REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute of Occupational Safety and Health 

Audit of Case PIID*from the Savannah River Site 

Contract No. 200-2004-03805 

Task Order No. 4 

SCA-TR-TASK4-CNPIID* 

Prepared by 

S. Cohen & Associates 

6858 Old Dominion Road, Suite 301 

McLean, Virginia 22101 

February 2005 

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

the written consent of the individual to whom the information pertains is strictly prohibited.
Document No. 

SCA-TR-TASK4-CNPIID* 

Effective Date: 

February 4, 2005 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 1 

AUDIT OF CASE PIID*FROM THE SAVANNAH 

RIVER SITE

Page 2 of 18 

Task Manager: ___________________ Date: 02/04/05 

 U. Hans Behling, PhD, MPH 

Project Manager: _________________ Date: 02/04/05 

 John Mauro, PhD, CHP 

Supersedes: 

Draft 0 

Savannah River Site Case #PIID* 2 S. Cohen & Associates 
TABLE OF CONTENTS 

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

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

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

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

2.1 Recorded Photon Doses .......................................................................................... 9 

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

2.2 Missed Photon Doses.............................................................................................. 9 

2.2.1 Reviewer’s Comments.............................................................................. 10 

2.3 Recorded Neutron Doses ...................................................................................... 10 

2.3.1 Reviewer’s Comments.............................................................................. 10 

2.4 Missed Neutron Doses .......................................................................................... 10 

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

2.5 Occupational Medical Exposures ......................................................................... 11 

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

2.6 Onsite Ambient Dose............................................................................................ 11 

2.6.1 Reviewer’s Comments.............................................................................. 11 

3.0 Audit of Internal Doses (Missed Dose) ............................................................................ 12 

3.1 Tritium .................................................................................................................. 12

3.1.1 Reviewer’s Comments.............................................................................. 12 

3.2 All Other Nuclides ................................................................................................ 12 

3.2.1 Reviewer’s Comments.............................................................................. 12 

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

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

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

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

Savannah River Site Case #PIID* 3 S. Cohen & Associates 
1.0 SUMMARY BACKGROUND INFORMATION 

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

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

worked at the Savannah River Site (SRS) for three periods of time; PIID*. The worker was 

diagnosed with prostate cancer on PIID*.

SRS operations played an important role in the U.S. nuclear weapons program (DOE 1997). 

SRS processes included nuclear fuel fabrication, reactor operation, radiochemical processing, 

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

The majority of the claimant’s radiation exposure was received during employment as a PIID*. 

As a PIID*, the claimant performed work all over the site. Based on the Dose Reconstruction 

Telephone Interview, the claimant worked in various areas including PIID*. About 50% of the 

time, the claimant was dressed out in protective clothing, including fresh-air suits. The claimant 

PIID*, and did general PIID*. 

The claimant was exposed to photon radiation fields and was monitored for ionizing radiation 

doses continuously during employment at the Savannah River Site. External dose records 

received from the Department of Energy were reviewed by NIOSH and found to be sufficient for 

the reconstruction of the external dose. A missed photon dose was assigned by NIOSH for all 

badge cycles when a zero dose was reported or when no information for a badge cycle was 

available. 

Based on the information in the telephone interview, the claimant also worked at PIID*. This 

facility presents the potential for neutron exposure. The energy employee was assigned a 

neutron dosimeter for 3 of the 12 badge cycles in PIID* and 2 of the 12 badge cycles in 

PIID*To apply claimant-favorable assumptions that result in the highest probability of causation 

for neutron exposure, the 221F, PIID*was used by NIOSH in the dose reconstruction for the 

years of potential neutron exposure. A missed neutron dose was assigned by NIOSH for all 

badge cycles when a zero dose was reported or when no information for a badge cycle is 

available. 

Onsite ambient doses were assessed as part of the dose reconstruction. In addition, the photon 

doses due to annual x-ray procedures were evaluated.

From the telephone interview, the worker identified potential exposure to unknown quantities of 

tritium, Co, Pb, I, Rn, and enriched U. The worker was monitored for tritium. A potential 

missed dose for tritium was assigned by NIOSH for each year that an annual tritium dose was 

not reported. Additionally, the missed dose was assigned by NIOSH to the worker for any year 

in which the reported dose was less than the potential missed dose. 

Internal dose monitoring records for radionuclides other than tritium were reviewed. All results 

of measurements for non-naturally occurring radionuclides showed an activity less than the 

minimum detection level for the given radionuclides and bioassay method. To account for any 

potential undetected dose for energy employees who participated in internal dose monitoring 

programs, internal dose was assigned by NIOSH based on a hypothetical intake. Assigned 

Savannah River Site Case #PIID* 4 S. Cohen & Associates 
internal doses for each radionuclide were based on a hypothetical acute intake on the first day of 

employment equal to the mathematical average of the largest five recorded intakes for that 

radionuclide documented at the Savannah River Site (referred to as the “high five” approach). 

The largest annual dose to a non-metabolic organ from these assumed intakes was calculated for 

each year from the first year of employment through the end of the year in which cancer was 

diagnosed. The high five approach is claimant favorable for workers who worked at the site in 

the PIID* and later, since it is unlikely that such workers would have been allowed to enter an 

area where they had the potential to experience high five exposures and not be properly 

monitored. 

 

Table 1 summarizes the results of NIOSH’s reconstruction of the doses to the energy employee’s 

prostate gland for the purpose of deriving the probability of causation (POC) using IREP. 

Because the ICRP dosimetric model (ICRP 60, 1991) and IMBA do not provide the means to 

derive the doses to the prostate gland, NIOSH used the testes as a claimant-favorable surrogate 

for the prostate for external exposures, and the colon (maximum dose to any non-metabolic 

organ) for internal exposures. NIOSH’s dose reconstruction included a total of 94 dose entries 

for determining the POC. Appendix A of this report is a reproduction of the IREP input, which 

identifies these doses as exposure entries #1 through #94. Throughout this report, reference will 

be made to select portions of Appendix A; for example, exposure entries #1 through #8 

correspond to the measured external photon dosimeter results, as shown in Table 1 below. 

The audit results are expressed in broad terms of whether we found the exposures to have been 

derived in compliance with applicable procedures, and in a scientifically valid and claimantfavorable manner. Using the dose estimate derived by NIOSH, the POC was determined by the 

Department of Labor (DOL) to be 3.19% at the 99% confidence interval, and on this basis, the 

claim was denied. 

Table 1. Summary of Internal/External Exposures as Estimated by NIOSH 

Appendix A 

Exposure Entry No.

Dose 

(rem) 

External Dose: 

 ▪ Photon Dosimeter Dose 1 – 8 0.174 

 ▪ Photon Missed Dose 53 – 67 0.298 

 ▪ Neutron Dosimeter Dose 9 – 10 0.175 

 ▪ Neutron Missed Dose 68 – 70 0.848 

 ▪ Occupational Medical 83 – 94 0.079 

 ▪ Onsite Ambient 71 – 82 0.610 

Internal Dose (Hypothetical): 

 ▪ Tritium 41 – 52 0.596 

 ▪ All Other Radionuclides 11 – 40 1.181 

Total 3.961 

1.1 AUDIT OBJECTIVES 

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

Savannah River Site Case #PIID* 5 S. Cohen & Associates 
• To determine if NIOSH assigned doses that are consistent with monitoring 

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

report 

• To determine if the dose reconstruction process complied with applicable 

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

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

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

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

favorable 

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

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

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

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

procedures, models, site-specific data, and assumptions NIOSH used to perform its dose 

reconstruction. The second step of the audit critically evaluates whether the methods employed 

by NIOSH are technically defensible, consistent with applicable procedures, and claimant 

favorable. 

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

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

1.2 SUMMARY OF AUDIT FINDINGS 

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

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

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

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

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

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

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

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

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

follows. 

Savannah River Site Case #PIID* 6 S. Cohen & Associates 
Table 2. Case Review Checklist 

CASE PIID* ASSIGNED DOSE: 3.961 rem POC: 3.19% 

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

A. REVIEW OF DATA COLLECTION: 

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

AWE site from any relevant data source? T

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

make a determination with regard to POC? T

B. REVIEW OF INTERVIEW AND DOCUMENTATION PROVIDED BY CLAIMANT 

B.1 Did NIOSH properly address all work history 

dates/locations of employment reported by claimant? T

B.2 Did NIOSH properly address all 

incidents/occurrences reported by claimant? T T

B.3 Did NIOSH properly address monitoring/ personal 

protection/work practices reported by claimant? T

B.4 Is the interview information consistent with data used 

for dose estimate? T

C. REVIEW OF PHOTON DOSES 

C.1 Was the appropriate procedure used for determining: 

C.1.1 - Recorded Photon Dose? T

C.1.2 - Missed Photon Dose? T

C.1.3 - Occupational Medical Dose? T

C.1.4 - Onsite-Ambient Dose? T

C.2 Did the DR properly account for all: 

C.2.1 - Recorded Photon Dose? T

C.2.2 - Missed Photon Dose? T

C.2.3 - Occupational Medical Dose? T

C.2.4 - Onsite-Ambient Dose? T

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

C.3.1 - Recorded Photon Dose? T

C.3.2 - Missed Photon Dose? T

C.3.3 - Occupational Medical Dose? T

C.3.4 - Onsite-Ambient Dose? T

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

C.4.1 - Recorded Photon Dose? T

C.4.2 - Missed Photon Dose? T

C.4.3 - Occupational Medical Dose? T

C.4.4 - Onsite-Ambient Dose? T

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

D.1 Was the appropriate procedure used for determining: 

D.1.1 - Recorded Shallow/Electron Dose? T

D.1.2 - Missed Shallow/Electron Dose? T

D.1.3 - Onsite Ambient Dose? T

D.2 Did the DR properly account for all: 

D.2.1 - Recorded Shallow/Electron Dose? T

D.2.2 - Missed Shallow/Electron Dose? T

D.2.3 - Onsite Ambient Dose? T

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

D.3.1 - Recorded Shallow/Electron Dose? T

 

1 Low means that the deficiency has only a marginal impact on dose. 2 Medium means that the deficiency substantially impacts the dose, but is unlikely to impact the compensability of the case. 3 High means that the deficiency substantially impacts the dose and may also impact the compensability of the case. 

Savannah River Site Case #PIID* 7 S. Cohen & Associates 
CASE PIID* ASSIGNED DOSE: 3.961 rem POC: 3.19% 

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

D.3.2 - Missed Shallow/Electron Dose? T

D.3.3 - Onsite Ambient Dose? T

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

D.4.1 - Recorded Shallow/Electron Dose? T

D.4.2 - Missed Shallow/Electron Dose? T

D.4.3 - Onsite Ambient Dose? T

E. REVIEW OF NEUTRON DOSES 

E.1 Was the appropriate procedure used for determining: 

E.1.1 - Recorded Neutron Dose? T

E.1.2 - Assigned Neutron Dose? T

E.1.3 - Missed Neutron Dose? T

E.2 Did the DR properly account for all: 

E.2.1 - Recorded Neutron Dose? T

E.2.2 - Assigned Neutron Dose? T

E.2.3 - Missed Neutron Dose? T

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

E.3.1 - Recorded Neutron Dose? T

E.3.2 - Assigned Neutron Dose? T

E.3.3 - Missed Neutron Dose? T

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

E.4.1 - Recorded Neutron Dose? T

E.4.2 - Assigned Neutron Dose? T

E.4.3 - Missed Neutron Dose? T

F. REVIEW OF INTERNAL DOSE: BASED ON HYPOTHETICAL MODEL 

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

model appropriate, based on the likely POC value? T

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

appropriate/conservative, based on claimant’s 

available bioassay data,? 

T

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

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

G.1 Was the appropriate procedure (or section of 

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

unlikely (<50%), or undetermined POC and 

compensability? 

T

G.2 Are bioassay data sufficiently adequate for internal 

dose reconstruction? T

G.3 Are assumptions pertaining to dates of uptake 

reasonable/conservative? T

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

size, etc.) used for IMBA organ dose estimates 

appropriate? 

T

G.5 Are assigned uncertainties (measurement errors) for 

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

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

_____________________________ 

1

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

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

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

Savannah River Site Case #PIID* 8 S. Cohen & Associates 
2.0 AUDIT OF EXTERNAL DOSES 

For external exposures to both photons and neutrons, NIOSH assumed that the exposure 

geometry was 100% anterior to posterior (AP). The testes were used as a surrogate organ for 

selection of the dose conversion factors (DCF) from Appendix B of the External Dose 

Reconstruction Implementation Guideline (OCAS-IG-001), which were applied based on 

energies for neutron and photons. 

For photon radiation, 25% <30 keV and 75% 30–250 keV energy ranges were applied, yielding a 

photon DCF of 1.011. For neutron exposures, 100% 0.1–2 MeV energy range was applied, 

along with the 1.91 neutron correction factor, yielding a neutron DCF of 2.495 for the testes. 

2.1 RECORDED PHOTON DOSES 

For measured photon deep dose corresponding to the years PIID*, NIOSH assigned a total dose 

of 174 mrem. SC&A reviewed the monthly DOE dosimeter records and was able to verify each 

of the dose entries, as given for entries #1 through #8 in Appendix A. 

2.1.1 Reviewer’s Comments 

Based on information contained in the Dose Reconstruction (DR) Report and the CATI report, 

the claimant started employment on PIID*. Yearly dosimeter records submitted by the DOE, 

however, only provide data starting in PIID*In fact, the only entry for PIID* is a 10 mrem dose 

recorded for cycle 9 (i.e., PIID*). The absence of DOE dosimeter data for 1984 likely reflects 

the fact that zero measurements at SRS were not documented for the period PIID*to 1988, as 

noted in OCAS-PER-001. It is noted, however, that NIOSH correctly accounted for this 

reporting deficiency by assuming the correct number of missed doses for PIID*. 

2.2 MISSED PHOTON DOSES 

NIOSH assumed a 12-badge cycle per year for photons and estimated a total of 118 zero dose 

records for the full period of employment. The resultant total of missed photon doses of 

298 mrem was derived by means of MDL values contained in Table 5.5.1-1 of ORAUT-TKBS0003. 

Savannah River Site Case #PIID* 9 S. Cohen & Associates 
2.2.1 Reviewer’s Comments 

SC&A independently recalculated all TLD photon doses and verified annual assigned doses cited 

as entries #53 to #67 of Appendix A. 

2.3 RECORDED NEUTRON DOSES 

Measured neutron doses were recorded for the years PIID*. A review of DOE dosimeter records 

shows neutron doses of 40 mrem and 30 mrem for years PIID*, respectively. By means of the 

combined neutron dose correction factor and organ (testes) dose conversion factor of 2.495, 

neutron doses of 99.8 mrem and 74.85 mrem are derived. 

2.3.1 Reviewer’s Comments 

Entries #9 and #10 of Appendix A match these derived values. 

2.4 MISSED NEUTRON DOSES 

NIOSH assigned missed neutron doses for the years PIID*, when the claimant was working at 

the 221 F, B-Line. NIOSH assumed a total of 34 zero neutron recordings and estimated a total 

neutron dose of 848 mrem. 

2.4.1 Reviewer’s Comments 

Our review of DOE dosimeter records for missed neutron doses (i.e., zero recordings) shows that 

this number is correct. In order to verify the above-cited dose, SC&A assumed that NISOH 

employed the following parameters for deriving the total missed neutron dose of 848 mrem: 

Assumptions: 

• Number of zeros found in neutron records: 34 

• LOD for neutron dosimeter: 20 mrem 

(as given in Table 5.5.2-1 of ORAUT-TKBS-0003) 

• (Neutron DCF)(Organ DCF) = 2.495 

Calculation: 

 848 mrem = (34)(20 mrem/2)(2.495) 

This dose estimate for missed neutron doses agrees with data for entries #68 to #70 in 

Appendix A. The methodology also complies with applicable procedures, is scientifically valid, 

and claimant favorable. 

Savannah River Site Case #PIID* 10 S. Cohen & Associates 
2.5 OCCUPATIONAL MEDICAL EXPOSURES 

For occupational medical exposure, NIOSH assumed an x-ray organ dose for each of the 

PIID*years of employment. For all years other than PIID*, the annual testicular dose of 6 

mrem was assigned; for PIID*an annual dose of 8 mrem was assigned per x-ray examination. A 

total occupational medical exposure of 79 mrem was assigned. 

2.5.1 Reviewer’s Comments 

SC&A reviewed default organ values for occupational medical x-rays, as given in Table 2.5.1-1 

of ORAUT-TKBS-0003. This table segregates organ doses into three groupings, with Group 3 

representing the testes. Based on data contained in Table 2.4.1-1, dose entries 83 to 94 comply 

with SRS default values. 

When added, the annual doses for medical x-rays total 76 mrem, which is close to, but lower 

than, the stated value of 79 mrem cited in the text of the DR Report. Ignoring this minor 

discrepancy, the assigned doses comply with procedural data, are scientifically valid, and 

claimant favorable. 

2.6 ONSITE AMBIENT DOSE 

Although the claimant was monitored for external exposure, NIOSH, nevertheless, assigned an 

onsite ambient dose in order to account for any erroneous subtraction of elevated ambient levels 

of external radiation (EALER) that might have been recorded on control badges. 

For onsite ambient doses, NIOSH employed default values, which represent the maximum 

annual onsite doses at SRS, and derived a total dose of 610 mrem. 

2.6.1 Reviewer’s Comments 

SC&A reviewed maximum annual onsite doses for the corresponding years, as defined in 

Table 3.4-1 of ORAUT-TKBS-0003. Entries #71 through #82 of Appendix A match those of 

Table 3.4-1 for corresponding years. These dose entries, therefore, comply with the applicable 

procedure, are scientifically valid, and claimant favorable. 

Savannah River Site Case #PIID* 11 S. Cohen & Associates 
3.0 AUDIT OF INTERNAL DOSES (MISSED DOSE)

NIOSH only calculated internal doses in behalf of missed dose for tritium and for all nuclides 

other than tritium. 

3.1 TRITIUM 

An annual tritium dose was assigned to all years when a tritium dose was not reported or the 

reported dose was less than the default value for a missed tritium dose. Accordingly, NIOSH 

assigned 12 years of missed tritium doses spanning the years PIID*and totaling 596 mrem. 

3.1.1 Reviewer’s Comments 

Review of DOE records shows that the claimant was monitored repetitively for tritium by means 

of urinalysis in the years PIID*. Results of bioassays show levels consistently below 0.100 

μCi/liter. In only two instances, urine levels of 0.7 and 0.3 μCi/liter were observed. These levels 

correspond to organ doses that are well below the organ dose assigned by default values. 

Organ dose default values for SRS are defined in Table 4.5.3-1 of ORAUT-TKBS-0003. SC&A 

reviewed these values and matched them against dose entries #41 to #52 of Appendix A. 

The reconstruction of missed tritium doses, therefore, complied with applicable procedures. The 

assigned doses are also likely to be scientifically valid and claimant favorable. This conditional 

judgment of scientific validity and claimant favorability rests with the assumption that tritium 

exist as tritiated water only. If tritium can be shown/assumed to be in organic form, the longer 

residency time of organified tritium in the body would raise the dose. 

3.2 ALL OTHER NUCLIDES 

For all other nuclides, assigned internal doses that may have gone undetected were also based on 

default values, as provided in Section 4.5.2 of ORAUT-TKBS-0003. Starting with the year of 

employment in PIID* until the year of cancer diagnosis in PIID*, annual organ doses were 

assigned. These doses are defined by entries #11 to #40 of Appendix A and correspond to a total 

dose of 1.181 rem. 

3.2.1 Reviewer’s Comments 

SC&A reviewed the default values cited in Table 4.5.1-1 of ORAUT-TKBS-0003 and verified 

that all entries in the DR Report matched those of Table 4.5.1-1. 

It is concluded that NIOSH used the correct procedure and default values for missed internal 

doses for nuclides other than tritium. 

A review of the method by which default values were derived, however, raises some concern 

about the scientific validity and claimant favorability of these default values. The following 

Savannah River Site Case #PIID* 12 S. Cohen & Associates 
provides a brief explanation and defines the potential magnitude of underestimated internal 

doses. 

For radionuclides other than tritium, default values are based on the “high five” approach. 

Radionuclide-specific high five values were derived from data contained in ORAUT-OTIB0001. In brief, ORAUT-OTIB-0001 models intakes that are based on ICRP 30 biogenetic 

models instead of current ICRP 68 models, as required in 42 CFR 82. We believe that the use of 

ICRP 30 calculated intakes may not be claimant favorable for several important radionuclides, 

and that ICRP 68 models should have been used to derive intakes. 

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

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

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

Site Profile). 

Savannah River Site Case #PIID* 13 S. Cohen & Associates 
4.0 CATI REPORT AND RADIOLOGICAL INCIDENTS 

NIOSH briefly acknowledged two radiological incidents cited in the CATI report. While the 

CATI specifically identifies two separate radiological incidents – the first in PIID* and the 

second in PIID* – there is no mention/documentation of these incidents in the DOE records. It 

is, therefore, uncertain whether these incidents actually occurred or whether appropriate records 

are missing from the DOE files. (On the cover page of NIOSH’s Request for Personnel 

Exposure Information, DOE checked the box indicating that these records do not exist.) 

The NIOSH DR Report provides no insight as to whether there was any follow-up conversation/ 

communication with either the claimant or DOE to resolve this matter. 

Based on the nature of the radiological incidents and the worker’s claim that no investigation or 

bioassays were performed for either incident, the potential exists that internal exposures were not 

accounted for. 

SC&A, however, does acknowledge that the NIOSH-assigned hypothetical internal doses for 

tritium and other nuclides are likely to be significantly greater than those that may have resulted 

from these incidents, which obviates the need for further investigation. 

Savannah River Site Case #PIID* 14 S. Cohen & Associates 
5.0 SUMMARY CONCLUSIONS 

This dose reconstruction demonstrates the level of detail and extensive effort that NIOSH is 

required to satisfy the regulatory and procedural requirements in behalf of EEOICPA. 

In general, the dose reconstruction was thorough, procedurally compliant, scientifically valid, 

and claimant favorable. The two issues that may require further discussion are generic issues 

that affect not only this case, but potentially many other SRS cases; these include (1) the failure 

to consider tritium in organic form, and (2) the use of ICRP 30 biogenetic models for deriving 

hypothetical internal exposure to radionuclides other than tritium. 

Savannah River Site Case #PIID* 15 S. Cohen & Associates 
REFERENCES 

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

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

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

Department of Energy (U.S.) (DOE). 1997. “Integrated Data Base Report − 1996: U.S. Spent 

Nuclear Fuel and Radioactive Waste Inventories, Projections, and Characteristics.” Revision 13. 

Office of Environmental Management. DOE/RW-0006. 

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

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

Elmsford, NY: Pergamon Press. 

International Commission on Radiological Protection (ICRP). 1991. “1990 Recommendations of 

the International Commission on Radiological Protection.” ICRP Publication 60. Annals of the 

ICRP, 21(1/3). Tarrytown, NY: Elsevier Science, Inc. 

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

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

Tarrytown, NY: Elsevier Science, Inc. 

OCAS-IG-001. 2002. “External Dose Reconstruction Implementation Guideline,” 

Rev 1. National Institute of Occupational Safety and Health, Office of Compensation Analysis 

and Support, Cincinnati, Ohio. 

OCAS-PER-001. 2003. "Error in Surrogate Organ Assignment Resulting in an Underestimate 

of X-ray Dose in SRS Dose Reconstruction," Rev. 0. National Institute of Occupation Safety 

and Health, Office of Compensation Analysis and Support. Cincinnati, Ohio. 

 

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

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

Team, Cincinnati, Ohio. 

ORAUT-OTIB-0005. 2004. “Technical Information Bulletin: IMBA Organ, External 

Dosimetry Organ, and IREP Model Selection by ICD-9 Code,” Rev. 01. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. 

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

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

 

Savannah River Site Case #PIID* 16 S. Cohen & Associates 
APPENDIX A: IREP INPUT

Deletions made to the following table -- please see hard copy labeled "#13 – Savannah River 

Site" 

Savannah River Site Case #PIID* 17 S. Cohen & Associates 
APPENDIX A (continued) 

Deletions made to the following table -- please see hard copy labeled "#13 – Savannah River 

Site" 

Savannah River Site Case #PIID* 18 S. Cohen & Associates