Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

ISSUES RESOLUTION MATRIX FOR 

PACIFIC PROVING GROUNDS SITE PROFILE

Contract No. 211-2014-58081 

Prepared by 

Kathleen Behling 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, Virginia, 22201 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

September 2017 

DISCLAIMER 

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
Effective Date:

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SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: Issues Resolution Matrix for Pacific Proving Grounds Site Profile

DOCUMENT NUMBER/

DESCRIPTION:

PPG Issues Matrix

REVISION NO.: September 2017 update (Draft)

SUPERSEDES: May 2014 version

EFFECTIVE DATE: September 6, 2017

TASK MANAGER: Hans Behling, PhD, MPH [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S):

Hans Behling, PhD, MPH [signature on file]

John Stiver, MS, CHP [signature on file]
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

AP anterior-posterior 

AWE Atomic Weapons Employer 

CE Claims Examiner

DCF dose conversion factor 

DNA Defense Nuclear Agency

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

EEOICPA Energy Employees Occupational Illness Compensation Program Act

ISO isotropic

keV kiloelectron volt

MDA minimum detectable activity

NIOSH National Institute for Occupational Safety and Health

NRC U.S. Nuclear Regulatory Commission 

NTS Nevada Test Site

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT technical information bulletin

POC probability of causation

PPG Pacific Proving Grounds 

REF radiation effectiveness factor

ROT rotational 

SEC Special Exposure Cohort 

TBD technical basis document

WG Work Group 
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Finding Resolution for Site Profile Issues for the Pacific Proving Grounds

Finding No.: 

Report Sect. Finding Description NIOSH Response Finding Resolution

1: 4 NIOSH needs to update ORAUTTKBS-0052, Rev. 00, with regard to the 

250-workday requirement for SEC 

Class inclusion. Revision 00 of 

ORAUT-TKBS-0052, Summary Site 

Profile for the Pacific Proving 

Grounds, was issued on August 30, 

2006. At that time, SEC status for 

presumptive cancer claimants required 

employment with at least 250 

workdays. The 250-workday 

requirement for PPG workers was 

subsequently amended by the 

Department of Labor (DOL) in 

EEOICPA Bulletin No. 06-15 issued on 

September 27, 2006, and EEOICPA

Bulletin No. 07-05 issued on January 

11, 2007. Additionally, there may be a 

need for further discussions pertaining 

to the surrogate use of film badge 

dosimetry for PPG employment 

period(s) as recommended in DOL’s 

EEOICPA Bulletin No. 07-05.

NIOSH agrees than an update is needed to 

ORAUT-TKBS-0052, Rev. 00, with regard to the 

250-workday requirement for SEC Class inclusion. 

The next revision of ORAUT-TKBS-0052 will 

include provisions of EEOICPA Bulletin No. 06-15 

issued on September 27, 2006, and EEOICPA 

Bulletin No. 07-05 issued on January 11, 2007 

which state, inter alia, that:

“For any 24-hour period that the employee was 

present (either worked or lived) on the PPG or on 

ships (evacuated prior to a nuclear weapon testing), 

the CE would credit the employee with the 

equivalent of three (8-hour) work days. If there is 

evidence the employee was present at the PPG or 

on ships for 24 hours in a day for 83 days, the 

employee would have the equivalent of 250 work 

days and would meet the 250 work day 

requirement.”

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. Section 1.3 was 

amended in accordance with EEOICPA 

Bulletins Nos. 06-15 and 07-05, which equate 

any 24-hour period (working or living on the 

PPG) with three 8-hour work days for 

establishing the 250-workday requirement for 

potential inclusion in the SEC class. At the 

April 21, 2017, PPG WG teleconference 

meeting, the WG concurred with the revision 

to Section 1.3 and closed the finding.
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Finding No.:

Report Sect. Finding Description NIOSH Response Finding Resolution

Observation 1:

5

There is a need for more definitive 

guidance pertaining to the assignment 

of occupational medical dose in behalf 

of claimants with no formal affiliation 

with a DOE or AWE facility.

The next revision of ORAUT-TKBS-0052 will 

include provisions from ORAUT-OTIB-0079 which 

states the NIOSH interpretation is that the EEOICPA 

defines covered radiation as the radiation received by 

a covered employee at a covered facility during a 

covered period. Section 2.0 of ORAUT-OTIB-0079 

also states that “For most cases in which energy 

employee medical records are not provided, dose 

reconstructors should assume that any occupational 

medical X-ray exposure occurred at the covered 

facility where the energy employee worked.”

Therefore, if a covered employee cannot be affiliated 

with a covered facility and there are no records of 

X-rays being administered at a covered facility, then 

occupational medical exposures should not be 

assigned. In addition, the next revision of ORAUTTKBS-0052 will delete reference to the guidance 

found in ORAUT-PROC-0061 for covered employees 

“hired on location.”

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. In Section 3.0 of the 

revised site profile, NIOSH substituted 

protocols defined in Occupational X-Ray 

Dose Reconstruction for DOE Sites

(ORAUT-PROC-0061, Rev. 03) for guidance 

provided in Guidance on Assigning 

Occupational X-Ray Dose under EEOICPA 

for X-Rays Administered Off Site (ORAUTOTIB-0079, Rev. 01). At the April 21, 2017,

PPG WG teleconference meeting, the WG 

concurred with the text revision to 

Section 3.0 and closed Observation 1.

2: 6 Section 4.0 “Occupational 

Environmental Dose” completely 

ignores occupational environmental 

doses for PPG locations from fallout. 

(Note: For PPG locations, occupational 

external environmental dose is for all 

practical purposes an integral part of the 

occupational external (as well as 

internal) dose and should be assessed as 

such in Section 6.0 of the PPG Site 

Profile.)

NIOSH agrees with the finding and Section 4 of the 

next revision of ORAUT-TKBS-0052 will be 

revised to instruct dose reconstructors that external 

dose should be assessed in Section 6.0 of the PPG 

Site Profile. Under the current SEC, in the absence 

of bioassay data, internal doses cannot be 

reconstructed.

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. Definitive guidance 

for assignment of unmonitored external 

exposure to fallout before 1955 was provided 

in revisions to Sections 6.2 and 6.3 and 

Attachment A of the PPG site profile. At the 

April 21, 2017, PPG WG teleconference 

meeting, the WG agreed that the revisions to 

Section 6.0 of the PPG site profile provided 

the necessary guidance to dose reconstructors 

and closed Finding 2.
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Finding No.:

Report Sect. Finding Description NIOSH Response Finding Resolution

3: 7.4.2 Available DOE records for a claimant 

may not only be incomplete/inaccurate, 

but more importantly may not include 

unmonitored exposures associated with 

cohort badging, exposure to fallout, etc.

NIOSH understands there are serious deficiencies 

related to film badge dosimetry data and procedural 

practices identified by the NRC (1989), SAIC 

(1989–2006), and Perkins and Hammond (1980). In 

light of these deficiencies, NIOSH finds it 

intractable to achieve more accurate dose 

assessments than those provided by the DNA and

reduced in Attachment A of ORAUT-TKBS-0052, 

with realistic uncertainty ranges; too many data 

have been lost or never captured to make such an 

effort feasible. However, the next revision 

ORAUT-TKBS-0052 will include revisions to the 

Attachment A to provide 95% doses as appropriate 

(see response to Findings 8 and 9 below). For cases 

where occupation on the various islands is 

documented in the dosimetry records and their stay 

times are known, either by personal or cohort film 

badges or reentry logs, additional dose can be 

calculated in accordance with the information 

provided in Figures 7-6 through 7-10 and added to 

doses assigned using Attachment A to account for 

unmonitored exposure to fallout. It should be noted 

that during Operation Castle in the first half of 

1954, 85% to 90% of all personnel were issued 

operational film badges. In addition, all personnel 

involved in reentry activities were also issued 

mission badges that were read at the end of each 

mission. (Castle Series, 1954, DNA 6035F). For 

Operation Wigwam on May 15, 1955, and all 

subsequent tests at PPG, 100% of all personnel 

were issued operational film badges. In addition, all 

personnel involved in reentry activities were also 

issued mission badges that were read at the end of 

each mission. (Wigwam, DNA 6000F, 1981)

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. Considering the 

limitations of personal dosimeters, their 

limited use, and other procedural practices, 

NIOSH proposed the use of the 95th 

percentile coworker doses defined in 

Attachment A of the revised PPG site profile 

as a reasonable resolution for assigning dose. 

At the April 21, 2017, PPG WG 

teleconference meeting, the WG concurred 

with the NIOSH resolution and closed 

Finding 3.
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Finding No.:

Report Sect. Finding Description NIOSH Response Finding Resolution

4: 7.4.2 ORAUT-TKBS-0052 does not provide 

a definition for unmonitored dose as it 

applies to PPG participants or any 

specific guidance.

The next revision of ORAUT-TKBS-0052 will 

revise this statement to read as follows: “Covered 

employees that participated in the various PPG 

operations and were not badged can be assigned 

coworker dose as outlined in Attachment A.”

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. In this revision, 

NIOSH has introduced guidance that

specifies the use of the 95th percentile 

coworker doses, as defined in Attachment A. 

At the April 21, 2017, PPG WG 

teleconference meeting, the WG concurred 

with NIOSH’s revision to the PPG site profile 

and closed Finding 4.

5: 7.4.2 Average photon energies associated 

with fallout are well above >250 keV. 

Depending on what exposure geometry 

is assumed, a default photon energy of 

30–250 keV may not be claimant 

favorable

Although ISO or ROT geometries might be more 

realistic, the general approach taken with all 

EEOICPA claims is to apply the DCF yielding the 

highest POC. Except for the lung, esophagus, red 

bone marrow, and bone surfaces (as discussed in 

IG-001, Section 4.4) the highest DCF is typically 

associated with the 30-250 keV photon energy 

range and the AP geometry. In addition, as 

described in Table 5A of the NIOSH –IREP 

Technical Documentation (2002), the radiation 

effectiveness factor (REF) is significantly higher 

for photons in the 30-250 keV range when 

compared to the > 250 keV range. These two 

factors lead to the recommendation given in 

Section 6.0.

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. While NIOSH 

acknowledged photon energies for fallout are 

well above 250 keV, its choice of 30–

250 keV photon energy and AP geometry 

represent claimant-favorable dose conversion 

factors for all but four organs (lung, 

esophagus, red bone marrow, and bone 

surfaces). For these four organs, revisions to 

Section 6.3.3 recommend that an AP-to-ROT 

geometry ratio be considered for claimant 

favorability, with ISO geometry for cases 

requiring best estimates. At the April 21, 

2017, PPG WG teleconference meeting, 

SC&A and the WG concurred with NIOSH’s 

approach to apply the DCF yielding the 

highest POC. Therefore, SC&A withdraws 

Finding 5.
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Finding No.:

Report Sect. Finding Description NIOSH Response Finding Resolution

6: 7.4.2 Since claims involving skin cancer 

usually specify the location(s) on the 

body, the critical variable of distance 

above the source plane defined by Barss 

and Weitz (2006) should be included in 

the assignment of beta-to-gamma dose 

ratios for PPG claimants.

Figure C-1 in Attachment C of the NTS external

TBD provides the information given in Table 7-4 

of the SC&A report. In addition, with respect to the 

ratios in Table C-1 of the NTS document, 

Attachment C recommends: “These values can be 

modified with appropriate factors for shielding and 

distance (Barss and Weitz 2006).” Guidance on the 

assignment of beta-to-gamma ratios from Barss and 

Weitz (2006) will be added to the next revision of 

ORAUT-TKBS-0052 for clarity. The guidance will 

include, from Barss and Weitz 2006, Table 1, Betato-gamma dose Ratios for Pacific Test Sites, 

Table 3, Beta-to gamma Ratios for eye Exposures, 

and Table 7, Standard Distances from Source Plane 

for Various Anatomical Locations.

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. In Section 6.1 of the 

revised PPG site profile, NIOSH eliminated 

the default Nevada Test Site beta-to-gamma 

ratio of 1:1 and introduced guidance that 

included beta-to-gamma ratios by Barss and 

Weitz (2006). The revision also incorporated 

critical variables that include age of fallout, 

distance, and weathering impacts on the betato-gamma ratios. At the April 21, 2017, PPG 

WG teleconference meeting, the WG agreed 

with the revision to Section 6.1 of the PPG 

site profile and closed Finding 6.
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Finding No.: 

Report Sect. Finding Description NIOSH Response Finding Resolution

7: 7.4.2 NIOSH’s guidance for the assignment 

of missed dose is based on assumptions 

that are not supported by facts and in 

the face of uncertainty are clearly not 

claimant favorable.

The next revision of ORAUT-TKBS-0052 will 

revise the missed dose guidance as follows: 

“Assign missed dose based on the number of 

exchanges found in the dosimetry records. Also, 

compare the total of the recorded dose plus the 

missed dose to the 50% dose in Attachment A and 

assign the larger dose. In addition, for cases where 

occupation on the various islands is documented in 

the dosimetry records and their stay times are 

known, additional dose can be calculated in 

accordance with the information provided in 

DNA’s 1983 report entitled Operation Greenhouse 

1951 related to calculating dose based on island 

occupation times and added to doses assigned as 

described above to account for potentially 

unmonitored exposure to fallout.” It should be 

noted that in most cases where an individual’s dose 

was assigned based on cohort badging, logs were 

maintained in the individual’s dosimetry records 

which documented the location and stay times 

associated with reentry activities. These logs can be 

used to estimate potential dose received during 

these reentry activities.

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. To account for 

unmonitored exposures and the uncertainties 

of recorded film badge data prior to 1955, 

NIOSH revised Section 6.0 of the PPG site 

profile. The revision states that the 95th 

percentile coworker doses should be assigned 

when data are incomplete or nonexistent. 

Pre-1955, recorded doses should be compared 

to 95th percentile doses, and the larger of the 

two doses should be assigned. Sections 6.1, 

6.2, and 6.3 were revised to address 

exposures to Operation Greenhouse fallout in 

1951. At the April 21, 2017, PPG WG 

teleconference meeting, the WG agreed with 

the revision to the PPG site profile and closed 

Finding 7.

8: 7.4.2 Independent of other 

concerns/limitations that characterize 

the DNA dose distribution data (e.g., 

their accuracy, completeness, etc.), use 

of the 50th percentile dose as a 

coworker dose is not justified for PPG 

participants for Operations up to and 

inclusive of Operation CASTLE and for 

the subsequent Operations where 

dosimeter damage was an issue.

Owing to the large uncertainties in the operationspecific dose reported by DNA, the next revision of 

ORAUT-TKBS-0052, Attachment A will be 

revised to replace the 50th percentile doses with the 

95th percentile doses to be used for coworker 

doses, as appropriate.

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. In this revision, 

NIOSH has introduced guidance that

specifies use of the 95th percentile coworker 

doses, as defined in Attachment A. At the 

April 21, 2017, PPG WG teleconference 

meeting, the WG concurred with NIOSH’s

revision to the PPG site profile and closed 

Finding 8.
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Finding No.: 

Report Sect. Finding Description NIOSH Response Finding Resolution

9: 7.4.2 Operation-specific dose distributions 

defined by DNA must be adjusted to 

account for the MDA value of film 

dosimeters regardless of what percentile 

value is employed.

The next revision of ORAUT-TKBS-0052, 

Attachment A will be revised to ensure the 

coworker dose approach follows the guidance in 

ORAUT-OTIB-0020 with respect to the treatment 

and inclusion of potential missed dose.

NIOSH issued Rev. 01 to ORAUT-TKBS0052 on July 11, 2016. In this revision, 

NIOSH has introduced guidance that

specifies the use of the 95th percentile 

coworker doses, as defined in Attachment A. 

At the April 21, 2017, PPG WG 

teleconference meeting, the WG concurred 

with NIOSH’s revision to the PPG site profile 

and closed Finding 9.