facility 

surveys were performed with large area survey pads because the standard disc smears were ten times 

less sensitive and also gave a poor measure of “sandy” particulate contamination. It was felt that this 

use of large pads more realistically represented what could “rub off” onto clothing, and also accounted 

for the “mysterious” source of activity on people who claimed to have never been in a “contaminated” 

area. As a result of the surveys, cleaning of facility buildings from “top down” was recommended 

(Contamination Surveys, 1975). 

In 1976, a “red-white-blue” contamination control program was initiated with the long-term goal of 

decontaminating CPP to essentially “non-detectable” levels through removal or isolation of the 

contamination source. Color codes were used to identify areas by contamination levels. In 1978, the 

“red-white-blue” program was replaced with one that segregated the plant into three zones in order of 

increasing contamination severity. These zones were designated: (1) “clean areas” for radioactivelyclean plant areas; (2) clean laboratories handling small quantities under stringent control measures; 

and (3) controlled areas for those plant areas known to contain smearable contamination on accessible 

surfaces. While the program resulted in major accomplishments in upgrading the CPP Health Physics 

program, improvements were still needed, as succinctly captured in the following statement from the 

1978 Health Physics Annual and Upgrade Status Report (Rich, 1979): 

Though the plant is undergoing major construction and upgrading, the record indicates that 

contamination and radiation have been controlled and reduced, indicating that ALARA 

efforts have been successful to a degree. It is equally obvious from a casual site inspection 

that the anticipated end goals have not yet been achieved. Much improvement is to be 

expected in the areas of job planning as it pertains to radiation exposure reduction and 

overall plant discipline in housekeeping and the related “crispness” in controlling 

contamination at the boundary barricades isolating areas of known or potential 

contamination. 

The criticality in H-Cell of CPP-601 in October 1978 resulted in an extended production outage that

was used to perform a wide-scale decontamination program at CPP. In addition to decontamination, 

sources of contamination were removed and needed facility modifications were made to improve 

contamination containment. The decontamination efforts were documented in at least one personnel 

interview as well (Personal Communication, 2014n). 

Over time, the contamination control program continued to improve with the growing importance of 

alpha monitoring becoming integrated into the program. Figures 5-3 and 5-4 provide contrasting 

visual examples of this integration. Figure 5-3 shows a contamination survey of CPP-601 Lab 211 in 

1977. The survey reports the contamination levels as less that radiation control guides “<RCG” except 

for posted “Ribboned Area.” 
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Figure 5-3: Example of Contamination Survey of CPP-602 Lab 211 in 1977

Source: CPP Contamination Surveys 1977, PDF p. 16
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Figure 5-4 shows a contamination survey of CPP-602 Lab 211 in 1981. In contrast to the 1977 

survey, this survey provides both beta-gamma and alpha contamination levels for each location 

smeared within the lab.

Figure 5-4: Example of Contamination Survey of CPP-602 Lab 211 in 1981

Source: CPP Contamination Surveys 1981, PDF p. 132
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An additional example of the emphasis on control and handling of alpha-emitting radionuclides is 

found in the 1982 Standard Operating Procedure, Control and Handling of Radioactive Materials. 

The included Radiological Hazards Checklist specifies “operation involves alpha emitters which are 

not tagged with detectable quantities of gamma emitters” as a condition that requires Health Physics 

approval prior to work (see Figure 5-5) (SOP, 1982, PDF p. 11). 

Figure 5-5: Radiological Hazards Checklist from CPP Procedure, Control and Handling of Radioactive Materials

(1982)

Source: SOP, 1982, PDF p. 11
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ORAUT-TKBS-0007-4, Table 4-13 provides a summary of the annual environmental external doses 

for each major operating area at INL. For the years 1975-1980, facility fence-line TLD measurements 

were read on a six-month basis and recorded in Environmental Monitoring Data reports. Because all 

the workers in INL’s radiological areas were monitored for external dose, and because the DOE 

provides each worker’s dosimeter data for NIOSH dose reconstruction, the only doses that need to be 

assigned for the unmonitored workers at INL are onsite ambient (environmental) external doses. 

Because the control dosimeters at INL were likely exposed to elevated levels of onsite ambient 

radiation due to being located at the entrances of the major operating areas, onsite ambient doses are 

also assigned to all monitored INL workers to account for any radiation dose that may have been 

inappropriately subtracted from their dosimeter results as background radiation (ORAUT-TKBS0007-6). To bound any onsite ambient dose when an energy employee’s work location for a given 

year was unknown (often the case for unmonitored workers), the highest onsite ambient dose for any 

operating area can be assigned for that year.

For INL EEOICPA claims, environmental internal doses are only assessed for certain unmonitored 

workers, as discussed in the guidance in ORAUT-TKBS-0007-5, Section 5.6. ORAUT-TKBS-0007-4 

and its supplement (Peterson, 2004) provide the historical background, rationale, and environmental 

intake data for reconstructing occupational environmental internal doses at the INL site. In summary, 

ORAUT-TKBS-0007-4 provides annual environmental intakes of the significant radionuclides for 

each major operating area on the INL site.

5.8 Radiological Source Term Data

The diverse fuel reprocessing, analytical, process testing and improvement, waste storage, and waste 

treatment operations at CPP resulted in potential exposures to various radionuclides. The radiological 

source term is described in detail in Rev. 2 of the SEC-00219 INL Evaluation Report (NIOSH, 2017). 

This evaluation for SEC-00238 identifies radionuclides of concern in fuel-reprocessing operations 

areas and in support areas. Of particular interest for the period under evaluation are the transuranic 

radionuclides, especially plutonium-238. Although most of the fission products appeared in the firstcycle waste at CPP, transuranic radionuclides tended to carry through the first-cycle separation 

process and appear in the second- and third-cycle waste. This resulted in a changing ratio of 

transuranics-to-fission products throughout fuel reprocessing. In practice, this meant that fission 

products were a very effective tracer early in the separation process; however, the relative hazard of 

the transuranic component became dominant over the fission product activity later in the process. 

While this phenomenon was very well known among CPP’s professional staff, this information was 

not effectively communicated to the workforce, including the radiological control staff.

The relative hazard associated with plutonium was presented in a 1980 document by dividing the 

typical concentrations of radionuclides found in the co-processing feeds by the maximum permissible 

concentration (MPC) to determine the percentage that each radionuclide contributes to the total hazard 

(Szulinski, 1980, PDF p. 11). Table 5-4 presents the results, which show that 58% of the hazard came

from Pu-238 and 35% came from Sr-90. 
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The processing of higher burnup fuels at CPP was expected to exacerbate the plutonium/mixed fission 

product ratios. Due to increased concentrations in plutonium, the hazard was not only present as a 

result of fuel reprocessing but also present in analytical samples and waste streams including the solid 

content generated by the calcining of liquid waste.

Table 5-4: Relative Hazard in CPP Fuels by Radionuclide in 1980

Radionuclide Percent of Total Hazard for 

Co-processing*

Percent of Total Hazard for 

FAST DBFE**

Sr-90 35.3 24.7

Cs-134 0.6 0.3

Cs-137 0.6 0.4

Cs-144 2.4 8.6

Pu-238 58.8 59.1

Pu-239 0.4 1.2

Pu-240 0.4 0.8

Pu-241 0.9 3.7

Sum f.p. 38.9 34.0

Sum TRU 60.5 64.8

Sum Total 99.4 98.8

Source: Szulinski, 1980, PDF p. 12

Notes: 

* Co-processing = Co-processing fuels (aluminum and zirconium)

** FAST DBFE = FAST Design Basis Fuel Element

Another change to the CPP transuranic source term during the period under evaluation involved the 

disposal of neptunium concentrate in 1977. Neptunium recovery from the CPP raffinate ceased in 

1973, but the accumulated neptunium concentrate was not disposed of until March 1977. The major 

reason for termination of neptunium recovery and the subsequent disposal of the concentrate was the

alpha-handling concerns associated with the material (Dickey, 1977, PDF p. 2). 

In the absence of employee or workplace-monitoring data, the source term and activity data available 

to NIOSH are not adequate to reconstruct radiation doses with sufficient accuracy. 

6.0 Feasibility of Dose Reconstruction for the Proposed Class

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient,

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy.

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible. 

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 
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research and analysis is required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and whose only possible remedy under EEOICPA is the addition 

of a class of employees to the SEC. 

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions.

6.1 Feasibility of Estimating Internal Exposures

NIOSH has evaluated the available employee and workplace monitoring data and source term 

information and has determined that there are insufficient data for estimating internal exposures, as 

described below.

As presented in Section 3.0 of this report, DHHS has previously designated an SEC class for INL CPP

from March 1, 1970 through December 31, 1974. The NIOSH-recommended class for the period 

January 1, 1963 through February 28, 1970 is still under active review by the Advisory Board on 

Radiation and Worker Health. 

In Rev. 2 of the SEC-00219 INL Evaluation Report (NIOSH, 2017), NIOSH determined that a routine 

bioassay monitoring program for transuranic radionuclides had not been established for CPP despite 

increased contamination levels during the evaluation period from January 1, 1949 through December 

31, 1970. Though outside the evaluation period, the end date for the identified monitoring deficiency 

was chosen as December 31, 1974, based on a report entitled Preliminary ICPP Health Physics 

Upgrade Program released in October 1974 (Rich, 1974). After the SEC-00219 evaluation, NIOSH 

continued its data capture activities in an attempt to locate additional data that could be used to 

determine when a transuranic bioassay program was established for CPP. 

Available bioassay data for CPP employees include beta/gamma urine bioassay, uranium bioassay, 

and very limited plutonium bioassay. In addition, there are comprehensive in-vivo bioassay data, 

primarily in the form of whole-body counting. There are limited chest-counting data (the method 

described in Section 5.5 of this report was still being developed and had limited detection capabilities 

for plutonium).

In 1966, the routine collection of urine samples at INL was halted in favor of a transition to reliance 

on whole-body counting (McCaslin, 1966, PDF p. 19). Incident-prompted special urine analyses were 

also performed, as deemed necessary at CPP, but not to a degree that would allow for the bounding of 

exposures to transuranic radionuclides, considering that there was a general lack of appreciation for 

the radiotoxicity of plutonium among the general CPP workforce. In addition, a complacent attitude 

towards low-level contamination had arisen at CPP (Rich, 1974). The analytical laboratories, in 

particular the CPP Shift Lab, were beleaguered with contamination control problems, including alphaemitting radionuclides. Table 6-1 provides examples of reported alpha contamination during the 

period June 1 to August 16, 1979. When intakes of plutonium and uranium were discovered via 
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routine bioassay for multiple CPP Shift Lab radioanalysts in 1981, plutonium and uranium analyses 

were fully implemented as demonstrated in INL documentation (Alexander, 1981). 

Table 6-1: CPP Shift Lab Alpha Contamination Reported Between June 1, 1979 to Aug., 16, 1979

Date Time Description

June 1, 1979 15:30 Shift Lab contaminated when sample spike with uranium spilled. After 

cleaning area once, lab smeared 240 dpm alpha. Requested to clean again.

June 1, 1979 18:20 Survey of Shift Lab showed contamination to 240 dpm alpha, 500 dpm 

beta/gamma.

June 13, 1979 14:35 Shift Lab survey showed contamination of 8,168 dpm alpha

June 15, 1979 23:00 Routine survey of Shift Lab showed the following: Sink 600-800 dpm 

beta/gamma; Controlled Area 400-9,000 dpm beta/gamma and 100 dpm 

alpha.

June 17, 1979 18:00 Survey of Shift Lab showed contamination on cabinet. Contamination to 

250 dpm alpha.

July 4, 1979 2:00 Shift Lab survey shows as follows: East Hood - 300 cpm alpha; Floor 

300-2000 dpm beta/gamma and 1700 dpm alpha

July 21, 1979 3:00 Survey of Shift Lab showed contamination as follows (smears): Second 

survey showed 22,500 dpm beta/gamma and 5,800 dpm alpha

August 13, 1979 18:30 Survey of Shift Lab is as follows: Hood ledges contaminated to 3,200 

dpm beta/gamma and 120 dpm alpha

Source: Norman, 1979

Much of the source term information for CPP is available through site records. INL established and 

maintains a centralized records program that has been used by NIOSH. Health physics records, 

source term and process information, including types and quantities of specific radionuclides and 

sources present, and the types and frequency of operations are available to NIOSH. 

NIOSH has concluded, based on assessment of the available employee monitoring data, that there are 

insufficient internal dosimetry data or air monitoring data available to bound intakes of transuranic 

radionuclides for the period from January 1, 1975 through December 31, 1980. Nor does NIOSH 

have access to sufficient source-term data, for programs or facilities over time, to estimate potential 

internal exposures to transuranic radionuclides during this period of DOE operations. Consequently, 

NIOSH finds that it is not feasible to estimate, with sufficient accuracy, internal exposures to 

transuranic radionuclides and resulting doses for the class of employees covered by this evaluation. 

Although NIOSH found that it is not possible to completely reconstruct internal radiation doses for the 

period from January 1, 1975 through December 31, 1980, NIOSH intends to use any internal 

monitoring data that may become available for an individual claim (and that can be interpreted using 

existing NIOSH dose reconstruction processes or procedures). Dose reconstructions for individuals 

employed at CPP during the period from January 1, 1975 through December 31, 1980, but who do not 

qualify for inclusion in the SEC, may be performed using these data as appropriate. 

6.2 Feasibility of Estimating External Exposures

This evaluation responds to a petition based on NIOSH determining that internal radiation exposures 

to transuranic radionuclides cannot be reconstructed for a dose reconstruction referred to NIOSH by 

the Department of Labor (DOL). As noted above, HHS will consider this determination to be 

sufficient without further consideration to determine that it is not feasible to estimate the levels of 
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radiation doses of individual members of the class with sufficient accuracy. Consequently, it is not 

necessary for NIOSH to fully evaluate the feasibility of reconstructing external radiation exposures for 

the class of employees covered by this report. 

In its previous SEC-00219 INL class designation, NIOSH found that it has access to sufficient 

employee monitoring data to bound potential external exposures for employees at CPP from the 

beginning of radiological operations in 1951 through 1974. This current evaluation has found no 

evidence to the contrary for the period from January 1, 1975 through December 31, 1980. NIOSH has 

established that it has access to sufficient information to either: (1) estimate the maximum external 

radiation dose for every type of cancer for which radiation doses are reconstructed that could have 

been incurred under plausible circumstances by any member of the class; or (2) estimate the external 

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

Adequate medical dose reconstruction is possible by using the assumptions described in Idaho 

National Laboratory and Argonne National Laboratory-West – Occupational Medical Dose

(ORAUT-TKBS-0007-3).

6.3 Class Parameters Associated with Infeasibility

On July 23, 2015, NIOSH recommended the following class definition for inclusion to the Special 

Exposure Cohort from the SEC-00219 evaluation of the Idaho National Laboratory. 

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

contractors and subcontractors who worked at the Idaho National Laboratory (INL) in 

Scoville, Idaho, and (a) who 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 February 28, 1970; or (b) who were monitored for external 

radiation at INL (e.g., at least one film badge or TLD dosimeter)between March 1, 1970 

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. 

On May 2, 2016, the Advisory Board on Radiation and Work Health recommended to the Department 

of Health and Human Services (DHHS) that SEC status be accorded to all employees of the 

Department of Energy, its predecessor agencies, and their contractors and subcontractors who worked 

at the Idaho National Laboratory and were monitored for external radiation at INL (at least one film 

badge or TLD dosimeter) during the period from March 1, 1970, through December 31, 1974. The 

HHS designation for inclusion in the SEC was finalized on June 3, 2016. The January 1, 1963 

through February 28, 1970 period is still under review. 

NIOSH has found insufficient documentation associating job titles and/or job assignments with 

specific radiological operations or conditions within CPP. Without this information, NIOSH is unable 

to define the proposed SEC class based on job descriptions. Using information presented in Section 

4.4, NIOSH is able to identify workers entering the CPP fenced area but not worker movement within 

CPP. NIOSH therefore recommends that the proposed class definition include all employees of the 

Department of Energy, its predecessor agencies, and their contractors and subcontractors who worked 

in any area at CPP, as identified by external dosimetry, during the specified time period. 
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7.0 Summary of Feasibility Findings for Petition SEC-00238

This report evaluates the feasibility for completing dose reconstructions for employees at the Idaho 

Chemical Processing Plant from January 1, 1975 through December 31, 1980. NIOSH determined 

that members of this class may have received internal radiation exposures from transuranic 

radionuclides. NIOSH lacks sufficient information, which includes biological monitoring data and air 

monitoring data, which would allow it to estimate the potential internal exposure(s) to which the 

proposed class may have been exposed. 

NIOSH has documented herein that it cannot complete the dose reconstructions related to this petition. 

The basis of this finding demonstrates that NIOSH does not have access to sufficient information to 

estimate either the maximum radiation dose incurred by any member of the class or to estimate such 

radiation doses more precisely than a maximum dose estimate.

External radiation exposures can be reconstructed for this class of CPP employees using ORAUTTKBS-0007-6. Likewise, occupational medicine doses and environmental doses can be reconstructed 

using ORAUT-TKBS-0007-3 and ORAUT-TKBS-0007-4, respectively. Internal doses, with the 

exception of transuranic radionuclides as described above, can be adequately reconstructed using 

ORAUT-TKBS-0007-5. 

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

CPP during the period from January 1, 1975 through December 31, 1980, but who do not qualify for 

inclusion in the SEC, may be performed using these data as appropriate. 

8.0 Evaluation of Health Endangerment for Petition SEC-00238

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by EEOICPA and 42 C.F.R. § 83.14(b) and § 83.13(c) (3). Pursuant to these requirements, 

if it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, 

NIOSH must determine that there is a reasonable likelihood that such radiation doses may have 

endangered the health of members of the class. The regulations require NIOSH to assume that any 

duration of unprotected exposure may have endangered the health of members of a class when it has 

been established that the class may have been exposed to radiation during a discrete incident likely to 

have involved high levels of exposure. If the occurrence of such an exceptionally high-level exposure 

has not been established, then NIOSH is required to specify that health was endangered for those 

employees who were employed for a number of work days aggregating at least 250 work days within 

the parameters established for the class or in combination with work days within the parameters 

established for one or more other classes of employees in the SEC. 

NIOSH has determined that the increased potential for intake due to poor contamination control, and 

inadequate personnel monitoring for exposures to transuranic radionuclides separated from mixed 

fission products, makes it unlikely that exposures to alpha-emitters can adequately be reconstructed 

from January 1975 through December 1980. This time period is a continuation of the 1963-1974 

period that NIOSH proposed to be added to the SEC in Rev. 2 of the SEC-00219 Idaho National 

Laboratory SEC Petition Evaluation Report (NIOSH, 2017). NIOSH believes that the establishment 
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in 1981 of a routine bioassay program for transuranic radionuclides at CPP provides the data 

necessary going forward for reconstructing dose with sufficient accuracy.

NIOSH did not identify any evidence supplied by the petitioners or from other resources that would 

establish that members of the proposed SEC class at the Idaho Chemical Processing Plant (CPP) 

between January 1, 1975 and December 31, 1980 were exposed to radiation during a discrete incident 

resulting in significant unmonitored exposures likely to have involved exceptionally high-level 

exposures. The H Cell criticality of October 17, 1978 resulted in a maximum whole-body dose of less 

than 130 mrem to the highest-exposed worker. However, evidence indicates that some workers in the 

proposed class may have accumulated substantial chronic exposures through episodic intakes of 

radionuclides, combined with external exposures to gamma, beta, and neutron radiation. Based on its 

assessment, presented in this evaluation report, NIOSH finds that there were issues that make it 

unlikely that exposures to alpha-emitters can be adequately reconstructed from January 1, 1975 

through December 31, 1980. Consequently, NIOSH has determined that health was endangered from 

January 1, 1975 through December 31, 1980 for CPP workers who were employed for at least 250 

aggregated work days either solely under their employment or in combination with work days within 

the parameters established for other SEC classes.

9.0 NIOSH-Proposed Class for Petition SEC-00238

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all employees of the Department of Energy, its 

predecessor agencies, and their contractors and subcontractors who worked at the Idaho National 

Laboratory (INL) in Scoville, Idaho, and who were monitored for external radiation at the Idaho 

Chemical Processing Plant (CPP) (e.g., at least one film badge or TLD from CPP) between January 1, 

1975 and December 31, 1980 for a number of work days aggregating at least 250 work days, 

occurring 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. 

10.0 Evaluation of Second Similar Class

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses is required. If a second class is identified, 

it would require additional research and analyses. Such a class would be addressed in a separate SEC 

evaluation rather than delay consideration of the current claim. At this time, NIOSH has not identified 

a second similar class of employees at the Chemical Processing Plant for whom dose reconstruction 

may not be feasible.
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11.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000; as amended; DCAS website

1979 CPP Criticality, 2000, A Review of Criticality Accidents: 2000 Revision; various authors; 

LA-13638; Los Alamos National Laboratory; May 2000; SRDB Ref ID: 895, PDF p. 59 

Alexander, 1981, Shift Lab Health Physics Report, DRA-90-81, internal correspondence from D. R. 

Alexander to W. S. Nechodom; Exxon Nuclear Idaho Company, Inc.; August 25, 1981; SRDB 

124259, PDF pp. 533-579 

Anderson, 1975, Request for Bioassay Program Support, FHA-33-75; F.H. Anderson; February 7, 

1975, SRDB Ref ID: 139017, PDF pp. 2-3 

Aoki, 1979, General Information for Evaluating Penetrating Exposure Summary at INEL for Years 

1950 Through 1979; May 31, 1959; SRDB Ref ID: 8529 

Bioassay, 1958-1986, INEL Bioassay CD 3 of 3; author unknown; 1958-1986; SRDB Ref ID: 123104 

Bioassay, 1978, ICPP Bioassay Program Outline; 1978; SRDB Ref ID: 143374 

Contamination Incidents, 1978, Handwritten List of CPP Contamination Incidents July-November; 

July 16 – November 12, 1978; SRDB Ref ID: 150607 

Contamination Surveys, 1975, Contamination Surveys of the CPP Building Area January 1975; 

January 1975; SRDB Ref ID: 141711 

CPP Area Exposures, 1976, CPP Area Exposure Report Summary 1976, Idaho National Laboratory; 

SRDB Ref ID: 166636 

CPP Area Exposures, 1977, CPP Area Exposure Report Summary 1977, Idaho National Laboratory; 

SRDB Ref ID: 166640 

CPP Area Exposures, 1978, CPP Area Exposure Report Summary 1978, Idaho National Laboratory; 

SRDB Ref ID: 166670 
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CPP Area Exposures, 1979, CPP Area Exposure Report Summary 1979, Idaho National Laboratory; 

SRDB Ref ID: 166671 

CPP Area Exposures, 1980, CPP Area Exposure Report Summary 1980, Idaho National Laboratory; 

SRDB Ref ID: 166672 

CPP Contamination Surveys 1976, CPP Routine Contamination Surveys September and October 

1976, Idaho National Laboratory; SRDB Ref ID: 166697 

CPP Contamination Surveys 1977, CPP Contamination Surveys August - October 1977, Idaho 

National Laboratory; SRDB Ref ID: 166691 

CPP Contamination Surveys 1981, CPP Contamination Surveys 1981, Idaho National Laboratory; 

SRDB Ref ID: 166700 

CPP Program Upgrade, 1980, Internal Dose Monitoring Program Upgrade / DRA-105-80, WAE-149-

81; Exxon Nuclear Idaho Company, Inc. internal memo to Distribution from D. R. Anderson; 

November 6, 1980; SRDB Ref ID: 139071, PDF pp. 2-3 

CPP Rad Controls, 1977, Radiological Controls at ICPP, memo to R. G. Bradley (Energy Research 

and Development Administration [ERDA]) from C. E. Williams (ERDA Idaho Operations Office); 

June 20, 1977; SRDB Ref ID: 118786, PDF pp. 2-3 

CPP Safety Review, 1974, Idaho Chemical Processing Plant Safety Review Document, Volume I, 

ICPP-SRD-1; G. K. Cederberg; Allied Chemical Corporation; March 1974; SRDB Ref ID: 14660 

CPP Safety Review, 1977, Idaho Chemical Processing Plant Safety Review Document, Section 4.10, 

Laboratory Facilities, Volume II, ACI-216-4.10; M. K. Valentine; Allied Chemical Corporation; April 

1977; SRDB Ref ID: 142059 

CPP West Gate, 1975, CPP West Gate Contaminated Items and Personnel Survey Results; February – 

June 1975; SRDB Ref ID: 141709 

CXM Area Exposures, 1975, CXM Area Exposure Report Summary 1975, Idaho National Laboratory; 

SRDB Ref ID: 146530 

CXM Area Exposures, 1976, CXM Area Exposure Report Summary 1976, Idaho National Laboratory; 

SRDB Ref ID: 166673 

CXM Area Exposures, 1977, CXM Area Exposure Report Summary 1977, Idaho National Laboratory; 

SRDB Ref ID: 166674 

CXM Area Exposures, 1978, CXM Area Exposure Report Summary 1978, Idaho National Laboratory; 

SRDB Ref ID: 166676 

CXM Area Exposures, 1979, CXM Area Exposure Report Summary 1979, Idaho National Laboratory; 

SRDB Ref ID: 166680 

CXM Area Exposures, 1980, CXM Area Exposure Report Summary 1980, Idaho National Laboratory; 

SRDB Ref ID: 166682 
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Decontamination, 1978, Decontamination of the Waste Calcining Facility – A Historical Review; 

ICP-1173; J.E. Johnson and D.J. Bradford; December 1978; SRDB Ref ID: 14662, PDF p. 34 

Dickey, 1977, Neptunium Concentrate Disposal; B.R. Dickey; March 23, 1972; SRDB Ref ID: 

136650, PDF p. 2 

DOE, 1978, Investigation of the October 17, 1978, Criticality Incident at the Idaho Chemical 

Processing Plant; DOE Investigating Committee; November 1978; SRDB Ref ID: 88394, PDF p. 43 

DOE Idaho Summaries, 1975, DOE Idaho Operations Office Area Exposure Report Summaries July

21 through August 30, 1975, U.S. Department of Energy, Idaho Operations Office; SRDB Ref ID: 

166664 

DOE Idaho Summaries, 1978, DOE Idaho Operations Office Area Exposure Report Summaries 

February - September and December 1978, U.S. Department of Energy, Idaho Operations Office; 

SRDB Ref ID: 166721 

DOE Idaho Summaries, 1979, DOE Idaho Operations Office Area Exposure Report Summaries 

February, March, May - December 1979, U.S. Department of Energy, Idaho Operations Office; 

SRDB Ref ID: 166715 

DOE Idaho Summaries, 1980, DOE Idaho Operations Office Area Exposure Report Summaries 1980, 

U.S. Department of Energy, Idaho Operations Office; SRDB Ref ID: 166713 

Dosimetry, 1972-1981, Dosimetry Program at the INL 1972-1981, various authors, 1972-1981, SRDB 

Ref ID: 125958 

Dosimetry Branch Changes, 1978, Dosimetry Branch Changes, chronology of changes from March 

1958 to March 1978; author unknown, Idaho National Laboratory; undated, but latest entry is March 

1978; SRDB Ref ID: 8436 

Dosimetry Program, 1974, Dosimetry Program at INEL, D. I. Walker, Health Services Laboratory; 

November 11, 1974; SRDB Ref ID: 125958, PDF p. 41

Dykes, 1981, Chronology of ICPP Modifications 1955 – Present; F.W. Dykes; July 21, 1981; SRDB 

Ref ID: 151575 

ERDA Idaho Summaries 1976, U.S. ERDA Idaho Operations Office Area Exposure Summaries 

September - December 1976, U.S. Energy Research and Development Administration; SRDB Ref ID: 

166742 

ERDA Idaho Summaries 1977, U.S. ERDA Idaho Operations Office Area Exposure Summaries 1977, 

U.S. Energy Research and Development Administration; SRDB Ref ID: 166728 

Exposure Reports, 1975, Area Exposure Reports INL CPP – 2, Idaho National Laboratory; January 

1975 through December 1975; SRDB Ref ID: 156512, PDF pp. 3035-3504

Exposures, 1973, Investigation of WCF High Exposures at Idaho Chemical Processing Plant; various 

authors; 1973-1974; SRDB Ref ID: 139030, PDF p. 182 
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Fuel Reprocessing Complex, 2006, Idaho National Laboratory Fuel Reprocessing Complex Historic 

American Engineering Record Report- ID-3-H; INL/EXT-06-11969; Brenda Pace, Julie Braun, and 

Hollie Gilbert; December 2006; SRDB Ref ID: 88464, PDF pp. 3-4 

ICPP HP Upgrade, 1971-1980, Preliminary ICPP Health Physics Upgrade Program; various authors, 

1971-1980; SRDB Ref ID: 124516 

Idaho Chemical Programs, 1976, Idaho Chemical Programs Annual Technical Report Fiscal Year 

1975; ICP-1086; various authors; June 1976; SRDB Ref ID: 83377 

INEEL, 1997, Historic American Engineering Record – Photographs, Written Historical and 

Descriptive Data for Various Years; Idaho National Engineering and Environmental Laboratory 

(INEEL); received September 15, 1998; SRDB Ref ID: 139434 

McCaslin, 1966, J. W. McCaslin Correspondence 1966; J. W. McCaslin; SRDB Ref ID: 126064 

NIOSH, 2005, An Epidemiologic Study of Mortality and Radiation-Related Risk of Cancer among 

Workers at the Idaho National Engineering and Environmental Laboratory, a U.S. Department of 

Energy Facility; various authors, January 2005; SRDB Ref ID: 33197, PDF p. 247

NIOSH, 2017, SEC Petition Evaluation Report for Petition SEC-00219-2, Idaho National Laboratory; 

Rev. 2, National Institute for Occupational Safety and Health (NIOSH); February 22, 2017; SRDB 

Ref ID: 166679 

Norman, 1979, Shift Lab Contamination, Norm-14-79; internal correspondence from G. R. Norman to 

M. A. Wade; Exxon Nuclear Idaho Company, Inc.; August 21, 1979; SRDB Ref ID: 151585 

Occupational Exposure History, 1993, Occupational Radiation Exposure History of Idaho Field 

Office Operations at the INEL, J. R. Horan and J. B. Braun; EGG-CS-11143; Idaho National 

Engineering Laboratory; October 1993: SRDB Ref ID: 1023 

ORAUT-TKBS-0007-1, Idaho National Laboratory and Argonne National Laboratory-West – 

Introduction, Rev. 03; ORAU Team Dose Reconstruction Project for NIOSH; Effective Date: March 

12, 2010; SRDB Ref ID: 79862 

ORAUT-TKBS-0007-2, Idaho National Laboratory and Argonne National Laboratory-West – Site 

Description, Rev. 04; ORAU Team Dose Reconstruction Project for NIOSH; Effective Date: August 

2, 2010; SRDB Ref ID: 84106 

ORAUT-TKBS-0007-3, Idaho National Laboratory and Argonne National Laboratory-West – 

Occupational Medical Dose, Rev. 02; ORAU Team Dose Reconstruction Project for NIOSH; 

Effective Date: December 21, 2009; SRDB Ref ID: 77829 

ORAUT-TKBS-0007-4, Idaho National Laboratory and Argonne National Laboratory-West – 

Occupational Environmental Dose, Rev. 02; ORAU Team Dose Reconstruction Project for NIOSH; 

Effective Date: January 8, 2010; SRDB Ref ID: 78635 

ORAUT-TKBS-0007-5, Idaho National Laboratory and Argonne National Laboratory-West – 

Occupational Internal Dose, Rev. 03; ORAU Team Dose Reconstruction Project for NIOSH; 

Effective Date: March 2, 2010; SRDB Ref ID: 79571 
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ORAUT-TKBS-0007-6, Idaho National Laboratory and Argonne National Laboratory-West – 

Occupational External Dose, Rev. 03; ORAU Team Dose Reconstruction Project for NIOSH; 

Effective Date: April 19, 2011; SRDB Ref ID: 94104 

Personal Communication, 2014a, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, ABRWH, and 

SC&A; June 24, 2014; SRDB Ref ID: 142401

Personal Communication, 2014b, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS and SC&A; June 24, 2014; 

SRDB Ref ID: 142397

Personal Communication, 2014c, Personal Communication with former Department of Energy-Idaho 

Office [job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ABRWH, and 

SC&A; June 24, 2014; SRDB Ref ID: 142359

Personal Communication, 2014d, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, ABRWH, and 

SC&A; June 25, 2014; SRDB Ref ID: 142404

Personal Communication, 2014e, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by ORAU Team, ABRWH, and SC&A; 

June 25, 2014; SRDB Ref ID: 142364

Personal Communication, 2014f, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, ABRWH, and 

SC&A; June 25, 2014; SRDB Ref ID: 142387 

Personal Communication, 2014g, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU Team, ABRWH and 

SC&A; June 26 2014; SRDB Ref ID: 142362

Personal Communication, 2014h, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, ABRWH, and 

SC&A; September 10, 2014; SRDB Ref ID: 142398

Personal Communication, 2014i, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH and SC&A; November, 

2014; SRDB Ref ID: 141472

Personal Communication, 2014j, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, ABRWH, and 

SC&A; November 17, 2014; SRDB Ref ID: 159717

Personal Communication, 2014k, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU Team, ABRWH, and 

SC&A; November 18, 2014; SRDB Ref ID: 141477
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Personal Communication, 2014l, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU Team, ABRWH, and 

SC&A; November 18, 2014; SRDB Ref ID: 141478

Personal Communication, 2014m, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU Team, ABRWH and 

SC&A; November 18, 2014; SRDB Ref ID: 142363

Personal Communication, 2014n, Personal Communication with current Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH and SC&A; November 18, 

2014; SRDB Ref ID: 141480

Personal Communication, 2014o, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH, ORAU Team and SC&A; 

November 19, 2014; SRDB Ref ID: 142360

Personal Communication, 2014p, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, and SC&A; 

November 19, 2014; SRDB Ref ID: 142405

Personal Communication, 2014q, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ORAU Team, ABRWH, and 

SC&A; November 19, 2014; SRDB Ref ID: 159715

Personal Communication, 2014r, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by NIOSH and ORAU Team; December 

11, 2014; SRDB Ref ID: 141471 

Personal Communication, 2016a, Personal Communication with former Idaho National Laboratory 

[job title redacted] and a DOE Idaho Operations [job title redacted]; In-person interview at Idaho 

Falls, Idaho by ORAUT and DCAS; January 27, 2016; SRDB Ref ID: 167245

Personal Communication, 2016b, Personal Communication with former Idaho National Laboratory 

[job title redacted]; In-person interview at Idaho Falls, Idaho by DCAS, ABRWH, and SC&A; 

January 27, 2016; SRDB Ref ID: 159731

Personal Communication, 2016c, Personal Communication with former Idaho National Laboratory 

[job title redacted]; Phone interview by ABRWH, and SC&A; February 16, 2016; SRDB Ref ID: 

159716

Personal Communication, 2016d, Personal Communication with former Idaho National Laboratory 

[job title redacted]; Phone interview by DCAS, ABRWH, and SC&A; April 5, 2016; SRDB Ref ID: 

159718 

Peterson, 2004, Supplement to Technical Basis Document 4 for the Idaho National Engineering and 

Environmental Laboratory: INEEL Occupational Environmental Dose, H. K. Peterson; March 9, 

2004; SRDB Ref ID: 15451
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Process Cells, 1984, Final Report Decontamination and Decommissioning of CPP-601 Process Cells 

“A,” “B,” “C,” “D,” and “L”, EGG-2304; Donald L. Smith and Jack G. Scott; September 1984; 

SRDB Ref ID: 139079, PDF p. 7 

Rich, 1974, Preliminary ICPP Health Physics Upgrade Program; ACI-167; B. L. Rich; October 

1974; SRDB Ref ID: 124516 

Rich, 1974a, CPP-603 Contamination Control Status, BLR-6-74; B. L. Rich; March 1, 1974; SRDB 

Ref ID: 118914 

Rich, 1979, 1978 Health Physics Annual and Upgrade Status Report, BLR-10-79; B. L. Rich; May 3, 

1979; SRDB Ref ID: 124517 

Shift Lab Intakes, 1981, Incident Investigation File ICPP Contamination 1981, various authors, 1981, 

SRDB Ref ID: 124519 

SOP, 1982, ICPP Standard Operating Procedures from 1982, SOP 1.6.32; various authors; 1982; 

SRDB Ref ID: 145316, PDF p. 11 

Stacy, 2000, Proving the Principle, DOE/ID-10799; Susan M. Stacy, Idaho Operations Office of the 

Department of Energy; 2000; SRDB Ref ID: 1152, PDF pp. 285-286 

Storms, 1976, Radiation Incident CPP-603, I-5980; J.N. Storms; November 28, 1976; SRDB Ref ID: 

160847, PDF p. 2 

Szulinski, 1980, A Review of the Plutonium Problem in ICPP Facilities and Projects, M.J. Szulinski, 

SAI-020-80-RI, Science Applications, Inc.; April 1980; SRDB Ref ID: 8431, PDF pp. 11-12 

Wagner, 1999, History for the CPP-601/-640/-627 Fuel Reprocessing Complex at the Idaho National 

Engineering and Environmental Laboratory; INELL/EXT-99-00400; E.P. Wagner, June 1999; SRDB 

Ref ID: 52645, PDF p. 9 

Williamson, 1976, HSL Bioassay and Whole Body Counting Services; M. Marcy Williamson; 

December 21, 1976; SRDB Ref ID: 139014, PDF pp. 2-3
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Attachment One: Data Capture Synopsis

NOTE: This custom data capture synopsis was developed by searching the SRDB for all Idaho National Laboratory documents for the activity date range of 01/01/1975 – 

12/31/1982, which resulted in 3,320 documents. Additional searches were performed of the 3,320 documents to identify when the term "Idaho Chemical Processing Plant" (or 

any of its alternate names) appears in the document title, subdocument title, text of the document, or health physics review notes. This effort resulted in a total of 1,737 identified 

documents that meet the criteria for this synopsis. Documents within the 3,320 that did not provide a positive result to the term searches (ICPP or alternate names) were manually 

reviewed to ensure that all responsive documents were identified. This is Rev. 1 of this synopsis. Since the submittal of Rev. 0, NIOSH and the ORAU Team conducted a site 

visit to Idaho National Laboratory and documents have been added through site association reviews, leading to the current total of 1,898 documents.

Table A1-1: Summary of Holdings in the SRDB for Idaho National Laboratory

Data Capture Synopsis General Description of Documents Captured Date Completed Uploaded to 

SRDB

Facility Name: INL, Idaho Chemical Processing Plant

 

Period of Interest for the 83.14 Evaluation: 1975 - 1982 

Alternate Facility Names: 

ICPP 

Chemical Processing Plant 

CPP 

Chem Plant 

Fuel Reprocessing Complex 

Chemical Processing Area 

Idaho Nuclear Technology and Engineering Center 

INTEC 

Westinghouse Idaho Nuclear Company 

WINCO 

Physical Size of the Facility: Approximately 200 acres

 

Facility Population: 1,800 

Internal dosimetry programmatic documents, environmental reports, 

neutron dosimetry, site telephone directories, individual medical 

records, environmental surveillances, monitoring and modeling effluent 

releases, occupational and environmental air sampling data, periodic 

health physics reports, periodic facilities reports, tritium reports, safety 

analyses for facilities and campaigns, surveys of specific areas with 

high radionuclide concentrations, ecological reports, contamination 

control plans, logbooks, bioassay results, whole body counting results, 

incident reports, employee health case files, temporary badge reports, 

standard operating procedures, policy and procedure manuals, 

correspondence files, routine surveys, health physics log sheets, safe 

work permits, annual exposure records, health and safety record sheets, 

periodic operations and technical reports, waste handling reports, 

internal dose assessments, shipping reports, air filter spectra, analytical 

methods, radiological incidents, criticality safety, employee locator 

cards, area exposure reports, documented site expert interview 

communications, and facility photographs. 

04/06/2017 873

Battelle Memorial Institute - King Avenue Battelle Research Reactor spent fuel sent to the ICPP. 04/12/2011 1

Dade Moeller External and internal dosimetry records index, internal dose 

assessments, whole body counting description, and problems with the 

ICPP stack monitoring system. 

03/10/2016 6

Dade Moeller / SC&A Investigation report from the 1975 ICPP Tank Farm contaminated soil 

incident. 

03/19/2007 1
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Data Capture Synopsis General Description of Documents Captured Date Completed Uploaded to 

SRDB

DOE Environmental Management Consolidated Business 

Center (EMCBC) - Cincinnati

An incident file including an ICPP radiation alarm incident. 03/30/2017 1

DOE Germantown NIOSH researcher's notes. 03/18/2014 1

DOE Idaho Operations Office A dosimetry records storage receipt. 12/20/2013 1

DOE Legacy Management - Morgantown Office Employee dosimetry files and recycled uranium reports. 09/19/2011 6

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

DOE annual Effluent Information System reports. 02/07/2007 2

DOE Oak Ridge Operations Office U-233 disposition strategies and options. 07/09/2012 1

DOE Office of Scientific and Technical Information 

(OSTI)

Environmental restoration and waste management site maps and source 

term data on contaminated sites.

09/05/2008 2

East Tennessee Technology Park (ETTP) Records Center A report confirming the routing of some recycled uranium through the 

ICPP.

05/05/2014 1

Federal Records Center (FRC) - Atlanta A 1986 Effluent Information System (EIS) / Onsite Discharge 

Information System (ODIS) executive summary.

03/16/2004 1

Federal Records Center (FRC) - Denver A 1995 DOE occupational exposure report with retrospective data. 04/20/2010 1

Federal Records Center (FRC) - Kansas City Argonne National Laboratory fuel cycle and waste management field 

work proposals and agreements.

08/15/2008 1

Federal Records Center (FRC) - Lee's Summit Spent fuel storage issues, shipment of West Valley samples to INL for 

isotopic analysis, a DOE plan to resolve spent fuel vulnerabilities, a 

discussion of an ICPP decontamination, and a review of hazardous 

waste issues.

06/07/2016 5

Hanford Site profiles for 20 major DOE sites. 01/02/2013 1

Idaho National Laboratory Electronic Document 

Management System (EDMS)

Neptunium purification and concentrate disposal, incident 

investigations, waste management reports, safety reviews, records 

submittals, and ICPP decontamination and decommissioning plans.

10/21/2015 32

Idaho National Laboratory / Idaho Nuclear Technology and 

Engineering Center (INTEC)

Documented site expert interviews. 11/20/2014 19

Idaho National Laboratory / SC&A The final environmental impact statement for waste management 

operations, reports, stack monitoring description and data, and a 

documented site expert interview.

06/25/2014 3

Interlibrary Loan A survey of mixed waste HEPA filters in the DOE Complex. 05/03/2012 1

Internet - Defense Technical Information Center (DTIC) Occupational dose reduction, waste classification for disposal, 

characterization of degraded EBR-II fuel, and corrosion studies.

02/16/2017 5

Internet - DOE The standard of good radiological protection practices in plutonium 

facilities, data for release fractions from nonreactor facilities, and the 

response to the first five year review of the Test Reactor Area operable 

unit.

07/07/2016 3

Internet - DOE Environmental Management Linking Legacies Chapter 3: Wastes. 10/28/2007 1
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Data Capture Synopsis General Description of Documents Captured Date Completed Uploaded to 

SRDB

Internet - DOE Legacy Management INL decontamination and decommissioning technology logic diagrams, 

an irradiated fuel materials shipping report, and a mixed waste report.

09/19/2014 4

Internet - DOE OpenNet Linking Legacies Appendix B, the final Advisory Committee on 

Human Radiation Experiments report, a documented site expert 

interview, and the summary of the Controlled Environmental 

Radioiodine Tests (CERT).

10/02/2014 4

Internet - DOE OSTI The Tiger Team Assessment of INL. 11/30/2009 3

Internet - DOE OSTI Energy Citations Facility histories which refer to the ICPP, a DOE radiation exposure 

report, radionuclide-specific treatment plans, a thorium utilization 

report, a decommissioning plan, historical photographs, proceedings of 

a nuclear air cleaning conference, and a contaminated concrete report.

01/01/2013 12

Internet - DOE OSTI Information Bridge Integrated spent fuel and radioactive waste inventories, Stannard's

Radioactivity and Health, spent fuel storage and disposal, liquid waste 

disposal, occupational dose reduction, environmental reports, waste 

treatment studies, inventory and sources of transuranic waste, thorium 

utilization reports, material control test and evaluation system, hazards 

evaluations, and safety analyses.

12/30/2012 73

Internet - DOE OSTI SciTech Connect The INEL historical dose evaluation-reconstruction of airborne releases, 

chemical processing technology periodic reports, technical progress 

reports, analytical branch reports, safety analyses, analyses of irradiated 

materials, ICPP waste handling and management reports, fuels and 

materials reports, metals and ceramics reports, environmental reports, 

air emissions reports, a stewardship report, mixed waste processing 

reports, reactor development progress reports, and decontamination and 

decommissioning plans and reports.

07/15/2016 154

Internet - Google Environmental reports, waste reports, DOE occupational exposure 

reports, INL history and photographs, waste shipments, environmental 

impact statements, radionuclide releases, environmental behavior of 

radionuclides, air sampling, remediation conceptual designs, EPA 

records of decision, facility descriptions, risk assessments, INL 

oversight reports, ICPP operational reports, estimating releases of 

various radionuclides, conference proceedings, planning for the long 

term storage of high-level ICPP waste, and waste characterization 

reports.

03/17/2017 170

Internet - Health Physics Journal Intakes of I-129 and plutonium by indigenous animal species. 07/02/2014 2

Internet - Idaho National Laboratory INL brochures, shipment of a Cs-134 aerosol generator to the ICPP for 

decontamination, an ARA hazardous waste determination, a report on a 

contaminated French drain, and an inventory of buried waste at the 

Radiological Waste Management Complex.

08/01/2016 10
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Data Capture Synopsis General Description of Documents Captured Date Completed Uploaded to 

SRDB

Internet - National Academies Press (NAP) Waste treatment and disposition, radionuclide releases, and a review of 

DOE's cleanup roadmap.

06/24/2015 5

Internet - National Institute for Occupational Safety and 

Health (NIOSH)

Two revisions of the INL SEC petition evaluation report, an 

epidemiologic study of mortality and cancer risk at INL, and an SC&A 

review of the INL site profile.

05/08/2017 4

Internet - National Service Center for Environmental 

Publications (NEPIS), US EPA

Superfund records of decision, a mixed energy waste study, and 

proceedings of a residual radioactivity and recycling criteria workshop.

09/30/2014 8

Internet - NRC Agencywide Document Access and 

Management (ADAMS) 

Integrated spent fuel inventories, waste reports, spent nuclear fuel 

management, a remedial investigation/feasibility study, studies on 

environmental transport, environmental reports, NRC reviews of INL 

remediation plans, facility safety assessments, waste disposal studies, 

the risk analysis of the subsurface disposal area, map of the CPP tank 

farm, and an environmental impact statement.

03/29/2016 43

Internet - Oak Ridge National Laboratory (ORNL) Library An ORNL division progress report showing waste treated at the ICPP 

and a reference to the 1978 ICPP criticality.

05/29/2015 2

Kansas City Plant DOE daily operations briefs. 10/20/2014 1

Los Alamos National Laboratory - LAHDRA A comparison of effluent quantities from DOE facilities on spent fuel 

and radioactive waste inventories.

12/13/2007 3

Mel Chew and Associates Treating plutonium processing wastes at ICPP. 12/15/2014 1

Missouri Department of Natural Resources Plutonium working group reports. 10/01/2008 2

National Archives and Records Administration (NARA) -

Atlanta

Health physics guidelines for Kr-85 operations. 06/08/2004 1

National Archives and Records Administration (NARA) -

Seattle

ICPP plot plans and fallout test station locations and radioactive 

material shipment records.

12/18/2014 2

National Institute for Occupational Safety and Health 

(NIOSH)

Internal dose assessment and bioassay manuals and reports, the 

histories of INL dosimetry programs, worker outreach meeting 

documents, a recycled uranium report, an ICPP plutonium inhalation 

exposure report, a classification release letter, and individual worker 

dosimetry files.

03/10/2016 27

NIOSH / SC&A A recycled uranium report. 08/14/2003 1

Nuclear Regulatory Commission Public Document Room Management of transuranic and high-level radioactive waste, a light 

water reactor source term study, a proposal for a liquid metal fast 

breeder reactor at INL, an INEEL emergency plan and Research 

Conservation Recovery Act contingency plan, a FOIA request, and a 

reference to ICPP high-level radioactive waste forms.

12/16/2014 7

Nuclear Testing Archive Off-gas monitoring technology and an effluent iodine filter efficiency 

monitor.

05/22/2015 2

Oak Ridge Library for Dose Reconstruction Discussion of Oak Ridge National Laboratory's design of the ICPP and 

the shipment of enriched recycled uranium to Y-12.

05/10/2011 2
SEC-00238 07-20-17 Idaho National Laboratory

55 of 55

Data Capture Synopsis General Description of Documents Captured Date Completed Uploaded to 

SRDB

Oak Ridge National Laboratory (ORNL) ORNL's design work for the Materials Test Reactor. 02/21/2008 1

ORAU Team Technical basis documents, an effluent monitoring report, recycled 

uranium reports, bioassay summaries, and documented site expert 

interview communications.

05/01/2017 56

Rocky Flats Plant An assessment of the flammability and explosion potential of defense 

transuranic waste.

05/17/2006 1

Sandia National Laboratory - Albuquerque, New Mexico Radiation exposure requests and potential relocation of Pantex 

operations.

02/17/2012 2

Savannah River Site (SRS) SRS periodic reports referencing the ICPP and a reference to the ICPP 

Decontamination Manual.

01/12/2012 4

S. Cohen & Associates (SC&A) The Radioactive Waste Management Complex history, ICPP recycled 

uranium shipped to Y-12, a list of major incident reports, an archives 

search results list, shipping reports, and the West Valley Tiger Team 

report.

04/07/2011 7

SC&A / INL Environmental monitoring reports, ICPP stack sampling reports, 

effluent monitoring reports, radiation safety monthly reports, 

investigation of the 1978 criticality, source term quality control tasks, 

incident reports, the site aerial radiological survey, effluent releases, 

waste management, decontamination and decommissioning plans, 

evaluations of plutonium and tritium analysis techniques, and 

radioactive pollution control appraisals.

10/17/2010 260

SC&A / Internet - DOE OpenNet The first 50 years of plutonium history. 10/28/2014 1

Unknown Historical dose evaluations, source term quality control tasks, the 1978 

ICPP criticality event, environmental monitoring data, bioassay sample 

analysis technical basis document, a review of the ICPP plutonium 

problem, decontamination and decommissioning information, 

dosimetry branch changes, and historical reports.

06/28/2010 40

Unknown / INL Environmental monitoring data (1979). 05/10/2012 1

Unknown / SC&A Environmental monitoring data. 06/24/2010 11

West Valley Demonstration Project A 1981 investigation of a radiation exposure at the MTR Plug Storage 

Area. 

08/02/2006 1

Y-12 / SC&A A report on plutonium contamination on recycled material from INL. 07/28/2010 1

TOTAL N/A N/A 1,898