SEC Petition Evaluation Report Petition SEC-00219 Report Rev Number: 1 Report Submittal Date: July 21, 2015 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-00219 Petition Type: 83.13 Petition Receipt Date: July 8, 2014 Qualification Date: September 16, 2014 DOE/AWE Facility Name: Idaho National Laboratory Petition Class Petitioner-Requested Class All employees who worked in any area of the Idaho National Laboratory Definition: from January 1, 1949 through December 31, 1970. Class Evaluated by NIOSH: All employees who worked in any area of the Idaho National Laboratory from January 1, 1949 through December 31, 1970. NIOSH-Proposed Class(es) to be All employees of the Department of Energy, its predecessor agencies, Added to the SEC: 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. 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 1 of 263 Related Evaluation Report Information Report Title: SEC Petition Evaluation Report for Petition SEC-00219, Rev. 0 DOE/AWE Facility Name: Idaho National Laboratory ORAU Preparation and Review ORAU Lead Technical Evaluator: Mitch Findley ORAU Peer Review Completed By: Dan Stempfley DCAS Review and Approval Peer Review Completed By: ___[Signature on File] ___ Timothy Taulbee July 21, 2015 SEC Petition Evaluation Reviewed By: [Signature on File]_____ James W. Neton July 21, 2015 SEC Petition Evaluation Reviewed By: [Signature on File]_____ Stuart L. Hinnefeld July 21, 2015 2 of 263 SEC-00219 07-21-15 Idaho National Laboratory Evaluation Report Summary: SEC-00219, Idaho National Laboratory 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-00219 was received on July 8, 2014, and qualified on September 16, 2014. The petitioner requested that NIOSH consider the following class: All employees who worked in any area of the Idaho National Laboratory from January 1, 1949 through December 31, 1970. Class Evaluated by NIOSH Based on its preliminary research, NIOSH accepted the petitioner-requested class. NIOSH evaluated the following class: All employees who worked in any area of the Idaho National Laboratory from January 1, 1949 through December 31, 1970. 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 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. The SEC class start date was established as January 1, 1963 because, in the face of increased alpha contamination, the CPP radiation protection program did not initiate a corresponding increase in the number of bioassay samples taken. For the period between January 1, 1963 and February 28, 1970, the external exposure records can be used to place workers in particular radiological work areas. This supports the ability to separate CPP workers as an individual group for the proposed SEC class between January 1, 1963 and February 28, 1970. However, for the period between March 1, 1970 and December 31, 1974, the external exposure records cannot be used to place workers in particular radiological work areas. This eliminates the ability to segregate workers by work area based on dosimetry records, leading to the conclusion that the CPP internal dose bounding deficiency applies to all monitored INL workers between March 1, 1970 and December 31, 1974. Therefore, the portion of the SEC class between March 1, 1970 and December 31, 1974 includes all INL workers who were 3 of 263 SEC-00219 07-21-15 Idaho National Laboratory monitored for external radiation at INL (e.g., at least one film badge or TLD dosimeter). The Preliminary ICPP Health Physics Upgrade Program report was published and delivered to management in October 1974. Although the proposed class end date is identified as December 31, 1974, further NIOSH-ORAUT review and assessment will be necessary to determine if the program data from 1975 forward is adequate to support reconstructing dose with sufficient accuracy for this area. Feasibility of Dose Reconstruction NIOSH finds it is not feasible to estimate internal exposures with sufficient accuracy for all workers who worked in the Chemical Processing Plant at INL from January 1, 1963 through December 31, 1974. 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 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 during the specified period. For the remainder of the INL site, other than the locations and periods defined as reserved for further assessment and evaluation, dose reconstructions are deemed feasible at INL from January 1, 1949 through December 31, 1970. The NIOSH dose reconstruction feasibility findings are based on the following: • Operations at the site began in 1949, when the Atomic Energy Commission (AEC) established the National Reactor Testing Station (NRTS). The site, known today as the Idaho National Laboratory (INL), was the primary nuclear reactor development laboratory in the United States. Over 100 reactor concepts were conceived and tested there. Between 1953 and 1992, the Idaho Chemical Processing Plant (CPP) at INL reprocessed spent nuclear fuel from naval propulsion, test, and research reactors to recover enriched uranium for reuse in nuclear weapons production. Other facilities at INL also conducted various nuclear weapons research and development activities over the INL operational period evaluated in this report. • Principal sources of internal radiation for members of the proposed class included inhalation and ingestion exposures to various isotopes of uranium, thorium, and plutonium, tritium, exotic radionuclides (produced from, or as a result of, reactor neutron irradiation), and mixed fission and activation products (MFP/MAP). These materials were most widely used and present on site at INL in the Test Reactor Area (TRA), Chemical Processing Plant (CPP), Test Area North (TAN), Miscellaneous Reactor Areas, Central Facilities Area (CFA), and Burial Ground. o TRA: NIOSH has determined that the internal dose potential during the period under evaluation at the TRA is associated with reactors, laboratories, machine shops, and other research and support activities as well as radioactive waste disposal. There was limited personnel internal exposure potential to alpha-emitting radionuclides, including plutonium and other actinides, during the evaluated period. Personnel monitoring data for mixed fission products exposures exist to support reconstructing doses for INL workers during the evaluated period. 4 of 263 SEC-00219 07-21-15 Idaho National Laboratory o CPP: NIOSH has determined that the internal dose potential at CPP over the evaluated period was related to its primary function of processing spent fuel elements containing enriched uranium for the recovery of the un-fissioned uranium. The uranium was separated from fission products by continuous liquid-liquid extraction. Although much of the processing equipment