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SEC-00224, Petition Evaluation Report, Argonne National SEC Petition Evaluation Report Petition SEC-00224 Report Rev Number: Rev. 0 Report Submittal Date: February 18, 2016 Subject Expert(s): Mitch Findley, Brian Gleckler, Jason Davis, Mike Mahathy Site Expert(s): N/A Petition Administrative Summary Petition Under Evaluation Petition Number: SEC-00224 Petition Type: 83.13 Petition Receipt Date: December 4, 2014 Qualification Date: March 13, 2015 DOE/AWE Facility Name: Argonne National Laboratory-West, Scoville, ID Petition Class Petitioner-Requested Class Definition: All workers who worked in any work location at the Argonne National Laboratory-West from January 1, 1949 through December 31, 1995, with the basis of inadequate monitoring for plutonium, neptunium and fission products during that time period. Class Evaluated by NIOSH: All workers who worked in any location of the Argonne National Laboratory- West from April 10, 1951 through December 31, 1979. NIOSH-Proposed Class(es) to be Added All employees of the Department of Energy, its predecessor agencies, and to the SEC: their contractors and subcontractors who worked at the Argonne National Laboratory-West between April 10, 1951 and December 31, 1957 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. Related Petition Summary Information SEC Petition Tracking Number(s): N/A Petition Type: N/A DOE/AWE Facility Name: N/A Petition Status: N/A Related Evaluation Report Information Report Title: N/A DOE/AWE Facility Name: N/A ORAU Preparation and Review ORAU Lead Technical Evaluator: Mitch Findley ORAU Peer Review Completed By: Dan Stempfley Page 1 of 260 SEC-00224 02-18-16 ANL-W DCAS Review and Approval Peer Review Completed By: [Signature on File] Timothy Taulbee February 18, 2016 SEC Petition Evaluation Reviewed By: [Signature on File] LaVon Rutherford February 18, 2016 SEC Petition Evaluation Reviewed By: [Signature on File] Stuart L. Hinnefeld February 18, 2016 2 of 260 SEC-00224 02-18-16 ANL-W Evaluation Report Summary: SEC-00224, ANL-W This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. § 7384 et seq. (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. Petitioner-Requested Class Definition Petition SEC-00224 was received on December 4, 2014, and qualified on March 13, 2015. The petitioner requested that NIOSH consider the following class: All workers who worked in any work location at the Argonne National Laboratory-West from January 1, 1949 through December 31, 1995, with the basis of inadequate monitoring for plutonium, neptunium and fission products during that time period. Class Evaluated by NIOSH Based on its preliminary research, NIOSH modified the petitioner-requested class. NIOSH evaluated the following class: All workers who worked in any location of the Argonne National Laboratory- West from April 10, 1951 through December 31, 1979. The petitioner-proposed class was modified (see Section 3.0 below). The start date was modified because the first reactor facility was completed, and its associated reactor assembly commenced, on April 10, 1951. The end date was modified because abundant plutonium bioassay data has been identified beginning in 1980. NIOSH-Proposed Class(es) to be Added to the SEC Based on its full research of the class under evaluation, NIOSH has defined a single class of employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSH- proposed class includes all employees of the Department of Energy, its predecessor agencies, and their contractors and subcontractors who worked at the Argonne National Laboratory-West between April 10, 1951 and December 31, 1957 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. The class under evaluation was modified (see Section 3.0 below) because there are sufficient routine internal and external exposure data beginning on January 1, 1958 to complete dose reconstructions with sufficient accuracy. Feasibility of Dose Reconstruction NIOSH finds it is not feasible to estimate internal and external exposures with sufficient accuracy for all workers at the ANL-W site from April 10, 1951 through December 31, 1957 due to insufficient data available during this time period. With the exception of this class, per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient information to: (1) estimate the maximum radiation dose, for every type of cancer for which radiation doses are reconstructed, that could have been incurred in plausible circumstances by any member of the class; or (2) estimate 3 of 260 SEC-00224 02-18-16 ANL-W radiation doses more precisely than an estimate of maximum dose. Information available from the site profile and additional resources is sufficient to document or estimate the maximum internal and external potential exposure to members of the evaluated class under plausible circumstances beginning January 1, 1958. The NIOSH dose reconstruction feasibility findings are based on the following: • The Argonne National Laboratory-West site, originally known as the Idaho Division of the Argonne National Laboratory or the Idaho Site, was established in 1949 and was operated as a separate site until 2005 when ANL-W was merged with the Idaho National Engineering and Environmental Laboratory (INEEL) to form the Idaho National Laboratory (INL). NIOSH determined that the most effective way of analyzing the ANL-W facilities was by focusing on the two ANL-W operating areas on the INL Site: the EBR-I Complex and the EBR-II Complex. The EBR-I Complex was originally commissioned to test a fuel-breeding reactor; later operations involved building and testing experimental reactors. The EBR-II Complex included test reactor facilities and support facilities for reactor fuel experiments and testing. • Principal sources of internal radiation for members of the evaluated ANL-W class working in the EBR-I and EBR-II Complexes included exposures to various isotopes of uranium, plutonium, thorium, and other actinides as well as exotic radionuclides (produced from, or as a result of, reactor neutron irradiation) that include mixed fission and activation products (MFP/MAP), radioiodines, and other radionuclides. • The internal dose potential during the period under evaluation was associated with reactors, laboratories, and other research and support activities as well as decontamination and decommissioning activities and radioactive waste disposal. There was limited personnel internal exposure potential to alpha-emitting radionuclides during the evaluated period. However, for the period from April 10, 1951 through December 31, 1957, NIOSH has not located sufficient personnel or area monitoring documentation to support complete reconstruction of internal personnel exposures. NIOSH has identified personnel monitoring data for mixed fission product exposures that are sufficient to support reconstructing internal doses for ANL-W workers beginning in 1958. • Principal sources of external radiation for members of the evaluated ANL-W class working in the EBR-I and EBR-II Complexes included beta-gamma and neutron exposures to various isotopes of uranium, plutonium, thorium, and other actinides as well as exotic radionuclides (produced from, or as a result of, reactor neutron irradiation) that include mixed fission and activation products (MFP/MAP), radioiodines, noble gases, and other radionuclides. By policy, ANL-W required external dosimetry (film or TLD) be worn within the operating (fenced) area. This dosimetry was issued at the security guard checkpoint. 4 of 260 SEC-00224 02-18-16 ANL-W • NIOSH has determined that the external dose potential during the period under evaluation was associated with reactors, laboratories, and other research and support activities as well as decontamination and decommissioning activities and radioactive waste disposal. For the period from April 10, 1951 through December 31, 1957, NIOSH has not located sufficient personnel or area monitoring documentation to support complete reconstruction of external personnel exposures. NIOSH has identified personnel monitoring data for external exposures that are sufficient to support reconstructing external doses for ANL-W workers beginning in 1958. • NIOSH finds that it is likely feasible to reconstruct occupational medical dose for ANL-W workers with sufficient accuracy. • Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient information for ANL-W personnel for the period from April 10, 1951 through December 31, 1957 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
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