one week of full time work. Bone surface doses over a one-week exposure period

. would range from about 400 rem to almost 2,500 rem, depending on working
conditions and thorium solubility. We do not have a basis on which to select a
mix of solubilities based on the available data. If the work was carried out for
several weeks, then the dose estimates would be correspondingly higher.

Overall, it appears that exposures to specific workers who worked on thorium
may have been severe. We have not been able to assess cumulative thorium
exposures in a manner similar to uranium since we lack even minimally adequate
air concentration data over the requisite period of time. Our estimate of thorium
exposures corresponding to one week’s work indicates that, for some workers,
thorium exposures may have been comparable to and perhaps greater than
uranium exposures. Finally, if some workers worked on both uranium and
thorium, those exposures would be additive.

The dose estimates above were made from workplace air concentration data. Worker interviews
regarding the amount of time for which thorium was processed could be critical in cases like this
to make an estimate of the dose, since the documentation for this was not contained in the facility
profile that was available to the dose reconstruction personnel.

Example 2. Recycled Uranium

Recycled uranium was processed at a number of facilities (both DOE-owned and FUSRAP).
Trace transuranic radionuclides (Pu-239/240, Np-237) can make a significant contribution to the
worker dose. However, the levels of transuranics in recycled uranium varied by orders of
magnitude, ranging from levels which would play no significant role in the dose to important
contributors to dose. A crucial parameter in determining this would be the stage of processing at
which the worker handled the uranium. For instance, plutonium concentrations at Paducah were
higher at the fluorination tower relative to several other places and steps of processing. Specific
job descriptions are therefore very crucial, since plant air monitoring data and biological
measurement data usually do not contain radionuclide-specific information. Similarly,
information on whether respirators were used is also important.

In light of the above, estimating the contribution of transuranics in recycled uranium processing
is typically very difficult and involves carefully combining worker interviews, worker monitoring
records, plant air monitoring data, and production data in facility profiles. Auditing worker
interviews to determine whether they had adequately covered the worker’s history with recycled
uranium could be a critical component of individual dose audits at many DOE and FUSRAP
sites. Coordinating facility profile and worker interview data across facilities may also be
insightful. For example, recycled uranium at Fernald came from Paducah.

SC&A 3-9 Sol. No. 2003-N-00768


. Time period for which data are available compared to the period for which the
worker in question worked a particular job.

. Whether a worker also performed other jobs that are not typical of those who are
members of a group for whom dose data are available.

. Solubility information regarding the chemical form of radionuclides to which a
particular worker or group of workers were exposed.

° How frequently bioassay data were taken for individual workers or for workers
belonging to the group from which dose for an individual might be imputed.

. When, how much, and in what form, recycled uranium was processed or present,
and whether data exist from which the transuranic and fission product
contamination of the recycled uranium can be determined or reasonably inferred.

. Handling of film badges and use of correction factors.

The checklist presented in Exhibit 3-2 provides a systematic review of the above considerations
and other specific information that SC&A proposes to use in performing these reviews.
However, this checklist is simply a guideline and may not contain all of these elements that can
and may be used for an audit. Each petition, and the information required for its review, will be
considered on a case-by-case basis. A “Comments” section is provided in the checklist if the
auditor chooses to elaborate or describe information which is not contained in the checklist.

The need to combine both a systematic review of criteria, such as that contained in the checklist,
with expert judgment of the radiological dosimetry and operation history of a facility can be
illustrated at any number of DOE sites.

For example, at Fernald, “blowouts” occurred in furnaces at Fernald, where UF, was reduced to
U metal. Workers present during blowouts or who were given the job of cleanup immediately
afterwards (if they were from the production area) might be in a different subcategory than the
other production workers in this area. Witness information can be useful not only in determining
unusual accidents, but also for determining accidents and process upsets that were not so
unusual, but nonetheless not part of the planned normal production process. Another example of
this kind of problem would be uranium chip fires, which were prevalent at a number of DOE
sites handling uranium metal.

At Los Alamos TA-33 (Tritium Facility), workers frequently lacked respirator protection while
working in tritium-contaminated atmospheres. When significant exposures occurred, some
workers would expedite urinary excretion by consuming large amounts of liquids; others would
delay routine bioassay monitoring. Exposure would vary by the particular job being performed,
the individual worker’s work practice, and ventilation present in the work area at the time. The
only area monitoring was an area tritium alarm set at relatively high activity levels. A
determination of the ability to reconstruct these doses would hinge on a combination of witness
interviews, historic area alarming data, and available dose records, and a judgment on their

SC&A 3-26 Sol. No. 2003-N-00768


performance of each case or task comprising the TORP, the TORP will be subdivided into
individual cases and/or tasks, and, as required by each case, may be further subdivided into
Jower-tier tasks, such as external and internal dose-reconstruction review, worker profile review,
interview record review, and site profile review. Filing and tracking the cost and performance of
each TORP will be performed under the following work breakdown structure:

Tier 1: Task Order Number

Tier 2: Case Number
Tier 3: Dose Reconstruction
Tier 3: Worker Profile
Tier 3: Interviews
Tier 3: Site Profile

Tier 2: SEC Petition Review

Tier 2: Worker Profile Review

Tier 2: Site Profile Review

Tier 2: Ad Hoc Investigations

Using a relational database, we will be able to sort according to site (e.g., Hanford, Savannah
River, etc.), category of site (e.g., FUSRAP site, uranium processing facilities, etc.) category of
exposure (e.g., external gamma, plutonium inhalation, etc.), or any other parameter that may
serve the Advisory Board’s purposes.

While the TORP filing system is being set up, each key member of the project team (see

Section 2.1) will receive copies of the TORP for initial inspection with respect to scope,
schedule, resource requirements, and conflict of interest (COD) issues. A meeting will be held
among the key members of the project team to discuss the TORP and any supporting records and.
documentation provided with it. The meeting will be designed to accomplish the following
objectives:

° Identify questions and concerns to be discussed with the Project Officer and/or
Advisory Board representatives. If acceptable to the Project Officer and the
Board, it may also be useful to begin discussions at this time with the NIOSH
contractors who prepared the dose reconstructions.

. Identify the Case Managers and/or Task Managers and assemble the teams for
performing the work required by each case or task contained in the TORP.

° Prepare a schedule for completion and delivery of the technical and cost proposal.
Under the direction of the Project Manager, a comprehensive technical and cost
proposal will be prepared that meets the requirements of Section H.20 of the
solicitation and that will be delivered to the Project Officer within 14 calendar
days of receiving the TORP. The first step in the preparation of the technical and
cost proposals for both basic and advanced reviews is to inspect the input and
output of the IREP computer run for each case. Case Managers will then be
selected based on either their familiarity with the site or category of the site and/or
special technical issues associated with the exposures (e.g., the case is limited to

SC&A 3-3 Sol. No. 2003-N-00768


source records exist. For many sites, source records, such as old dosimeter readouts, microfiche
urinalysis results, and incident reports with estimated exposures can be located through deliberate
inquiry and onsite searching. In other instances, databases have been compiled in the past as part
of broader worker dose surveys, epidemiological studies, or summary radiation dose reporting. It
needs to be ascertained that all such databases have accessible identifiers. Some summary
teports, such as the Radiation Exposure Information Reporting System (REIRS), have originating
identifiers that are maintained by the project manager.

To determine the completeness of records available to the NIOSH worker profile, it may be
necessary to make inquiries of workers and records management personnel] at some sites. The
purpose of these inquiries is to identify the possible availability of records (with identifiers)
based on recollections of programs, incidents, or procedures where monitoring may have taken
place, and where corresponding records may have been maintained. In the early years, these are
often at the facility or operations level and may not have been compiled in formal radiation dose
records. SC&A will make inquiries to independently verify that the profile is complete from this
standpoint.

3.4.3 Characterization of Historic Radiation Protection and Dosimetric Practice:

Another issue is whether the appropriate caveats and limitations of the profile data are reflected.
Each site radiation dosimetry program had a unique history and technical evolution. Some sites
have conducted retrospective dose reconstructions to develop a reliable historic worker dose
database and have reflected the limitations and qualifications associated with the dose values
cited for individuals. Others have simply collected and reproduced available dose records
without any effort to acknowledge or compensate for the inadequacies or incompleteness of the
resulting database. Tritium and neutron doses were included and recorded for the first time at
varying times at different sites. Urinalysis policy and recording thresholds vary widely as a
function of radionuclide, operation, and site. Certain radiological source terms, such as trace
contaminants in process streams, were not measured routinely, and what exposure records exist
can be found in operational reports estimating doses to workers on a particular process line.
SC&A will review the historic status of site radiation records for selected worker profiles and
ascertain whether the dose information provided is consistent with them.

3.5. Reviewing Site Profiles

SC&A will review selected site profiles as determined first by NIOSH direction, and second by
relevant aspects of site profiles associated with cases undergoing advanced dose reconstruction
review (the latter will provide a two-for-one economy of work that will support both sampling
objectives).

The NIOSH site profile database is designed to support the conduct of individual dose
reconstructions by compiling data other ‘than dosimetric information, such as that related to
facility operations and processes over time, radiological source term characterization, chemical
and physical forms of the radionuclides, historic workplace conditions and practices, and
incidents and accidents involving potential exposures. SC&A will evaluate the quality and

SC&A 3-13 Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

! This conflict of interest plan will flow down to team members in their subcontracts.

SC&A 2-26 Sol. No. 2003-N-00768


and lungs. The breasts and esophagus have the same composition as the total body minus the
skeleton and lungs, with different densities.

The red bone marrow (RBM), a very important tissue to consider, is difficult to represent
mathematically due to the intricate mixture of RBM and bone in the skeleton. In this analysis,
the composition of the skeleton will be regarded as a homogeneous mixture of true bone and
marrow. The RBM will be assumed to absorb energy per gram as efficiently as the bone. The
dose to the RBM will be determined by taking the sum of the percentages of RBM found in the
different bones. These values are available in MIRD Pamphlet No. 5.

The source type, energy, and geometry (volume, planar, point, etc.) will be modeled from
available information. Conservative approximations will be assumed if information regarding the
source geometry is unavailable. The most conservative irradiation geometry (usually AP-PA
depending on source type and energy) as well as the most likely irradiation geometry will be used
for the calculations.

The organ doses will be calculated in the phantom using the energy deposition tally in MCNP4C.
Once all of the organ doses are known, the effective dose can also be calculated using the
appropriate ICRP tissue and radiation weighting factors.

3.7. Special Exposure Cohort Petition Reviews

The SEC is a specific group of employees defined by Congress in the Energy Employees
Occupational Illness Compensation Program Act (EEOICPA) who are eligible for compensation
under this Act. They are defined by the proposed rule 42 CFR 83 as follows:

. . employees of DOE, DOE contractors or subcontractors, or Atomic Weapons
Employers (AWEs) who worked an aggregate of at least 250 days before
February 1, 1992 at a gaseous diffusion plant in (1) Paducah, KY,

(2) Portsmouth, OH, or (3) Oak Ridge, TN and who were monitored using
dosimetry badges or worked in a job that had exposures comparable to a job that
is or was monitored using dosimetry badges; or (4) employees of DOE or DOE
contractors or subcontractors employed before January 1, 1974 on Amchitka
Island, AK and exposed to ionizing radiation in the performance of duty related to
the Long Shot, Milrow, or Cannikin underground nuclear tests.

If any of these employees had or has been diagnosed with one of 22 specified cancers, then they
or their survivors will receive a “lump sum payment of $150,000 and prospective medical
benefits” as compensation for illness which resulted from these radiation exposures. These
individuals are automatically eligible for compensation and do not have to undergo dose
reconstruction under 42 CFR 82 in order to determine PC of their cancers. Proposed rule 42 CFR
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:
Notice of Proposed Rulemaking,” describes the petition process that is being developed for the
addition of employees of other DOE facilities and AWEs to the SEC. Addition to the SEC

SCK&A 3-24 Sol. No. 2003-N-00768


Audit Interview Forms

Besides the specifics of the audit, discussed above, we will also review the interview forms for

adequacy as applicable to a particular case. Some gaps that may hinder complete elicitation of
potentially important information from workers could include the following:

. The NIOSH questionnaire does not address food in the work place. Workers
often ate in contaminated places and may have stored their food in contaminated

places.
. There is no question about handling of badges. This could affect badge readings.
. The questions about badges imply that a worker would have worn only one badge

(except to the extent that one question asks what part of the body the badge was
worn). At Fernald, some workers had wrist badges, and some workers may also
have worn ring badges.

° The reference to monitoring of “breath” is too vague to elicit data on breathing
zone air contamination measurements. Many workers wore these portable air
samplers. The interview form asks the question about monitoring “breath” in the
context of biological monitoring, such as occurs after an inhalation of
radionuclides. This may cause a worker to miss mentioning breathing zone
measurements, which are not biological measurements, as such. Breathing zone
data could be crucial in determining internal dose in some cases, especially where
biological monitoring documentation is missing, as may be the case for many
workers at FUSRAP facilities.

. The questions may not reveal the specific ways in which the particular worker
may have come into contact with radioactive material. As is clear from the
example of workers who stamped uranium ingots at Fernald (formally called the
Feed Materials Production Center during the period of production, 1951-1989)
noted above, it is necessary to go into the physical details of how a worker
processed radioactive materials or handled them in considerable depth.

. The only question about neutrons relates to neutron-generating facilities. This
omits neutrons from spontaneous fission of various isotopes, notably Pu-240, as,
for instance, in Pantex igloos.

Audit Form Review Checklist
In order to facilitate and standardize the documentation of our reviews, the forms presented in

Appendix C will be used, in part, to explicitly evaluate the thoroughness of the completed
NIOSH questionnaires.

SC&A 3-10 Sol. No. 2003-N-00768


SC&A will determine whether the NIOSH dose reconstruction contractor appropriately
identified, evaluated, and incorporated all relevant data sources by comparing the extent to which
such information is present in the profile with what can be identified via an independent review
of such sources of information. Data sources that will be scanned include the following:

. Department of Energy
- Field Offices
- Operating contractors
- Institutional histories
- Inspector General files
- Headquarters and field oversight reports
- Radiation exposure assessments
. Atomic Weapons Establishment
° Centers for Disease Control
Nuclear Regulatory Commission
Environmental Protection Agency
General Accounting Office
Defense Nuclear Facilities Safety Board
Congressional Hearing Records
State environmental and safety regulatory agencies
National Academy of Science
Administrative/court records
Department of Defense
. Environmental Measurements Laboratory (formerly the Health and Safety
Laboratory)
. Workers compensation records
. Worker and public advocacy groups
. Historic records in private hands

.

oe ee ewe

It is anticipated that a baseline of relevant information contained in these and other data sources
will be established at the onset, facilitating subsequent comparisons with site profile information.

3.5.4 Interviewing Sources of Site Knowledge

SC&A, as necessary, will conduct one-on-one or group interviews with selected sources,
including worker representatives, worker advocacy organizations, individuals with site
“expertise” due to past employment or familiarity with operational history, and others who can
verify the adequacy of site profile information that has been collected by the NIOSH contractor.
Interviews will be conducted where convenient for these groups, including near the actual site in
question. Lines of inquiry would include the following:

. How did actual radiation protection practice compare with documented policy and
procedures?
° Were there instances of obvious “missed dose,” e.g., not wearing or improperly

wearing dosimeters, non-recording of dose, etc.?

SC&A 3-16 Sol. No. 2003-N-00768


° While early health physics reports indicate that limited in-vitro bioassay
monitoring for transuranics was conducted, there are no urinalysis data in the
electronic databases prior to 1989.

. The historical urinalysis databases did not indicate the type of sampling (routine,
special, etc.) or the solubility class of material being monitored.

. The databases have not been verified against any of the original records.
. The databases have not had any quality assurance/quality control evaluations.
. The databases are not complete; for example, it was determined that at least some

elevated data from exposures as a result of incidents and accidents were not
included in the electronic database. The database may contain data-entry errors.

. Some of the units used in the database are not clearly documented.

. Not all department numbers found in the health physics reports could be
correlated with the department numbers recorded in the electronic databases.

The evaluation team in this case concluded that, “based on the above, the databases should not be
used at this time to estimate individual worker doses.”

As the NIOSH worker profiles will initially consist of many of these historic site electronic
databases, SC&A intends to do sufficient “sampling” quality verification checks to assure that
their reliability can support application to individual dose estimation. This will be accomplished
by identifying the original source data and comparing them with the submitted electronic or hard
copy data used in selected worker profiles. The degree and nature of potential “missing doses”
will be determined as a means to ascertain the representativeness and usability of profile data.
As dose reconstructions proceed over time and reconstructed individual doses are added to the
database, the representativeness of the database will steadily improve, aided by these quality
verification reviews.

3.4.2 Completeness of Records Incorporated

Each DOE site, if not facility, has a unique operational, radiological, and managerial history.
While DOE and its predecessor agencies (Manhattan Engineering District, Atomic Energy
Commission, Energy Research and Development Administration) issued directives governing
radiation protection standards, dosimetry and record keeping in the early decades (1940s~1980s)
were typically general and left to individual contractor interpretation and implementation. To
gauge the completeness of records reflected in the NIOSH worker profile, SC&A will verify the
“universe” of radiological data having identifiers for a particular facility or site, and compare that
data with what is entered in the selected profile.

For this review, it will be essential to identify what monitoring was conducted for different types
of radiation, for what worker categories and time periods, and in what form and condition the

SC&A 3-12 Sol. No. 2003-N-00768


depends primarily on the ability of NIOSH to perform a dose reconstruction under 42 CFR 82.
The EEOICPA states that a class of employees may be considered part of the Cohort if:

HHS determines that (1) it is not feasible to estimate with sufficient accuracy the
radiation dose that the class received; and (2) there is a reasonable likelihood
that such radiation dose may have endangered the health of members of the class.

Individuals or groups seeking to be added to the SEC must submit a petition to the DOL.
Categories of petitions are described in 42 CFR 83 as follows:

(1) Petitions from claimants in which NIOSH has already determined that a dose
reconstruction cannot be completed under 42 CFR 82. These petitioners only
need to cite this decision in their petitions, since NIOSH has already compiled an
administrative record for this class of employees. The petitioners are not
required to provide any additional information. These petitions are considered
the highest priority;

(2) Petitions from employees who have not submitted a claim for dose
reconstruction under 42 CFR 82. These petitions are considered the second
highest priority;

(3) Petitions from claimants who are currently waiting for results from dose
reconstruction under 42 CFR 82. These petitions are considered low priority.

The EEOICPA indicates that the Advisory Board will independently review a small sample of
petitions evaluated by NIOSH. These audits will allow the Board to oversee the work being done
by NIOSH. As prescribed by the proposed SEC rule and guided by the Board, the basis for a
worker to be considered a member of a class of workers for purposes of this sampling review
would include (but not be limited to):

Range of uncertainty in doses for the workers for which data are available. This
will include factors such as missing and faulty data, measurement uncertainties,
and incomplete data. For example, at Fernald, group doses have been calculated
with low uncertainty, but the same data indicate uncertainties that are very large
for individual workers. A review would include an evaluation of the statistical
procedures by which the best dose estimate is assigned to a worker who does not
have any or adequate data for a reliable dose reconstruction to be done.

How closely job descriptions fit the actual work done by workers. In some cases,
workers had particular job designations, but in practice performed other duties as
well.

Degree to which facility reviews show that the particular worker consistently
performed the work described for which relatively reliable dose reconstruction
cases are available.

SC&A

3-25 Sol. No. 2003-N-00768


records. The following describes our approach to basic and advanced claimant-interview
reviews, including the checklist in Appendix C that includes elements addressing the NIOSH
questionnaire. This will be used to evaluate the completeness of the NIOSH questionnaire and to
compare the information provided by the claimant or survivor during the interview with the other
information in the administrative record.

The audit of worker and family interviews will include (1) specific elements relating to the use of
each worker interview that is audited in the process of dose reconstruction, and (2) general
elements relating to the methodological aspects of the relationship of interviews to dose
reconstruction.

Specific Elements

The audit of every worker interview will be closely coordinated in each case with the various
elements of the overall audit of the dose reconstruction for that worker. Specifically, the audit
will involve:

. Determining whether the elements of the worker interview regarding frequency of
film badge changes, the components and frequency of various types of monitoring
of internal burdens of radionuclides, and the monitoring of the general air in the
work environment have been checked against the facility profiles for the period in
question and against the dose records of the worker.

. Checking how the discrepancies between the worker’s account, the dose records,
and facility profiles have been dealt with in regard to the estimation of the
uncertainties in the dose estimates from particular radionuclides.

Depending on the results of the dose reconstruction, highly specific “forensic health physics”
follow-up inquiries may be required. For instance, a worker job description might include sitting
astride uranium metal ingots to stamp serial numbers on them (as was the practice at Fernald).
The film badge doses could seriously underestimate external exposure to the gonads, and hence
the total effective dose equivalent (TEDE), and misrepresent the doses to specific organs of
interest. As another example, the time at which urine samples are taken may influence the
concentration of uranium in the urine. For instance, Monday morning urine samples taken after
coffee would tend to reduce reported concentrations relative to actual averages. In addition,
depending on the solubility of the compound, Monday morning urine or feces samples may also
result in an underestimate of doses. Such practices could distort dose estimates, especially if
samples were taken infrequently. Other important questions include: (1) Did the worker collect
24-hour excreta samples or just an aliquot? and (2) Was the worker under medication (diuretics,
for example, may affect the excreted activity and other drugs may affect the analytical processing
of the samples)? Worker interviews will be used as a way of checking on the completeness of
specific aspects of workers’ dose records and to help focus follow-up inquiries to find records
that may be missing or misplaced and which could be critical to the dose reconstruction and the
resulting PC calculations. The audit will include an evaluation of the adequacy of such efforts
deriving from worker interviews.

SC&A 3-7 Sol. No. 2003-N-00768


Exhibit 2-3. Conflict of Interest Certification (continued)

Additional Certification for Teaming Partners and Key Personnel

T understand that my participation on this contract means that I will not be permitted to bid or perform
any work for NIOSH, ORAU, or any of ORAU's primary teaming partners while performing work under
this contract.

Individual Name or Company Name

Signature

Date

SC&A 2-31 Sol. No. 2003-N-00768


In the cases in which a worker handled, in the same monitoring period, two or more
radionuclides that emit both high and low photon energies, the evaluation of the external photon
dose using photographic dosimetry becomes more difficult. For early dosimetric systems, it is
possible that only the high energy or only the low energy component of the dose was reported.
Again, if the calibration, evaluation, and dose reporting procedures are available, the uncertainty
in the dose estimates may be assessed. With the advent of LiF TLD monitoring systems, this
problem no longer exists due to the lower energy dependence of LiF.

To evaluate the organ dose, it is necessary to discriminate the energy spectrum of the photon field
into the three‘energy bands established in OCAS-IG-001. The evaluation of dose through film
dosimetry or TLDs normally requires the previous evaluation of the average energy of the photon
field that is being measured. This energy is, however, not always reported together with the
dose. In these cases, it is necessary to determine the radionuclide or radionuclides the worker
handled over the monitoring period to determine the relevant energy spectrum. The
determination of the relative distribution using the site relative inventory or the review of
historical operations is recommended in item 2.1.1.2 of OCAS-IG-001.

As for the neutron dose (item 2.2, OCAS-IG-001), even today, neutron dosimetry is subject to
large uncertainties. The main problem is that film and TLD neutron dosimeters have a large
energy dependence, together with the fact that the energy range of neutron fields is huge (a few
eVs to many MeVs—around seven orders of magnitude). The dosimeter may be typically
calibrated for one energy spectrum, and to the others a “calibration factor” was applied. Even
today, an uncertainty of + 100% and - 50% for any neutron dose, would be considered an
“acceptable result.” All procedures recommended in item 2.2 of OCAS-IG-001 will be followed.
The OCAS-IG-001 document defines five energy ranges for neutron fields. The establishment of
the neutron field energy spectrum is therefore important for the calculation of the organ dose.

All data available will be carefully analyzed. All sources of complementary data will be used, for
example, neutron energy spectrum studies made at a number of work places using Bonner
Spheres and published in the literature. These studies might even be applied to early dates if
conditions remained the same. Another example is the use of the ratio of neutron to gamma dose
in workplace situations for which it has been well-established.’ Also, when TLD techniques were
used'to determine the neutron dose, the photon dose was also evaluated and should have been
recorded. In these cases, the ratio can serve as an estimate of the missing neutron dose for cases
when the neutron source geometry and the laboratory moderation are relatively unchanged and
where only the photon dose was evaluated and recorded.

For electron dose reconstruction using film dosimeter records (item 2.3.1, OCAS-IG-001), it is
important to determine whether the worker was also exposed to low energy (15 - 25 keV) photon
fields, as these can leave an image similar to an electron irradiation on film dosimeters.

Although the calibration process and energy dependence of the film emulsion lead to
uncertainties in the electron dose evaluation process, the main source of uncertainty is due to the
short range of electrons in air and clothing and the irradiation geometry. For example, consider a
worker doing decontamination work and directly handling a source of beta-gamma radiation.

The electron dose registered on the thorax dosimeter would be quite low, and the electron dose to
the skin of the thorax could be considered zero due to the shielding of the worker's clothing.
However, the electron dose to the hands would be much greater, and, unless reliable extremity

SC&A 3-22 Sol. No. 2003-N-00768


(AMAD or absorption parameters) and choice between default and specific values (items 4.3 and
4.4, OCAS-IG-02). Radioactive progeny that grow in after an intake of a parent radionuclide are
treated as recommended by the ICRP. Generally, it is assumed that the biokinetic behavior of the
decay products is the same as that of the parent nuclide. However, in the biokinetic models for
tellurium, lead, radium, thorium and uranium, separate systemic biokinetics are applied to the
parent and its decay products, as specified in ICRP 71. An input for the intake of progeny is
available, in an optional basis, with chosen equilibrium factors (item 4.2.3, OCAS-IG-02). This
feature is very important when decay products are used to assess intakes of the parent.

The software calculates excretion rates and accumulation of radioactive material per unit intake
in all organs described in ICRP current models for single intakes, chronic intakes, and exposures
during a certain period of time. Thus, it is possible for all those scenarios to produce annual
doses, committed doses until date of diagnosis of cancer or throughout the individual's entire
employment, for all organs and tissues described by ICRP models as specified in OCAS-IG-02,
as well as 50-year committed doses. In addition to calculating organ doses for the most probable
intake scenarios, results from all those scenarios may be easily and rapidly compared, as required
in items 6.1 and 6.2 of OCAS-IG-02.

When detailed dose reconstruction is required, a special feature, workers’ chronic intakes (x days
a week, y hours per day, and w days of vacation—for example, 5 days per week, 8 hours per day
exposure, 2 days weekend and 20 days vacation) may be used. The workers’ pattern of exposure
takes into account the smaller activity excreted after a weekend or after a non-working period,
typical of certain compounds. In some cases, as for example '*'J, the urinary excretion functions
diminish by orders of magnitude within a few days, and therefore the choice of the time pattern
of intake can influence the assessed dose by that same order of magnitude.

The information on the working history is very important. For long-lived nuclides, the amount

present in the body and the amount excreted depends on the time the individual has been

exposed. Following a chronic intake of 1 Bq per day of type S ?”Th, 5 days a week, its

concentration in the lungs after 20 years of work is expected to increase by a factor of 4.4 in

relation to the concentration after one year of work, for both AMAD 5 micron and 1 micron. On

the other hand, the concentration excreted in the feces is supposed to be constant throughout that
- time period.

The software accepts the input of a series of data points from bioassay results collected at
different times after intake and determines the best estimate of an intake using a least squares fit,
maximum likelihood fit, or Bayesian approach. Thus, multiple data points may be used to
estimate the actual intake, as specified in item 5.1 of OCAS-IG-02. The software will also
determine the best estimate of an intake from information on different monitoring techniques,
e.g. urine, fecal, and in vivo monitoring. The simultaneous use of multiple data from different
monitoring techniques may be used as a tool to infer the route(s) of intake and the date(s) of
intake and in refining preliminary estimates of intake (items 4.1.2 , 5.1 and 6.5 of OCAS-IG-02).

If bioassay data are not adequate to evaluate the individual's internal dose, workplace monitoring
data will be used, if available, as specified in item 5.2 of OCAS-IG-02. All recommendations in
item 5.2 will be followed to determine the concentration of the radionuclide in the breathing zone

SC&A 3-19 Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

SC&A 2-28 Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

SC&A 2-27 Sol. No. 2003-N-00768


General Elements

When a sufficient number of worker interviews and records have been audited for specific
facilities or processes (such as uranium chemical processing or machining, plutonium processing
or machining, etc.), a check will be made about whether and how the worker interview data have
been used in conjunction with facility profiles. Consistent worker testimony about the frequency
of badge use or internal monitoring, for instance, could lead to discovery of gaps in facility
documentation. Hence, worker interview data can be pooled to provide insight into the quality of
and uncertainties in dose estimates for specific facilities or processes. The audit will examine
whether the worker interview data have been used to the extent possible to improve the quality of
dose estimates for groups of people who worked in specific processes or places.

When the audits of worker interviews and dose records from a sufficient number of different
facilities and processes are complete, worker interviews can then be used to determine the
adequacy of dose records across the nuclear weapons complex as a whole for specific time
periods and processes.

This pooling of worker interview and dose data will allow an analysis of possible patterns in the
discrepancies between worker accounts and dose data at specific facilities and over the entire
complex. The dose reconstruction methodology will be audited to determine whether the worker
interview and records have adequately taken these patterns into account in order to improve dose
estimates, and possibly to develop correction factors to dose estimates, in case they are
warranted.

Examples of Importance of the Interview Process

Example 1. Thorium-232 Processing

Thorium was processed at a number of facilities, such as the Simonds Saw & Steel Co.,
Lockport, NY (a FUSRAP site) and at the Femald plant. The following quote from the study
performed for USA Today about this (and two other sites) is illustrative of the importance of the
interviews. This quote is about Simonds Saw & Steel:

Thorium processing operations may have taken as little as one week and possibly
much longer”! Based on available data, it is not possible for us to estimate the
total number of full time equivalent days for which the thorium milling operation
was conducted. We have therefore calculated thorium doses corresponding to

? The study was unable to make a reasonable estimate of the number of days for which thorium was
processed. Hence, there is a corresponding uncertainty concerning worker exposures to thorium. The lowest
estimate of working time was one week of full time work for thorium processing based on a comparison with
uranium processing rates. The thorium throughput per hour would be about 40 percent of the uranium throughput
per hour due to the difference in mill sizes (10 inches versus 16 inches, yielding a cross-sectional area ratio of about
40 percent). A June 8, 1953, document indicates that thorium processing rates may have been somewhere between
roughly 1,000 pounds and 4,000 pounds per day, assuming that all work indicated in a month’s period was done in a
single full working day. On this basis, the total thorium processing time can be estimated to be between 10 and 40
working days—that is, 2 to 8 weeks. [Survey of Accounting Control over Source and Fissionable Material, Simonds
Saw and Steel Company, Lockport, New York, with cover letter dated June 8, 1954.]

SC&A 3-8 Sol. No. 2003-N-00768


Exhibit 2-3. Conflict of Interest Certification

TEAM MEMBER AND INDIVIDUAL CONFLICT OF INTEREST CERTIFICATION
CONTRACT RESULTING FROM CDC SOLICITATION NUMBER 2003-N-00768

SC&A 2-30 Sol. No. 2003-N-00768


completeness of this information to ascertain the adequacy of the information contained in the
NIOSH site profiles.

SC&A will identify and evaluate the approach taken in compiling the site profiles through a
‘comprehensive process of (1) independently identifying the selected site’s operational history,
(2) conducting an “exposure mapping” exercise to identify historic work processes and worker
categories, (3) reviewing all relevant data sources, such as occurrence reports, inspection
documentation, safety analyses, etc., and (4) interviewing worker representatives, worker
advocacy groups, and other individuals having knowledge or expertise on site operational or
radiological history.

3.5.1 Reviewing Site Operational History

For many DOE and AWE sites, reliable dosimetry records may be lacking, particularly for
workers from the 1940s through 1960s. In these instances, historic operational information that
includes the nature of operations, radiological source terms in use, process material
concentrations, and location and time periods of worker activities may be the only data available
for dose estimations. Such information can be extracted from historic records and documentation
being collected by (or accessible from) DOE, including operational records, material inventories,
safety and health inspections and assessments, occurrence reports, and routine memoranda and
facility reports. This possible source of information will be surveyed at the DOE site or AWE
records collection point to ascertain whether the site profiles adequately reflect at least the
following information, where feasible:

. Operational processes over time, including improvements, upgrades,
modifications and terminations (important because worker exposures are often
higher during major process changes).

. Historic radiological inventory, source terms, and movement through facility
(“mass balance”) to include feed material, products, and byproduct and waste
streams.

. Any unplanned events, including radiological over-exposures, contaminations,

releases, spills, criticality incidents, and unusual occurrences.

. Changes in contractor management and attendant changes in safety policies,
procedures, and practices (important because new contractors import new
radiation protection programs).

. Applicable standard operating procedures, memoranda, directives or recorded
practices governing onsite management of radioactive materials and processes.

. Actual historic operational practices established by first hand accounts (e.g.,
worker representatives, site “experts,” etc.) (important because actual facility
practices often varied from official procedures).

SC&A 3-14 Sol. No. 2003-N-00768


SC&A 2-22 Sol. No. 2003-N-00768


3.0 TECHNICAL APPROACH'*

This section describes our technical approach to performing basic and advanced case reviews,
blind dose reconstructions, and Special Exposure Cohort (SEC) petition reviews. In addition,
our approaches to performing reviews of worker-profile and site-profile databases, independent
of the review of specific cases, and ad hoc reports are also described. Imbedded in the
discussions are anticipated major problem areas, together with recommended approaches for
their resolution. The section concludes with “Special Topics,” which highlights those issues and
technical strategies that we believe are worth noting, especially with regard to internal dosimetry.

3.1 Concept of Operations

SC&A is proposing a highly structured, transparent, and well-documented approach to reviewing
dose reconstructions and SEC petitions. Exhibit 3-1 presents our understanding of the
interrelationships between the various tasks that comprise the review of dose reconstructions.
Our technical approach to the project assumes that, whether the Task Order Request Package
(TORP) requires a basic or advanced review, or a blind dose reconstruction, the administrative
record and other pertinent technical material, in hard copy and/or electronic form, will
accompany the TORP. These records, and any other information provided by NIOSH or
uncovered as a result of our investigations, will be loaded into our relational database, which will
be designed to be compatible and consistent with the relational database being employed by
NIOSH.

In brief, for Basic Reviews, the focus of attention will be on the relevant portions of the
administrative record and ensuring the completeness and internal consistency of the dose
reconstruction, interview record, and, to the extent applicable to the basic review, NIOSH worker
and site profiles. Primary attention will be given to the appropriateness of any assumptions that
were used in the determination of dose as well as the completeness and internal consistency of
the NIOSH dose reconstruction with Office of Compensation Analysis and Support (OCAS)
guidelines in support of the dose reconstruction and the adjudicated decision. :

Advanced Reviews will evaluate the entire administrative record and review pertinent worker and
site profiles, seek out primary records (original log books, work permits, strip chart recorders,
etc.), co-worker records, and supplemental information obtained from the claimant and co-
workers (if authorized by the Board) as required to verify the dose reconstruction in those areas
that could have a significant impact on the dose estimates and adjudicated decision. In order to
perform advanced reviews in a manageable time period, advanced reviews will be limited to
those exposure settings and occurrences that have the potential to significantly influence the
ability to reconstruct doses and the resulting adjudicated decision. Nevertheless, during the

1 This section, which describes our technical approach to the project, and Volumes 2 and 3 of the proposal
which describe our technical approach to the two example tasks, cover many of the same points. We tried to avoid
repetition. As such, we request that the committee reviewing our technical approach to this project consider Section
3.0 of Volume I of the proposal, as well as Volumes 2 and 3 in their entirety. Taken together, this information will
offer the review panel a solid understanding of how we would approach tasks issued under this contract.

SC&A 3-1 Sol. No. 2003-N-00768


2.7 Confidentiality and Security Provisions

SC&A fully understands the importance of protecting personal, proprietary, and other sensitive
information to which we may have access under this contract. We have reviewed the provisions
contained in HHSAR 352.224-70, Confidentiality of Information; FAR 52.224-1, Privacy Act
Notification; 52.224-2, Privacy Act; and 52.239-1, Privacy or Security Safeguards, and are
prepared to comply fully with all the requirements contained in these clauses.

Privacy Act

We will ensure that all individuals working on this contract with access to data protected by the
Privacy Act are aware of the restriction on disclosure of records maintained on individuals and
the conditions that must be met in order for disclosure to be permissible under the Privacy Act,
Section 552a(b)(1)-(12). In addition, upon contract award, SC&A will establish procedures and
policies with respect to (1) accounting for certain disclosures, (2) access to records, (3) relevant
agency requirements, and (4) relevant agency rules.

Confidentiality of Information

In addition to the requirements of the Privacy Act, we understand that we will be subject to
compliance with the provisions of HHSAR 352.224-70. We will obtain written consent from any
individual, institution, or organization prior to disclosing confidential/proprietary information or
data about that individual, institution, or organization. We will also provide the Contracting
Officer with written advance notice of at least 45 days in the event that we intend to release
findings of studies or research which have the possibility of adverse effects on the Agency.
Finally, if we are unsure of the proper handling of material or information under this contract, or
if the material in question is subject to the Privacy Act or is confidential information under
HHSAR 352.224-70, we will obtain a written determination from the Contracting Officer prior to
releasing, disclosing, disseminating, or publishing such information or material.

Security Safeguards

In the event that we develop or implement safeguards under this contract, we will not publish or
disclose these safeguards without the prior written consent of the Contracting Officer. We agree
to cooperate with the Government should it be necessary to carry out a program of inspection to
safeguard against threats and hazards to the security, integrity, and confidentiality of Government
data, and in this instance will provide the Government access to our facilities, installations,
technical capabilities, operations, documentation, records, and databases. We understand that
under this contract, should it become evident to either the Government or SC&A that existing
safeguards have ceased to function, it will be the obligation of the discovering party to bring the
situation to the attention of the other party.

All of our obligations under this section will flow down to our subcontractors at any tier.

SC&A 2-32 Sol. No. 2003-N-00768


radionuclides, graphs of doses as a function of lung absorption Type and AMAD reveal “areas of
invariance,” i.e., time periods where the assessment of dose is relatively insensitive to
assumptions made about lung absorption Types and AMAD. Thus, in dose reconstruction
analysis, when AMAD and/or lung absorption Types are not known or are poorly defined, the use
of monitoring data, if available, in the period of time corresponding to the invariance area, can
minimize parameter uncertainties.

Those graphs are also useful for assigning a weight to multiple bioassay results, e.g., using the
criteria of weighting data according to sensitivity in relation to dose calculations. The weight to
multiple bioassay result will also depend on the specific organ for which dose is calculated, e.g.,
urine is best correlated to systemic organs. These correlations are also well visualized in the
mentioned graphs.

The graphs may be used for defining the uncertainties related to an unknown or poorly defined
model parameter. The graphs of dose per unit measured activity also provide a tool to rapidly
compare doses derived from the same data set of bioassay results, using different assumptions.
Thus, the choice of the hypothesis that leads to the greatest dose is easily visualized and
determined.

3.6.3 Basic Approach to External Dose Reconstruction Reviews

For external dose radiation exposure, OCAS-IG-001 provides guidance on the methods of dose
reconstruction. The procedures for blind reviews will be exactly the ones specified in OCAS-IG-
001. As specified in this document, the three groups of workers who require dose reconstruction
are: workers who were not monitored, workers who were monitored inadequately, and workers
whose monitoring records are incomplete or missing.

Among the workers that were monitored inadequately, special technical attention will be given to
the results from individual monitoring done in early times, when the sensitivity and accuracy of
the dosimeters were inadequate as compared to modem standards (items 1.1.3, 2.2.1 and
2.3.1,0CAS-IG-001). We anticipate considerable uncertainties in the evaluation of low energy
photon dose, mixed photon field evaluation, electron dosimetry and neutron dosimetry.

For the Dosimeter Photon Dose (item 2.1.1.2), the evaluation of external photon doses using film
dosimetry is straightforward for photon energies above 250 keV. In this region, the energy
dependence of the film emulsion is quite low. It was, and still is, usual to perform the calibration
of the dosimetric system using only a high-energy source of photons (above 250 keV). Unless
the dosimetric system was characterized and calibrated for low energy photons, the evaluation of
external dose due to exposure to, for example, the plutonium isotopes, will be compromised.
The review of the individual monitoring reported doses for plutonium workers will include,
where possible, an evaluation of the calibration, evaluation, and dose reporting procedures. For
example, if the dose due to 17 keV photons was evaluated using the net optical density under the
lead filter, and not through the “open window dose” the lower limit of detection will be much
higher than 30 millirem (mrem), and probably closer to 500 mrem. This would increase the
“missing dose” for these cases.

SC&A 3-21 Sol. No. 2003-N-00768


and to estimate the workers’ intake. If physical-chemical characteristics of the aerosol are not
known, ICRP default parameters will be used. Organ doses will be calculated using ICRP CD-
ROM, The ICRP Database of Dose Coefficients: Workers and Members of the Public, Version
2.01, Elsevier Science Ltd., 1998.

The same applies to the estimation of doses using information on the source term, as specified in
item 5.3 of OCAS-IG-02. The software used for calculating organ doses from bioassay
measurement may also be used for calculating organ doses from calculated intakes. It will be
used to calculate doses when the use of specific absorption factors from lungs to blood is
necessary (item 4.3 of OCAS-IG-02).

The software is thus a very efficient tool to perform blind reviews of internal doses in accordance
with OCAS-IG-02. All guidelines contained in the document will be followed: the ICRP
models; the collection of data for the individual case; the calculation of the dose to the organ or
tissue of interest, including the correlation of ICD-9 Codes to ICRP Models; the collection of
work area data; the collection of the individual dosimetry data; the preliminary dose estimates
and the detailed dose estimates that include the estimate of the date of intake; the estimation of
the uncertainty in the internal dose calculation; the treatment of missed doses; and the estimation
of radon and progeny doses. All information given in the examples for item 8.0 will be used.

3.6.2 Dose Per Unit Measured Activity in the Body or in the Excreta:_A Tool to Minimize
Uncertainties

When multiple data points from bioassay monitoring collected at different times after intake or
resulting from different bioassay monitoring methods are used to estimate the dose, the fitting
procedure chosen for the analysis is very important. In a recent intercomparison among the most
recently developed software that utilizes the most current ICRP models, a discrepancy was noted
related to the different methods of fitting to calculate the best estimate of the intake and dose.
The second reason for the discrepancy was due to the level of expertise and the choice made by
the user on “reasonable” assumptions such as particle sizes; choice of solubility types as
exemplified in item 4.3 of OCAS-IG-02; treatment of rogue data, as exemplified in item 5.1 of
OCAS-IG-02; weight given to some bioassay results or to a particular bioassay method; etc.
[Review of Methods and Computer Codes for Bioassay Data Interpretation,” E.Ansoborlo,
P.Bérard, M. Bailey, V. Berkovski, A. Birchall, F. Fry, R. Guilmette, G. Miller, N. Ishigure,

J. Lipsztein, and D.Nosske, presented at the Workshop on Intakes of Radionuclides, Oxford, UK,
2002, which will be published in 2003 in “Radiation Protection Dosimetry.”] Thus, we should
not be surprised if we find different dose estimates from the same data, unless very specific
instructions are given in the Task Order. Alternatively, these issues could be addressed as part of
the uncertainty analysis in the reconstructed doses.

Tabulations and graphs of dose per unit-measured activity (in the body or in excreta) at specified
times after intake will be used. The variable dose per unit measured bioassay quantity is
obtained using the most recent published ICRP dosimetric and metabolic models. Those
tabulations and graphs are very helpful in determination of the best estimate of a dose (organ
dose or effective dose) from results collected at different times, or from different monitoring
techniques, e.g., urine, fecal, and direct measurements data. For example, for some

SC&A 3-20 Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

SC&A

2-29 Sol. No. 2003-N-00768


3.4 Procedures for Worker Profile Reviews

SC&A will review selected worker profiles from NIOSH’s database to ascertain the quality and
completeness of that database to support individual dose reconstruction. These reviews can be
performed as part of the review of a given case, or as a stand-alone Task Order requested by the
Advisory Board and authorized by the Project Officer. To accomplish these twin objectives,
SC&A will address the following questions: (1) Are the data of sufficient quality and reliability
to be used as a means to estimate dose when individual dose records are inadequate or not
complete? (2) Have all relevant dose records with personal identifiers, such as plant records,
monitoring data, memorandums, electronic databases, and accident and occurrence reports, been
included? (3) Has there been sufficient characterization of historic radiation protection programs
in place, including personnel monitoring requirements, protective equipment practices,
dosimetric techniques and equipment in use, and procedural enforcement history?

3.4.1 Quality and Reliability of the Database

The quality and reliability of the database will be a function of the number of data points
available for a particular job category, the facility process location or time period, and the
consistency of the data entered in comparison with the original source information. As the
worker profiles are populated with data from DOE sites, some searchable fields will contain
more data than others, as will some facilities, and locations and time periods within facilities.
“Missing data” will be apparent for certain operations and time periods due to any one of the
following reasons:

. Lack of personnel monitoring data (dosimeter not assigned or not processed)
. Inadequate monitoring techniques
. Errors in transcribing dosimetry readings to official reports, historic dosimetry

practices that ignored certain exposure sources (e.g., radon, low-energy photon,
neutron), etc.

One important issue is the quality and reliability of electronic dose-record databases submitted by
DOE for a site or facility. Unless these submitted databases have been verified from a quality
assurance standpoint against the original source records at the site, they cannot be considered
fully reliable. In its September 2000 Exposure Assessment report for the Paducah Gaseous
Diffusion Plant, a review team consisting of DOE, University of Utah, and the Paper, Allied
Industrial, Chemical and Energy Workers (PACE) International Union found a number of
instances where the data on the “official” Paducah electronic historic worker dose database did
not encompass all dosimetry records over the history of the plant.

At Paducah, the aforementioned exposure assessment found that the following limitations existed
for personal external radiation exposure measurements, uranium urinalyses, and whole-body
counting in the electronic database.

SC&A 3-11 Sol. No. 2003-N-00768


. Were there any incidents involving potential radiation exposure, whether reported
or unreported?

. Were there special work activities or facility modifications which constituted
process changes that increased radiation exposure potential?

. Were workers concerned about past exposure or radiation protection practices?
How did management respond and what, if any, changes occurred in onsite
practice?

. Did workers wear protective equipment, as required?

° Were radiological jobs planned for exposure minimization (e.g., ALARA)?

. What was the general housekeeping in the facility; was radiological contamination

common during the history of the facility?

. Were there special feed materials introduced or contaminants of concern
identified from which radiation exposures may have resulted?

. Were there certain work activities at the facility that were considered “hotter” jobs
from the standpoint of potential radiation exposure?

. Were safety procedures followed literally and did management assure that they
were enforced uniformly?

° In terms of conduct of operation, were workers permitted to smoke, eat, or drink
in control areas? Was protective clothing and equipment worn in these areas; was
egress monitoring conducted?

. Were negative or “zero” doses recorded on periodic dosimetric records despite
known exposure to significant radiation sources?

. Were records and other documentation of radiation exposure discarded or retained
by management?
. Were there cases of over-exposed film and how were they treated?

The information extracted from these interviews will be used to ascertain the completeness and
representation of that in the NIOSH site profiles.

3.6 Blind Dose Reconstruction
A great deal of information, procedures, and guidelines are provided throughout this proposal

that demonstrate how we will go about performing basic and advanced reviews, worker profile
reviews, and site profile reviews. Given this as background, suffice it to say that our procedures

SC&A 3-17 Sol. No. 2003-N-00768


2.6.2 Conflict of Interest Plan

We have chosen to modify SC&A’s current OCI plan to reflect the provisions of this proposed
work. Exhibit 2-2 presents this draft plan. In addition, Exhibit 2-3 presents the Conflict of
Interest Certification that SC&A required each potential team member to sign prior to developing
this proposal. Actual signed copies of this certification for each team member proposed are
included in Appendix B.

Exhibit 2-2. SC&A Organizational Conflict of Interest Plan

PROPOSED ORGANIZATIONAL CONFLICT OF INTEREST PLAN FOR
CONTRACT RESULTING FROM CDC SOLICITATION NUMBER 2003-N-00768

SC&A 2-25 Sol. No. 2003-N-00768


reviewing the dose reconstruction of a person who experienced internal exposures
to inhaled plutonium and the associated bioassay data). The administrative
records provided with the cases will be used to define the qualifications of the
Case Managers and technical specialists who will be assigned to each case.

For basic reviews, it may only be necessary to assign a single individual to perform the review.
However, for advanced reviews and blind dose reconstructions, a minimum of three individuals
will be assigned to each case. As required by the TORP, these individuals will have the
following assigned functions: Dose Reconstruction Reviewer (perhaps separated into internal
and external doses), Worker Profile Reviewer, Interview Records Reviewer, and Site Profile
Reviewer. One of these individuals will also be the designated Case Manager. We recognize
that some of the basic reviews will not require access to the NIOSH worker profile or site profile
database; however, we will be prepared to review these sources of information as required to
complete the basic or advanced reviews, or blind dose reconstructions. The individuals assigned
to each case can draw upon any of the other specialists on the project team, The teams will be
assembled using the following criteria:

. Familiarity with the site

. Familiarity with the health physics issues at the site
. Ongoing case commitments
. Consistency of team makeup

In general, for basic reviews, the Case Manager will likely be a health physicist with specialized
expertise in the primary types of exposure of concer (e.g., external exposure versus inhalation of
plutonium) and the associated dosimetric records. For advanced reviews, the Case Manager
could be an appropriately qualified health physicist or an individual with in-depth experience
with the site or types of operations responsible for the exposures.

3.3. Procedures for Performing Basic and Advanced Reviews

Following approval of the technical and cost proposal, the Government will issue a Task Order
and work will commence. For basic and advanced reviews, the individuals comprising each of
the teams assigned to each case will review the IREP input and results to determine technical
areas of emphasis (e.g., acute versus chronic exposures, external gamma or neutron exposures,
internal exposures and radionuclides of concern, etc.) that are the primary drivers for the outcome
of the IREP calculations. Based on this initial review, additional specialty resources (see

Section 2-1, the charts and biosketches in Section 4, and the resumes in Appendix A) will be
drawn upon as needed to perform the review. The review of each case will then commence
under the direction of its assigned Case Manager.

Each case will be reviewed by the team assigned to the case, and, depending on the complexity of
the case, review responsibilities may be divided into internal and external dose reconstruction
reviews (which will include a review of the claimant interview record). In addition, for some
basic reviews and all advanced reviews, the review process will also include worker and site
profile reviews, as required by the technical proposal and Task Order. If several cases are from
the same site, there may be efficiencies we can incorporate into the process by assigning a single

SC&A 34 Sol. No. 2003-N-00768


3.3.1 External and Internal Dosimetry Review Procedure and Checklists

The basic and advanced individual dose reconstruction review processes will each utilize a
checklist for conducting the technical reviews. The checklists are provided in Appendix C. The
checklists are designed to satisfy the basic level and additional advanced level review elements
specified by the NIOSH Advisory Board Dose Reconstruction Working Group. The checklists
allow the basic/advanced review process to be conducted in a systematic, consistent, efficient,
and transparent manner. They will also serve as a means of tracking and formally documenting
the individual steps of the audit process. When the audit is completed, the information collected
in the checklist will be entered into a database in a format that is compatible with Microsoft SQL
2000. All records/documents collected and used in the audit process that were not included in
the case file will be duplicated and provided to NIOSH.

The basic individual dose reconstruction checklist is structured to evaluate the following five
areas of review: (1) data collection process, (2) interview/claimant documentation, (3) external
dose reconstruction process, (4) internal dose reconstruction process, and (5) applicable portions
of NIOSH procedures and methodologies associated with the reconstruction of dose for each
individual case . When an advanced dose reconstruction audit is requested, a second checklist
will be completed, which incorporates elements that will provide for a more extensive review of
the data gathering, work-history interview, and external/internal dose reconstruction processes.
These checklists are designed to take into account all requirements established in the U.S. Code
of Federal Regulations (CFR) Title 42, Part 82, and follow guidelines provided in the External
and Internal Dose Reconstruction Implementation Guidelines (OCAS-IG-001 and OCAS-IG-002,
respectively), as well as other relevant technical documents. However, it is recognized that, due
to the variety of conditions associated with each individual’s exposure scenario, these checklists
may not be all inclusive. The intent of the checklists is to provide the auditor with a roadmap to
evaluate the dose reconstruction process in a stepwise, thorough, and reasonable manner.

3.3.2 Claimant Interview Review Procedure and Checklist

The claimants, their family members, and co-workers play a key role in the dose reconstruction
procéss, especially for the advanced reviews. In general, basic reviews will be limited to a
review of the completed questionnaire and the degree to which that information was
appropriately incorporated into the dose reconstruction. Advanced reviews will go beyond a
simple checking of the questionnaires. Work history interviews will be assessed for their
effectiveness and, in the cases involving survivors, will evaluate whether a reasonable effort was
made to follow up on information provided by the claimant (i.e., contacting co-workers and
tracking down historical records). Advanced reviews may also include approved follow-up
interviews.

For each claim, NIOSH will conduct a voluntary interview with the claimants or their survivors
which will allow them to collect detailed information concerning the claimant’s employment
history, work environment, and radiation monitoring history. All of this information, which will
be contained in the structured interview forms used by NIOSH, should be considered by NIOSH
when performing the dose reconstruction, and should be consistent with the information gathered
by NIOSH fromthe DOE/Atomic Weapons Employer (AWE) personnel and site-monitoring

SC&A 3-6 Sol. No. 2003-N-00768


SC&A

2-24

Sol. No. 2003-N-00768


. Historic radiation protection programs in place, including personnel monitoring
requirements, protective equipment practices, dosimetric techniques and
equipment in use, and procedural enforcement history (important to determine
whether and to what degree the dosimetry program reflected actual potential
exposures possible, given source terms involved).

. Worker rosters with identifiers, work assignments and location, as well as
summary of work histories sufficient to determine what categories of workers
were assigned to what type and locations of radiological work.

It would be useful to have data on the number of monitored workers, number of workers with
doses higher than the minimum detectable levels, average measurable recorded doses, minimum
detection levels, and whether doses below the detection limit were recorded as zero. Even better
would be to have data on the number of workers in specified dose ranges.

The foregoing information will be used in a comparative manner to ascertain whether the site
profiles are complete in how they characterize, from a historic standpoint at a particular site,
what radiological materials were present and in what concentrations and chemical forms; what
worker groups may have been in proximity with sources of exposure and whether certain
activities or unplanned events may have made such exposure likely; and what administrative
procedures, operational practices, protective equipment use, and facility conditions may have
influenced the likelihood of such exposure. The quality of the profile will be evaluated by what
can be termed “exposure mapping.”

>

3.5.2 Conducting “Exposure Mapping’

Exposure mapping will be used to evaluate the extent to which the profile provides information
that can characterize the potential radiation exposure to which workers may have been exposed
in specific work activities and locations or time periods at the site in question. Sources of
information include published site reports, memoranda, area monitoring data, process
descriptions, and general worker exposure summary information. Higher activity radiological
sources in the facility’s process streams will be linked to those worker categories and locations
where potential exposure levels were highest.

An example of the types of published information that can provide historical site information that
can be very helpful in preparing and reviewing site profiles is “Exposure Assessment Project at
the Paducah Gaseous Diffusion Plant,” prepared by PACE and the University of Utah on behalf
of the DOE Office of Environment, Safety, and Health (September 2000). Table 7-3 from that
report is one example of the outcome of an historical exposure mapping for the Paducah Gaseous
Diffusion Plant. This type of information can be compiled for virtually any site, and can be
extremely valuable in a blind dose reconstruction and in an advanced review of a NIOSH dose
reconstruction.

3.5.3 Reviewing Relevant Data Sources

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dosimetry was provided, a better estimate of the electron dose may be obtained through source
term investigations.

For the Photon Dose Reconstruction from a Source Term (item 3.1.3, OCAS-IG-001), it is
advisable to use a computer program, as specified in item 3.1.3.2, OCAS-IG-001. We will use
NIOSH recommended software. If the Task Order does not specify particular software, we will
use a program that uses a voxel phantom to simulate the human body and the Monte Carlo
technique to provide the organ doses for external photon fields in the energy range of 15 keV -2
MeV. The program simulates the source of the radiation, which can be of a complex geometry,
and the shielding, which can include many layers of different material. Using the Monte Carlo
technique, self-shielding and build-up are taken into account. The use of voxel phantoms is the
most modern accepted technique for the simulation of the whole body and is derived from whole
body magnetic resonance image (MRI) scan. The program reports the absorbed dose to each
organ and tissue relevant to the calculation of the effective dose as defined in ICRP 60. Ground
sources or cloud sources may be simulated. The phantom may be placed in a standing, sitting,
lying, or other geometry in relation to the source. Although the program sitnulates multi-energy
photon emission and integrates the dose in each relevant tissue over all energies, it can also be
used to determine the Hp(10) dose and the photon energy spectrum arriving at the voxel
phantom, and therefore permit the application of the Dose Conversion Factors tabled in
Appendix B of OCAS-IG-001. The software may be applied to find the “worst case geometry.”

There are few programs that have all characteristics described above. They are currently used in
different laboratories, but most of them are not commercially available. We will use software that
has been extensively benchmarked against other Monte Carlo programs for simple geometries,
and against physical phantoms with TLDs for more complex geometries. However, this will only
be done with the approval of the Task Order. All guidelines contained in document OCAS-IG-
001 will be used.

Currently, we are inclined to derive the effective dose and organ dose using anthropomorphic
phantoms with the specified ICRP tissues and organs and the radiation transport codé, MCNP4C.
Modified (to include the esophagus and skin) versions of the Pacific Northwest National
Loaboratory male and female MIRD-like anthropomorphic phantom will be used for the
calculations. These modified phantoms are similar to the Adam and Eva phantoms developed in
1982 at Germany’s National Research Center for Environment and Health, GSF.

The anthropomorphic phantoms consist of three principal sections: an elliptical cylinder
representing the arms, torso and hips; two truncated circular cones representing the two legs and
feet; and an elliptical cylinder representing the neck region and lower portion of the head, which
is topped by half an ellipsoid. The gonads and eyes are specified. The arms are not separated
from the torso, and minor appendages such as fingers, feet, ears, chin and nose are omitted.
Internal organs are approximated by simple mathematical equations describing the average
shapes and sizes. .

Each internal organ is considered to be homogeneous in composition and density. Different
compositions and densities are used for the lungs, skeleton, and the total body minus the skeleton

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for performing blind reviews will be in accord with OCAS-IG-001 and OCAS-IG-002, with all
the qualifiers for ensuring quality that are described in depth in the other sections of this
proposal. Upon completion of each blind review, the work products will receive the same
independent advanced review audits as performed for NIOSH dose reconstructions as a form of
quality assurance documentation.

3.6.1 Internal Dosimetry Procedures and Software.

For internal exposures, the document OCAS-IG-002 recommends for dose reconstruction
purposes the use of the International Commission on Radiological Protection’s (ICRP) most
recent biokinetic and dosimetric models. Bioassay measurements, when available and reliable,
should be used as a basis for relevant dose calculations. The interpretation of monitoring
bioassay results, using ICRP models, requires the derivation and use of intake retention functions
(describing body and organ contents) and excretion functions (describing activity in excreta), as a
function of time following intake. Once the intake is estimated, the committed effective dose
and the annual/committed organ dose are calculated by multiplying the intake by the appropriate
dose coefficient.

As the models describing the uptake, distribution, and retention of radionuclides taken into the
body are complex, the interpretation of bioassay data requires the use of a computational code
that is based on the recommendations of the ICRP. Publication 78 of the ICRP [Individual
Monitoring for Internal Exposure of Workers, Annals of the ICRP 27 (3-4), Pergamon, 1997.]
gives limited information on the interpretation of bioassay data for selected radionuclides, for
selected times after an acute intake and some graphical information on chronic intakes.

We will use NIOSH guidelines to perform blind reconstructions, and NIOSH-recommended
software. If the Task Order does not specify particular software, we will use a computational
code that uses the ICRP’s most recent biokinetic and dosimetric models. There are few computer
codes that utilize the new ICRP models. Most of them are not commercially available, were
developed by ICRP members, and are used in their home institutions. The ICRP does not
recommend the use of any particular software. The one we will use, if agreed by the Task Order,
was developed by ICRP members and was officially adopted by the International Atomic Energy
Agency (IAEA), for use in Latin America in its program for Harmonization of Internal Dosimetry
Programs, involving 10 countries in Latin America. This software has been benchmarked against
ICRP 78 for all radionuclides and all times contained in the publication and reproduces ICRP 78
graphs for chronic intakes. It has all features necessary to reconstruct occupational radiation dose
from internally deposited radionuclides as specified in OCAS-IG-002.

This software accepts input information on various types of measurements, e.g., urine, feces,
lung, thyroid, bone, whole body, etc. Urine activities may be given as 24-hour excretion rates or
on a per liter excretion rate. If given on a per liter basis, unless otherwise specified, a nominal
excretion rate of 1400 milliliters (ml( of urine per day will be used. Fecal excretion activities
may also be given as 24-hour excretion or on a per gram or per gram of fecal ash basis. Unless
otherwise specified, the nominal excretion rate of the ICRP reference man will be used. The
software accepts inhalation of gases and particles, ingestion, and injection as routes of entry. It
accepts inputs on information on the elements or compounds, such as number of radionuclides
available for intake (item 4.2, OCAS-IG-02), physical-chemical characteristics of the compound

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Adjudicated Decision

Review Ei} Review Worker
fy} Co Worker 2) and Site Profiles
Process : ive** 4 i
Descriptions Representative’ EY

* Worker-profile and site-profile reviews will be part of the basic review only if they were used
in the preparation of the original dose reconstruction prepared by NIOSH; otherwise they will
be limited to advanced reviews or stand-alone tasks authorized under a Task Order.

**We recognize that direct conversations with claimants may not be authorized.

Exhibit 3-1. Interrelationships of Activities

course of advanced reviews, all findings will be documented, regardless of their importance to a
particular dose reconstruction and adjudicated decision. We believe such findings may have
relevance to the review of other claims and to the overall dose reconstruction process. Blind
Reviews will be similar to advanced reviews, with the exception that the review team will not
have access to the dose reconstruction, IREP input, and resulting adjudicated decision. Instead,
blind reviews will include the performance of our own dose reconstruction and IREP
calculations. The outcome of the blind review will then be compared to the dose reconstruction
and JREP input/output resulting from NIOSH’s investigations.

3.2 Preparation of Technical and Cost Proposals in Response to Task Order Request
Packages .

Upon delivery to SC&A, all TORPs will be logged in, date stamped, assigned a Task Order
number, and placed into the dedicated project file which will be maintained under lock and key
pursuant to SC&A’s records management procedures (see Section 2.1). As a means of tracking

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individual to perform the worker and site profile reviews for those cases. However, for complex
sites, where operations were highly diverse in space and time, such as at several major Federal
facilities, the supporting worker profile and site profile reviews may be highly unique to the
operations associated with the particular worker, or category of worker, and the specific
campaign at the site at a given point in time.

As described in greater detail in the example tasks, as our team becomes more familiar with
worker and site profiles for specific sites and categories of operations, Case Managers and team
members will be assigned to each new case in a manner that takes advantage of the experience
and knowledge gained by previous reviews. As such, we expect that we will become
increasingly efficient in performing both basic and advanced reviews as we acquire experience.
However, it is important to note that we will be beginning this process with individuals who
already have a great deal of experience and knowledge of the operations and exposure histories
of many of the DOE sites (e.g., see the biosketches of

The following sections describe the checklist and procedures for performing external and internal
dosimetry reviews, worker profile reviews, claimant interview reviews, and site profile reviews.
The checklists are extensive, and, in most cases, only those portions of the checklists that apply
to a particular case will need to be completed in detail.

During the review process, there will be a great deal of interaction among the review team
members in order to evaluate and ensure internal consistency and compatibility of the dosimetric
information with the worker profile information, the claimant interview information, and with
the site (or event’) profile. We suggest that, throughout this process, SC&A have an opportunity
to obtain clarifications and discuss our preliminary findings with Advisory Board representatives,
and, if acceptable to the Advisory Board, with the original authors of the dose reconstructions.

In addition, as work proceeds, should we uncover substantial errors or deficiencies in a dose
reconstruction, we will immediately contact the Advisory Board representatives, and not wait
until our reports are completed and delivered. We hope to establish a very close and cooperative
relationship with the Board members and seek their counsel throughout the review process.

Accompanying each item in the checklist will be a narrative explaining our findings. The level
of detail of the review will differ between the basic and advanced reviews. Blind dose
reconstructions will be performed in a similar manner as the advanced reviews, except the review
team will not have access to the IREP input and output prepared by NIOSH. In this way, our
team will perform an independent dose reconstruction, the results of which can be compared to
the results provided in the administrative record.

? For some cases, a major contributor to exposure may have been a transient or accidental release, referred
to here as an “event,” which will require a more focused historical reconstruction of the exposure setting than what
would normally be contained in a site profile, where exposures occurred as a result of routine operations.

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