ORAUT‐OTIB‐0023

Assignment of Missed Neutron Dos

Based on Dosimeter Records

Report from the Procedures Review Subcom

Presented to the

Advisory Board on Radiation and Worker H

Idaho Falls, Idaho

July 16–17, 2013
ORAUT‐OTIB‐0023 Summa

• The purpose is to provide information to allo

dose reconstructors to determine when it is

appropriate to assign missed neutron doses 

sites using the nLOD/2 method or an “alternmethod.

• Use of the “alternative” method should be a

when the missed neutron central estimate (

nLOD/2) exceeds 75% of the assigned photo

(i.e., from recorded dosimeter dose + misse

dose).
ORAUT‐OTIB‐0023 Timelin

• March 7, 2005 – NIOSH Issued Revision 0

• June 8, 2006 – SC&A Review (SCA‐TR‐TASK3‐000• September 25, 2007 – NIOSH Initial Response

• October 2, 2007; November 7, 2007; January 7, 

June 24, 2008 – Discussed at Subcommittee Me

Findings Resolved

• November 5, 2007 – SC&A and NIOSH held conf

call to discuss OTIB‐0023 findings.

• May 14, 2008 – NIOSH Issued Revision 1, incorp

comments from Procedures Review Subcommitt

aligned with OCAS‐IG‐001.
Findings Summary: ORAUT‐OTIB

• 8 Findings in total – complete histories captu

the Board Review System (BRS)

– http://app‐cinc‐dcas.cdc.gov:8106/document

default.aspx?mode=ASSIGNED

– Resolution spanned 2 years (6/2006 to 6/200– All 8 findings are Closed

• The following slides provide summary inform

the resolution of each Finding – Details in BR

handout.
Findings Summary: ORAUT

‐OTIB

Many of the findings/resolutions deal w

OTIB

‐0023, Rev. 00, Section 6, Condition 

which SC&A believed to be inconsistent OCAS

‐IG

‐001:

• IG

‐001, Section 2.2.2.2.1: “..., when the neutron mis

central estimate (nLOD/2) exceeds 75% of the photo

(dosimeter dose

+ missed dose), the [neutron] expo

should be evaluated to determine if it should be con

to be an unmonitored exposure.”

• OTIB

‐0023, Section

6: “Missed neutron doses do no

be assigned if:

1. The neutron missed dose central estimate (nLOD/2) wou

75% of the photon dose (dosimeter dose

+ missed dose)

[Emphasis added.]
ORAUT‐OTIB‐0023 Review Fin

# Finding Resolution

1 The procedure lacks clarity by

failing to provide cleardefinition(s), and is inconsistent

in its terminology.

Closed on June 24, 2008.

OTIB‐0023, Revision 1, addressefinding.

2 For the alternative method,

detailed information is required

that will not be readily available

to the dose reconstructor.

Closed on June 24, 2008.

Rev. 00, Section 6, Condition #1 

eliminated by Rev. 01, which re

Finding 2.
ORAUT‐OTIB‐0023 Review Fin

# Finding Resolution

3 References OCAS‐IG‐001 as the

basis for its guidance; however,guidance contained in OTIB‐0023

and OCAS‐IG‐001 is inconsistent.Review Objective 1.4: “Is the

procedure consistent with allother procedures that are part of

the hierarchy of proceduresemployed by NIOSH for dosereconstruction?”

Closed on January 7, 2008.

OTIB‐0023, Revision 1 (and IG‐

corrected the inconsistencies b

001 Section 2.2.2.2.1 and OTIBSection 6.

4 It is questionable whether dose

reconstructors are in a position or

Closed on June 24, 2008.

have the information to make the Rev. 00, Section 6, Condition #

potentially subjective decisions eliminated by Rev. 01, which rerequired. Finding 4.
ORAUT‐OTIB‐0023 Review Fin

# Finding Resolution

5 Refer to Finding OTIB‐0023‐03 for

Review Objective 1.4.

Review Objective 4.2: “Does the

procedure adhere to the

hierarchical process as defined in

42 CFR 82.2?”

Closed on January 7, 2008.

The Subcommittee indicated t

OTIB‐0023‐03 was "Closed," s

issue refers to issue OTIB‐002

also been "Closed."
ORAUT‐OTIB‐0023 Review Fin

# Finding Resolution

6 The reconstruction of missed

neutron doses from “...numerous

neutron measurements andaccurate time information” is

unrealistic.

Closed on June 24, 2008.

Rev. 00, Section 6, Condition #

eliminated by Rev. 01, thus reFindings 6, 7, and 8 moot.

7 The regulatory recommendation

for “striking a balance between

the need for technical precision

and process efficiency” has been

ignored.

8 The generic assumption of a

neutron‐to‐photon ratio of 0.75:1

as a limiting value for the

application of nLOD/2 is neither

technically defensible nor claimant

favorable.
Questions?