REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute of Occupational Safety and Health

Audit of Case PIID* from the Savannah River Site 

Contract No. 200-2004-03805 

Task Order No. 4 

SCA-TR-TASK4-CN011362 

Prepared by 

S. Cohen & Associates 

6858 Old Dominion Road, Suite 301 

McLean, Virginia 22101 

February 2005 

NOTICE: This information is protected by Privacy Act 5 USC §552a; disclosure to any third party without 

the written consent of the individual to whom the information pertains is strictly prohibited.
.

Document No. 

SCA-TR-TASK4-CNPIID* 

Effective Date: 

February 4, 2005 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 1 

AUDIT OF CASE PIID* FROM THE SAVANNAH 

RIVER SITE

Page 2 of 16 

Task Manager: ___________________ Date: 02/04/05 

 U. Hans Behling, PhD, MPH 

Project Manager: _________________ Date: 02/04/05 

 John Mauro, PhD, CHP 

Supersedes: 

Draft Rev. 0 

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TABLE OF CONTENTS 

1.0 Summary Background Information .................................................................................... 4 

1.1 Audit Objectives ..................................................................................................... 5 

1.2 Summary of Audit Findings.................................................................................... 6 

2.0 Audit of External Doses...................................................................................................... 9 

2.1 Occupational Medical Dose.................................................................................... 9 

2.1.1 Reviewer’s Comments................................................................................ 9 

2.2 Onsite Ambient Dose.............................................................................................. 9 

2.2.1 Reviewer’s Comments................................................................................ 9 

3.0 Audit of Internal Doses..................................................................................................... 10 

3.1 Tritium .................................................................................................................. 10

3.2 Radionuclides Other Than Tritium ....................................................................... 10 

3.2.1 Reviewer’s Comments.............................................................................. 10 

4.0 CATI Report and Radiological Incidents ......................................................................... 11 

5.0 Summary Conclusion........................................................................................................ 12 

References..................................................................................................................................... 13 

Appendix A: IREP Input.............................................................................................................. 14 

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1.0 SUMMARY BACKGROUND INFORMATION 

This report presents the results of an independent audit of a dose reconstruction performed by the 

National Institute of Occupational Safety and Health (NIOSH) for an energy employee who 

worked at the Savannah River Site (SRS) from PIID* through PIID* as an PIID*. The worker 

was diagnosed with colon cancer on PIID* and prostate cancer on PIID*. 

SRS operations played an important role in the U.S. nuclear weapons program. SRS processes 

included nuclear fuel fabrication, reactor operation, radiochemical processing, uranium 

recycling, plutonium production, neutron source production, and waste management. 

Although documents provided by the Department of Labor (DOL) confirm that the energy 

employee worked at SRS from PIID*, through PIID*, the Department of Energy (DOE) has no 

records for this claimant. In response to NIOSH’s request for Personnel Exposure Information, 

DOE indicated that no records exist for external dosimetry, internal dosimetry, occupational 

medical x-rays, incident investigation reports, and other monitoring results. In summary, the 

absence of DOE records/documentation pertaining to the claimant’s employment at SRS, the 

nature of work performed by the claimant, assigned work locations, and radiation monitoring 

records provide a limited basis for dose reconstruction. 

Thus, it is uncertain whether the absence of records for the claimant implies that this individual 

was never engaged in work activities that required radiation monitoring, or whether this is a case 

of misplaced/missing records. Support for the latter is discussed in Section 4.0 of this audit 

report. For dose reconstruction, NIOSH assumed that the energy employee was not monitored, 

since no internal or external dose records were provided. 

In the absence of monitoring data, NIOSH limited the assignment of doses for the claimant to the 

following exposure categories. 

• Onsite ambient external doses 

• Occupational medical X-rays 

• Internal exposures for radionuclides other than tritium, based on an acute 

hypothetical intake 

In summary, a dose reconstruction was performed by NIOSH that included a total of 71 exposure 

data entries to be used for determining the probability of causation. These dose entries are #1 

through #77 and are reproduced herein as Appendix A. Throughout this report, reference will be 

made to select portions of Appendix A; for example, exposure entries #1 through #62 identify 

hypothetical internal doses, while entries #69 through #71 correspond to occupational medical 

exposure. 

Table 1 provides a summary of dose estimates derived by NIOSH that correspond to data 

contained in Appendix A. Using NIOSH’s dose estimates, the probability of causation (POC) 

was determined by the DOL to be 11.28% at the 99% confidence interval, and on this basis, the 

claim was denied. 

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Table 1. Summary of NIOSH-Derived External/Internal Dose Estimates 

Appendix A 

Exposure Entry No.

Dose 

(rem) 

External Dose: 

 ▪ Photon Dosimeter Dose NC* — 

 ▪ Missed Photon Dose NC* — 

 ▪ Neutron Dosimeter Dose NC* — 

 ▪ Missed Neutron Dose NC* — 

 ▪ Occupational Medical: 69 – 71 0.125 

 ▪ Onsite Ambient 66 – 68 0.273 

Internal Dose (Hypothetical): 

 ▪ Tritium 63 – 65 1.065 

 ▪ All Other Radionuclides 1 – 62 2.143 

Total: 3.606 

* NC – Not considered 

1.1 AUDIT OBJECTIVES 

SC&A’s audit was performed with the following objectives: 

• To determine if NIOSH assigned doses that are consistent with monitoring 

records provided by the DOE and with information contained in the CATI report 

• To determine if the dose reconstruction process complied with applicable 

procedures that include generic procedures developed by NIOSH and ORAUT, as 

well as data/procedures that are site-specific to SRS 

• In instances when procedure(s) provide more than one option or require subjective 

decisions, determine if the process is scientifically defensible and/or claimant 

favorable. 

In pursuit of these objectives, a two-step process is followed. The first step of this audit is to 

independently duplicate and, therefore validate, doses derived by NIOSH. This step of the audit 

process is not only contractually mandated under Task 4, but provides NIOSH and the Advisory 

Board with a high level of assurance that the SC&A reviewer understands which procedures, 

models, site-specific data, and assumptions NIOSH used to perform its dose reconstruction. The 

second step of the audit critically evaluates whether the methods employed by NIOSH are 

technically defensible, consistent with applicable procedures, and claimant favorable. 

Lastly, in compliance with the Privacy Act, this report makes no reference to the claimant’s 

name, SSN, address, or any personal data that might reveal the identity of the claimant. 

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1.2 SUMMARY OF AUDIT FINDINGS 

An overview of SC&A’s audit findings for Case PIID* is provided in Table 2 in the form of a 

checklist. This checklist evaluates the data collection process, information obtained from the 

CATI interview, and all methods used in the dose reconstruction. When deficiencies are 

identified by the audit, such deficiencies are further characterized with regard to their impact(s) 

by means of the following definitions: (1) low means that the deficiency has only a marginal 

impact on dose; (2) medium means that the deficiency substantially impacts the dose, but is 

unlikely to impact the compensability of the case; and (3) high means that the deficiency 

substantially impacts the dose and may also impact the compensability of the case. A full 

description of deficiencies identified in the checklist is provided in the text of the audit that 

follows. 

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Table 2. Case Review Checklist 

CASE PIID* ASSIGNED DOSE: 3.606 rem POC: 11.28% 

Audit Response If No, Potential Significance No. Description of Technical Elements of Review YES N/A NO LOW1 MEDIUM2 HIGH3

A. REVIEW OF DATA COLLECTION: 

A.1 Did NIOSH receive all requested data for the DOE or 

AWE site from any relevant data source? T

A.2 Is the data used by NIOSH for the case adequate to 

make a determination with regard to POC? T

B. REVIEW OF INTERVIEW AND DOCUMENTATION PROVIDED BY CLAIMANT 

B.1 Did NIOSH properly address all work history 

dates/locations of employment reported by claimant? T

B.2 Did NIOSH properly address all 

incidents/occurrences reported by claimant? T

B.3 Did NIOSH properly address monitoring/ personal 

protection/work practices reported by claimant? T

B.4 Is the interview information consistent with data used 

for dose estimate? T T

C. REVIEW OF PHOTON DOSES 

C.1 Was the appropriate procedure used for determining: 

C.1.1 - Recorded Photon Dose? T

C.1.2 - Missed Photon Dose? T

C.1.3 - Occupational Medical Dose? T

C.1.4 - Onsite-Ambient Dose? T

C.2 Did the DR properly account for all: 

C.2.1 - Recorded Photon Dose? T

C.2.2 - Missed Photon Dose? T

C.2.3 - Occupational Medical Dose? T

C.2.4 - Onsite-Ambient Dose? T

C.3 Is the recorded/assigned dose properly converted to the organ dose of interest for: 

C.3.1 - Recorded Photon Dose? T

C.3.2 - Missed Photon Dose? T

C.3.3 - Occupational Medical Dose? T

C.3.4 - Onsite-Ambient Dose? T

C.4 Is the organ dose uncertainty properly determined for: 

C.4.1 - Recorded Photon Dose? T

C.4.2 - Missed Photon Dose? T

C.4.3 - Occupational Medical Dose? T

C.4.4 - Onsite-Ambient Dose? T

D. REVIEW OF SHALLOW (i.e., 7 mg/cm2)/ELECTRON DOSES 

D.1 Was the appropriate procedure used for determining: 

D.1.1 - Recorded Shallow/Electron Dose? T

D.1.2 - Missed Shallow/Electron Dose? T

D.1.3 - Onsite Ambient Dose? T

D.2 Did the DR properly account for all: 

D.2.1 - Recorded Shallow/Electron Dose? T

D.2.2 - Missed Shallow/Electron Dose? T

D.2.3 - Onsite Ambient Dose? T

 

1 Low means that the deficiency has only a marginal impact on dose. 2 Medium means that the deficiency substantially impacts the dose, but is unlikely to impact the compensability of the case. 3 High means that the deficiency substantially impacts the dose and may also impact the compensability of the case. 
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Savannah River Site Case #PIID* 8 S. Cohen & Associates 

CASE PIID* ASSIGNED DOSE: 3.606 rem POC: 11.28% 

Audit Response If No, Potential Significance No. Description of Technical Elements of Review YES N/A NO LOW1 MEDIUM2 HIGH3

D.3 Is the recorded/assigned dose properly converted to the organ dose of interest for: 

D.3.1 - Recorded Shallow/Electron Dose? T

D.3.2 - Missed Shallow/Electron Dose? T

D.3.3 - Onsite Ambient Dose? T

D.4 Is the organ dose uncertainty properly determined for: 

D.4.1 - Recorded Shallow/Electron Dose? T

D.4.2 - Missed Shallow/Electron Dose? T

D.4.3 - Onsite Ambient Dose? T

E. REVIEW OF NEUTRON DOSES 

E.1 Was the appropriate procedure used for determining: 

E.1.1 - Recorded Neutron Dose? T

E.1.2 - Assigned Neutron Dose? T

E.1.3 - Missed Neutron Dose? T

E.2 Did the DR properly account for all: 

E.2.1 - Recorded Neutron Dose? T

E.2.2 - Assigned Neutron Dose? T

E.2.3 - Missed Neutron Dose? T

E.3 Is the recorded/assigned dose properly converted to the organ dose of interest for: 

E.3.1 - Recorded Neutron Dose? T

E.3.2 - Assigned Neutron Dose? T

E.3.3 - Missed Neutron Dose? T

E.4 Is the organ dose uncertainty properly determined for: 

E.4.1 - Recorded Neutron Dose? T

E.4.2 - Assigned Neutron Dose? T

E.4.3 - Missed Neutron Dose? T

F. REVIEW OF INTERNAL DOSE: BASED ON HYPOTHETICAL MODEL 

F.1 Is the use of the selected hypothetical internal dose 

model appropriate, based on the likely POC value? T

F.2 Is the use of a hypothetical internal dose model 

appropriate/conservative, based on claimant’s 

available bioassay data,? 

T

F.3 Was the hypothetical dose value correctly derived? T

G. REVIEW OF INTERNAL DOSE: BASED ON BIOASSAY/IMBA 

G.1 Was the appropriate procedure (or section of 

procedure) used for determining likely (>50%), 

unlikely (<50%), or undetermined POC and 

compensability? 

T

G.2 Are bioassay data sufficiently adequate for internal 

dose reconstruction? T

G.3 Are assumptions pertaining to dates of uptake 

reasonable/conservative? T

G.4 Are critical parameters (e.g., solubility class, particle 

size, etc.) used for IMBA organ dose estimates 

appropriate? 

T

G.5 Are assigned uncertainties (measurement errors) for 

bioassay data (used as input to IMBA) appropriate? T

H. Total Number of Deficiencies and Their Combined Potential Significance 1 T

_____________________________ 

1

 Low means that the deficiency has only a marginal impact on dose. 2

 Medium means that the deficiency substantially impacts the dose, but is unlikely to impact the compensability of the case. 3

 High means that the deficiency substantially impacts the dose and may also impact the compensability of the case. 
.

2.0 AUDIT OF EXTERNAL DOSES 

2.1 OCCUPATIONAL MEDICAL DOSE 

In spite of the absence of records, NIOSH assumed the energy employee was given an annual 

medical x-ray examination as a condition of employment for the years PIID* through PIID* . 

Based on guidance contained in Section 2 of ORAUT-TKBS-0003, NIOSH assigned a dose of 

42 mrem as the organ dose to the colon and prostate for each annual x-ray exam (see entries #69 

through #71 of Appendix A). 

2.1.1 Reviewer’s Comments 

SC&A reviewed Section 2 of ORAUT-TKBS-0003 and the default data contained in 

Table 2.5.1-1 for Group 3 organs. The assigned doses by NIOSH match those given in 

Table 2.5.2-1 and are, therefore, scientifically valid and comply with the applicable data, as 

defined in ORAUT-TKBS-0003. 

2.2 ONSITE AMBIENT DOSE

Because the energy employee was assumedly not monitored, NIOSH assigned an external onsite 

ambient dose (chronic) for the years PIID* to PIID*. To maximize the probability of causation, 

ambient photon doses were assigned to the energy range 30–250 keV, and the energy employee 

was assumed to have worked an average of 50 hours per week for the full duration of each year. 

Onsite ambient doses were based on the maximum annual onsite ambient external doses reported 

for any area of the SRS during the 3 years of employment. NIOSH assigned annual doses of 

101 mrem, 94 mrem, and 78 mrem (see entries #66 through #68 of Appendix A) for PIID*, 

PIID*, and PIID*, respectively. 

2.2.1 Reviewer’s Comments 

SC&A reviewed Section 3 of the Savannah River Technical Basis Document (ORAUT-TKBS0003) and verified the above-cited values as the appropriate values provided in Table 3.4-1. 

The assigned onsite ambient doses for the claimant are compliant with applicable procedures, are 

scientifically valid, and claimant favorable. 

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3.0 AUDIT OF INTERNAL DOSES

3.1 TRITIUM 

Due to the short biological and therefore effective half-life of tritium, hypothetical internal doses 

were assigned for each of the 3 years of employment; for all other radionuclides, the hypothetical 

internal doses extend from PIID* to the time of cancer diagnosis in PIID*. For tritium, an 

internal organ dose of 1.065 rem was assigned to the colon/prostate. 

3.2 RADIONUCLIDES OTHER THAN TRITIUM 

In order to account for any incidental dose that might have been received but not documented, 

NIOSH assigned yearly internal doses based on a single hypothetical acute intake on the first day 

of employment through the year of cancer diagnosis. Assigned internal doses for hypothetical 

exposure included all nuclides other than tritium. The technical basis for hypothetical internal 

doses is described in Section 4 of ORAUT-TKBS-0003. For radionuclides other than tritium, 

NIOSH derived an internal dose of 2.143 rem. 

3.2.1 Reviewer’s Comments 

As part of SC&A’s audit of hypothetical internal exposures, we verified all data entries against 

the default values cited in Table 4.5.3-1 for tritium, and Table 4.5.1-1 for all other radionuclides. 

At this time, we conclude that all assigned internal doses for tritium and nuclides other than 

tritium are correct and comply with applicable procedures. However, there may be a generic 

flaw in the hypothetical internal exposure model for tritium and all other nuclides that may not 

only adversely affect the scientific validity and claimant favorability of this claim, but other SRS 

claims as well. The following provides a brief explanation. 

The potential exception to scientific validity/claimant favorability reflects two issues. The first 

involves the unconfirmed assumption that all tritium exposures are those involving tritiated 

water. If, in fact, intakes involved a significant fraction of organified tritium, with a biological/ 

effective half-life that is about 2.3-fold higher, then the assigned doses herein may be too low. 

 

The second issue is considerably more complex and involves estimated yearly doses from all 

other internal radionuclides, as defined in Table 4.5.1-1 of ORAUT-TKBS-0003, which in turn 

were derived from data contained in ORAUT-OTIB-0001. In brief, ORAUT-OTIB-0001 models 

intakes that are based on ICRP 30 biokinetic models instead of the current ICRP models, as 

required in 42 CFR 82. We believe that the use of ICRP 30 calculated intakes may not be 

claimant favorable for several important radionuclides and that ICRP 68 models should have 

been used to derive intakes. 

Although the two issues cited above may impact both recorded internal doses (defined by 

bioassay data and IMBA) and assigned hypothetical doses, an agreement has been reached by 

the Advisory Board, SC&A, and NIOSH to evaluate these issues under Task 1 (i.e., Review of 

Site Profiles). 

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4.0 CATI REPORT AND RADIOLOGICAL INCIDENTS 

As previously acknowledged, DOE has no radiological records for this claimant. Consequently, 

there is no formal documentation of any radiological incidents. According to NIOSH records, 

because the claimant declined to be interviewed, there is also no CATI report available for audit. 

However, what is part of the claimant’s file is the NIOSH OCAS Phone Log Report, which 

identifies several critical statements that may have relevance to the dose reconstruction/claim. A 

copy of this phone log is enclosed herein as Exhibit 1. (In compliance with the Privacy Act, all 

personal identifiers have been blacked out.) 

It must be noted, however, that Column 1 of Exhibit 1 identifies phone dates which post-date the 

completion of the dose reconstruction on December 1, 2003. Thus, the dose reconstructor was 

not aware of allegations brought up by claimant’s spouse/family members during the closeout 

interview. Nevertheless, the following issues appear to conflict with assumptions by NIOSH in 

the dose reconstruction and may require a follow-up evaluation. 

Issue of Concern 1: In the phone log entry for December 23, 2003, the spouse of the employee 

insists that the claimant “wore a dosimeter all the time.” This conflicts with the NIOSH 

assumption that the claimant was not monitored. In support of claimant favorability, a reversal 

of NIOSH’s assumption would imply that the dose reconstruction might have to consider 

assignment of doses for photons and neutrons based on co-worker data, if such could be found. 

In the absence of co-worker data, an alternate approach may be to assign doses corresponding to 

annual dose limits for the claimant for each year of employment. 

Issue of Concern 2: In the phone log entry dated December 13, 2003, the spouse of the energy 

employee further raises questions about dates of employment. It is uncertain if the reference to 

the employee’s “whole employment” is a statement of disagreement with the employment period 

of PIID*, through PIID*, that was used by NIOSH for dose reconstruction. A longer 

employment period would clearly raise assigned radiation doses for the claimant. 

Issue of Concern 3: In the phone log entry dated February 20, 2004, the spouse of the energy 

employee states that the employee may have also worked at/visited other DOE sites that include 

the Los Alamos and Hanford sites. If this statement can be confirmed, the dose reconstruction 

may have to be further amended to account for non-SRS exposures. 

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Exhibit 1: Phone Log Report 

Phone log deleted – please see hard copy marked ‘#10 – Savannah River Site’ 

5.0 SUMMARY CONCLUSION

On the condition that the absence of monitoring records for the claimant is due to the fact that the 

claimant was never monitored, our audit shows that the dose reconstruction complied with 

applicable procedures and is generally scientifically correct and claimant favorable (with 

exceptions noted in text). However, there remains reasonable concern that the absence of 

records may reflect misplaced/missing records, in which case the dose reconstruction must 

clearly be viewed as incomplete, scientifically invalid, and claimant unfavorable. 

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REFERENCES

42 CFR 82. 2002. “Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule (42 CFR 82).” Federal 

Register 2002 May 2; Vol. 67, No. 85: 22314-22336. 

International Commission on Radiological Protection (ICRP). 1979. “Limits for Intakes of 

Radionuclides by Workers, Part 1,” ICRP Publication 30. Annals of the ICRP, 2 (3/4). 

Elmsford, NY: Pergamon Press. 

International Commission on Radiological Protection (ICRP). 1994. “Dose Coefficients for 

Intakes of Radionuclides by Workers,” ICRP Publication 68. Annals of the ICRP, 24 (4). 

Tarrytown, NY: Elsevier Science, Inc. 

ORAUT-OTIB-0001. 2003. “Technical Information Bulletin: Maximum Internal Dose 

Estimates for Savannah River Site (SRS) Claims,” Rev. 00. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. 

ORAUT-OTIB-0006. 2003. “Technical Information Bulletin: “Technical Information Bulletin: 

Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedure,” Rev. 02. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. 

ORAUT-TKBS-0003. 2002. “Technical Basis Document: Basis for Savannah River Site,” 

Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

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APPENDIX A: IREP INPUT 

Tables deleted – Please see hard copy marked “#10 – Savannah River Site’ 

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APPENDIX A (continued) 

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