Larry J. Elliott
Director, Office of Compensation Analysis and Support
National Institute for Occupational Safety and Health
Centers for Disease Control and Prevention
Mail Stop C-46
Re: Return of All Cases for New SEC Classes: Y-12 Plant,
1943 – 1947; and IAAP Radiographers, 1948 - 1949
Dear Larry:
On
Y-12 Plant, 1943 – 1947:
Department of Energy (DOE) employees or DOE
contractor or subcontractor employees who worked in uranium enrichment operations
or other radiological activities at the Y-12 facility in Oak Ridge, Tennessee
from March 1943 through December 1947 and who were employed for a number of
work days aggregating at least 250 work days, either solely under this
employment or in combination with work days within the parameters (excluding
aggregate work day requirements) established for other classes of employees
included in the SEC.
This designation became effective on
A report attached to Secretary Leavitt’s letter, entitled
“HHS Designation of Additional Members of the Special Exposure Cohort,”
provided the supporting rationale for designating a class of employees from the
Y-12 Plant in
Section
IV, “Designation Findings,” summarized NIOSH’s finding that “… it lacks access
to sufficient information to either 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
to estimate the radiation doses of members of the class more precisely than a
maximum dose estimate with sufficient accuracy.”
Also,
“NIOSH found that employees involved in the calutron uranium enrichment process
were exposed to levels of airborne uranium products that cannot be determined
because of the absence of bioassay data for the time period and the lack of air
sampling sufficient to develop maximum exposure scenarios.”
The
discussion further notes, “NIOSH is unable to estimate such doses based on
source term and process information for lack of documentation on the varying
levels of enrichment of the source materials and on the production rate of
operations, and because the manual recycling and cleaning activities are unique
and not comparable to any operations for which NIOSH has access to adequate
monitoring data.”
Finally,
“There is not sufficient information for individual dose reconstruction on
other radiological activities during this time period, including the
development of beneficial radiological isotopes, development and testing of a
neutron monitor, maintenance and use of a large Radium 226 sealed source, and
thorium extraction. However, NIOSH has
determined that it is possible to estimate the exposure that resulted from
occupational medical x-ray doses alone to complete sufficiently accurate dose
reconstruction for this class.”
The Secretary of Health and Human Services has determined that it is not feasible to undertake dose reconstructions for the class of employees employed at Y-12 Plant from March 1943 through December 1947. However, NIOSH has determined that it is possible to estimate the exposure that resulted from occupational medical x-ray doses alone to complete sufficiently accurate dose reconstruction for this class.
Thus,
NIOSH should provide two lists of employees at the Y-12 Plant during the SEC
class period. One list should cover
employees with specified cancers and the other list should address employees
with non-specified cancers. NIOSH should
return all cases with specified cancers (with the administrative record on a
CD) to the Department of Labor Jacksonville District Office for the Office of
Workers’ Compensation Programs to complete adjudication as appropriate. DOL will review employment and medical
information for both lists of employees.
Since NIOSH has determined that it is possible to estimate the exposure
that resulted from occupational medical X-ray doses alone, after the district
office review DOL will request that NIOSH continue to perform dose
reconstructions for cases with non-specified cancers for the SEC class time
period based solely on medical x-ray dose.
Also, for any cases with a specified cancer that do not meet the 250
work day or cancer latency period criteria, DOL will request that NIOSH perform
a dose reconstruction based solely on medical x-ray dose.
IAAP
Radiographers, 1948 – 1949:
Department of Energy (DOE) employees or DOE
contractor or subcontractor employees who worked as radiographers from May 1948
to March 1949 in support of Line 1 operations at the Iowa Army Ammunition Plant
and who were employed for a number of work days aggregating at least 250 work
days, occurring under this employment or in
combination with work days within the parameters (excluding aggregate work
day requirements) established for other classes of employees included in the
SEC.
This designation became effective on
A report attached to Secretary Leavitt’s letter, entitled
“HHS Designation of Additional Members of the Special Exposure Cohort,”
provided the supporting rationale for designating radiographers who supported Line 1 operations at the Iowa Army Ammunition
Plant (IAAP),
Section
IV, “Designation Findings,” summarized NIOSH’s finding that “… it lacks access
to sufficient information to either 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
to estimate the radiation doses of members of the class more precisely than a
maximum dose estimate with sufficient accuracy.”
The
discussion further notes, “NIOSH found that there is insufficient information
to estimate either the maximum radiation dose incurred by the workers defined
in the class or to estimate such radiation doses more precisely than a maximum
dose estimate. Additional information is
needed on the radiological sources, shielding, and the radiography process of
radiographic operations during the period May 1948 -
March 1949 to reconstruct doses using surrogate data from later time periods. NIOSH concluded that it is not feasible to
estimate with sufficient accuracy the external doses incurred by these
radiographers at IAAP during the time period in question”
The
Secretary of Health and Human Services has determined that it is not feasible
to undertake dose reconstructions for radiographers
who supported Line 1 operations at the Iowa Army Ammunition Plant from May 1948
through March 1949.
Thus,
NIOSH should return all cases concerning workers in this SEC class to the
Department of Labor Denver District Office for the Office of Workers’
Compensation Programs to complete adjudication as appropriate.
Sincerely,
Peter M. Turcic
Director, Division of Energy Employees
Occupational Illness Compensation