REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute of Occupational Safety and Health 

Audit of Case PIID* from the Rocky Flats Plant 

Contract No. 200-2004-03805 

Task Order No. 4 

SCA-TR-TASK4-CN PIID* 

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-CN PIID*

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 ROCKY 

FLATS PLANT

Page 2 of 17 

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 

Rocky Flats Plant Case PIID* 2 S. Cohen & Associates 
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TABLE OF CONTENTS 

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

1.1 Audit Objectives ..................................................................................................... 4 

1.2 Summary of Audit Findings.................................................................................... 5 

2.0 Audit of External Doses...................................................................................................... 8 

2.1 Dose Reconstruction Overview .............................................................................. 8 

2.2 Recorded Photon Doses .......................................................................................... 8 

2.2.1 Reviewer’s Comments................................................................................ 8 

2.3 Missed Photon Doses.............................................................................................. 9 

2.3.1 Reviewer’s Comments................................................................................ 9 

2.4 Missed Neutron Dose............................................................................................ 10 

2.4.1 Reviewer’s Comments.............................................................................. 10 

2.5 Ocupational Medical Exposures ........................................................................... 11 

2.5.1 Reviewer’s Comments.............................................................................. 11 

2.6 Onsite Ambient Doses .......................................................................................... 11 

2.6.1 Reviewer’s Comments.............................................................................. 12 

3.0 Audit of Internal Doses..................................................................................................... 13 

3.1 Reviewer’s Comments.......................................................................................... 13 

4.0 CATI Report and Radiological Incidents ......................................................................... 14 

5.0 Summary Conclusions ...................................................................................................... 15

References..................................................................................................................................... 16 

Appendix A: IREP Input.............................................................................................................. 17 

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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). This dose reconstruction was for 

an energy employee that worked at the Rocky Flats Plant for almost PIID* years, from PIID*, 

through PIID*. This period included the time when the Rocky Flats Plant produced plutonium 

triggers for nuclear weapons and processed weapons for plutonium recovery. 

Because of claimant’s employment as an instrumentation engineer in the plutonium recovery and 

waste treatment buildings, the worker likely experienced internal exposures due to the intake of 

particles of plutonium oxide in the workplace and outside environment, and external exposures 

from working near the production operations. 

The employee was diagnosed with rectal cancer on PIID*. NIOSH judged that the probability of 

causation (POC) would be very low for this individual because of the cancer type, the short 

latency period between exposure and diagnosis, and the relatively short exposure time. In cases 

like this one, with low causation probabilities, NIOSH intentionally overestimates the dose 

using, in some cases, very unrealistic assumptions. Using the colon as a surrogate to the rectum, 

they quantified doses from measured and missed external exposures, missed internal exposures, 

and occupational medical x-rays, and determined that the POC was 0.45%. 

Table 1 presents an overall summary of NIOSH dose reconstruction. 

Table 1. Summary of Exposure as Estimated by NIOSH 

Appendix A 

Exposure Entry No.

Dose 

(rem) 

External Dose: 

 ▪ Photon Dosimeter Dose 1 – 3 0.48 

 ▪ Photon Missed Dose 22 – 26 1.8 

 ▪ Neutron Dosimeter Dose NC* — 

 ▪ Neutron Missed Dose NC* — 

 ▪ Occupational Medical 27 – 31 0.415 

 ▪ Onsite Ambient NC* — 

Internal Dose (Hypothetical): 4 – 21 8.68 

Total 11.375 

*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 the information contained in the CATI 

report 

Rocky Flats Plant Case PIID* 4 S. Cohen & Associates 
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• 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 

• 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 in this audit. 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. 

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. 

Rocky Flats Plant Case PIID* 5 S. Cohen & Associates 
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Table 2. Case Review Checklist 

CASE PIID* ASSIGNED DOSE: 11.375 rem POC: 0.45% 

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

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 T

C.1.3 - Occupational Medical Dose? T T

C.1.4 - Onsite-Ambient Dose? T

C.2 Did the DR properly account for all: 

C.2.1 - Recorded Photon Dose? T T

C.2.2 - Missed Photon Dose? T 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 T

C.3.2 - Missed Photon Dose? T

C.3.3 - Occupational Medical Dose? T 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 T

C.4.3 - Occupational Medical Dose? T 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

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

D.3.1 - Recorded Shallow/Electron 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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CASE PIID* ASSIGNED DOSE: 11.375 rem POC: 0.45% 

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

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 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 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 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 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 12 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. 

Rocky Flats Plant Case PIID* 7 S. Cohen & Associates 
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2.0 AUDIT OF EXTERNAL DOSES 

2.1 DOSE RECONSTRUCTION OVERVIEW 

Dose estimates derived by NIOSH for various exposure categories that were used as input values 

for IREP are included as Appendix A of this report and summarized below. There were a total 

of 31 exposure data entries for the following exposure categories: 

• Measured external dose from positive TLD results (Entries #1–#3 of Appendix A) 

• Missed dose from internal alpha radiation (Entries #4–#9 of Appendix A) 

• Missed dose from internal photon radiation (Entries #10–#15 of Appendix A) 

• Missed dose from internal electrons (Entries #16–#21 of Appendix A) 

• Missed external dose (Entries #22–#26 of Appendix A) 

• Dose from medical x-rays (Entries #27–#31 of Appendix A) 

2.2 RECORDED PHOTON DOSES 

NIOSH found the external dose records to be sufficient to estimate the claimant’s measured 

external dose. The reconstructor found positive TLD measurements for PIID* and PIID* that 

totaled 0.24 rem. NIOSH doubled this dose to account for uncertainty and assumed that the 

photon energy range was 30–250 keV to maximize the causation probability. 

2.2.1 Reviewer’s Comments 

SC&A reviewed the TLD records and verified that the total individual year TLD measured dose 

was 0.24 rem. This dose represents the sum of two annual TLD reports dated PIID*, and PIID*. 

The reports listed the following doses: 

Reporting Date Quarter Penetrating Dose (mrem)

PIID* 1 0 

2 0 

3 0 

4 37

Total 37 

PIID* 1 73 

2 53 

3 44 

4 28

Total 203 

Grand Total 240 

 * Reporting date is the year following the measurements 

Doubling this dose yields the 0.48 rem used in the IREP input and eliminates the need for 

uncertainty. 

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However, there is a discrepancy with a DOE record that shows the accumulated dose for the 

years including PIID* to be 0.277 rem, not 0.240 rem. This record was found on page 39 of 40 

in the supplied .pdf file named DOE_Response_008121_D238. SC&A has no way to determine 

which value is correct or why there is this discrepancy between the summary printout and the 

individual yearly records. 

Secondly, Appendix A shows that entry #3 corresponds to the identical PIID* dose of 0.074 rem 

as entry #1. Thus, entry #3 is either a redundant entry or entry #3 should have the assigned year 

of PIID*. 

Lastly, in compliance with guidance contained in ORAUT-OTIB-0008 (which identifies the 

Standard Overestimating Correction/Conversion Factor of 2 for recorded TLD values), doubling 

this dose yields the 0.48 rem and eliminates the need for uncertainty. However, ORAUT-OTIB0008 also identifies a single generic HP(10)-to-organ dose conversion factor (DCFmax) of 1.1, 

which was not applied to entries #1, #2, and #3. (The dose reconstructor either ignored the need 

for a DCF or assumed a value of 1.0.) 

2.3 MISSED PHOTON DOSES 

To estimate missed photon dose, NIOSH employed the following approach, as contained in the 

DR Report and reproduced below verbatim. 

Missed dose was assigned to each actual or potential dosimeter cycle to 

maximize the external dose estimate. Missed dose represents the dose that may 

have been received but not recorded because of dosimeter detection limits or 

site reporting practices. Based on the Technical Information Bulletin: 

Overestimating External Doses Measured with Thermoluminescent Dosimeter,8

the total number of dosimeter cycles assigned was 60 for photons. This number 

was based on a claimant-favorable assumption of 12 badge exchanges each full 

or partial year of employment to ensure that all possible instances of a zero 

badge reading were accounted for in this dose reconstruction. Based on 

information provided in the Technical Information Bulletin: Overestimating 

External Doses Measured with Thermoluminescent Dosimeter,8 this results in a 

maximum missed dose of 3.600 rem from photons. For the purpose of 

calculating probability of causation, this value was divided by 2 in accordance 

with the External Dose Reconstruction Implementation Guideline.3

 [Emphasis 

added.]

2.3.1 Reviewer’s Comments 

The above-cited explanation for estimating missed photon dose contains an erroneous 

interpretation of ORAUT and OCAS procedures, an erroneous interpretation of DOE dosimetry 

data, and a numerical error, as explained below. 

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• The dose reconstructor erroneously applied the standard overestimating C/C factor of 2 

and derived the above-cited total of 3.600 rem: 

Total Missed Dose = (30 mrem/cycle)(12 cycles)(5 years)(2) 

 = 3.600 rem 

• Next the dose reconstructor cancels the first error (i.e., the misuse of the standard 

overestimating factor of 2) by dividing the dose estimate by 2 and explains this by the 

following statement “. . . for the purpose of calculating probability of causation, this 

value was divided by 2 in accordance with the External Dose Reconstruction 

Implementation Guideline.3

” (Note: OCAS-IG-001 provides standard guidance for 

missed dose expressed as nLOD/2 and a GSD of 1.52 for uncertainty; OCAS-IG-001 is 

not intended to be combined with ORAUT-OTIB-0008.) 

• The use of LOD (as opposed to LOD/2) for estimating missed dose per cycle represents 

the 95th percentile value and, therefore, precludes the need to incorporate uncertainty in 

the dose estimate. The dose reconstructor erroneously applied the GSD of 1.52 for 

uncertainty to a dose derived by LOD. 

• The assumption of 12 cycles per year applies to situations in which data are lacking. 

Dosimetry records provided by DOE in behalf of Claim PIID* clearly indicate that the 

individual was monitored on a quarterly (not monthly) basis. 

While the combination of procedural misinterpretations had only marginal impacts on assigned 

dose and clearly did not significantly affect the POC (and the compensability of the claim), it 

does demonstrate various difficulties associated with the implementation of this procedure. 

2.4 MISSED NEUTRON DOSE 

NIOSH did not estimate or discuss a neutron dose for this individual. 

2.4.1 Reviewer’s Comments 

A review of DOE dosimeter records, however, indicates that claimant was, in fact, monitored for 

neutrons. The records reveal that all neutron dosimeter readings were recorded as zero. Based 

on procedural guidance, zero readings must be accounted for as missed dose. Given the history 

of neutron dose for the recovery facility (ORAUT-TKBS-0011-6, Technical Basis Document for 

the Rocky Flats Plant – Occupational External Dosimetry), ignoring the missed neutron dose is 

not in keeping with the idea of intentional overestimation. The TBD estimates the missed dose 

during the term of the claimant employment to be 30 mrem per TLD. This value includes a 30% 

uncertainty factor. Given the fact that the claimant was employed for PIID* calendar quarters, 

total missed neutron dose is estimated at 0.480 rem and should have been included in the dose 

reconstruction. 

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While the inclusion of 0.480 rem for missed neutron dose would neither significantly increase 

the total assigned dose nor the POC, its inclusion, however, does satisfy procedural guidance, as 

given in Section 3 of ORAUT-PROC-0006, Attachment D-2, which states the following: 

In general, this instruction applies maximizing assumptions for both recorded and 

potentially unrecorded doses to ensure that the covered employee’s dose and 

probability of causation (POC) are not underestimated. This approach is 

consistent with the external dose reconstruction IG and the principles outlined in 

42 CFR 81 and 82. Unlike the approach for potentially >50% POC cases, this 

process does not allow a partial dose reconstruction as all potential sources of 

radiation dose must be evaluated. 

2.5 OCUPATIONAL MEDICAL EXPOSURES 

NIOSH used ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related 

Diagnostic X-ray Procedures, to estimate the dose from medical x-rays. NIOSH used annual 

x-ray exams and a maximum default organ dose (lateral view of breast = 0.0638 rem per x-ray 

exam) in Table 4.0-1 of ORAUT-OTIB-0006 and multiplied by 1.3 to account for uncertainty, as 

recommended by the reference document. This resulted in a total dose of 0.415 rem, as follows: 

0.0638 rem/exam x 1.3 x 1 exam/year x 5 years = 0.415 rem 

2.5.1 Reviewer’s Comments 

SC&A reviewed the DOE records of the claimant and found no records for diagnostic x-ray 

exams. NIOSH’s record request form is marked as “does not exist” by the DOE. Equally, the 

CATI report did not provide any information on the claimant having medical x-rays for 

employment. NIOSH’s assumption of an annual chest x-ray is, therefore, inappropriately 

claimant favorable. 

SC&A regards NIOSH’s dose estimate to be procedurally and scientifically difficult to justify. 

Table 4.0-1 of ORAUT-OTIB-0006 clearly identifies the corresponding dose to the rectum, and 

there is no scientific justification for using the breast as a surrogate organ for rectal cancer. 

According to Table 4.0-1 of ORAUT-OTIB-0006, the value for the colon/rectum is 

1.5E-04 rem/exam for the lateral view. This is the relevant organ for external exposures (OCASIG-001, External Dose Reconstruction Implementation Guideline. The colon/rectum value is 

about 425 times less than the value for the breast. This is not scientifically defensible, but is in 

keeping with intentionally overestimating the dose. 

2.6 ONSITE AMBIENT DOSES 

NIOSH did not include onsite ambient doses because the claimant was monitored during his 

employment, and because missed doses were assigned to dosimeter cycles. ORAUT-OTIB0007, Occupational Dose from Elevated Ambient Levels of External Radiation, recommends that 

an ambient dose assessment need not be performed in cases like this. In addition, the site 

Rocky Flats Plant Case PIID* 11 S. Cohen & Associates 
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measurement program did not subtract elevated background readings from the dosimeters, so the 

assigned missed doses exceed any onsite ambient levels. 

2.6.1 Reviewer’s Comments 

Our audit finds NIOSH’s reasoning not to include ambient doses scientifically defensible, 

especially since the missed external dose is overestimated. 

 

Rocky Flats Plant Case PIID* 12 S. Cohen & Associates 
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3.0 AUDIT OF INTERNAL DOSES 

According to NIOSH, there were no bioassay data, suggesting that claimant was unlikely to 

receive internal dose. Nevertheless, NIOSH used the hypothetical calculation based on ORAUTOTIB-0002, Maximum Internal Dose Estimates for Certain DOE Complex Claims, to reconstruct 

any potential missed internal dose. Based on this calculation, NIOSH obtained a total missed 

internal dose of 8.684 rem. 

3.1 REVIEWER’S COMMENTS 

It was noted that ORAUT-OTIB-0002 recommends calculating the dose to the colon as a 

surrogate organ for the rectum. In SC&A’s review of this document, ORAUT-OTIB-0005, and 

OCAS-IG-002, we found that Lower Large Intestine (LLI) is the correct surrogate for the 

rectum. 

SC&A acknowledges, however, the difference between colon and LLI as surrogate organs for 

the rectum is small and, therefore, of limited relevance to the conservative assumptions 

surrounding the hypothetical internal dose model employed by NIOSH. 

Rocky Flats Plant Case PIID* 13 S. Cohen & Associates 
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4.0 CATI REPORT AND RADIOLOGICAL INCIDENTS 

Our review of the CATI report reviewed no additional information useful and/or relevant to dose 

reconstruction. 

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5.0 SUMMARY CONCLUSIONS 

Our review of Case PIID* identified numerous minor deficiencies most of which involved a 

combination of misuse/misinterpretation of procedures for deriving maximized estimates of 

missed photon dose. This combination of nearly identical errors was also observed in behalf of 

two other cases (i.e., Case # PIID* and Case # PIID*). The fact that these three cases represent 

the work of three different dose reconstructors suggest that the cause is rooted in procedural 

guidance that is ambiguous and difficult to interpret. 

Rocky Flats Plant Case PIID* 15 S. Cohen & Associates 
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REFERENCES 

ACJ & Associates and the UK National Radiological Protection Board, Integrated Modules for 

Bioassay Analysis, (IMBA), Phase 1, Software produced for NIOSH-OCAS as part of the 

EEOICPA program, Version 1.0.63, UK, November 2002. 

“NIOSH Report of Dose Reconstruction Under the Energy Employee Occupational Illness 

Compensation Program Act (EEOICPA).” NIOSH ID: 008121. 

NIOSH. 2002. “External Dose Reconstruction Implementation Guideline, Rev 1,” 

OCAS-IG-001. National Institute for Occupational Safety and Health, Office of Compensation 

Analysis and Support, Cincinnati, Ohio, 2002. 

NIOSH. 2002. “Internal Dose Reconstruction Implementation Guideline, Rev 0,” 

OCAS-IG-002. National Institute for Occupational Safety and Health, Office of Compensation 

Analysis and Support, Cincinnati, Ohio, August 2002. 

ORAUT-TKBS-0011-6. 2004. “Technical Basis Document for the Rocky Flats Plant – 

Occupational External Dosimetry,” January 20, 2004. 

ORAUT –TKBS-0011-5 2004. “Technical Basis Document for the Rocky Flats Plant to be used 

for EEOICPA Dose Reconstruction,” January 12, 2004. 

ORAUT-OTIB-0008. 2003. “Standard Complex-Wide Conversion /Correction Factor for 

Overestimating External Doses Measured with Thermoluminescent Dosimeter,” November 7, 

2003. 

ORAUT-OTIB-0007. 2003. “Occupational Dose from Elevated Ambient Levels of External 

Radiation,” November 12, 2003. 

ORAUT-OTIB-0006, “Dose Reconstruction from Occupationally Related Diagnostic X-ray

Procedures,” November 29, 2003. 

ORAUT-OTIB-0002. 2004. “Maximum Internal Dose Estimates for Certain DOE Complex 

Claims,” January 10, 2004. 

Rocky Flats Plant Case PIID* 16 S. Cohen & Associates 
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APPENDIX A: IREP INPUT

 Table Below has been deleted – Please see hard copy labeled “#16 – Rocky Flats Plant” 

Rocky Flats Plant Case PIID* 17 S. Cohen & Associates