REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute of Occupational Safety and Health 

Audit of Case PIID* from Hanford 

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 HANFORD Page 2 of 21 

Task Manager: ___________________ Date: 02/04/05 

 U. Hans Behling, PhD, MPH 

Project Manager: _________________ Date: 02/04/05 

 John Mauro, PhD, CHP 

Supersedes: 

Draft Rev. 0 

Hanford Case PIID* 2 S. Cohen & Associates
TABLE OF CONTENTS 

1.0 Relevant Background Information...................................................................................... 4 

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

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

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

2.1 Photon Dose............................................................................................................ 8 

2.1.1 Recorded Photon Dose................................................................................ 8 

2.1.2 Missed Photon Doses.................................................................................. 8 

2.2 Missed Neutron Doses ............................................................................................ 9 

2.3 Occupational Medical Exposure........................................................................... 10 

2.3.1 Reviewer’s Comments.............................................................................. 11 

2.4 Onsite Ambient Dose............................................................................................ 12 

3.0 Internal Dose..................................................................................................................... 13 

3.1 Comments Pertaining to the Applicability of ORAUT-OTIB-0002 for 

Lymphoid Tissue that may be Associated with the Lung..................................... 14 

4.0 CATI Report and Radiological Incidents ......................................................................... 17 

5.0 Summary Conclusions ...................................................................................................... 18

References..................................................................................................................................... 19 

Appendix A: IREP Input.............................................................................................................. 20 

Hanford Case PIID* 3 S. Cohen & Associates
1.0 RELEVANT BACKGROUND INFORMATION 

This report presents an independent audit of a Dose Reconstruction (DR) Report performed by 

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

has worked as an PIID* at the Hanford Site from PIID* to the present. On PIID*, the energy 

employee was diagnosed with Hodgkin’s disease. 

Throughout the PIID* of consideration, the claimant had been monitored for external exposure 

on a monthly basis by TLD. For internal assessment, claimant was given a baseline and yearly 

whole-body counts. NIOSH’s dose reconstruction included a total of 54 exposure data entries to 

be used for determining the probability of causation. These dose data entries are reproduced 

herein as Appendix A. Throughout this report, reference will be made to select portions of 

Appendix A; for example, exposure entries #51 through #54 correspond to occupational medical 

exposure. 

Summarized in Table 1 below are dose estimates derived by NIOSH’s that correspond to data 

contained in Appendix A. Using the dose estimate derived by NIOSH, the probability of 

causation (POC) was determined by the Department of Labor (DOL) to be 4.77% at the 99% 

confidence interval, and on this basis, the claim was denied. 

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

Appendix A 

Exposure Entry No.

Dose 

(rem) 

External Dose: 

 ▪ Photon Dosimeter Dose NC* — 

 ▪ Missed Photon Dose 31 – 40 0.840 

 ▪ Neutron Dosimeter Dose NC* — 

 ▪ Missed Neutron Dose NC* — 

 ▪ Occupational Medical: 51 – 54 0.021 

 ▪ Onsite Ambient 41 – 50 0.295 

Internal Dose (Hypothetical): 1 – 30 9.762 

Total: 10.918 

 *NC – Not considered. 

1.1 AUDIT OBJECTIVES 

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

• To determine if assigned doses are consistent with monitoring records provided 

by the DOE and 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 Hanford 

Hanford Case PIID* 4 S. Cohen & Associates
• 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 evaluates whether the methods employed by 

NIOSH are consistent with applicable procedures, scientifically defensible, 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.

Hanford Case PIID* 5 S. Cohen & Associates
Table 2. Case Review Checklist 

CASE PIID* ASSIGNED DOSE: 10.918 rem POC: 4.77% 

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

A. REVIEW OF DATA COLLECTION: 

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

AWE site from any relevant data source? T

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

make a determination with regard to POC? T

B. REVIEW OF INTERVIEW AND DOCUMENTATION PROVIDED BY CLAIMANT 

B.1 Did NIOSH properly address all work history 

dates/locations of employment reported by claimant? T

B.2 Did NIOSH properly address all 

incidents/occurrences reported by claimant? T

B.3 Did NIOSH properly address monitoring/ personal 

protection/work practices reported by claimant? T

B.4 Is the interview information consistent with data used 

for dose estimate? T

C. REVIEW OF PHOTON DOSES 

C.1 Was the appropriate procedure used for determining: 

C.1.1 - Recorded Photon Dose? T

C.1.2 - Missed Photon Dose? T

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 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 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. 

Hanford Case PIID* 6 S. Cohen & Associates
CASE PIID* ASSIGNED DOSE: 10.918 rem POC: 4.77% 

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 2 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. 

Hanford Case PIID* 7 S. Cohen & Associates
. 

2.0 AUDIT OF EXTERNAL DOSES 

2.1 PHOTON DOSE 

2.1.1 Recorded Photon Dose 

Based on assigned duties that had the potential for external exposure, the claimant was 

monitored on a monthly change-out schedule for the full PIID* period under consideration. 

External dose records submitted by the DOE provide a complete record of the claimant’s 

external exposure. A review of DOE records shows that the claimant had no monthly dosimeter 

readings that were positive. Thus, external photon exposures were limited to missed photon dose 

estimates (see Exhibit 1). 

2.1.2 Missed Photon Doses 

Of relevance to this case are exposures recorded as deep dose (HP(10)). The claimant’s Dose 

Reconstruction report states that: 

. . . For the purpose of estimating probability of causation, all photon doses, 

except on-site ambient are assumed to be acute as this maximizes probability of 

causation . . . [Emphasis added.] 

And, 

For the purposes of this dose reconstruction, the distribution of . . . exposure 

geometry and radiation energies was selected to maximize dose. To ensure that 

the estimated dose has been maximized, an organ dose conversion factor of 1 has 

been applied. To maximize the probability of causation, a photon energy range of 

100% 30–250 keV was applied. 

A review of the claimant’s external photon dosimeter data shows that for the entire PIID*

monitoring period, there were no positive dosimeter readings. Correspondingly, estimates of 

external deep-dose photon exposure were based on missed dose assumed for monthly 

dosimeters’ minimum detectable limits (MDLs), as provided in Table 6-30 of ORAUT-TKBS0006-2. Table 6-30 identifies the following MDLs. 

Period Of Use

MDL 

(mrem)

Maximum Annual 

Missed Dose (mrem)

PIID* 20 120 

PIID* 10 60 

Missed doses for the claimant’s PIID* period for monitoring were calculated at 840 mrem 

((4 yrs x 120 mrem/yr) + (6 yrs x 60 mrem/yr) = 840 mrem). 

The selected method for estimating missed photon doses was based on the LOD/2, which defines 

a central value along with an uncertainty that assumes a lognormal distribution with a geometric 

Hanford Case No. PIID* 8 S. Cohen & Associates 
. 

standard deviation of 1.52. The generic geometric standard deviation was derived by the 

following formula: 

 

52.1

2

2/

50

95

6558.1/1

)6558.1/1(

=

=

=

=

LOD

tissueLOD

percentile

percentile GSD th

th

 

This generic approach is recommended by OCAS-IG-001, ORAUT-PROC-0006, and ORAUTTKBS-0006-6. Thus, for missed photon exposure, the DR Report followed procedural 

recommendations and assigned the correct missed doses. 

2.2 MISSED NEUTRON DOSES 

In reviewing the DOE dosimetry records for this case, there is the potential that the DR Report 

may have underestimated the missed neutron doses. The Radiological Exposure Individual 

Dosimeter History Report for Case PIID* (see Exhibit 1) identifies the annual neutron dose as 

zero for the entire PIID* employment period of concern. This implies that the claimant was 

monitored for neutrons. However, the DR Report failed to account for any missed neutron 

doses. It should be noted that the claimant’s work location included the Hanford PIID*. 

Moreover, Exhibit 1 shows positive ring dosimeter results, which suggests that the energy 

employee may have been exposed to Pu and, therefore, to neutrons. 

As stated in the Hanford Technical Basis Document, ORAUT-TKBS-0006-6, missed neutron 

doses should be calculated based on MDLs of the dosimeters in use at the time. Table 6-31 of 

ORAUT-TKBS-0006-6 identifies the MDL and maximum annual missed dose for the periods of 

concern as follows: 

Period Of Use

MDL 

(mrem)

Maximum Annual 

Missed Neutron Dose

(mrem)

Total Missed 

Neutron Dose 

(mrem)

PIID* 50 300 1,500 

PIID* 15 100 500 

2,000 

Using this procedural guidance, the missed neutron dose for the claimant’s PIID* monitoring 

period should have been 2,000 mrem ((5 years)(300 mrem) + (5 years)(100 mrem) = 2,000 

mrem). 

Hanford Case No. PIID* 9 S. Cohen & Associates 
. 

Exhibit 1 

Deletions made to the following table – please see hard copy labeled “#7-Hanford” 

2.3 OCCUPATIONAL MEDICAL EXPOSURE 

A total dose of 0.021 rem (21 mrem) was assigned to lymphatic tissue from external 

occupational medical exposure for the PIID* period, with the following explanations given in the 

claimant’s Dose Reconstruction report: 

The external dose to the lymphatic tissue was determined by using the dose 

calculated for the remainder organ. There is no existing model that calculates 

external dose to the lymphatic tissue. [Emphasis added.] 

and, 

Occupational Medical Dose 

 In addition to the estimated dose received from site operations, the dose received 

from diagnostic X-ray procedures that were required as a condition of 

employment was also included in the overall dose to the lymphatic tissue. Based 

on information in the External Dose Reconstruction procedure6

 and an assumed 

annual X-ray procedure each year of employment up to the date of cancer 

diagnosis, a total X-ray dose of 0.021 rem was assigned. This X-ray dose is 

considered claimant favorable as it likely exceeds the true X-ray dose to the 

lymphatic tissue. [Emphasis added.] 

Hanford Case No. PIID* 10 S. Cohen & Associates 
. 

and, 

The actual doses to the lymphatic tissue from occupational medical X-ray

procedures are likely to be smaller than were calculated based on the maximizing 

assumptions used in this dose reconstruction. [Emphasis added.] 

No additional information was provided, and the above-cited Reference 6 is given as ORAUTPROC-0006, “External Dose Reconstruction,” Revision 00, June 27, 2003 in the report’s 

Reference List. 

2.3.1 Reviewer’s Comments 

As stated above, the assigned organ dose of 21 mrem was described in the text of the DR Report 

as representing a total of 10 medical x-rays. This value is in error, as explained below. 

• Outdated Reference. Reference #6 in the DR Report identifies ORAUT-PROC0006, Rev. 00, June 27, 2003. Rev. 00, June 27, 2003, does not contain the cited 

“Attachment E.” Attachment E was not added to ORAUT-PROC-0006 until 

November 2003, along with a subsequent revision in December. Reference #6 in 

the DR Report should, therefore, have identified ORAUT-PROC-0006 with an 

effective date of December 11, 2003, and a Revision No. 00 PC-2. 

• Table 2 of Attachment E of ORAUT-PROC-0006 contains organ doses for PA 

chest x-ray exams by year. Organ doses are categorized into three groupings and 

by year. Although organ doses are considered “high,” the dose reconstructor may 

further maximize the dose by multiplying the organ dose by 1.3 and enter the dose 

as a constant. 

 Lymphoid tissue in the chest cavity should have been defined as a Group 2 tissue 

instead of Group 3. For the PIID* period between PIID* and PIID*, the 

occupational medical x-ray dose of 161 mrem should have been entered as 

follows: 

Year Organ Dose (mrem)

PIID* constant 18 

PIID* constant 18 

PIID* constant 18 

PIID* constant 18 

PIID* constant 18 

PIID* constant 18 

PIID* constant 18 

PIID* constant 15 

PIID* constant 10 

PIID* constant 10 

Total 161 

Hanford Case No. PIID* 11 S. Cohen & Associates 
. 

In summary, the assigned dose of 21 mrem is not claimant favorable and clearly conflicts with 

statements contained in the DR Report; secondly, the dose reconstructor failed to assign the 

proper Group 2 dose, as defined in ORAUT-PROC-0006. 

2.4 ONSITE AMBIENT DOSE 

Ambient onsite external exposures that may result from plume immersion, stack releases, 

environmental surface contamination, and other sources are generally only included for 

unmonitored workers or for monitored workers with missing dosimetry data. 

Although the claimant was continuously monitored, which should have recorded any elevated 

ambient levels of external radiation (EALER), onsite ambient doses were, nevertheless, assigned. 

For the assignment of ambient onsite dose, the DR Report made use of historical onsite dose rate 

measurements, as summarized in Table 4.3.1-1 of ORAUT-TKBS-0006-4. To maximize 

claimant favorability, the onsite location with the highest average annual dose was selected 

without regard to claimant’s actual work location(s). Additional claimant-favorable assumptions 

included a correction factor of 1.3 that represented an increase of the number of annual work 

hours from 2,000 hours to 2,600 hours and an organ dose conversion factor of 1. 

For the PIID* period of employment, the following maximum average annual onsite ambient 

doses were identified in Table 4.3.1-1 of ORAUT-TKBS-0006-4 for a 2,000 hr/yr and 2,600 

hr/yr. 

Year

Max. Avg. Annual

Dose for 2,000 hr 

(mrem)

Dose Adjusted to 

2,600 hr/yr

PIID* 27 35 

PIID* 24 31 

PIID* 23 30 

PIID* 28 36 

PIID* 20 26 

PIID* 20 26 

PIID* 20 26 

PIID* 21 27 

PIID* 22 29 

PIID* 22 29 

Total 295 

These claimant-favorable maximum estimates of annual onsite ambient doses were in fact 

assigned as annual organ doses, as shown in Appendix A, exposure entries #41-#50. 

Hanford Case No. PIID* 12 S. Cohen & Associates 
. 

3.0 INTERNAL DOSE 

Records indicate that the claimant was monitored for internal dose by means of whole-body 

counting. In addition to a baseline whole-body count (WBC) at time of initial employment in 

PIID*, claimant was subject to periodic whole-body counting for the years PIID* through PIID* 

None of the in vivo measurements resulted in radionuclide body burdens above minimum 

detectable activity (MDA). 

A simple QA check that suggests proper operation of the whole-body counting systems is the 

recorded level of the naturally occurring isotope potassium-40 (K-40). The WBCs showed levels 

of K-40 that were consistent over time and commensurate with the claimant’s sex, age, and body 

weight. 

To account for any potential undetected dose, an internal dose was assigned based on 

hypothetical intake, as defined in ORAUT-OTIB-0002, Technical Information Bulletin – 

Maximum Internal Dose Estimates for Certain DOE Complex Claims, Rev. 01. 

The purpose of procedure ORAUT-OTIB-0002 is to provide a method that employs worst-case 

assumptions in order to expedite the processing of claims in instances with little or no reported 

internal dose to the tissue/organ under evaluation. On the basis of conservative/claimantfavorable parameter assumptions, this procedure models internal organ doses for a single acute 

inhalation uptake at time of hire for 12 radionuclides for sites without a reactor, and 28 

radionuclides for sites with a reactor. For calculating organ doses, each of the radionuclides is 

characterized for radiation type (i.e., alpha, electron >15 keV, or photon >250 keV). For this 

case, maximum internal organ doses were derived for 28 radionuclides. 

As a benefit to the dose reconstructor and to facilitate data entry into the IREP computer code, 

NIOSH has developed an Excel® workbook entitled Maximum Internal Dose Calculation 

Workbook.xls. 

As part of this review, the maximum internal dose to the lymphatic tissue was recalculated by 

means of the Excel® workbook. It should be noted that Table 3.1.1-4 of ORAUT-OTIB-0002 

does not list lymphatic tissues among the 15 organs; however, in Section 4.0 Applications and 

Limitations of the TIB, the following conditional application is stated: “. . . The target organ 

must be listed in Table 3.1.1-4 or must be an organ whose dose is based on the highest nonmodeled organ dose.” 

Among the 15 organs modeled in ORAUT-OTIB-0002, the colon yields the highest dose and 

was, therefore, used as the surrogate tissue for estimating maximum internal dose to the 

lymphatic tissue. Exhibit 2 summarizes the maximum estimated internal dose to the lymphatics 

for 28 radionuclides. Our estimated dose of 9.762 rem matches the dose cited in Attachment 1 of 

the DR Report (see exposure entries #1 through #30 of Appendix A). 

Hanford Case No. PIID* 13 S. Cohen & Associates 
. 

3.1 COMMENTS PERTAINING TO THE APPLICABILITY OF ORAUT-OTIB-0002 

FOR LYMPHOID TISSUE THAT MAY BE ASSOCIATED WITH THE LUNG 

In general, the use of ORATU-OTIB-0002 for estimating maximum internal doses for certain 

DOE complex claims must be regarded as highly conservative and favorable to the claimant. An 

exception, however, may involve a case in which the target tissue involves specific tissues/lymph 

nodes of the lymphatic system on the basis of anatomical location, as explained below. 

Dose estimates derived by procedure ORAUT-OTIB-0002 represent non-metabolic organ doses, 

which may reasonably serve as surrogate values for most lymphatic tissues except those 

associated with the lungs. Materials deposited into the lung are cleared by three main routes that 

include (1) absorption into blood, (2) ciliary-mucus transport into the gastrointestinal tract, and 

(3) endocytotic uptake by either phagocytosis or pinocytosis. Pinocytosis is followed by transfer 

to the lymphatic system and lymph nodes associated with the lung. As noted in ICRP 

Publication 66 (page 154): 

Macrophages that have phagocytised particulate matter may enter lymphatics 

and are then transported into lymph nodes, where they can stay for long periods

of time. . . [Emphasis added.] 

The potential for high doses to lymph nodes associated with the lung is also acknowledged in 

OCAS-IG-002 (page 11): 

. . . insoluble compounds often cause the lymph nodes associated with the lungs to 

receive high doses, often the highest dose of any organ. Because lymph nodes in 

the lung are considered to retain radioactive material almost indefinitely, the 

material is not transferred throughout the lymphatic system. This means that 

lymphatic cancers not associated with lymph nodes of the lungs . . . [should be 

assigned] . . . the highest exposed organ that is not described by the ICRP 

metabolic models . . . as the appropriate dose. [Emphasis added.] 

Hanford Case No. PIID* 14 S. Cohen & Associates 
. 

Exhibit #2. Maximum Internal Dose for Case PIID* Based on Methodology Defined in 

Procedure No. ORAUT-OTIB-0002 

Enter first exposure year in cell 

H3, for IREP input format PIID* PIID*

Copy internal dose data from the first year 

through the year of cancer diagnosis 

Exposure Year Exposure Rate Radiation Type 

Dose 

Distribution 

Type 

Parameter 1 Parameter 2 Parameter 3 

PIID* chronic alpha Constant 7.69E-01 0 0 

PIID* chronic electrons E>15keV Constant 4.46E+00 0 0 

PIID* chronic photons E>250keV Constant 1.52E+00 0 0 

PIID* chronic alpha Constant 2.65E-01 0 0 

PIID* chronic electrons E>15keV Constant 1.93E-01 0 0 

PIID* chronic photons E>250keV Constant 1.52E-01 0 0 

PIID* chronic alpha Constant 2.59E-01 0 0 

PIID* chronic electrons E>15keV Constant 9.13E-02 0 0 

PIID* chronic photons E>250keV Constant 4.16E-02 0 0 

PIID* chronic alpha Constant 2.53E-01 0 0 

PIID* chronic electrons E>15keV Constant 6.53E-02 0 0 

PIID* chronic photons E>250keV Constant 1.57E-02 0 0 

PIID* chronic alpha Constant 2.49E-01 0 0 

PIID* chronic electrons E>15keV Constant 5.20E-02 0 0 

PIID* chronic photons E>250keV Constant 8.10E-03 0 0 

PIID* chronic alpha Constant 2.45E-01 0 0 

PIID* chronic electrons E>15keV Constant 4.28E-02 0 0 

PIID* chronic photons E>250keV Constant 4.96E-03 0 0 

PIID* chronic alpha Constant 2.43E-01 0 0 

PIID* chronic electrons E>15keV Constant 3.57E-02 0 0 

PIID* chronic photons E>250keV Constant 3.32E-03 0 0 

PIID* chronic alpha Constant 2.40E-01 0 0 

PIID* chronic electrons E>15keV Constant 2.98E-02 0 0 

PIID* chronic photons E>250keV Constant 2.29E-03 0 0 

PIID* chronic alpha Constant 2.38E-01 0 0 

PIID* chronic electrons E>15keV Constant 2.50E-02 0 0 

PIID* chronic photons E>250keV Constant 1.64E-03 0 0 

PIID* chronic alpha Constant 2.37E-01 0 0 

PIID* chronic electrons E>15keV Constant 2.11E-02 0 0 

PIID* chronic photons E>250keV Constant 1.20E-03 0 0 

 TOTAL INTERNAL ORGAN DOSE* = 9.76218 

* It should be noted that ORAUT-OTIB-0002 does not identify lymphatic tissue among the 15 organs 

 for which a maximum internal dose is calculated. For this reason, the above-cited internal organ doses 

 were derived for the colon, which is considered an appropriate surrogate organ for lymphatic tissue. 

Hanford Case No. PIID* 15 S. Cohen & Associates 
. 

In brief, while the use of a non-metabolic organ dose as a surrogate for lymphatic cancers may be 

applied to lymphatic tissues/lymph nodes not associated with the lung, such a non-metabolic 

surrogate organ dose would significantly underestimate the dose to lymphatic tissue and lymph 

nodes that are associated with the lungs. It should further be noted that for lymphatic tissues that 

are associated with the lung, claimant-favorable dose estimates should be based on an 

assumption of radionuclide insolubility (i.e., Type S). 

As a final note, a substantial number of ICD-9 codes describe cancers of the lymph system 

without identifying their anatomical/physiological relationship to the lung. 

Relevant to the review of this case is the indeterminacy as to whether or not this lymphatic 

cancer is associated with the lung. In response to this concern, NIOSH confirmed that for Case 

PIID*, the lymphoid tissue was not associated with the lung, and the assigned hypothetical dose 

is, therefore, correct. 

Hanford Case No. PIID* 16 S. Cohen & Associates 
. 

4.0 CATI REPORT AND RADIOLOGICAL INCIDENTS 

The CATI report was reviewed for consistency with DOE-submitted records and the NIOSH DR 

Report. The CATI report identifies that the energy employee was monitored for internal 

exposure by means of urinalysis. However, neither the DOE records nor the DR Report makes 

mention of such monitoring data. The absence of documented radiological incidents and 

NIOSH’s assignment of a hypothetical internal dose adequately addresses any potential 

exposures that can reasonably be attributed to this discrepancy. 

For this case, there were no formal records involving radiological incidents submitted by the 

DOE. In the report that summarizes the telephone interview with the claimant, the response was 

negative. It can therefore be concluded that there were no radiological incidents that could 

significantly add to the claimant’s exposure. 

Hanford Case No. PIID* 17 S. Cohen & Associates 
. 

5.0 SUMMARY CONCLUSIONS 

Official records submitted by the DOE indicate that claimant was provided radiological 

monitoring for the relevant PIID* employment period. External monitoring consisted of monthly 

TLDs, and internal monitoring consisted of a baseline and yearly whole-body counts. Neither 

TLDs nor WBC data revealed exposures above their detection limits. For the PIID* period, 

official records show only two medical chest x-rays that are regarded as occupational medical 

exposures. 

In support of reconstructing an organ dose from external sources, 840 mrem was assigned as 

missed photon dose in behalf of 120 zero dosimeter readings, 295 mrem was assigned to onsite 

ambient dose, and 21 mrem was assigned for occupational medical exposure. The external 

photon dose and onsite ambient dose estimates are consistent with stated assumptions in the DR 

Report and/or official records, and comply with the claimant-favorable/process-efficient methods 

prescribed for cases with a low probability of compensability. 

In order to account for potential undetected internal organ doses, the dose reconstruction 

employed a hypothetical model defined in ORAUT-OTIB-0002 and assigned an organ dose of 

9.762 rem. On the assumption that the lymphatic tissue is not associated with the lung, this 

hypothetical model and the assigned organ dose of 9.762 rem must be regarded as highly 

claimant favorable. 

Since the hypothetical internal organ dose of 9.762 rem represents nearly 90% of the total 

assigned dose of 10.918 rem, it is reasonable to conclude that the actual organ dose was 

considerably smaller. 

The DR Report assumptions that are not considered claimant favorable include (1) neglecting to 

assign any missed neutron dose, which, based on procedural guidance, would have resulted in an 

additional external dose of 2,000 mrem, and (2) the assignment of an occupational medical dose 

of 21 mrem for 10 x-ray exams. 

Hanford Case No. PIID* 18 S. Cohen & Associates 
. 

REFERENCES

OCAS-IG-001. 2002. “External Dose Reconstruction Implementation Guide,” Rev. 1. National 

Institute for Occupational Safety and Health, Office of Compensation Analysis and Support. 

Cincinnati, Ohio. 

OCAS-IG-002. 2002. “Internal Dose Reconstruction Implementation Guide,” Rev. 0. National 

Institute for Occupational Safety and Health, Office of Compensation Analysis and Support. 

Cincinnati, Ohio. 

ORAUT-PROC-0006. 2003. “External Dose Reconstruction,” Rev. 00. Oak Ridge Associated 

Universities Team. Cincinnati, Ohio. 

ORAUT-OTIB-0002. 2004. “Technical Basis Document: Maximum Internal Dose Estimates 

for Certain DOE Complex Claims,” Rev. 01. Oak Ridge Associated Universities Team. 

Cincinnati, Ohio. 

ORAUT-OTIB-0006. 2003. “Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Diagnostic X-ray Procedures,” Rev. 02. Oak Ridge Associated 

Universities Team. Cincinnati, Ohio. 

ORAUT-TKBS-0006-3. 2004. “Technical Basis Document for the Hanford Site – Occupational 

Medical Exposure,” Rev. 01. Oak Ridge Associated Universities Team. Cincinnati, Ohio. 

ORAUT-TKBS-0006-4. 2004. “Technical Basis Document for the Hanford Site – Occupational 

Environmental Dose,” Rev. 01. Oak Ridge Associated Universities Team. Cincinnati, Ohio. 

ORAUT-TKBS-0006-6. 2004. “Technical Basis Document for the Hanford Site – Occupational 

External Dosimetry,” Rev. 01. Oak Ridge Associated Universities Team. Cincinnati, Ohio. 

Hanford Case No. PIID* 19 S. Cohen & Associates 
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APPENDIX A: IREP INPUT 

The following information was obtained from the NIOSH Dose Reconstruction Report. This 

information was used as the input file for IREP.

CLAIMANT CANCER DIAGNOSIS 

 

Primary 

Cancer #1 

Primary 

Cancer #2 

Primary 

Cancer #3 

Secondary 

Cancer #1 

Secondary 

Cancer #2 

Secondary 

Cancer #3 

Cancer Type 

Hodgkin's 

Disease N/A N/A N/A N/A N/A 

Date of Diagnosis PIID* N/A N/A N/A N/A N/A 

 

EXPOSURE 

INFORMATION 

Number of exposures 

54 

Exposure # 

Exposure 

Year 

Exposure 

Rate Radiation Type 

Dose 

Distribution 

Type Parameter 1 Parameter 2 Parameter 3

1 PIID* chronic alpha Constant 0.769 0.000 0.000 

2 PIID* chronic alpha Constant 0.265 0.000 0.000 

3 PIID* chronic alpha Constant 0.259 0.000 0.000 

4 PIID* chronic alpha Constant 0.253 0.000 0.000 

5 PIID* chronic alpha Constant 0.249 0.000 0.000 

6 PIID* chronic alpha Constant 0.245 0.000 0.000 

7 PIID* chronic alpha Constant 0.243 0.000 0.000 

8 PIID* chronic alpha Constant 0.240 0.000 0.000 

9 PIID* chronic alpha Constant 0.238 0.000 0.000 

10 PIID* chronic alpha Constant 0.237 0.000 0.000 

11 PIID* chronic photons E>250keV Constant 1.519 0.000 0.000 

12 PIID* chronic photons E>250keV Constant 0.152 0.000 0.000 

13 PIID* chronic photons E>250keV Constant 0.042 0.000 0.000 

14 PIID* chronic photons E>250keV Constant 0.016 0.000 0.000 

15 PIID* chronic photons E>250keV Constant 0.008 0.000 0.000 

16 PIID* chronic photons E>250keV Constant 0.005 0.000 0.000 

17 PIID* chronic photons E>250keV Constant 0.003 0.000 0.000 

18 PIID* chronic photons E>250keV Constant 0.002 0.000 0.000 

19 PIID* chronic photons E>250keV Constant 0.002 0.000 0.000 

20 PIID* chronic photons E>250keV Constant 0.001 0.000 0.000 

21 PIID* chronic electrons E>15keV Constant 4.458 0.000 0.000 

22 PIID* chronic electrons E>15keV Constant 0.193 0.000 0.000 

23 PIID* chronic electrons E>15keV Constant 0.091 0.000 0.000 

24 PIID* chronic electrons E>15keV Constant 0.065 0.000 0.000 

25 PIID* chronic electrons E>15keV Constant 0.052 0.000 0.000 

26 PIID* chronic electrons E>15keV Constant 0.043 0.000 0.000 

27 PIID* chronic electrons E>15keV Constant 0.036 0.000 0.000 

28 PIID* chronic electrons E>15keV Constant 0.030 0.000 0.000 

29 PIID* chronic electrons E>15keV Constant 0.025 0.000 0.000 

Hanford Case PIID* 20 S. Cohen & Associates 
. 

30 PIID* chronic electrons E>15keV Constant 0.021 0.000 0.000 

31 PIID* acute photons E=30-250keV Lognormal 0.120 1.520 0.000 

32 PIID* acute photons E=30-250keV Lognormal 0.120 1.520 0.000 

33 PIID* acute photons E=30-250keV Lognormal 0.120 1.520 0.000 

34 PIID* acute photons E=30-250keV Lognormal 0.120 1.520 0.000 

35 PIID* acute photons E=30-250keV Lognormal 0.060 1.520 0.000 

36 PIID* acute photons E=30-250keV Lognormal 0.060 1.520 0.000 

37 PIID* acute photons E=30-250keV Lognormal 0.060 1.520 0.000 

38 PIID* acute photons E=30-250keV Lognormal 0.060 1.520 0.000 

39 PIID* acute photons E=30-250keV Lognormal 0.060 1.520 0.000 

40 PIID* acute photons E=30-250keV Lognormal 0.060 1.520 0.000 

41 PIID* chronic photons E=30-250keV Constant 0.035 0.000 0.000 

42 PIID* chronic photons E=30-250keV Constant 0.031 0.000 0.000 

43 PIID* chronic photons E=30-250keV Constant 0.030 0.000 0.000 

44 PIID* chronic photons E=30-250keV Constant 0.036 0.000 0.000 

45 PIID* chronic photons E=30-250keV Constant 0.026 0.000 0.000 

46 PIID* chronic photons E=30-250keV Constant 0.026 0.000 0.000 

47 PIID* chronic photons E=30-250keV Constant 0.026 0.000 0.000 

48 PIID* chronic photons E=30-250keV Constant 0.027 0.000 0.000 

49 PIID* chronic photons E=30-250keV Constant 0.029 0.000 0.000 

50 PIID* chronic photons E=30-250keV Constant 0.029 0.000 0.000 

51 PIID* acute photons E=30-250keV Constant 0.005 0.000 0.000 

52 PIID* acute photons E=30-250keV Constant 0.005 0.000 0.000 

53 PIID* acute photons E=30-250keV Constant 0.005 0.000 0.000 

54 PIID* acute photons E=30-250keV Constant 0.005 0.000 0.000 

Hanford Case PIID* 21 S. Cohen & Associates