DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

A LIMITED REVIEW OF ORAUT-OTIB-0082, REV. 00 PC-1 

DOSE RECONSTRUCTION METHOD FOR CHRONIC 

LYMPHOCYTIC LEUKEMIA 

Contract No. 211-2014-58081 

SCA-TR-PR2014-0091, Revision 0 

Prepared by 

U. Hans Behling, PhD, MPH 

SC&A, Inc. 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

October 2014 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on Radiation and 

Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, the ABRWH and its 

contractor, SC&A, caution the reader that at the time of its release, this report is pre-decisional and has not been 

reviewed by the Board for factual accuracy or applicability within the requirements of 42 CFR 82. This implies that 

once reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, the reader 

should be cautioned that this report is for information only and that premature interpretations regarding its 

conclusions are unwarranted.
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S. Cohen & Associates: Technical Support for the 

Advisory Board on Radiation and Worker Health 

Review of NIOSH Dose Reconstruction Program

Document No. 

SCA-TR-PR2014-0091

Effective Date:

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Revision No. 

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A Limited Review of ORAUT-OTIB-0082, Rev. 00

PC-1, Dose Reconstruction Method for Chronic 

Lymphocytic Leukemia

Page 2 of 19

Task Manager:

______________________ Date: ____________ 

U. Hans Behling, PhD, MPH 

Supersedes:

N/A

Project Manager:

______________________ Date: ____________

John Stiver, MS, CHP

Reviewer(s):

 John Stiver

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 10/06/2014 Initial issue.
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4

1.0 Relevant Background Information .......................................................................................6

2.0 Statement of Purpose ...........................................................................................................7

3.0 Overview of OTIB-0082, Rev. 00 PC-1 ..............................................................................9

3.1 Review of Guidance for Estimating Internal CLL Dose .......................................11

3.2 Review of DCAS-RPT-004: Chronic Lymphocytic Leukemia (CLL) Dose 

Conversion Factors for Deriving External Dose ....................................................12

3.3 Review of Guidance for Estimating Medical X-ray Dose to Compartments 

Comprising the CLL Model ...................................................................................15

3.4 Validation of Guidance Provided in ORAUT-OTIB-0082 in Dose 

Reconstruction .......................................................................................................15

4.0 Summary Conclusions .......................................................................................................18

References ......................................................................................................................................19
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ABBREVIATIONS AND ACRONYMS 

ABRWH or 

Advisory Board Advisory Board on Radiation and Worker Health 

ACS American Cancer Society 

AIC Akaike Information Criterion 

AP anterior-posterior 

CAD Chronic Annual Dose (tool)

CFR Code of Federal Regulations

CLL chronic lymphocytic leukemia 

DCAS Division of Compensation Analysis and Support 

DCF dose conversion factor 

DHHS U.S. Department of Health and Human Services 

dpm/d disintegrations per minute/per day 

EE Energy Employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 

2000 

ET2 extrathoracic region 2 

FR Federal Register 

GI gastro-intestinal 

GM geometric mean 

GSD geometric standard deviation 

HNM highest nonmetabolic organ 

Hp penetrating dose 

ICRP International Commission on Radiological Protection 

IMBA Integrated Modules for Bioassay Analysis 

IREP Interactive RadioEpidemiological Program 

keV kiloelectron volt 

LAT lateral 

LLI lower large intestine 

LN(ET) extrathoracic lymph nodes 

LN(TH) thoracic lymph nodes 

μ micron 

MDA minimum detectable activity
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MeV mega-electron volt 

NIOSH National Institute for Occupational Safety and Health 

ORAUT Oak Ridge Associated Universities Team 

OCAS Office of Compensation Analysis and Support 

ORNL Oak Ridge National Laboratory 

PA posterior-anterior 

POC probability of causation 

RBM red bone marrow 

SC&A S. Cohen & Associates (SC&A, Inc.) 

SI small intestine 

TBD Technical Basis Document 

TIB technical information bulletin 

ULI upper large intestine 
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1.0 RELEVANT BACKGROUND INFORMATION 

Among adults, chronic lymphocytic leukemia (CLL) is the most frequent form of leukemia in 

western countries, accounting for 30% of all leukemias. For the current year 2014, the American 

Cancer Society estimates 15,720 new cases of CLL among the 52,380 new cases of all leukemias 

(ACS 2014). Of the 15,720 new cases, 9,100 cases are expected to be males with a median age 

of 65 years at time of diagnosis. Given these incidence rates, it is reasonable to assume that a 

substantial number of Energy Employees (EEs) have been/will be diagnosed with CLL. NIOSH 

estimated that approximately 363 CLL cases may have been diagnosed that either filed claims 

that were rejected or were never filed due to knowledge that CLL was previously not considered 

a radiogenic cancer. 

On March 21, 2011, the U.S. Department of Health and Human Services (DHHS) announced its 

intention in the Federal Register to treat CLL as a radiogenic cancer under the Energy 

Employees Occupational Illness Compensation Act of 2000 (EEOICPA) (FR 15268); and on 

February 6, 2012, the final rule was published that now regards CLL as being potentially caused 

by radiation. 

As a result of this change and in compliance with Subpart D §81.10 of 42 CFR 81, a model was 

developed to derive estimates of radiation dose to a specific lymphocytic cell line that, after 

transformation and clonal expansion, gives rise to CLL. Details of this dosimetric CLL model 

were developed under contract by SENES Oak Ridge, Inc., and described in a 64-page report 

authored by A.J. Apostoaei and J.R. Trabalka. The report entitled, Review, Synthesis, and 

Application of Information on the Human Lymphocytic System to Radiation Dosimetry for 

Chronic Lymphocytic Leukemia, was issued in March 2012. 

Based on technical information presented by Apostoaei and Trabalka (2012), NIOSH issued 

ORAUT-OTIB-0082, Dose Reconstruction Method for Chronic Lymphocytic Leukemia on 

December 20, 2012 (ORAUT 2012). 
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2.0 STATEMENT OF PURPOSE 

Under the EEOICPA and Title 42, Part 82, Methods for Radiation Dose Reconstruction Under 

the Energy Employees Occupational Illness Compensation Program Act of 2000, of the Code of 

Federal Regulations (42 CFR Part 82), the Advisory Board on Radiation and Worker Health 

(Advisory Board or Board) is mandated to conduct an independent review of the methods and 

procedures used by the National Institute for Occupational Safety and Health (NIOSH) and its 

contractors for dose reconstruction. 

As contractor to the Advisory Board, S. Cohen & Associates (SC&A) has been charged to 

support the Advisory Board in this effort by conducting critical reviews of ORAUT-OTIBs.

SC&A’s review method is described in our report entitled, A Protocol for the Review of 

Procedures and Methods Employed by NIOSH for Dose Reconstruction, which was approved by 

the Advisory Board in November 2009 (SC&A 2009). In brief, SC&A identified the following 

objectives in its protocol to the Advisory Board, which have formed the basis for conducting past 

reviews: 

Objective 1: Determine the degree to which procedures support a process that is expeditious 

and timely for dose reconstruction. 

Objective 2: Determine whether procedures provide adequate guidance to be efficient in select 

instances where a more detailed approach to dose reconstruction would not affect 

the outcome. 

Objective 3: Assess the extent to which procedures account for all potential exposures, and 

ensure that resultant doses are complete and based on adequate data. 

Objective 4: Assess procedures for providing a consistent approach to dose reconstruction 

regardless of claimants’ exposures by time and employment locations.

Objective 5: Evaluate procedures with regard to fairness and the extent to which the claimant 

is given the benefit of doubt when there are unknowns and uncertainties 

concerning radiation exposures.

Objective 6: Evaluate procedures for their approach to quantifying the uncertainty distribution 

of annual dose estimates that is consistent with and supports a U.S. Department of 

Labor probability of causation (POC) estimate at the upper 99% confidence level. 

Objective 7: Assess the scientific and technical quality of methods and guidance contained in 

procedures to ensure that they reflect the proper balance between current/ 

consensus scientific methods and dose reconstruction efficiency. 

For each of the above-cited seven general objectives, the review protocol was structured on a 

series of relevant questions contained in a checklist, which the SC&A reviewer used for rating a 
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given procedure. A rating system of 1 through 5 corresponded to the following answers: 1 = No 

(or Never), 2 = Infrequently, 3 = Sometimes, 4 = Frequently, 5 = Yes (or Always). 

SC&A’s assessment of ORAUT-OTIB-0082, however, will not adhere to the above-cited 

standard review protocol, which includes a critical evaluation of technical supporting documents 

and associated references, for the following reason: 

In a written communique received on May 8, 2014, SC&A was given the following instruction 

regarding SC&A’s review of ORAUT-OTIB-0082: 

 . . . please note this tasking does not include a review of the CLL risk model [as 

presented by A. Julian Apostoaei and John R. Trabalka, 2012] which was 

extensively peer-reviewed already.

Correspondingly, SC&A’s review of ORAUT-OTIB-0082 will not include the technical basis of 

the CLL risk model, but will be limited to the guidance/protocol for its implementation in dose 

reconstruction.
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3.0 OVERVIEW OF OTIB-0082, REV. 00 PC-1 

Of all cancers assessed under EEOICPA, estimating radiation dose(s) to cells suspected of giving 

rise to CLL is by far the most complex and challenging, as explained in the following statements 

cited in ORAUT-OTIB-0082: 

CLL originates in the B lymphocytes rather than in a well-defined organ as with 

other cancers. These lymphocytes are distributed throughout the lymph system 

and, as noted in Review, Synthesis, and Application of Information on the Human 

Lymphatic System to Radiation Dosimetry for Chronic Lymphocytic Leukemia 

(Apostoaei and Trabalka 2012), they can travel throughout the body and their 

inventories in various compartments of the body can change significantly with 

age, gender, health status and other factors. Estimation of dose to the cancer 

site for CLL cases requires the calculation of the radiation dose to this 

population of CLL precursor cells. This is more complex than dose assessment 

to other cancer sites because CLL precursor cells can be present in different 

compartments of the lymphatic system throughout the body, and these 

compartments can receive substantially different doses. Because the B 

lymphocyte population in a given organ is not constant, probability distributions 

are used in the assessment. 

Current information indicates that CLL is produced by transformation of mature, 

antigen-experienced B lymphocytes, possibly memory cells, potentially anywhere 

in the body (i.e., including but not restricted to the bone marrow). This situation 

complicates an assessment of the risk of developing CLL of radiogenic origin 

because definition of an appropriate target organ or tissue is problematic 

because radiation doses from internally deposited radionuclides and from some 

types of external exposures can be very different at different locations within the 

body. B cells at different sites can thus receive markedly different doses. 

In the development of the CLL dosimetric model, information was analyzed to 

derive compartment-specific weights based on relative sizes of B-lymphocyte 

(more properly a B-cell precursor for CLL) pools to be used in estimating a 

weighted average radiation dose. Because of the variability and uncertainty in 

the distribution of these cells, probability distribution functions were assigned to 

the number of lymphocytes and to the fraction that represent B cells for each 

organ of interest. The final model consists of an average dose (and its 

uncertainty) obtained using weights based on the fractional distribution of Blymphocyte precursors across 30 compartments for CLL. [Emphasis added.]

For internal dose calculation, the B lymphocytes compartments correspond to . . . 

a total of 28 organs must be assessed . . . Table 3-1 lists the corresponding organs 

to be assessed for each compartment of the CLL model [in behalf of occupational 

internal, external, and medical dose]. 
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However, this can be a complicated process and at a minimum is very lengthy, so 

specific issues associated with this calculation are addressed here. Although the 

CLL tool is mentioned, details of its use are not included here; these are 

addressed in the tool user guide. [Emphasis added.] 

As a convenience to the reader, Table 3-1 of ORAUT-OTIB-0082 is reproduced herein as 

Exhibit #1. In addition to the large number of organs that the model must consider, the 

complexity of the CLL model is further compounded by secondary variables that include the 

need to select (1) the type of medical x-ray examination administered and whether the beam was 

poorly or properly collimated, (2) the chemical form and solubility class for internalized 

radionuclides, (3) use of a special/blended dose conversion factor (DCF) (described in DCASRPT-004) representing the weighted fractions of DCF values for the 15 organs cited in Table 3-1 

(Exhibit #1) for measured (or missed) external exposures to photons and neutrons, and (4) the 

potential assignment of geometry correction factors to glovebox work/uranium facilities and 

dose assignment to the skin (a compartment of the CLL model) from both penetrating and nonpenetrating radiation. Guidance for the selection and use of these and other input parameters are 

provided in Section 4.0 of ORAUT-OTIB-0082.

EXHIBIT #1: Table 3-1. Correspondence of CLL model to ICRP-modeled organs. 

Compartment of CLL

dosimetry model X-ray dose organa

Internal dose organ External dose organ

Lymph nodes 

 Extrathoracic Thyroid LN(ET) Thyroid 

 Thoracic Lung LN(TH) Lung 

 Remainder Ovaries HNMbStomachc 

Spleen Spleen (lung or ovaries) Spleen Stomachc

Peyer's Patches Colon (ovaries) SI Stomachc 

Thymus Thymus (lung) Thymus Thymus 

Red bone marrow Bone marrow RBM RBM 

Tonsils Esophagus (lung) LN(ET) Esophagus 

Blood Remainder HNMbStomachc

Intestinal mucosa 

 Small intestinal wall Ovary SI Stomachc

 Upper intestinal wall Colon (ovaries) ULI Colonc

 Lower large intestinal wall Colon (ovaries) LLI Colonc 

Respiratory mucosa 

 Extrathoracic airways Esophagus (lung) ET2 Esophagus 

 Lung Lung Lung Lung 

Skin Skin Skin Skin 

Liver Liver (lung or ovary) Liver Liverc

Vermiform appendix Colon (Ovaries) ULI Colonc

Residual soft tissue 

 Muscle Remainder Muscle Remainder 

 Breast Breast Breast Breast 

 Kidneys Remainder Kidney Liverc

 ST wall Stomach (lung or ovaries) Stomach Stomachc

 Pancreas Pancreas (lung or ovaries) Pancreas Stomachc

 Uterus Uterus Uterus Uterusc

 Urinary bladder wall Urinary bladder (ovaries) Bladder Bladderc

 Esophagus Esophagus (lung) Esophagus Esophagus 

 Testes Testes Testes Testesc

 Thyroid Thyroid Thyroid Thyroid 

 Prostate Prostate (ovaries) HNMb Bladderc

 Adrenals Remainder Adrenals Remainder 

Ovaries Ovaries Ovaries Ovariesc

Source: ORAUT-OTIB-0082 
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3.1 REVIEW OF GUIDANCE FOR ESTIMATING INTERNAL CLL DOSE 

Due to the fact that the CLL risk model identified 28 separate anatomical compartments with 

representation of CLL precursor cells, an assessment of the CLL internal dose in effect 

corresponds to a weighted dose assessment in behalf of 28 different organs/tissues cited in 

Column #3 of Exhibit #1. 

Given the complexity of deriving weighted organ/tissue doses, NIOSH developed the CLL 

Simulator Tool, which allows the Integrated Modules for Bioassay Analysis (IMBA) and 

Chronic Annual Dose (CAD) Workbook files to be imported for calculating internal doses to all 

CLL organs simultaneously. In addition, the CAD Workbook was modified in order to create a 

separate file for each of the 28 organs/tissues, which can be used in the CLL Simulator Tool. 

OTIB-0082 also provides brief instructions for saving files in IMBA that can be imported into 

the CLL Tool. 

Other tools that were modified or CLL-specific guidance added to address the complexity of the 

CLL risk model include (1) ORAUT-OTIB-0018 (Internal Dose Overestimates for Facilities 

with Air Sampling Programs), (2) ORAUT-OTIB-0054 (Fission and Activation Product 

Assignment for Internal Dose-Related Gross Beta and Gross Gamma Analysis), (3) ORAUTOTIB-0049 (Estimating Doses for Plutonium Strongly Retained in the Lung), (4) ORAUTOTIB-0011 (Technical Information Bulletin: Tritium Calculated and Missed Dose Estimates), 

(5) site-specific radionuclide chooser tools, and (6) site-specific internal environmental tools. 

SC&A Comments Pertaining to Internal Dose Guidance for CLL Cases 

SC&A was provided training on running the CLL Simulator Tool. Subsequently, we generated 

both IMBA and CAD files for a CLL claim, imported these files into the CLL Simulator Tool, 

and evaluated the internal doses generated by the tool. 

In addition, SC&A assessed the modifications made to tools or changes to the dose 

reconstruction guidance for performing internal doses as specified in OTIB-0018 (ORAUT 

2005), OTIB-0049 (ORAUT 2010), OTIB-0054 (ORAUT 2007), OTIB-0011 (ORAUT 2004), 

site-specific radionuclide chooser tools, and site-specific environmental tools. We were able to 

confirm that appropriate changes have been incorporated into these tools and the tools generated 

internal doses that included the weighted organs/tissues specified in OTIB-0082. In addition, we 

verified that guidance for using generic and site-specific tools had been appropriately updated to 

include changes required for performing best-estimates for CLL claims. 

SC&A’s evaluation of internal dose tools and technical guidance revealed no findings, but 

identified the following minor observation. 

Observation #1. Section 4.2 of OTIB-0082 states the following: “. . . Although the CLL tool 

[for CLL internal dose] is mentioned, details of its use are not included here; these are addressed 

in the tool user guide.” [Emphasis added.] Currently, however, a tool user guide does not exist; 

and unless a tool user guide is developed, this sentence should be removed from OTIB-0082.
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3.2 REVIEW OF DCAS-RPT-004: CHRONIC LYMPHOCYTIC LEUKEMIA (CLL) 

DOSE CONVERSION FACTORS FOR DERIVING EXTERNAL DOSE 

As shown in Exhibit #1, for external CLL dose calculation, there are 15 CLL compartments for 

which doses must be derived from dosimeter measurements and properly weighted to reflect 

fractional distribution of CLL precursor cells. The protocol for these blended CLL dose 

conversion factors (CLL-DCFs) is described in DCAS-RPT-004 (DCAS 2013) and is based on 

the following equation: 

CLL-DCFblended = ƩorganB-cell Fraction × DCForgan

Important to note is that the DCForgan is defined by (1) radiation type (photons, neutrons, 

electrons), (2) energy, (3) exposure geometry, and (4) the recording of the external dose 

measurement [Roentgen, Hp(10), or H*(10)]. Moreover, since both the DCForgan value and 

B-cell fraction represent probability distributions, their multiplicative product represents a 

sample value from each distribution. For each CLL-DCF, NIOSH employed a total of 50,000 

interactions, which in turn were fitted to five standard probability distributions that included 

normal, lognormal-3 parameter,1lognormal-2 parameter, Weibull-3 parameter, and Weibull-2 

parameter. To determine the best fit of the data among the five distributions, NIOSH employed 

the Akaike Information Criterion (AIC) and selected the fit(s) with the lowest AIC score (5), as 

provided in Appendix B of DCAS-RPT-004, and summarized in Table 4 of DCAS-RPT-004. As 

a convenience to the reader, Table 4 is reproduced herein as Table 1. Additionally, Table 2 

provides the key for each parameter value of the five distribution types. 

In order to properly apply the blended DCF values in dose reconstruction, NIOSH added a “CLL 

DCF” tab/spreadsheet with these CLL DCFs to all site-specific external dose calculation 

workbooks. 

SC&A Comments Pertaining to DCAS-RPT-004 and External Dose Guidance for CLL Cases 

SC&A critically reviewed the statistical approach described in DCAS-RPT-004, which correlates 

external dosimeter measurements to radiation doses received by B-lymphocytes (representing 15 

anatomically separated compartments) by means of blended CLL DCFs. Blended DCFs were 

based on previously assessed DCF values cited in External Dose Reconstruction Implementation 

Guide (OCAS 2007) for select radiation types, energies, and exposure geometries using Monte 

Carlo techniques. 

In addition, SC&A verified that the site-specific external dose calculation workbooks had been 

updated with the “CLL DCF” tab, and that the data entered into the spreadsheet associated with 

this tab were consistent with data provided in DCAS-RPT-004. 

SC&A concurs with the methodology used to derive blended CLL DCF values, and there are no 

findings. 

 

1

 Note: Due to software limitations, the lognormal-3 parameter distribution is not available for use. 
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Table 1: CLL Dose Conversion Factors (DCFs)

Photons – Standard Program AIC Distribution 

Type Parameter 1 Parameter 2 Parameter 3

AP, Hp(10), 20 keV R Code -260741 Weibull-3 22.47131 0.349317 -0.223322

@Risk -261126 Weibull-3 20.7300 0.3218 -0.1958

AP, Hp(10), <30 keV R Code -163211 Lognormal-2 -1.813092 0.289966

@Risk -163749 Weibull-3 3.1523 0.1547 0.0316

AP, Hp(10), 30-250 keV R Code -115811 Weibull-3 7.199207 0.507184 0.179760

@Risk -115774 Weibull-3 7.4933 0.5264 0.1613

AP, Hp(10), >250 keV R Code -215872 Weibull-3 40.13267 0.924499 -0.045126

@Risk -216930 Weibull-3 40.0000 0.9134 -0.0337

AP, H*(10), 20 keV R Code -260926 Weibull-3 22.51689 0.349347 -0.223217

@Risk -260804 Weibull-3 18.9010 0.2951 -0.1692

AP, H*(10), <30 keV R Code -162595 Weibull-3 2.929355 0.147035 0.040620

@Risk -162782 Weibull-3 2.9167 0.1461 0.0417

AP, H*(10), 30-250 keV R Code -102949 Weibull-3 6.538252 0.527992 0.208968

@Risk -102681 Weibull-3 6.6675 0.5392 0.1980

AP, H*(10), >250 keV R Code -214109 Weibull-3 39.45216 0.937975 -0.043503

@Risk -214188 Weibull-3 40.0000 0.9492 -0.0548

AP, Exposure, 20 keV R Code -311040 Weibull-3 22.67735 0.213126 -0.137000

@Risk -311007 Weibull-3 22.6070 0.2126 -0.1365

AP, Exposure, <30 keV R Code -163352 Weibull-3 2.971961 0.147084 0.037963

@Risk -163447 Weibull-3 3.1430 0.1544 0.0309

AP, Exposure, 30-250 keV R Code -55009 Weibull-3 4.901520 0.660023 0.328846

@Risk -55182 Weibull-3 4.9724 0.6674 0.3215

AP, Exposure, >250 keV R Code -173835 Normal 0.902252 0.042539

@Risk -173857 Normal 0.9024 0.0425

ISO, H*(10), <30 keV R Code -293749 Lognormal-2 -3.006159 0.259159

@Risk -293828 Lognormal-2 -3.0026 0.2580

ISO, H*(10), 3-250 keV R Code -173300 Weibull-3 6.328391 0.252389 0.106626

@Risk -173544 Weibull-3 6.2922 0.2505 0.1083

ISO, H*(10), >250 keV R Code -205435 Weibull-3 4.770665 0.142480 0.523519

@Risk -206081 Weibull-3 4.9605 0.1465 0.5197

ISO, Exposure, <30 keV R Code -308204 Weibull-3 3.252577 0.037359 0.013826

@Risk -308245 Weibull-3 3.2695 0.0375 0.0137

ISO, Exposure, 3-250 keV R Code -139362 Weibull-3 6.379246 0.356836 0.106916

@Risk -139466 Weibull-3 6.4273 0.3590 0.1050

ISO, Exposure, >250 keV R Code -253408 Normal 0.656806 0.019196

@Risk -253829 Normal 0.6567 0.0191

Photons – Glovebox

GL, AP, Hp(10), 20 keV R Code -153384 Weibull-3 4.573391 0.231926 0.035918

@Risk -153959 Weibull-3 4.5404 0.2294 0.0385

GL, AP, Hp(10), <30 keV R Code -73923 Weibull-3 2.618190 0.326542 0.065149

@Risk -74765 Weibull-3 2.5422 0.3158 0.0741

GL, AP, Hp(10), 30-250 keV R Code 11108 Normal 1.353380 0.270388

@Risk 10711 Normal 1.3547 0.2693

GL, AP, Hp(10), >250 keV R Code 12631 Normal 1.730032 0.274537

@Risk 12653 Normal 1.7302 0.2746
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Table 1: CLL Dose Conversion Factors (DCFs) (continued)

Photons – Glovebox Program AIC Distribution 

Type Parameter 1 Parameter 2 Parameter 3

GL, AP, Exposure, 20 keV R Code -203800 Weibull-3 4.600174 0.140813 0.021185

@Risk -203991 Weibull-3 4.4847 0.1374 0.0242

GL, AP, Exposure, <30 keV R Code -71732 Weibull-3 2.713886 0.343538 0.057365

@Risk -72049 Weibull-3 2.6518 0.3356 0.0654

GL, AP, Exposure, 30-250 keV R Code 58114 Normal 1.945418 0.432643

@Risk 58593 Normal 1.9425 0.4347

GL, AP, Exposure, >250 keV R Code 19277 Normal 1.806214 0.293404

@Risk 19192 Normal 1.8060 0.2932

Neutrons – Standard

AP, Hp,slab(10), <10 keV R Code -14546 Weibull-3 4.354067 0.888335 0.699164

@Risk -14445 Weibull-3 4.7636 0.9649 0.6237

AP, Hp,slab(10), 10-100 keV R Code -38366 Lognormal-2 0.176877 0.138136

@Risk -38538 Lognormal-2 0.1776 0.1378

AP, Hp,slab(10), 0.1-2 MeV R Code -119373 Weibull-3 6.592743 0.450670 0.297627

@Risk -118907 Weibull-3 6.4519 0.4442 0.3042

AP, Hp,slab(10), 2-20 MeV R Code -123009 Weibull-3 6.284880 0.417064 0.611094

@Risk -121974 Weibull-3 6.4707 0.4329 0.5954

Neutrons – Glovebox

GL, AP, Hp,slab(10), <10 keV R Code 104679 Weibull-3 3.277786 2.325402 1.068565

@Risk 105394 Weibull-3 3.3979 2.4149 0.9920

GL, AP, Hp,slab(10), 10-100 keV R Code 81559 Lognormal-2 0.894352 0.223635

@Risk 81019 Lognormal-2 0.8960 0.2221

GL, AP, Hp,slab(10), 0.1-2 MeV R Code 17016 Normal 1.490459 0.286843

@Risk 16828 Normal 1.4921 0.2863

GL, AP, Hp,slab(10), 2-20 MeV R Code 38162 Normal 2.029914 0.354389

@Risk 38603 Normal 2.0320 0.3560

Electrons

Electrons – 1.5 MeV R Code -411625 Weibull-3 1.432950 7.2274e-3 4.6557e-5

@Risk -412382 Weibull-3 1.4000 0.0071 0.0002

Source: DCAS-RPT-004, Table 4 

Table 2: Parameter Key for the Various Distribution Types 

Distribution Type Parameter 1 Parameter 2 Parameter 3 

Lognormal-3 μ (GM = eμ

) σ (GSD = eσ) Shift Factor (γ) 

Lognormal-2 μ (GM = eμ

) σ (GSD = eσ) 

Weibull-3 k (Shape) λ (Scale) Shift Factor (θ) 

Weibull-2 k (Shape) λ (Scale) 

Normal μ σ 

 Source: DCAS-RPT-004, Table 5 
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3.3 REVIEW OF GUIDANCE FOR ESTIMATING MEDICAL X-RAY DOSE TO 

COMPARTMENTS COMPRISING THE CLL MODEL 

Section 4.1 of OTIB-0082 explains the basis for estimating doses to each of the compartments 

containing CLL precursor cells that may be exposed to occupational medical radiation associated 

with either a chest or lumbar spine x-ray examination. Dose estimates to each compartment are 

defined by the product of the incident air kerma and the compartment-specific DCFs assigned to 

organs shown in the second Column of Exhibit #1. 

For the CLL compartment involving the skin, an entrance and exit skin dose is defined as well as 

the fraction of exposed skin, which varies from 0.19 for a properly collimated beam to 0.38 for a 

poorly collimated beam. 

The effective organ to CLL precursor cells from occupational medical exposure is the sum of the 

weighted organ doses that takes into consideration uncertainties associated with each organspecific DCF value and the weighted fraction of CLL cells. 

For estimates of CLL medical x-ray doses, NIOSH developed CLL x-ray doses that were 

facility-specific, view-specific (e.g., PA or LAT), and facility-specific to given time periods. 

Variables among time periods included assigned organ doses and whether beams were properly 

or poorly collimated. A lookup table containing these values has been incorporated into each 

site-specific external dose calculation workbook as a single tab (“CLL X-ray Data”).

SC&A Comments Pertaining to Occupational Medical Doses for CLL Cases 

Our review of NIOSH’s methodology and guidance pertaining to the assignment of medical 

x-ray dose to compartments indicate that they are consistent with existing models and, when 

properly adjusted to account for the distribution of CLL precursor cells among compartments,

comply with the CLL risk model. In addition, SC&A reviewed all site-specific external dose 

calculation workbooks to ensure that the ‘CLL X-ray Data” tab had been added and the data 

were consistent with TBD guidance. 

There are no findings pertaining to estimates of medical x-ray doses applicable to the CLL risk 

model.

3.4 VALIDATION OF GUIDANCE PROVIDED IN ORAUT-OTIB-0082 IN DOSE 

RECONSTRUCTION

In an effort to assess the functionality of guidance provided in ORAUT-OTIB-0082, SC&A 

conducted a preliminary review of a CLL case assigned as part of our audit of the 19th set of dose 

reconstructions. A summary of the case specifics is provided below: 

Case Overview

The Energy Employee (EE) worked at ORNL (X-10) as an [redacted] during the period 

[redacted]. Diagnosed with CLL in [redacted] ([redacted] years exposure, [redacted]
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years latent period). NIOSH performed a partial dose reconstruction in May 2013, since 

this was sufficient to produce a POC of >50%. 

External Dose 

Recorded Photon/Neutron Doses – The EE was monitored for most of the 10-year 

employment period and external doses were calculated based on guidance in the X-10 

TBD data and OTIB-0082. The most current version of the X-10 Calculation Workbook 

was used, which includes the CLL DCFs that were applied in this case. 

Occupational Medical Doses – The EE was also assigned doses from occupational x-ray 

exams in accordance with OTIB-0082 and X-10 TBD guidance. The X-10 Calculation 

Workbook was used, and appropriate values from the CLL X-ray Data sheet were 

applied. 

Internal Dose 

Bioassays – The EE was bioassayed for numerous radionuclides by urinalyses and whole 

body counts, with all results below the minimum detectable activity (MDA) levels. 

NIOSH used the urinalysis data to estimate internal dose in this case. Missed Pu-239 

dose was based on 1⁄2 MDA = 0.5 × 0.06 dpm/d = 0.03 dpm/d. 

IMBA – The missed intake value of 0.03 dpm/d (last bioassay on March 16, 1969) was 

used as the bioassay input into the IMBA program to provide a projected chronic intake 

of 3.57 dpm/d Type M, and 56.36 dpm/d Type S Pu-239 for the period 1960–1970. 

Type S was used in this case. 

IMBA Report - An IMBA Report was created that included all the individual CLL 

organ/compartment annual doses for use in the CLL Simulator.

Type SS Pu – The organ doses in the IMBA Report for Type S Pu are then adjusted using 

the recommendations of OTIB-0049, Table 4-5, page 12, and page 14. For this case, this 

included the lungs, thoracic lymph nodes, extra-thoracic, gastro-intestinal (GI) tract, and 

systemic organs as per the Urinalysis column. 

Multiple IMBA Reports – In general, an IMBA Report (that includes all the CLL organs) 

is generated for each radionuclide, and for each solubility type. For this case, a 

comparison is made between Pu-239 Type M, Type S, and Type SS, with Type SS 

resulting in the highest dose.

CLL Simulator – The IMBA Report for Pu-239 Type SS was then imported into the CLL 

Simulator 1.3.0, and the CLL calculation was performed. This created a CLL Report, 

which was compared to the IREP Input Table for use in the POC calculations. 
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ORAUT-OTIB-0082 Validation Summary Conclusions

From this preliminary evaluation and a spot check of calculations, doses, etc., it appears that, for 

this case, the dose reconstructor used the proper procedures and assigned the correct doses. The 

detailed calculations in the IMBA Report, CLL Simulator, POC calculations, etc., were not 

evaluated.
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4.0 SUMMARY CONCLUSIONS

SC&A’s assessment of ORAUT-OTIB-0082 was limited to the methodology and guidance 

needed to perform a dose reconstruction in behalf of a CLL claim. In recognition of the 

complexity of the CLL risk model, an extraordinary effort was required for the development of a 

new CLL internal dose tool, as well as the modification of numerous internal and external tools,

in order to reduce the potentially time-consuming effort that would otherwise be required to 

perform a dose reconstruction. SC&A was able to verify that guidance and tools are adequate 

for deriving external and internal dose for CLL clams in accordance with ORAUT-OTIB-0082.

There were no findings associated with our review of ORAUT-OTIB-0082.
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REFERENCES

42 CFR Part 82. 2002. Methods for Radiation Dose Reconstruction under the Energy

Employees Occupational Illness Compensation Program Act of 2000; Final Rule Federal 

Register / Vol. 67, No. 85 / Thursday, May 2, 2002, p 22314.

42 CFR Part 81. 2002. Guidelines for Determining the Probability of Causation Under the 

Energy Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, May 2, 2002, p. 22296

American Cancer Society (ACS) 2014. Cancer Facts & Figures 2014, Atlanta, Georgia. 2014.

Apostoaei, A.J. and J.R. Trabalka. 2012. Review, Synthesis, and Application of Information on 

the Human Lymphatic System to Radiation Dosimetry for Chronic Lymphocytic Leukemia, Final 

Report. SENES Oak Ridge, Inc., Center for Risk Analysis, Oak Ridge, Tennessee. March 2012.

DCAS 2013. Chronic Lymphocytic Leukemia (CLL) Dose Conversion Factors, DCAS-RPT004, NIOSH’s Division of Compensation Analysis and Support, Cincinnati, Ohio. December 

2012.

OCAS 2007. External Dose Reconstruction Implementation Guideline, OCAS-IG-001, Rev. 3. 

National Institute for Occupational Safety and Health (NIOSH), Office of Compensation 

Analysis and Support: Cincinnati, Ohio. November 21, 2007.

ORAUT 2004. Technical Information Bulletin: Tritium Calculated and Missed Dose Estimates, 

Rev. 00, ORAUT-OTIB-0011, Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 

29, 2004.

ORAUT 2005. Internal Dose Overestimates for Facilities with Air Sampling Programs, Rev. 

01, ORAUT-TKBS-0018, Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 

9, 2005.

ORAUT 2007. Fission and Activation Project Assignment for Internal Dose-Related Gross Beta 

and Gross Gamma Analyses, ORAUT- OTIB-0054, Rev. 00, PC-1, Oak Ridge Associated

Universities Team, Cincinnati, Ohio. November 19, 2007.

ORAUT 2010. Estimating Doses for Plutonium Strongly Retained in the Lung, Rev. 01, PC-2, 

ORAUT-OTIB-0049. November 29, 2010.

ORAUT 2012. Dose Reconstruction Method for Chronic Lymphocytic Leukemia, Rev. 00, PC-1, 

ORAUT-OTIB-0082. Oak Ridge Associated Universities Team, Cincinnati, Ohio. December 

12, 2012.

SC&A 2009. A Protocol for the Review of Procedures and Methods Employed by NIOSH for 

Dose Reconstruction, SCA-TR-PR2009-0001, Rev. 3. SC&A, Inc., Vienna, Virginia. 

November 16, 2009.