SCA-TR-Task3, Rev. 0, Final Draft, January 17, 2005 

Final Draft Report 

NATIONAL INSTITUTE OF 

OCCUPATIONAL SAFETY AND HEALTH 

ADVISORY BOARD ON DOSE RECONSTRUCTION 

TASK 3 

THE REVIEW OF NIOSH/ORAUT 

PROCEDURES AND METHODS USED 

FOR DOSE RECONSTRUCTION

Contract No. 200-2004-03805 

Prepared by 

S. Cohen & Associates 

McLean, VA 

January 2005
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Document No. 

 SCA-TR-Task3 

Effective Date: 

 January 17, 2005 

S. Cohen & Associates: Technical Support for the Advisory 

Board on Radiation and Worker Health Review of NIOSH 

Dose Reconstruction Program 

Revision No. 0 

THE REVIEW OF NIOSH/ORAUT PROCEDURES AND 

METHODS USED FOR DOSE RECONSTRUCTION

Page 2 of 260 

Task Manager: ______________________ Date: 1/17/05 

 U. Hans Behling, PhD, MPH

Task Manager: ______________________ Date: 1/17/05 

 Joyce Lipsztein, PhD 

Project Manager: _____________________ Date: 1/17/05 

 John Mauro, PhD, CHP 

Supersedes: 

 N/A 

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has been edited accordingly, and is now cleared for distribution.
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TABLE OF CONTENTS 

Executive Summary.........................................................................................................................5 

Summary Findings...............................................................................................................5 

1.0 Introduction..........................................................................................................................9 

1.1 Statement of Purpose ...............................................................................................9 

1.2 Identification of Procedures Subject to Review.......................................................9 

1.3 SC&A’s Approach for Task 3................................................................................14 

1.4 Structure and Organization of the Report..............................................................17 

2.0 External Dosimetry Procedures/Documents......................................................................21 

2.1 

................................................................................................................21 

OCAS-IG-001 — External Dose Reconstruction Implementation 

Guideline

2.2 OCAS-PR-003 — Performing and Reporting Dose Reconstruction.....................53 

2.3 ORAUT-PROC-0006 — External Dose Reconstruction.......................................59 

2.4 

..............63 

ORAUT-OTIB-0010 — A Standard Complex-Wide Correction Factor for 

Overestimating External Doses Measured with Film Badge Dosimeters

2.5 

.....................................................72 

ORAUT-OTIB-0008 — Technical Information Bulletin for a Standard 

Complex-Wide Conversion Factor for Overestimating External Doses 

Measured with Thermoluminescent Dosimeter

2.6 

.................................78 

ORAUT-OTIB-0007 — Technical Information Bulletin: Occupational 

Dose From Elevated Ambient Levels of External Radiation

2.7 

...................................................................83 

ORAUT-OTIB-0006 — Dose Reconstruction From Occupationally 

Related Diagnostic X-Ray Procedures

2.8 

....................................................................................88 

OCAS-TIB-006 — Interpretation of External Dosimetry Records at the 

Savannah River Site (SRS)

2.9 

...............................93 

OCAS-PER-001 — Misinterpreted Dosimetry Records Resulting in an 

Underestimate of Missed Dose in SRS Dose Reconstruction

2.10 OCAS-TIB-007 — Neutron Exposures at the Savannah River Site......................94 

2.11 

..............................101 

OCAS-PER-002 — Error in Surrogate Organ Assignment Resulting in an 

Underestimate of X-Ray Dose In SRS Dose Reconstruction

References........................................................................................................................103 

3.0 Internal Dosimetry Procedures/Documents.....................................................................105 

3.1 OCAS-IG-002 — Internal Dose Reconstruction Implementation Guideline ......105 

3.2 ORAUT-PROC-0003 — Internal Dose Reconstruction......................................117 

3.3 OCAS-TIB-008 — Use of ICRP 66 to Calculate Respiratory Tract Doses........122 

3.4 ORAUT-PROC-0002 ― Use of Integrated Modules for Bioassay Analysis......125 

3.5 OCAS-TIB-002 — Tritium Calculation with IMBA...........................................130 

3.6 

.........................................................................................134 

ORAUT-OTIB-0002 — Maximum Internal Dose Estimates for Certain 

DOE Complex Claims

3.7 

...............................................................140 

ORAUT-OTIB-0005 — Imba Organ, External Dosimetry Organ, and 

IREP Model Selection By ICD-9 Code

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3.8

......................................................................................144 

ORAUT-OTIB-0001 — Maximum Internal Dose Estimates for Savannah 

River Site (SRS) Claims

3.9 ORAUT-OTIB-0003 — Savannah River Site Tritium Dose Assignment...........165 

3.10 

..................169 

ORAUT-OTIB-0004 — Technical Basis for Estimating the Maximum 

Plausible Dose to Workers at Atomic Weapons Employer Facilities

4.0 Interactive Radioepidemiological Program (IREP) Requirements/Issues.......................177 

4.1 OCAS-TIB-001 ― IREP Issues...........................................................................177 

4.2 

.....................................................................180 

OCAS-TIB-003 ― Interactive Radioepidemiological Program 

Requirements for Multiple Cancers

4.3 OCAS-TIB-005 ― Dose Reconstruction Cancer Data Requirements ................183 

5.0 Telephone Interviews.......................................................................................................187 

5.1 ORAUT-PROC-0004 ― Scheduling Telephone Interviews, ORAUTPROC-0005 ― Performing Telephone Interviews, and ORAUT-PROC0017 ― Reviewing Telephone Interviews ..........................................................187 

5.2 Overview of Procedures Used in the Computer Assisted Telephone 

Interview ..............................................................................................................189 

5.3 Strengths of ORAUT-PROC-0004, -0005, and -0017, Letter (NIOSH 

Tracking No. 54), and CATI Forms.....................................................................192 

5.4 Summary Review Findings..................................................................................192 

5.5 Comments Regarding CATI Forms.....................................................................202 

5.6 Significant Findings Pertaining to Procedures.....................................................206 

5.7 Summary and Conclusions ..................................................................................212 

5.8 Suggestions for Improvement..............................................................................213 

References........................................................................................................................215 

6.0 Quality Assurance Plans ..................................................................................................237 

6.1 ORAUT-PLAN-0001 ― Quality Assurance Program Plan ................................237 

6.2 ORAUT-PLAN-0002 ― Internal Management Review Plan.............................240 

6.3 ORAUT-PLAN-0003 ― Information Systems Quality Assurance Plan ............243 

7.0 Documentation/Records Management.............................................................................247 

7.1 OCAS-TIB-004 ― Naming Conventions............................................................247 

7.2 ORAUT-PLAN-004 ― Records and Information Management Plan.................251 

7.3 ORAUT-PROC-0001 ― Document Program .....................................................256 

Addendum SC&A’s Protocol for the Review of Procedures and Methods Employed By 

NIOSH for Dose Reconstruction 

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EXECUTIVE SUMMARY 

Under the Energy Employees Occupational Illness Compensation Program Act (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 is mandated to conduct 

an independent review of the methods and procedures used by the National Institute of 

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 under 

Task 3 to support the Board in this effort by completing the following two work products: 

(1) Develop a Formal Review Protocol for the Evaluation of Procedures Used in Dose 

Reconstruction — The purpose of a review protocol is to ensure a structured and 

systematic review process that determines whether procedures are consistent with the 

philosophy, intent, and/or statutory directives cited in EEOICPA and comply with the 

general requirements, methods, and guidance provided in 42 CFR Part 82. 

In behalf of the first work product, SC&A submitted a report entitled A Protocol for the 

Review of Procedures and Methods Employed by NIOSH for Dose Reconstruction, which 

was approved by the Board in April 2004. The Board-approved version of this report is 

enclosed as an addendum. 

(2) Conduct a Critical Review of Methods and Procedures Used by NIOSH for Dose 

Reconstruction — The Board identified a total of 33 procedural documents for SC&A’s 

review that included implementation guidelines, procedures, technical information 

bulletins, and plans. These documents were evaluated against seven major review 

objectives, which define SC&A’s review protocol. The main text of this report contains 

SC&A’s evaluation of these procedures. A brief summary of the review findings is 

presented below. 

Summary Findings 

The 33 documents identified to SC&A for review represent a sizeable body of written text that 

embraces a wide array of complex topics and clearly reflects an intense effort by many 

individuals who are regarded as scientific experts in their fields. However, these documents 

were created by the Office of Compensation Analysis and Support (OCAS) and the Oak Ridge 

Associated University Team (ORAUT) over a 3-year period in a fragmented fashion and on an 

as-needed basis. It is important to note that none of the 33 documents contain site-specific data 

that are essential to dose reconstruction. Only Site Profiles that have been or continue to be 

developed contain site-specific data, as well as guidance that may significantly differ and 

supercede guidance provided by the 33 documents under review in Task 3. 

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It is equally important to note that some of the 33 documents have been revised and are likely to 

be revised in the future due to the fact that these documents are regarded as “living documents.” 

The need for living documents, as explained to SC&A by NIOSH, reflects the urgent demand for 

NIOSH to begin the adjudication of claims by a progressive selection process that started with 

claims requiring the least amount of procedural guidance and data. Future, more complex dose 

reconstructions may, therefore, require further procedural revisions and/or the development of 

additional procedures. 

In brief, SC&A’s review of the methods and procedures used for dose reconstruction must be 

viewed with some caution since these findings are not only limited to generic procedures, as they 

exist currently, but more importantly do not include the role of Site Profiles in dose 

reconstruction. 

An overview of SC&A’s findings is given below in behalf of the seven general review objectives 

identified by SC&A in its review protocol. Due to the large number of documents and their 

heterogeneous contents, some comments may not apply to all documents and, in select instances, 

may only apply to one or a few procedures. 

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

expeditious and timely for dose reconstruction. 

A well-written procedure presents all required data in a logical, concise, unambiguous, and 

prescriptive manner. Frequently, SC&A found that poorly structured procedures sequester the 

key information or guidance in the final section. This requires the dose reconstructor to read 

through voluminous and frequently irrelevant background information. An improved format 

would provide the essential guidance and data for dose reconstruction at the front of the 

procedure. Relevant background or technical support data would be more effective as addenda 

that the dose reconstructor could consult if needed. 

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.

SC&A understands the benefit of and endorses the need for an efficient dose reconstruction 

process that, in appropriate instances, either avoids a full-blown dose reconstruction (i.e., when a 

partial dose reconstruction yields a probability of causation (POC) > 50%) or simplifies a dose 

reconstruction by means of worst-case assumptions/dose assignments for claims with a low 

POC. A sizeable number of procedures, while making reference to the likely or unlikely 

compensability of a claim, provide little or no guidance to the dose reconstructor for prejudging a 

claim. (It should be noted that ORAUT-PROC-0006 potentially may negate this concern by 

implying that a preliminary assessment by “Task 2 personnel” will identify the likely 

compensability of a claim to the dose reconstructor.) 

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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 in instances where the 

POC is not evidently clear.

This objective was assessed at two levels. The first is based on the structure, format, and scope 

of the Computer Assisted Telephone Interview (CATI) process. SC&A identified several 

limitations and deficiencies by which CATI data are obtained and integrated into the dose 

reconstruction process. 

The second level focused on claims for which assignment of external and internal doses must be 

scientifically defensible and invariably requires site-specific information relating to timedependent health physics practices, personnel monitoring, dosimeter and bioassay performance 

criteria, etc. With some exceptions, most procedures under review are generic and contain no 

site-specific information. 

A simple resolution to this deficiency would be to integrate all relevant portions of generic 

OCAS and ORAUT procedures into each Site Profile. This would eliminate redundancy and 

reduce the number of documents necessary for dose reconstruction for any given site to a single 

document. 

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

regardless of claimants’ exposures by time and employment locations.

In order for the adjudication process to be fair to claimants, the process of dose reconstruction 

must attempt to remain consistent over time and space. Consistency implies that the same 

procedures are applied to claims that share a high degree of commonality. SC&A’s review of 

procedures shows that some of the procedures tend to overlap, which presents the dose 

reconstructor with multiple options. In other instances, the absence of clear guidance requires 

the dose reconstructor to make independent and subjective decisions that are prone to variability. 

Other potential sources of inconsistency (that is not subject to review under Task 3) are the Site 

Profiles and their interpretation and adoption of generic guidance contained in the 33 documents. 

(An evaluation of consistency among Site Profiles and between a given Site Profile and generic 

NIOSH/ORAUT procedures will be reported by SC&A under Task 1.) 

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.

The statutory requirement of a claimant-favorable dose reconstruction process is achieved by (1) 

giving the benefit of doubt when there are unknowns, and (2) defining uncertainties for 

measured data and selecting the 99th percentile value of a Monte Carlo distribution. 

SC&A’s review of procedures suggests that the method for determining the uncertainty of 

personnel dosimeters may have been incomplete and significantly underestimated. In instances 

of unknowns, select procedures either lack the necessary guidance or employ default values that 

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NOTICE: Th

would be inappropriate. For example, limited guidance is given for situations when monitoring 

data are missing or lost, and questionable default values are used in instances when a claimant 

was not monitored. 

Objective 6: Evaluate procedure for its ability to adequately account for the uncertainty of 

dose estimates.

The input to the Interactive Radioepidemiological Program of annual external doses as 

measured by weekly, monthly, or quarterly assigned film or thermoluminescent dosimeters not 

only requires an estimate of uncertainty for each individual dosimeter (i.e., film or 

thermoluminescent dosimeter), but also considers the collective uncertainty of the annual dose 

that may correspond to as many as 52 dosimeters for a weekly exchange frequency. 

While all external dosimetry procedures reference the need to include uncertainty, only 

OCAS-IG-001 attempts to explain how this is to be done. However, guidance in OCAS-IG-001 

is inadequate and scientifically questionable, as described below in the review of Implementation 

Guide OCAS-IG-001. The treatment of uncertainty pertaining to internal exposures as assessed 

by bioassay techniques is equally deficient. 

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.

The seventh and final review objective not only assessed the scientific credibility of procedural 

methods, but also the EEOICPA directive that the methods and procedures must achieve a 

balance between technical precision and dose reconstruction efficiency. 

SC&A’s review of procedures identified a number of technical inaccuracies and errors. Many 

prompt the dose reconstructor to pursue levels of detail that would not reasonably be obtained. 

On a more subjective level, SC&A believes that currently select portions of the dose 

reconstruction process demand a high degree of sophistication and detail that goes well beyond 

the regulatory requirement of a “reasonable dose estimate” and comes at the expense of reducing 

process efficiency. 
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1.0 INTRODUCTION 

1.1 STATEMENT OF PURPOSE 

The purpose of this draft report is to assist the Advisory Board in fulfilling its mandate to review 

the methods and procedures used by the National Institute of Occupational Safety and Health 

(NIOSH) and its contractors in the performance of dose reconstruction, as directed by the Energy 

Employees Occupational Illness Compensation Program Act (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). 

Specifically, Section B of 42 CFR Part 82 Final Rule identifies the following statutory 

requirement for: 

. . . The Advisory Board on Radiation and Worker Health to independently review 

the methods established by this rule and to verify a reasonable sample of dose 

reconstructions established under these methods. [Emphasis added.] 

Section P of 42 CFR Part 82 Final Rule restates this requirement, but further directs the Advisory 

Board to identify those procedures that are to be reviewed by the Board, as stated in the 

following: 

As described above under the discussion of statutory provisions related to the 

rule, EEOICPA requires the Board to conduct an independent review of a sample 

of NIOSH dose reconstruction. 42 U.S.C. 7348 n(d). Since this review is 

specified to be independent, the Board, rather than HHS, must determine the 

procedures for the Board’s review of NIOSH dose reconstructions. Moreover, 

this level of autonomy is important for the credibility of the review. [Emphasis 

added.] 

1.2 IDENTIFICATION OF PROCEDURES SUBJECT TO REVIEW 

Based on the above-cited statutory and regulatory requirements, the Board provided S. Cohen 

and Associates (SC&A) with an electronic file of those procedures that must be assessed to 

satisfy the requirement of an “independent review.” Procedural documents issued and used by 

the Office of Compensation Analysis and Support (OCAS) and the Oak Ridge Associated 

University Team (ORAUT) for dose reconstruction are described below. 

1.2.1 OCAS Implementation Guides 

OCAS-IG-001 — External Dose Reconstruction Implementation Guideline

This document contains the core guidance on the components, standards, and methods of 

external radiation dose reconstruction for probability of causation (POC) calculations in support 

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of the EEOICPA. It is a core document in the reconstruction of external doses and provides very 

comprehensive guidance. 

OCAS-IG-002 — Internal Dose Reconstruction Implementation Guideline

This document provides basic information on the methods to be employed in internal dose 

reconstruction. The dose reconstruction should result in the calculation of claimant-favorable 

reasonable estimates of the equivalent dose received by the worker, in individual calendar years, 

to the organ of interest, as well as the uncertainty associated with the dose. 

1.2.2 OCAS Technical Information Bulletins 

OCAS TIB 001 — Interactive Radioepidemiological Program Issues

This Technical Information Bulletin (TIB) clarifies three issues related to using the Interactive 

Radioepidemiological Program (IREP). The document provides specific instruction in the use of 

IREP when (1) choosing the exposure type for radon, (2) handling cases involving leukemia and 

thyroid latency, and (3) determining the use of the “should alternate cancer be run” field. 

OCAS TIB 002 — Tritium Calculations with Integrated Modules for Bioassay Analysis

This TIB provides guidance on how to use Integrated Modules for Bioassay Analysis (IMBA) 

for calculating tritium gas doses. 

OCAS TIB 003 — Interactive Radioepidemiological Program Requirements for Multiple 

Cancers 

This TIB contains specific IREP program instructions for dose calculations involving multiple 

primary cancers, as well as cases where no primary cancer is provided. 

OCAS TIB 004 — Naming Conventions

This TIB is an administrative document containing the naming convention to be employed for 

documents that are included in the Administrative Record. 

OCAS TIB 005 — Dose Reconstruction Cancer Data Requirements 

This TIB is an administrative document that defines the NIOSH OCAS Claims Tracking System 

requirements and business rules governing cancer data requirements for performing dose 

reconstructions and conducting IREP runs at OCAS and ORAU. 

OCAS TIB 006 — Interpretation of External Dosimetry Records at Savannah River Site 

This document provides guidance on the interpretation of Savannah River Site (SRS) dosimetry 

from 1973 through 1988. 

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OCAS TIB 007 — Neutron Exposures at Savannah River Site 

This TIB provides guidance on the inclusion of neutron exposures in SRS dose reconstructions 

prior to the implementation of the thermoluminescent neutron dosimeter (TLD) in 1971. 

OCAS TIB 008 — Use of ICRP 66 to Calculate Respiratory Tract Doses 

This TIB provides guidance on the assignment of the appropriate tissue to serve as the surrogate 

to the internal dose to specific organs/tissues associated with or near the respiratory tract. 

1.2.3 OCAS Program Evaluation Reports 

OCAS-PER-001 — Misinterpreted Dosimetry Records Resulting in an Underestimate of Missed 

Dose in Savannah River Site Dose Reconstructions

This report evaluates the programmatic effect of an error in the interpretation of incomplete SRS 

dosimetry records between 1973 and 1988. Data gaps during this time period were interpreted as 

not monitored and may have resulted in an underestimation of missed dose. 

OCAS-PER-002 — Error in Surrogate Organ Assignment Resulting in an Underestimate of XRay Dose in Savannah River Site Dose Reconstruction

This report evaluates the programmatic effect of an error in surrogate organ assignment resulting 

in potential underestimation of X-ray dose for certain SRS dose reconstructions. 

1.2.4 OCAS Procedures 

OCAS-PR-003 — Performing and Reporting Dose Reconstructions 

The purpose of this procedure is to provide guidance for the OCAS staff and its technical support 

contractors in the performance, review, and documentation of dose reconstructions for covered 

employees with cancer per the requirements of 42 CFR Part 82. The basic principle of dose 

reconstruction is to characterize the radiation environments to which workers were exposed, and 

to then place each worker in time and space within this exposure environment. 

1.2.5 ORAUT Plans 

ORAUT-PLAN-0001 — Quality Assurance Program Plan 

This plan is an administrative document describing the organizational structure, functional 

responsibilities, levels of authority, and interfaces for those personnel managing, performing, and 

assessing the quality of work performed. 

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ORAUT-PLAN-0002 — Internal Management Review Plan 

This administrative document provides guidance for the management reviews of activities for the 

ORAU Team Dose Reconstruction Project. 

ORAUT-PLAN-0003 — Information Systems Quality Assurance Plan 

This is an administrative document for attesting to the quality of data and information 

management practices used. The plan presents a strategy to promote processes and/or 

procedures for their utility in identifying and/or limiting vulnerabilities to data quality. 

ORAUT-PLAN-0004 — Records and Information Management Plan 

This is an ORAU administrative document that provides the requirements and responsibilities for 

a functional records and information management system for the ORAU Team Dose 

Reconstruction Project. 

1.2.6 ORAUT Procedures 

ORAUT-PROC-0001 — Document Program 

This administrative procedure provides the process for development, revision, cancellation, and 

control of documents generated by the ORAU Team Dose Reconstruction Project for NIOSH. 

ORAUT-PROC-0002 — Use of Integrated Modules for Bioassay Analysis 

This document serves as an administrative procedure which provides instructions on how to use 

the software IMBA. 

ORAUT-PROC-0003 — Internal Dose Reconstruction 

This procedure is mostly administrative and addresses steps to be taken to assure that internal 

dose reconstructions are sufficiently complete, correct, and consistent for determining the POC 

of a covered employee’s specified cancer(s). 

ORAUT-PROC-0004 — Scheduling Telephone Interviews

This ORAU administrative document provides instructions on the process for the scheduling of 

Computer-Assisted Telephone Interviews (CATI). 

ORAUT-PROC-0005 — Performing Telephone Interviews 

This procedure provides ORAUT personnel with instructions on the process for the performance 

of CATIs. 

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ORAUT-PROC-0006 — External Dose Reconstruction 

This procedure provides specific steps and instructions for performing external dose 

reconstructions based on principles contained in OCAS-IG-001 guidelines. 

ORAUT-PROC-0007 — Reviewing Telephone Interviews 

This administrative document provides instructions on the process for reviewing and processing 

documents created within the ORAU Team Dose Reconstruction Project as part of the telephone 

interview process. 

1.2.7 ORAU Technical Information Bulletins 

ORAUT-OTIB-0001 — Maximum Internal Dose Estimates for Savannah River Site Claims 

To facilitate timely processing of SRS claims under the EEOICPA, this document specifies the 

method for evaluating internal dose to cases that meet specific criteria. 

ORAUT-OTIB-0002 — Maximum Internal Dose Estimates for Certain Department of Energy 

Complex Claims 

This TIB expedites the processing of claims that involve cancer in an organ with little or no 

reported internal dose from internally deposited radionuclides that might be associated with work 

at U.S. Department of Energy (DOE) complex sites. 

ORAUT-OTIB-0003 — Savannah River Site Tritium Dose Assignment

This TIB provides guidance for the evaluation of tritium dose for SRS dose reconstruction and is 

based on the SRS Technical Basis Document. 

ORAUT-OTIB-0004 — Technical Basis for Estimating the Maximum Plausible Dose to 

Workers at Atomic Weapons Employer Facilities 

For the purpose of expediting the processing of claims, this TIB describes an efficient process for 

estimating the maximum plausible annual organ dose to workers at Atomic Weapons Employer 

facilities. 

ORAUT-OTIB-0005 — Integrated Modules for Bioassay Analysis Organ, External Dosimetry 

Organ, and Interactive Radioepidemiological Program Model Selection by ICD-9 Code

This TIB provides guidance on selecting appropriate International Committee for Radiological 

Protection (ICRP)-modeled organs/tissues in the IMBA software program to estimate the internal 

dose for specific ICD-9 codes, the appropriate organs/tissues to estimate external dose, and the 

appropriate model in the IREP. 

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ORAUT-OTIB-0006 — Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures

This TIB is a generic document that provides guidance on the performance of a dose 

reconstruction associated with occupationally related diagnostic x-ray procedures. 

ORAUT- OTIB-0007 — Occupational Dose from Elevated Ambient Levels of External 

Radiation

This TIB discusses the issue of determining whether external dosimeter results represent 

occupational doses that have been separated appropriately from potentially elevated 

environmental doses. 

 

ORAUT-OTIB-0008 — Standard Complex-Wide Conversion/Correction Factor for 

Overestimating External Exposures Measured with Thermoluminescent Dosimeters

The objectives of this TIB are to discuss the degree of standardization of DOE TLD 

measurements and develop a standard correction factor that will overestimate dose. This 

document examines the performance of TLD dosimeters, discusses the application of a standard 

correction factor to overestimate doses, and addresses specific sources of uncertainties. 

ORAUT-OTIB-0010 — Standard Complex-Wide Conversion/Correction Factor for 

Overestimating External Exposures Measured with Film Badge Dosimeters

This TIB presents external radiation dose assumptions that may be applied to dose 

reconstructions involving cases where dose estimates are based on recorded deep and/or shallow 

doses using film badges. Information in this document supports radiation dose estimates for 

complex-wide cases covering the time period of 1970 and after. 

1.3 SC&A’S APPROACH FOR TASK 3 

Phase 1 of Task 3. Under Task 3, SC&A was directed to review the methods and procedures 

used in dose reconstruction by means of a Board-approved methodology. Accordingly, the first 

phase of Task 3 stated that SC&A “. . . develop a methodology for conducting the baseline 

review. This methodology will be provided to the Advisory Board for review and approval prior 

to initiating the baseline review.” 

Technical Issues. In the Statement of Work specified by NIOSH for Task 3, key technical

elements to be addressed in the review included the following: 

(a) Review the internal and external radiation dose reconstruction technical basis documents 

(including procedure for performing internal dose reconstructions and external dose 

reconstructions) 

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(b) Review of methods for estimating “missed dose” and “unmonitored dose” (for cases 

related to monitoring technology and for cases where monitoring was not performed, 

monitoring data are not available or incomplete, or otherwise inadequate) 

(c) Review of the statistical approaches developed for multiple dose reconstructions 

(d) Review procedures used for determining whether data are sufficient to make a reasonable 

dose estimate 

(e) Review methods or procedures used for substituting exposure information for unavailable 

or incomplete information 

(f) Review methods for estimating uncertainty in dose and uncertainty distributions 

surrounding internal and external dose reconstructions on a facility- and time-specific 

basis, and evaluate whether the benefit of the doubt was resolved in favor of the claimant 

where there were uncertainties 

(g) Review procedures and questionnaire used for work history telephone interview (includes 

review of CATI scheduling, performance, and review procedures) 

(h) Review quality assurance plan and related procedures 

(i) Review procedures related to document acquisition (records request, management, 

assembly and handling) 

(j) *Review procedures related to completing a Site Profile (Site and Exposure Profiles), 

Worker Profiles, and Special Exposure Cohort petition review and procedures on how 

Worker Profile and Site Profile data will be used for individual case dose reconstruction 

(k) Review the NIOSH methods, procedures, and performance in evaluating, analyzing, and 

validating all contractor work products 

_________________ 

* Note: In behalf of Task 3, this element was excluded from the review process. 

Nontechnical Issues. In addition to technical elements, SC&A also recognized that the review of 

methods and procedures must also address nontechnical issues that reflect the philosophy, intent, 

and/or statutory directives cited in EEOICPA and the Final Rule for 42 CFR Part 82. 

The Act (as stated in the Final Rule) requires that “. . . HHS establish by regulation, methods for 

arriving at reasonable estimates of the radiation doses incurred by covered employees in 

connection with claims seeking compensation for cancer . . .” [Emphasis added]. 

Other directives issued to the U.S. Department of Health and Human Services (HHS) mandated 

the establishment of, by regulation, methods that are (1) efficient, (2) consistently applied, (3) 

reasonable dose estimates, (4) complete, and (5) well grounded in the best available science. 

As acknowledged in the Act, the level of effort involved in dose reconstructions depends largely 

on the quantity and quality of available dose monitoring data and the extent to which these data 

are, in fact, complete. The EEOICPA further recognized the complexity of traditional

approaches for dose reconstruction, which frequently require extensive research and analysis, 

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and in instances of “. . . health research studies dose reconstruction may take from months to 

years to complete.” 

Owing to the large number of claims requiring dose reconstruction, Section 7384 of EEOICPA 

specifically states that “. . . one of the purposes of the compensation program is to provide for 

timely compensation” [Emphasis added], and Section E of 42 CFR Part 82 Final Rule states that 

“. . . An additional critical factor affecting how doses are reconstructed is the amount of time 

available . . . In compensation programs, however, a balance must be struck between efficiency

and precision.” [Emphasis added.] 

According to these directives, SC&A’s evaluation of procedures cannot limit itself to a process 

that simply determines whether applicable procedures are technically correct and make use of the 

most current ICRP biokinetic models, dose conversion factors, cancer risk coefficients, computer 

codes, etc., but must equally address the more difficult and subjective question of whether a 

proper balance has been struck between efficiency and precision. 

SC&A’s review of the technical and scientific methods prescribed in applicable procedures must, 

therefore, also assess nontechnical issues and the impacts of scientific detail that are required 

procedurally, and weigh the incremental precision gained against the reduced efficiency and 

higher costs for reconstruction and added delay in the adjudication of claims. 

In brief, SC&A identified the following objectives in its protocol to the Board, which form the 

basis for conducting the review: 

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 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. 

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A report of the draft protocol was reviewed by the Board and approved for use during a public 

meeting held in Richland, Washington, on April 20-23, 2004. For convenience, the full text of 

the final report, entitled A Protocol for the Review of Procedures and Methods Employed by 

NIOSH for Dose Reconstruction, is included as an addendum to this report. 

1.4 STRUCTURE AND ORGANIZATION OF THE REPORT 

Structure. 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 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). 

For example, Objective 1 focused on timeliness. The need for NIOSH to perform large numbers 

of dose reconstructions in a timely manner places specific demands on procedures and the dose 

reconstruction process as a whole. SC&A’s evaluation of procedures for their support of a 

timely reconstruction process was, therefore, based on rating the answers to the following 

questions: 

 Is the procedure written in a style that is concise and unambiguous? 

 Is the procedure written in a manner that presents the data in a logical sequence? 

 Is the procedure complete in terms of required data (i.e., does not reference other sources 

that are needed for additional data)? 

 Is the procedure consistent with and does it avoid duplication of other procedures that are 

part of the hierarchy of procedures employed by NIOSH for dose reconstruction? 

 Is the procedure sufficiently prescriptive to minimize the need for subjective decisions 

and data interpretation? 

Answers that resulted in a rating other than a 5 (or a perfect score) in the checklist were 

supported with specific review Comments. Table 1 below identifies the Procedure Review 

Outline/Checklist that was used whenever applicable in the review of the 33 procedures/ 

documents identified by the Board for review. 

Organization. The individual procedures/documents for review are grouped by topic in the 

following sections: 

 Section 2.0, External Dosimetry Procedures/Documents 

 Section 3.0, Internal Dosimetry Procedures/Documents 

 Section 4.0, IREP Requirements/Issues Procedures/Documents 

 Section 5.0, Telephone Interview Procedures/Documents 

 Section 6.0, Quality Assurance Procedures/Documents 

 Section 7.0, Documentation/Records Management Procedures/Documents 

For a specific section, procedures/documents are sequenced as given in the table of contents for 

this report.
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Table 1.4-1. Procedure Review Outline/Checklist 

Document No.: Effective Date: 

Document Title: 

Reviewer: 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? 

 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? 

3.1.4 Is the interview process sensitive to the claimant? 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) 

3.2.2 In vivo/In vitro bioassays 

3.2.3 Missing dosimetry data 

3.2.4 Unmonitored periods of exposure 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters effecting dose estimates? 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 

__________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 
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2.0 EXTERNAL DOSIMETRY PROCEDURES/DOCUMENTS 

2.1 OCAS-IG-001 — EXTERNAL DOSE RECONSTRUCTION IMPLEMENTATION 

GUIDELINE 

The review of Office of Compensation Analysis and Support (OCAS)-IG-001, External Dose 

Reconstruction Implementation Guideline, Rev. 1, dated August 2002, was prepared by U. Hans 

Behling, PhD, MPH, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

2.1.1 Purpose of Procedure 

The purpose of this guide is stated in the preface of the implementation guideline and is cited 

verbatim below: 

. . . to provide basic information on the methods employed in reconstructing doses 

under the Energy Employees Occupational Illness Compensation Program Act of 

2000. The intent of this guide is to assist a qualified health physicist in 

determining annual organ dose from exposure to various sources of external 

radiation. Because not all possible exposure scenarios can be foreseen, this 

guide does not provide step by step instructions for how the dose reconstruction 

should be performed. It is recognized there will be situations for which the 

methods outlined in this guide result in underestimates or overestimates of a 

claimants actual dose. In these cases, care must be exercised that the doses are 

conservative (claimant friendly) but reasonable for the claimant’s exposure 

scenario. [Emphasis added.] 

The introduction of OCAS-IG-001 further states: 

The purpose of this section is to provide guidance on the components, standards, 

and methods of external radiation dose reconstruction for probability of 

causation calculations in support of the Energy Employees Occupational Illness 

Compensation Program Act (EEOICPA). . . 

2.1.2 Review Protocols 

As one of two primary guidance documents, OCAS-IG-001 fulfills the requirements set forth in 

the EEOIPCA. As such, this document represents the principal source of (1) technical support 

and background information and (2) procedural guidance for implementing the reconstruction of 

external exposure doses from photons, electrons, and neutrons under a variety of exposure 

conditions, which may or may not have been recorded. 

SC&A’s evaluation of OCAS-IG-001 is summarized in Table 2.1-1 below. Table 2.1-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 
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Table 2.1-1. Procedure Review Outline/Checklist 

Document No.: OCAS-IG-001 Effective Date: August 2002 

Document Title: External Dose Reconstruction Implementation Guide

Reviewer: U. Hans Behling

No. Description of Objective Rating 

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 3 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional data)? 4 See Review Comments 

1.4 Is the procedure consistent with all other procedures that are part 

of the hierarchy of procedures employed by NIOSH for dose 

reconstruction? 

3 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for identifying a 

potentially high probability of causation as part of an initial dose 

evaluation of a claim? 

3 See Review 

Comments 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 3 See Review 

Comments 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating 

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic as 

well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) 3 See Review 

Comments 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data 5 

3.2.4 Unmonitored periods of exposure 5 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 4 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as defined 

in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing data? 4 See Review 

Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3 See Review Comments 

5.3 Is the procedure claimant favorable in instances where claimant 

was not monitored? 5 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting the 

types of probability distributions (i.e., normal, lognormal)? 4 See Review 

Comments 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 3 See Review 

Comments 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can reasonably 

be accounted for by the dose reconstructor? 3 See Review 

Comments 

7.2 Does the procedure avoid levels of detail that have only limited 

significance to the final dose estimate and its POC? 3 See Review Comments 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

2.1.3 Review Comments 

Review Objective 1.1

Due to the complexity and potential level of detail that would be required for dose 

reconstruction, the dose reconstructor will consult OCAS-IG-001for each step of the external 

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dose reconstruction process. A key element for efficiency in completing a dose reconstruction is 

that the procedure provides a logical sequence for the dose reconstructor to follow. 

The structure employed by OCAS-IG-001 is fragmented and, therefore, inefficient and time 

consuming. Guidance for external dose reconstruction is spread over the following three major 

sections of the implementation guide: 

(1) Section 2.0, External Dose Reconstruction — Monitoring Data; Section 3, External Dose 

Reconstruction — Incomplete, Missing or No Monitoring Data; and Section 4.0, 

Conversion to Organ Dose, represent the overwhelming portion of OCAS-IG-001. 

(2) In turn, each of these three sections has separate discussions/guidance for (1) photon 

dose, (2) neutron dose, and (3) electron dose. 

(3) For example, the reconstruction of a photon dose, therefore, requires the dose 

reconstructor to consult Sections 2.0, 3.0, and 4.0. 

A more efficient structure would eliminate this fragmented approach by separating select 

information for photons from Sections 2.0, 3.0, and 4.0 and consolidating this information into a 

single section. For example, Sections 2.1, 3.1, and 4.1 dealing with photons could be integrated 

more efficiently into a single comprehensive section for estimating external photon dose from 

monitored data, incomplete data, and missing/no monitoring data. (Note: ORAUT-PROC-0006, 

External Dose Reconstruction, has in fact revised its structure in accordance with the above-cited 

recommendation.) 

A related but more significant issue centers on information that was introduced into core text of 

the implementation guide, which is of limited value/use to the dose reconstructor. For each of 

the five major sections of OCAS-IG-001, a substantial body of data and/or historical background 

information is provided. It is not only time-consuming, but also confusing and distracting for the 

dose reconstructor to read and comprehend this information. In many cases, what appears to be 

procedural guidance for dose reconstruction cannot be implemented due to the lack of data, 

complexity, or need for timeliness and process efficiency. This has apparently been recognized 

by the National Institute for Occupational Safety and Hazard (NIOSH)/OCAS since, near the end 

of each major topic/section of the implementation guide, procedural guidance ignores preceding 

information by recommending the use of (1) a simplified approach, (2) a table of default values, 

or (3) a complete substitution of data. For illustration, several examples are provided below. 

This problem characterizes nearly all other procedures as well. 

 Example 1: Section 2.1, Photon Dose. This section provides a detailed discussion as 

well as equations for dosimeter uncertainties that are unique to film and 

thermoluminescent dosimeter (TLD) photon and neutron dosimeters. Unfortunately, 

neither data nor resources are available to the dose reconstructor to make any functional 

use of this guidance. OCAS-IG-001 concludes with a simplified dosimetry uncertainty, 

as provided in Section 2.1.1.3.3. (Additional comments pertaining to the treatment of 

uncertainty are discussed below.) 

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 Example 2: Section 2.1.3, Occupational Medical Dose. This section identifies the 

variable operating parameters of an x-ray machine (i.e., kVp, mA, duration msec, 

filtration, and distance) that define the skin entrance dose described as kinetic energy 

released in material or air, or kerma. This information provides no useful information to 

the dose reconstructor for assessing occupational medical dose. (Note: A separate 

procedure exists for occupational medical exposures but is not referenced in the OCASIG-001; under Task 3, S. Cohen & Associates (SC&A) also reviewed ORAUT-OTIB0006, Occupational Medical X-ray Exposure, and provided comments.) 

 Example 3: Section 2.2, Neutron Dose, and Section 3.2.3, Neutron Dose ReconstructionSource Term Data. In Section 2.2, OCAS-IG-001 provides an ambiguous, historical 

discussion of nuclear track emulsion (NTA) neutron dosimeters, their limitations, and 

their potential use in dose reconstruction. In Section 3.2.3, OCAS-IG-001 proposes to 

reconstruct neutron doses when neither dosimeter nor survey data are available. The 

proposed protocol involves a calculational method that would require the dose 

reconstructor to first derive a neutron fluence (n/sec) from a source (e.g., reactor), and 

then determine a neutron dose based on the reconstructor’s knowledge regarding 

(1) shielding components, (2) distance between work and source, and (3) duration of 

exposure. While this type of reconstruction may be reasonable in instances of a single 

acute event, such as a criticality accident, it cannot be viewed as a reasonable approach 

for dose reconstruction in instances of long-term routine neutron exposures. 

 Limitations of this type have clearly been recognized by NIOSH/Oak Ridge Associated 

Universities Team (ORAUT). Thus, Site Profiles, such as the Savannah River Site (SRS) 

ORAUT-TKBS-0003, have simply excluded NTA neutron data and provided guidance 

for neutron dose reconstruction via neutron to photon dose ratios. 

 Example 4: Section 4.0, Conversion to Organ Dose. This section provides various 

references and a detailed discussion/data regarding the relationship between air kerma 

and the more conventional units of radiation exposure/dose, as well as converting such 

units of exposure to organ dose based on the radiation energy and exposure geometry. 

Because this information is unlikely to be used, the OCAS-IG-001 again presents a dose 

conversion factor (DCF) simplification (Section 4.1.3.), which refers the dose 

reconstructor to a simple set of DCFs contained in Appendix B. 

 SC&A concludes that, for improved clarity and efficiency, the extensive amount of 

historical and support data that are currently the main body of the implementation 

guideline should be separated from specific dose reconstruction guidance representing the 

core of the document. In a series of referenced appendices, this background information 

and support data would still provide the dose reconstructor with the option of 

understanding the technical basis for guidance contained in the implementation guideline. 

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Review Objective 1.3

In order for a procedure to be highly usable and effective, it should confine itself to a protocol 

that can reasonably be followed, as well as provide relevant and required data. OCAS-IG-001 

frequently recommends protocols that are unrealistic in scope and fails to provide data that are 

essential. For practical reasons, an exhaustive citation is beyond the scope of this review. For 

illustration, the following examples are provided that deal with the important issue of dosimeter 

uncertainty. 

 Example 1: Section 2.1.1.3.1, Film Badge Uncertainty. This section contains the 

following statement: 

The uncertainty associated with each dosimeter reading is assumed to be 

normally distributed, where the dosimeter reading is the mean and the 

upper 95% confidence dose is calculated by multiplying the uncertainty 

factor K(E) by each dosimeter reading using the following equations: 

E

e

D

E

E

E EK



















 



 

*

)(

)( 96.11)(

 where: E = Exposure in roentgen 

 σ* = Densitometer reading uncertainty (typically 0.015 density units) 

 D = Saturation density of film (e.g., Dupont 502 = 2.8) 

 γ = Film sensitivity (e.g., Dupont 502 = 0.25)

Reviewer’s Comments

To comply with this procedure, for each film badge reading, the dose reconstructor would 

have to pursue information pertaining to the type of film used, the densitometer’s 

sensitivity, and the film’s sensitivity and saturation density. Even if OCAS-IG-001 

provided all necessary data, it would, nevertheless, be unreasonable to determine the 

uncertainty for each dosimeter reading since there were times in the 1950s and 1960s 

when film badges were exchanged weekly. For long-term energy employees, this 

recommended procedure for assigning film badge uncertainties could easily involve data 

gathering for hundreds of film dosimeter cycles/reading, corresponding to an 

unreasonable level of effort. At this time, SC&A has completed its review of the first 20 

dose reconstruction claims and has noted that calculation of dosimeter uncertainty has 

either been ignored or avoided in all applicable cases. 

 Example 2: Section 2.1.1.3.2, TLD Uncertainty. For TLDs, OCAS-IG-001 recommends 

that uncertainty be derived by the following equation: 

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σt

2

 = σn

2

 + σμ kt

2

where: σt = standard deviation of total air kerma 

σn = standard deviation of null readings 

σμ = relative standard deviation observed at high air kerma 

 kt = total air kerma 

The OCAS-IG-001 further states “ . . . data for σn and σμ should be readily 

available from most DOELAP accredited programs.” 

Reviewer’s Comments 

To comply with this procedural recommendation, the dose reconstructor is asked to 

contact individual Department of Energy (DOE) sites for values of σn and σμ and then 

apply such data to each individual TLD reading. Beyond the inordinate amount of time 

needed to obtain these data and calculate uncertainties for each TLD reading, at least two 

technical issues would affect the use and validity of this procedure. First, TLDs are/were 

generally not calibrated in the unit of air kerma. Second, Department of Energy 

Laboratory Accreditation Program (DOELAP) accreditation for most DOE sites did not 

take place prior to the 1990s, at which time DOE introduced the state-of-the-art 

Panasonic 802 dosimeter. Therefore, DOELAP values for σn and σμ cannot be assumed 

to apply to different TLDs that were used as early as the 1960s and 1970s. 

 Example 3: Section 2.1.1.3.4, Uncertainty Combination. This section states, “. . . the 

uncertainty from each film dosimeter should be calculated and the combined annual

uncertainty should be calculated using standard error propagation methodology (square 

root of the sum of the squares), as shown in the following equation.” [Emphasis added.] 

σD

2

 = σ1

2

 + σ2

2

 + σ3

2

 + . . . σi

2

where: σD = uncertainty of annual dose 

 σi = uncertainty of a single dosimeter 

Reviewer’s Comments 

 As previously stated, procedural guidance that requires the dose reconstructor to define 

annual dosimeter uncertainty through individual dosimeter uncertainties by means of 

standard error propagation methodology appears excessive and inefficient, and places an 

unreasonable burden on the dose reconstructor for securing the necessary data. 

 Example 4: Section 2.1.3, Occupational Medical Dose. The practice of subjecting 

employees to medical exams that involved diagnostic x-rays (i.e., chest x-rays and 

photofluoroscopic exams) was confined to employment periods of the 1940s and early 

1950s. Section 2.1.3 of OCAS-IG-001 acknowledges (1) the need to include such 

exposure in dose reconstruction and (2) the likely absence of dosimetry data for 

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occupational medical exposure. Therefore, OCAS-IG-001 provides a significant amount 

of information that explains the relationship of several critical x-ray machine operating

parameters and suggests that, when the dose from a diagnostic procedure is unknown but 

the operating parameters of the x-ray machine are known (e.g., kVp, mA, total 

aluminum filtration, exposure duration, and skin-to-tube distance), the air kerma may be 

estimated, as cited in the example in Section 2.1.3.4. 

It is highly unlikely that such detailed data were ever recorded or are available at this 

time. Thus, to suggest to the dose reconstructor that such data are available and should, 

therefore, be pursued is unrealistic and misleading. Any attempt to pursue such data will 

result in the loss of valuable time or in subjective assumptions that lead to inconsistencies 

among dose reconstructors. 

Review Objectives 1.4 and 1.5

By design, OCAS-IG-001 provides basic information on the methods for dose reconstruction 

with which secondary procedures must comply and be consistent. There are numerous instances 

in which secondary procedures that include Site Profiles differ with the basic guidance provided 

in OCAS-IG-001. For example, OCAS-IG-001 consistently specifies that missed dosimeter dose 

for photons, electrons, or neutrons be defined in terms of the limit of detection (LOD) divided by 

2 for each cycle (i.e., LOD/2) and assigned an uncertainty for the assumed lognormal 

distribution. This protocol is described as one that is likely to overestimate the true dose and is, 

therefore, regarded as claimant favorable. 

There are, however, other procedures that, at the discretion of the dose reconstructor, allow 

missed dose to be defined as (1) LOD, a point estimate representing the 95th percentile value of a 

lognormal distribution (ORAUT-PROC-0006, Attachment D-2), or (2) ORAUT-OTIB-0008 and 

ORAUT-OTIB-0010. 

In summary, missed dosimeter dose may be derived by LOD/2 or LOD, which results in 

assigned missed doses that differ by a factor of 2. 

Inconsistencies of this type are common among procedures, and selection of the approach to 

apply is determined by the magnitude of the anticipated probability of causation (POC) value of 

the claim. For example, LOD/2 is minimally claimant favorable and is used in instances where 

the POC is close to or exceeds the 50% value; conversely, LOD is recommended when there is 

no possibility of compensating a claim. It is SC&A’s opinion that variable approaches of this 

nature for dose reconstruction are not scientifically valid and cannot be justified on the basis of 

process efficiency. 

Review Objective 2.0

As specified in Title 10, Section 82.10(k), of the Code of Federal Regulations (42 CFR 

82.10(k)), Section 1.4, Initial Dose Assessment, of OCAS-IG-001 acknowledges the 

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recommendation of a limited/partial dose reconstruction for claims where it is readily evident 

that the outcome will be unaffected by a more detailed and complete analysis. 

However, little or no guidance is provided regarding specific criteria for identifying a claim with 

a low probability for compensation and the constraints (if any) that apply to the use of worst-case 

assumptions. 

Without stating so, OCAS-IG-001 merely implies that the identification of a claim with either a 

high or low POC value rests with the individual dose reconstructor. This conflicts with ORAUTPROC-006, which makes reference to “. . . a preliminary assessment performed by Task 2 

personnel . . .” [emphasis added], who classify claims as either >50% POC or <50% POC along 

with the appropriate instructions for conducting an abridged dose assessment. 

A future revision to OCAS-IG-001 should identify the role of the Task 2 personnel and their 

role in preclassifying claims with high or low POCs. 

Review Objective 3.2.1

Section 2.1.1.3.2 discusses TLD uncertainty and provides a formula for deriving the standard 

deviation of the total air kerma, as cited by Hirning (1992). This formula is used for each 

recorded TLD dose and requires input data for (1) σn, the standard deviation of the null readings, 

and (2) σμ, the standard deviation observed at high air kermas. 

The implementation guide states that “. . . data for σn and σμ should be readily available from 

most DOELAP accredited programs. . . .” 

In Section 2.1.1.3.3, the implementation guide states, “While site-specific data, if available, 

should be used, in many instances this data will not be known . . . [and] the simple estimate of 

uncertainty is proposed based on the general equation provided by Hirning (1992).” [Emphasis 

added.] 

Reviewer’s Comments 

(1) If in fact data for σn and σμ are readily available, a more efficient procedure would 

provide such data to avoid the repetitious need for each dose reconstructor to obtain it 

from the DOE. 

(2) Section 2.1.1.2 states, “At most, large facilities . . . multi-element TLDs have been used 

since the mid 1960s”; and Section 2.1.1.3.2, TLD Uncertainty, recommends the use of 

site-specific data from DOELAP accredited programs, which only came into existence in 

the late 1980s. Since the introduction of TLDs, these devices have undergone many 

design changes and improvements. As such, it is unreasonable to assume that the 

uncertainty parameters that define current and state-of-the-art TLDs also apply to 

DOELAP TLDs of the 1960s and 1970s. In fact, OCAS-IG-0001, Section 2.1.1.1, clearly 

acknowledges this in the statement, “Through the years, technological developments have 

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greatly improved the accuracy and sensitivity of the dosimeters.” [Emphasis added.] 

Thus, the use of present-day uncertainty parameters as surrogate values for past TLDs 

cannot be considered claimant favorable. 

(3) Because OCAS-IG-001 only recommends the use of site-specific data “if available,” it 

provides the dose reconstructor the option of using the simplified dosimetry uncertainty 

described in Section 2.1.1.3.3, even when site-specific data are available. When multiple 

options of this nature may be selected at the discretion of the individual dose 

reconstructor, a critical concern is the potential lack of consistency of the dose 

reconstruction process. 

Review Objective 4.0

Over the period of time during which claimants may have been exposed/monitored, there have 

been substantial changes in radiological practices and technological improvements, as noted in 

OCAS-IG-001, Section 2.1.1.1, which states the following: 

Since the beginning of nuclear weapons research and production, individual 

workers have been monitored using personal dosimeters at many facilities. . . . 

Through the years, technological developments have greatly improved the 

accuracy and sensitivity of the dosimeters. [Emphasis added.] 

Thus, the accuracy and sensitivity of dosimeters and their use varied with time and location. 

Nevertheless, the OCAS-IG-001 approach for defining the uncertainty of film and TLDs does 

not address the variability of uncertainty with time and space. Section 2.1.1.3.1 states, “For 

simplicity, the approach outlined by the National Research Council (1989) will be employed for 

dose reconstruction under EEOICOPA.” 

However, in its evaluation of film badge dosimetry used between 1945 and 1962 for the 19 

nuclear weapons test operations, the National Research Council/National Academy of Sciences 

(NRC/NAS) Committee on page 80 concluded that “Each test operation was different in some 

aspect of personnel film badge dosimetry. . . . To assure that all these different factors affecting 

film dosimetry programs were considered, the film dosimetry bias and uncertainty for each test 

operation were analyzed separately.” [Emphasis added.] 

Equally, Fix et al. (1994), who assessed the bias and uncertainty in recorded external dose for 

Hanford, stated the following (pages 2.11 and 2.12): 

Dosimetry practices at Hanford changed over time as technology evolved, 

resulting in improved capabilities to measure a wide range of energies and types 

of radiation . . . . Because of the different capabilities of dosimeters used in 

different time periods, separate evaluations of bias and uncertainty are presented 

for the period 1944-56, 1957-71, and 1972-93. [Emphasis added.] 

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The extent to which Site Profiles may provide time- and facility-specific data for defining 

dosimeter uncertainty remains undetermined at this time. This review does not intend to be 

critical of the OCAS-IG-001 simplified approach for defining uncertainty; however, such a 

simplified/generic method for defining uncertainty must provide assurance of claimant 

favorability by applying the highest observed uncertainty value(s) to the entire time period. 

A more extensive evaluation of the OCAS-IG-001 dosimeter uncertainty methodology is 

provided below under Review Objective 6.0. 

Review Objective 5.0

In behalf of Review Objective 5.0, five issues were identified, which are discussed separately 

below. 

Issue 1: Limits of Detection 

Section 2.1.2 discusses the LOD for personnel dosimeters and the use of LOD values for 

assigning missed dose. Table 2.1 provides LOD values for 1956 through 1960, which range 

from 30 millirem (mrem) to 10 mrem. As early as 1959, the LOD value of 10 mrem is cited. 

For the stated time periods, these values are inconsistent with Site Profiles and other reported 

values. 

For example, in its investigation of film dosimeters used during atmospheric testing that 

extended until 1962, the NRC/NAS Committee concluded that “For most test series, the 

minimum detectable level was determined to be approximately 40 mR.” [Emphasis added] 

(NRC 1989, page 3). 

An LOD value of 40 mR is also cited for dosimeters worn at the Rocky Flats Plants (RFP) during 

the 1950s and 1960s. Table 6-9 of the RFP Technical Basis Document provides photon LOD 

values from 1951 through 2003, as reproduced below (ORAUT-TKBS-0011-6, Table 6-9, page 

26): 

In summary, the NRC/NAS Committee and RFP data are inconsistent with LODs cited in 

OCAS-IG-001, Table 2.1; the use of Table 2.1 values would clearly not be claimant favorable. 

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OCAS-IG-001 also implies the assumption that, for a given dosimeter, the LOD for deep dose 

from gammas may also be applied to the electron dose, which would have involved the “open 

window” or the 7 mg/cm2

 shallow dose (see Sections 2.3.2.3 and 2.3.2.4). Historical data 

consistently show that the uncertainty, and therefore the LOD of the shallow dose, which 

includes the electron dose, is considerably higher than the deep dose or HP(10). 

Issue 2: Failure to Include Potential Exposures From Electrons to Lens of Eye 

Section 1.2.3 of OCAS-IG-001 describes electron (beta particle) exposure and states that: 

Generally, external electron exposures are only important for surface tissue such 

as skin. Thus, for skin cancer, a dose reconstruction from exposure to electrons is 

required. . . . The other two organs for which external electron exposure from 

high energy electrons (> 1 MeV) might be significant are the testes and the 

breast. [Emphasis added.] 

Among the cancers eligible for compensation is eye cancer (Interface Control Document (ICD)-9 

Code 190), with the lens of the eye as the external dose organ. Given the lens’ shallow tissue 

depth of ~300 mg/cm2

 (or about 3 mm), it would appear reasonable to include the eye for 

electron dose estimates along with tissues of the testes and breast. Moreover, unlike the testes 

and breast, which may benefit from the added shielding affects of clothing, the eye (in the 

absence of eyeglasses) is not shielded. 

Issue 3: Assumed Limitations of NTA Neutron Dosimeters 

Section 2.2.1of OCAS-IG-001 acknowledged several limitations for NTA film dosimeters. A 

serious limitation of fast neutron dosimetry by track analysis is its insensitivity to neutrons. 

OCAS-IG-001 has assumed that NTA film dosimeters were insensitive to neutrons below 500 

keV. This value significantly differs from the 1 MeV value cited by others, including Fix et al. 

(1997), whose work is heavily referenced throughout this procedure, as summarized below. 

Fix et al., (1997). Fix’s reference to a lower energy neutron cutoff of about 1 MeV is cited on 

pages iv and v of the executive summary. On page 3.3 of Section 3.2, Fix et al. state that “. . . 

tracks of length less than about 3 microns are difficult to identify at Hanford, the observation of a 

track was confined to tracks with four or more grains. . . . As such, the lower energy threshold 

for the Hanford NTA film dosimeters is expected to be about 1 MeV, particularly when photon 

‘fogging’ is present.” 

Hine and Brownell (1956). In their classic reference text Radiation Dosimetry, Hine and 

Brownell assume a similar value, as described on page 338, which is reproduced below: 

A serious limitation on fast-neutron dosimetry by track analysis is its unsuitability 

at lower energies. Tracks of length less than perhaps 3 μ (proton energy of about 

0.3 Mev) are difficult to distinguish from the change alignment of fog grains. 

Since three-tenths of the proton recoils from 1-Mev neutrons are of energy less 

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than 0.3 Mev, the error introduced by neglecting to count the shorter tracks is 

large at neutron energies this low. [Emphasis added.] 

In summary, 500 keV threshold value assumed by OCAS-IG-001 appears inconsistent (and not 

claimant favorable) when compared to the 1 MeV value cited by others. 

Issue 4: Reconstruction of Neutron Dose(s) from Survey Data or Source Term Data 

Section 2.2.2.1 of OCAS-IG-001 states, “Neutron monitoring was not fully implemented, or was 

generally inadequate, until the late 1950s . . . even though large-scale operations were ongoing 

since 1945.” In the absence of data for this 12-year period, Sections 3.2.2 and 3.2.3 discuss 

methods for neutron dose reconstruction by means of survey data and source term data. For 

claims that may have involved individuals with neutron exposures under variable and complex 

conditions, as well as over extended periods of time, the suggested methods do not appear 

practical/achievable/defensible. 

OCAS-IG-001, Section 2.2.2.1, acknowledges that neutron exposures occur in combination with 

photon exposures and references the work of Watson (1959), who correlated the magnitude of 

neutron exposures with photon exposures. However, OCAS-IG-001 dismisses the potential use 

of a neutron-to-photon dose ratio as a viable method and concludes that “. . . at most facilities, 

neutron exposures were generally less than 20% of the photon exposures.” 

Not acknowledged by OCAS-IG-001 is the fact that the neutron to photon ratio method for 

estimating neutron doses prior to 1971 has been adopted for dose reconstruction at SRS and, 

therefore, conflicts with the OCAS-IG-001 statement. In fact, neutron/photon ratios of up to 2.4 

are cited in the SRS Technical Basis Document (ORAUT-TKBS-0003), which is 12 times higher 

than the 20% stated in OCAS-IG-001. 

Also, not acknowledged by OCAS-IG-001 is the retrospective calculation of neutron doses and 

their relationship to recorded photon doses by Fix et al. (1997) in behalf of 14 Hanford workers 

(exposed between 1950-1961). These data are summarized by Fix et al. (1997) in Table 4.2 of 

Section 4.4 and reproduced below for verification (Table 2.1-2). Depending upon the method 

used to recalculate neutron dose, its value may be as much as 75% of the deep dose. 

It is recommended that this section be revised to acknowledge the likely use of the 

neutron/photon ratio method in neutron dose reconstruction in lieu of survey data or source term 

data. 

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Table 2.1-2. Comparison of Integrated Neutron Dose Component, 1950-1961 

(Source: Fix et al. 1997) 

Recorded Dose (a) Method Used to Recalculate Neutron Dose Worker Shallow Deep X-ray Neutron 1 2 3 4 5 

1 15,190 13,880 3,090 130 2,900 1,018 846 494 540 

2 17.760 14,100 0 40 5,531 1,937 1,547 778 914 

3 33,760 24,960 0 80 3,420 1,457 1,172 823 868 

4 18,520 13,580 2,080 1,000 4,974 2,228 1,826 1,212 1,210 

5 20,340 18,570 1,840 1,850 8,023 3,987 3,528 2,482 2,669 

6 14,010 4,890 10 730 3,149 1,684 1,524 1,179 1,170 

7 19,120 17,530 0 220 4,300 1,667 1,340 616 763 

8 17,250 7,300 20 1,360 1,873 1,186 1,162 1,018 943 

9 23,450 22,030 2,630 4,150 7,932 4,356 4,038 3,259 3,026 

10 17,010 13,780 3,220 920 5,381 2,341 2,063 1,173 1,329 

11 32,960 26,230 0 130 3,456 1,150 771 376 472 

12 4,420 3,980 0 50 2,994 1,151 825 418 496 

13 20,460 14,060 1,090 2,750 4,699 2,647 2,505 2,129 1,937 

14 8,030 6,810 0 0 4,882 1,798 1,373 729 839 

(a) Whole-body skin dose = Shallow + 65% of x-ray + neutron 

 Whole-body deep dose = Deep + 35% of x-ray = neutron 

Issue 5: OCAS-IG-001, Appendix B, DCFs for Bone Surface and Red Marrow 

At low photon energies, absorption is principally by means of the photoelectric effect and varies 

with the atomic number (z) of the absorbing medium. The variation with atomic number is not 

straightforward but is complicated by a rapid rise at discrete absorption degrees that define Kshell, L-shell, and other electrons. At photon energies above the absorption edge, the 

photoelectric cross section per electron varies as z3 and per atom as z4. 

This phenomenon is exploited in diagnostic radiography in which bone tissue is readily 

distinguishable from soft tissue. Thus, simple depth dose curves derived from unit density 

phantom measurements cannot be applied to convert dosimeter data to bone doses. 

Spiers (1946) has corrected the standard depth dose for this effect, and his results are shown 

below in Figure 2.1-1, in which a beam of 200-kv radiation, HVL 1.5 mm Cu, is passed through 

successive layers of skin, fat, muscle, and bone. Curve A is the standard depth dose curve, and 

curve B is the corrected curve. In the region beyond the bone, the actual depth dose is about 

one-half the expected value. Spiers has calculated the energy absorption, and this is shown by 

curve C of Figure 2.1-1. If there were no discontinuities, the energy absorption would be 

proportional to the depth dose curve, but with the bone present, the energy absorption is 

increased by a factor of about 5. In this case, more energy is delivered to the bone layer at a 

depth of 6 to 9 cm than is delivered to the skin of the patient. Figure 2.1-1 further shows that 

the average dose over a bone thickness of 2 cm is greater than (1) the entrance dose and (2) the 

HP(10) deep dose. The higher bone surface and red marrow doses defined by Spiers (1946) 

conflict with the lower DCFs contained in Appendix B of OCAS-IG-001. 

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Figure 2.1-1. Relative Depth Dose in a Phantom Consisting of Layers of Skin, Fat, Muscle, 

and Bone. Field size 100 cm2, TSD 50 cm, HVL 1.5 mm Cu. (Spiers 1946)

Potential Effects on Marrow Doses. Spiers (1949) investigated the effects of the higher atomic 

number and density of bone from another point of view. The trabecular cavities within bone are 

filled with the highly sensitive bone marrow stem cells. Spiers investigated the shift of electron 

equilibrium that takes place at the soft tissue to bone interphase and ionization within these small 

cavities. Some of his results are shown below in Figure 2.1-2 for three types of radiation. For 

low-energy radiation, the ionization within a small 1-μ cavity is 9.6 ions per cubic micron; 

whereas for a large cavity, 100 μ in diameter, the ionization at the center of the cavity is only 1.8 

ions per cubic micron and rises to about 5 ions per cubic micron at the edge of the cavity. The 

range of the electrons, which are set in motion by low-energy radiation, is small; and none of the 

electrons set in motion in the walls of the cavity reach the center. The ionization density at the 

center of a large cavity is, therefore, nearly the same as for soft tissue. The results for mediumenergy radiation are shown in Figure 2.1-2(b) and the high-energy radiation in Figure 2.1-2(c). 

For high-energy radiation, the range of the electrons is considerable, and the ionization density is 

essentially uniform throughout the cavity. 

In summary, marrow contained in small bone cavities may receive doses that are several times 

higher than that assumed for full electron equilibrium in soft tissue. 

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Figure 2.1-2. Ionization in Soft Tissue Inside Bone Cavities for Radiation Generated at 

80 kv, 200 to 250 kv, and 0.5 to 1.0 MeV 

In summary, data show that, when soft radiation is used (i.e., 30-250 keV), the layers of red 

marrow tissue adjacent to the bony structure receive a larger dose than tissue at the center of a 

larger cavity. Depending on the size of the bone cavity, the dose to bone marrow may vary 

significantly. 

It appears that DCFs for bone surface and bone marrow derived from International Commission 

on Radiological Protection (ICRP) 74 data may not have taken these two effects into account. 

Review Objective 6.0

Section 2.1.1.3 of OCAS-IG-001 discusses the uncertainty of personnel dosimeters. It provides 

the following statement for film badges (discussed in Subsection 2.1.1.3.1): 

A technical committee appointed by the National Academy of Sciences outlined 

three components (laboratory, radiological, and environmental) of uncertainty in 

personal dosimetry for film badge dosimetry used during atmospheric nuclear 

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tests (NRC 1989). The uncertainty in the environmental component is discussed in 

section 2.1.3, and the radiological component is discussed in the exposure 

geometry section 4.4. Thus the laboratory uncertainty is the only source of 

uncertainty addressed in this section. [Emphasis added.] 

In summary, the NRC/NAS Committee identified the three separate components for uncertainty: 

laboratory, radiological, and environmental. The following discusses issues of concern related to 

each of the three components. 

Issue 1: Laboratory Uncertainty 

A review of the above-referenced NRC (1989) report reveals the following: 

 

Page 68: 

This category includes all the uncertainties introduced in film calibration, 

chemical processing of films, reading their optical densities, comparing these 

densities with the densities of unexposed and calibration films, and in interpreting 

the measured densities in terms of exposure. 

Even under the best controlled laboratory conditions, laboratory uncertainties 

[K(E)] are a strong function of exposure levels, particularly at low exposure 

levels. [Emphasis added.] 

Page 71: 

The 95% uncertainty factor for the additional uncertainty for exposures below 

0.2 R is obtained as 

2.1ln)((ln2 2

)(*   EK eEK , 

 

where K(E) = 1 + 0.042 e0.25E/E for Du Pont 502 film. Values of K*(E) are given 

in Table 5-1. 

Table 5-1 Additional Uncertainty Factors for Film Badge Readings Below 0.2 R 

E(R) K(E) K*(E) 

0.02 3.11 3.07 

0.04 2.06 2.01 

0.06 1.71 1.66 

0.08 1.54 1.47 

0.10 1.43 1.36 

0.12 1.36 1.28 

0.14 1.31 1.22 

0.16 1.27 1.17 

0.18 1.24 1.13 

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These factors are to be combined with uncertainties from other sources as usual, 

including the “standard” laboratory uncertainty factor, which is 1.2 or 1.3 for 

most test series. [Emphasis added.] 

The above-cited table from NRC (1989) not only identifies standard uncertainties (i.e., K(E)) 

that parallel the assumed value of 1.3 by OCAS-IG-001, but also additional uncertainties (i.e., 

K*(E)) for exposures below 0.2 R. 

However, OCAS-IG-001, Section 2.1.1.3.1, states that: 

. . . For simplicity, the approach outlined by the National Research Council 

(1989) will be employed for dose reconstruction under EEOICPA. However, the 

additional uncertainty discussed for exposures below 200 mR will not be 

employed, since routine monitoring is generally more precise than large sampling 

events such as atmospheric test monitoring. . . . 

OCAS-IG-001 provides no technical support for this nonconservative/nonclaimant-favorable 

assumption that excludes the additional uncertainty associated with exposures of less than 200 

mrem. 

Issue 2: Radiological Uncertainties — DCFs for Posterior to Anterior (PA) Exposure 

Geometry 

NRC 1989 identifies the following three areas of uncertainty in behalf of the radiological 

category: photon energy, body wearing position, and radiation backscatter. It states the 

following: 

. . . A film badge is normally expected to be worn on the chest. At such a position, 

it is not experiencing the same radiation field as if it were freely exposed in air 

because body attenuates radiation from the back. The presence of the body on 

which a badge is worn [also] increases the radiation field . . . because the body 

backscatters photons.

OCAS-IG-001 considers photon energy and discusses radiological uncertainties in Section 4.4 in 

behalf of four exposure geometries; and Appendix B provides tissue/organ DCFs in behalf of 

three energy intervals and four exposure geometries. 

SC&A’s review of radiological uncertainties and exposure-geometry-specific DCFs presented 

in Appendix B of OCAS-IG-001 has led to the conclusion that PA geometry DCFs are in error, 

as explained below. 

DCFs for PA Exposure Geometry. OCAS-IG-001, Section 1.5 (page 11), states that “. . . 

typically, film badge and TLDs were worn on the upper front torso of the body.” Therefore, on 

the assumption that personnel dosimeters were commonly worn on the chest, the DCFPA values 

given in Appendix B for photons and neutrons appear in error. SC&A has concluded that DCFs 

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for PA geometry given in Appendix B wrongly assumed that the measured dosimeter dose was 

worn on the posterior of the torso instead of the anterior. The consequence of this error would 

be most pronounced for those tissues/organs that are located at/near the posterior surface of the 

body (e.g., female breast, male testes, eye, thyroid). 

For example, for photons between 30 and 250 keV, Appendix B gives a thyroid DCFPA value of 

0.298 rem for a recorded deep dose (Hp(10)) of 1 rem. If the recorded deep dose involved a 

dosimeter (either film or TLD) worn on the chest, the assigned thyroid DCFPA of 0.298 is in 

error, as shown in the diagram below: 

Source

Personnel 

Dosimeter

Thyroid 

Figure 2.1-3. Worker Receiving Radiation Exposure From Posterior Geometry 

(1) the personnel dosimeter received radiation that is attenuated by the full thickness of the chest 

(2) the thyroid receives radiation that is attenuated by tissues that are limited to the neck 

(3) additionally, tissues/organs within the body would also receive exposure from backscatter,

which would not be recorded on an anterior-worn dosimeter that is subjected to a PA exposure 

geometry 

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In fact, for a recorded Hp(10) dosimeter reading of 1 rem, the dose to the thyroid must be 

assumed at 1 rem or greater and, therefore, corresponds to a DCFPA of ≥1. 

It appears that the DCFPA values given in Appendix B for photons and neutrons erroneously 

assumed that the dosimeter of record was worn on the body surface facing the source of 

radiation. For a PA exposure geometry, this would falsely assume that the dosimeter was placed 

on the posterior-side of the individual. 

If this interpretation is correct, than DCFPA values for all tissues should be ≥1.0 with the highest 

DCFPA values for (1) low-energy radiation and/or (2) tissues/organs located near the posterior 

portion, since these tissues are subject to a beam that is least attenuated and subject to a 

maximum backscatter. 

The likelihood that DCFs cited in Appendix B are inappropriate for the reconstruction of doses 

for energy employees (who must be assumed to have worn their personnel dosimeter on the body 

at the center of the chest) is validated by data presented in Figure 2.1-4 below, which has been 

taken directly from National Council on Radiation Protection and Measurements (NCRP) Report 

No. 122, 1995 (see Figure 3.1, page 19 of NCRP No. 122). 

Figure 2.1-4 reproduces the conversion coefficients provided by the International Commission 

on Radiation Units and Measurements (ICRU) (1988) for the ratio HE/HP(10), where HP(10) is 

the measured dose equivalent at a depth of 10 mm in the ICRU sphere and HE is the effective 

dose equivalent defined as: 

HE = ∑ WT HT

 Where: WT = tissue weighting factor 

 HT = dose equivalent to the various tissues/organs irradiated. 

Conversion coefficients for HE/HP(10) are given for personnel monitors located either (1) on the 

body at the center of the chest (i.e., front) or (2) the center of the back for the following exposure 

geometries: 

 Personnel monitor located on the front of the body (i.e., at the center of the chest)

 AP—broad parallel beam from front to back (anterior to posterior) 

 PA—broad parallel beam from back to front (posterior to anterior) 

 LAT—broad parallel beam from either side (lateral) 

 IS—isotropic field 

 PL.IS—planar isotropic field, perpendicular to body axis 

Personnel monitoring location on the back of the body (i.e., at the center of the back)

 AP—broad parallel beam from front to back (anterior to posterior) 

 PA—broad parallel beam from back to front (posterior to anterior) 

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The critical difference in the HE/HP(10) coefficient for a dosimeter that in fact is worn on the 

front, but is wrongly assumed to have been worn on the back, is dramatized by comparing the 

curves represented by and □. The difference is most pronounced for low-energy and lowpenetrating photons. For example, for 30 keV photons in cases in which the dosimeter is worn 

on the back, the coefficient is about 0.14; when the dosimeter is worn on front, the HE/HP(10) 

coefficient is about 100, or nearly 1,000 times higher. 

Figure 2.1-4. Ratio of HE to HP(10) as a Function of Photon Energy 

As previously stated and verified in Figure 2.1-4, for all photon energies, the ratio of organ dose 

to recorded HP(10) must be greater than unity when the recorded dose was measured on the 

body’s anterior and when exposure corresponds to a PA geometry. 

It is, therefore, concluded that PA DCFs cited in Appendix B for photons and neutrons were 

erroneously based on the assumption that the recorded dose represented a dosimeter that had 

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been placed on the back of the wearer. For low-energy photons, the resultant error in assigned 

dose may be greater than 100 times the true value. 

Issue 3: Radiological Uncertainties and Potential Errors with Other Exposure 

Geometries/DCFs 

A similar discrepancy for cited DCFs appears to apply to the rotational and isotropic exposure 

geometries. Under rotational exposure geometry, a dosimeter would be subject to a small 

fraction of photons that define the undisturbed radiation field. The balance of photons would be 

variably attenuated, as determined by the amount of tissue that must be traversed prior to 

reaching the dosimeter. With linear attenuation, a tissue/organ (e.g., lung) that falls at or near 

centerline to the vertical axis of the body would be expected to receive a dose that is essentially 

equal to the recorded deep dose (HP(10)) of a dosimeter. This relationship is supported by Fix et 

al. (1994) and NRC (1989), which produced the following statements and data: 

Fix et al. (1994) (page VI): 

In general, deep dose slightly overestimates lung dose for the anterior-posterior 

geometry and slightly underestimates lung dose for the rotational geometry. . . . 

Deep dose is a fairly accurate estimate of red bone marrow dose for the 

rotational geometry, but overestimates red bone marrow dose substantially for 

the anterior-posterior geometry. . . [Emphasis added.] 

 Fix et al. (1994) (page 2.10): 

. . . Tables are available in the scientific literature (ICRP 1987, ICRU 1988) that 

provide factors for converting . . . deep dose to doses to various organs. These 

relationships, which depend on both energy and geometry, are based on computer 

calculations of particle fluency, exposure, deep dose based on the International 

Commission on Radiation Units and Measurements (ICRU) 30-cm diameter 

sphere, and the effective dose equivalent on an anthropomorphic phantom for 

different photon energies and exposure geometries. Tables . . . 2.3 and 2.4 show 

the respective relationship between . . . deep dose and bone marrow dose, and 

deep dose and lung dose. . . . 

Pertinent data from Tables 2.3 and 2.4, cited above, are presented in Tables 2.1-3 and 2.1-4 

below. The data show marrow doses that are equal to or greater than the deep dose equivalent. 

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Table 2.1-3 Ratio of Red Bone Marrow Dose to Deep Dose Equivalent 

(Source: Fix et al., 1994) 

Photon Energy (keV) Rotational Irradiation 

70 1.0 

100 0.99 

120 1.0 

200 1.04 

500 1.0 

662 (Cs-137) 1.0 

1,000 1.0 

Table 2.1-4. Ratio of Lung Dose Equivalent to Deep Dose Equivalent 

(Source: Fix et al., 1994) 

Photon Energy (keV) Rotational Irradiation 

70 1.13 

100 1.13 

120 1.12 

200 1.12 

500 1.07 

662 (Cs-137) 1.07 

1,000 1.07 

Similar findings are reported in the 1989 NRC report: 

 NRC (1989) (page 78): 

The relationship between effective dose equivalent and deep-dose equivalent for . 

. . rotational exposure geometries is presented in Table 5-2. For the rotational 

geometry, the deep-dose equivalent and the effective dose equivalent are nearly 

identical for photon energies above 0.08 MeV. . . 

 Deep-dose equivalent does not indicate dose equivalent to [any] specific organs. 

To assess the risk of a clinically detectable effect (e.g., cancer) to a specific

organ, it [is] necessary to estimate the dose equivalent to that organ. 

Calculations may be performed to estimate an organ-dose equivalent from deep 

dose equivalent. Tables 5-4 and 5-5 are examples for red bone marrow and lung, 

respectively, for rotational irradiation. [Emphasis added.] 

Tables 5.2, 5.4, and 5-5 from NRC 1989 are provided below as Tables 2.1-5, 2.1-6, and 2.1-7, 

respectively. 

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Table 2.1-5. Generic Ratios of Organ Effective Dose Equivalent HE

to the Deep-Dose Equivalent, HP(10) 

(Source: NRC 1989) 

Photon Energy (MeV) Anterior-Rotational Irradiation 

0.05 0.87 

0.08 1.06 

0.10 1.09 

0.20 1.06 

0.40 1.03 

0.60 1.03 

0.80 1.02 

1.00 1.02 

2.00 0.99 

Table 2.1-6. The Ratio of the Red Bone Marrow-Dose Equivalent 

to the Deep-Dose Equivalent, HP(10) 

(Source: NRC 1989) 

Photon Energy 

(MeV) 

Ratio for 

Rotational Irradiation 

0.05 0.69 

0.08 0.92 

0.10 0.99 

0.20 1.04 

0.50 1.00 

1.00 1.00 

Table 2.1-7. The Ratio of the Lung-Dose Equivalent 

to the Deep-Dose Equivalent, HP(10) 

(Source: NRC 1989) 

Photon Energy 

(MeV) 

Ratio for 

Rotational Irradiation 

0.05 0.93 

0.08 1.12 

0.10 1.14 

0.20 1.12 

0.50 1.08 

1.00 1.07 

The ratios of organ dose to deep dose equivalent for red bone marrow and lung cited by Fix et al. 

(1994) and NRC (1989) are identical for rotational exposure geometry and for photon energies 

above 0.08 MeV (80 keV), equal or exceed unity (i.e., 1.0). 

These ratio values (or DCFs) should be compared to DCFsRot given in OCAS-IG-001, Appendix 

B, and reproduced in Table 2.1-8 below. When, for example, the 30-250 keV energy values are 

compared to the 400 keV values cited by Fix et al. (1994) and NRC (1989), a difference of a 

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factor of 2 is noted and suggests that organ doses reconstructed by DCFRot may have been 

significantly underestimated. 

Table 2.1-8. DCFRot Values for Red Bone Marrow and Lung Cited in Appendix B 

Photon Energy Bone (Red Marrow) Lung 

< 30 keV 0.036 0.052 

30 – 250 keV 0.482 0.552 

> 250 keV 0.760 0.802 

Issue 4: Radiological Uncertainty — Angular Sensitivity 

A serious limitation involving personnel dosimeters (film and TLD) used to assess photon and 

neutron exposures concerns angular sensitivity, as determined by body-wearing position relative 

to the radiation field. When personnel dosimeters are calibrated, the incident radiation is normal 

(i.e., 0) to the plane of the dosimeter, yielding a dose response (i.e., calibration factor) that is 

optimal. At incident angles that deviate from 0, the response of the dosimeters can be greatly 

diminished, which leads to an underestimate of the true exposure that is measured. 

Empirical measurements of angular sensitivity of film to photons and neutrons have been 

reported by Hine and Brownell (1956) and are reproduced below in Tables 2.1-9 and 2.1-10. 

Table 2.1-9. Sensitivity of NTA Film Badge in Free Air to Neutrons 

from Two Sources Incident at Various Angles 

(Source: Hine and Brownell 1956) 

Angle of Incidence Po-B Neutrons Po-Be Neutrons 

0 1 1 

90 0.63 0.50 

0-90 (rotating) 0.72 0.65 

Table 2.1-10. Relative Film Badge Sensitivity in Free Air for Gamma-Rays 

Incident at Various Angles 

(Source: Hine and Brownell 1956) 

Angle of Incidence 0.11 MeV 0.20 MeV 1.2 MeV 

0 (perpendicular incidence) 1.00 1.00 1.00 

22.5 0.87 0.92 0.97 

45 0.46 0.73 0.91 

67.5 0.33 0.45 0.92 

90 0.16 0.41 0.94 

The above data identify a significant reduction in response based on the angle of incidence. 

Thus, an assumed constant anterior to posterior (AP) exposure geometry for a recorded 

dosimeter that in reality represents exposure angles that may vary between 0 and  90 would 

significantly underestimate the person’s true exposure. 

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The need to assess angular dependence is specifically addressed by the DOE in Section 3.3, 

Angular Dependence of the Department of Energy Standard for the Performance Testing of 

Personnel Dosimetry Systems, DOE Laboratory Accreditation Program from Personnel 

Dosimetry Systems, of DOE/EH-0027 (1986). DOE’s recommended procedure for assessing 

angular dependence includes the rotation of an on-phantom dosimeter through at least seven 

different angles of incidence from -85 to +85, including 0, with the results of the angular 

dependence expressed as the ratio of the dose equivalent response to the administered dose 

equivalent at 0. 

Section 4.4 of OCAS-IG-001 identifies four exposure geometries and provides tissue-specific 

organ DCFs for each exposure geometry in Appendix B. However, these DCFs merely reflect 

the extent of beam attenuation for these tissues under these exposure geometries and range of 

energies, and do not account for angular sensitivity of the personnel dosimeter. 

In summary, it is unclear whether the dose reconstruction protocol defined by OCAS-IG-001 

incorporates angular dependence of personnel dosimeters in the overall uncertainty of these 

devices. As shown by Hine and Brownell (1956), the impact of angular dependence on 

uncertainty is significant and can easily parallel the magnitude assigned to laboratory 

uncertainty. 

Issue 5: Radiological Uncertainty — Backscatter 

Backscatter may significantly influence the dose-response of a dosimeter and reflects the 

calibration protocol. Fix et al. (1994) states that “ In 1984, the dosimeter calibration procedure 

was changed to “on-phantom” as opposed to “in-air” to better simulate the dose to workers.” 

This implies that, prior to 1984, dosimeters were calibrated in free air and, after 1984, calibration 

of personnel dosimeters was performed on-phantom. For these two calibration conditions, the 

recorded dose may significantly differ. 

For illustration, suppose that a dosimeter is placed at the point P on the surface of the phantom 

and that the amount of radiation is measured in a given length of time. Then suppose that the 

phantom is removed, leaving the dosimeter P at exactly the same point in space, and the 

exposure is run for an equal length of time. It will be found that the dose recorded by the 

dosimeter at P will be considerably less in the second case, because part of the radiation 

observed in the first case is radiation that is scattered back from the phantom to the point P. The 

backscatter factor is defined as follows: 















 

a

s

D

D factorrBackscatte

The percentage backscatter is defined as 















  

a

as

D

DD Percentage rbackscatte

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Figure 2.1-5. Diagram to Illustrate the Meaning of Surface Backscatter 

and Percentage Depth Dose 

Here, Da stands for the dose measured by the dosimeter in air, and Ds is the corresponding dose 

with the scattering material (i.e., phantom) in place. 

Hine and Brownell (1956) evaluated backscatter and concluded that it depends (1) in a complex 

way on the energy of the radiation, (2) the area of the field, and (3) thickness of the scattering 

medium. The percentage of backscatter may be as high as 50% for a large field, adequate 

thickness, and select photon energy. Backscatter factors related to radiation quality and field size 

are summarized in Figure 2.1-6. The data indicate that, for photons with HVL between 0.6 mm 

Cu and 1.0 mm Cu (or ~60 keV-80 keV), the backscatter factor for a dosimeter worn on the 

upper torso of an adult could reach a value of about 1.5. Such a backscatter factor would apply 

to DCFs with photon energies between 30 and 250 keV, as given in OCAS-IG-001. 

Equivalency between HVL 

 and Photon Energy

 HVL (Cu) keV

0.1 37 

0.2 45 

 0.4 55 

 0.6 64 

 0.8 70 

 1.0 77 

 2.0 110 

 3.0 135 

 4.0 155 

 5.0 185 

Figure 2.1-6. Variation of the Backscatter Factor with the Quality 

of the Radiation for a Number of Field Sizes 

(Source: Hine and Brownell 1956) 

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Since DCFs provided in OCAS-IG-001 do not distinguish between dosimeter readings as pre- or 

post-1984 when the conversion of free air to on-phantom calibration took place, questions that 

must raised include the following: 

(1) Was the difference between free-air versus on-phantom calibration (and, therefore, the 

impact of backscatter) considered in the derivation of DCFs cited in Appendix B? 

(2) If backscatter was factored into DCFs, what values were assigned in order to ensure 

conservatism and claimant favorability? 

SC&A concludes that radiological uncertainty was not addressed in the overall uncertainty 

estimate for dosimeter readings. 

Issue 6: Dosimeter Uncertainty — Environmental 

The third and final category of uncertainty associated with personnel dosimeters was termed 

environmental by the NRC/NAS Committee (NRC 1989). Environmental uncertainty is the 

collective impact of environmental factors that include high temperatures, humidity/moisture, 

light, pressure, reactive chemicals, and radioactive contamination to which the dosimeter may be 

exposed in the field during the wear period. For adverse environmental conditions, the 

environmental uncertainty (KENV.) was estimated at 1.3 (NRC 1989). 

As previously mentioned, OCAS-IG-001, Section 2.1.1.3.1, identifies environmental uncertainty 

in the following passage: 

A technical committee appointed by the National Academy of Sciences outlined 

three components (laboratory, radiological, and environmental) of uncertainty in 

personal dosimetry for film badge dosimetry used during atmospheric nuclear test 

(NRC, 1989). The uncertainty in the environmental component is discussed in 

section 2.1.3 . . . [Emphasis added.] 

The referenced “Section 2.1.3,” in fact, provides a discussion of occupational medical dose and 

makes no mention of environmental uncertainty. 

It is likely that the intent was to identify Section 2.1.4, Environmental Dose, along with Section 

2.1.4.3, which discusses the uncertainty for quantifying the environmental dose. However, the 

NRC (1989) definition of environmental uncertainty in dosimeter response to environmental 

factors, such as heat and humidity, has no relation to the discussion in OCAS-IG-001, Section 

2.1.4.3, of environmental uncertainty associated with onsite ambient radiation doses to 

unmonitored personnel. SC&A concludes that environmental uncertainty was not addressed in 

OCAS-IG-001. 

In summary, OCAS-IG-001 extensively references the study results of NRC (1989), Fix et al. 

(1996), Hine and Brownell (1956), and others without acknowledging their recommendations 

and findings, including dosimeter uncertainty categorized as radiological and environmental. 

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The discussion of uncertainty in OCAS-IG-001, therefore, appears incomplete and leaves 

several questions unanswered as to what was and what was not included, and whether the more 

restrictive treatment of uncertainty is truly claimant favorable. It would be helpful if OCAS-IG001 provided summary uncertainty data similar to the sample data shown in Tables 2.1-11 and 

2.1-12 below that was given in NRC (1989). 

Table 2.1-11. Sample Data for Bias (B) and Uncertainty (K) for Operation CROSSROADS 

(Source: NRC 1989) 

Source B K 

Laboratory 1.0 1.3 

Radiological 

 Spectrum 1.3 1.3 

 Wearing 0.8 1.3 

 Backscatter 1.1 1.1 

Total Radiological 1.1 1.5 

Environmental 1.0 1.3 

Overall (Exposure) 1.1 1.7 

Conversion to Deep-Dose Equivalent 1.3 1.2 

Overall (Deep-Dose Equivalent) 1.5 1.8 

Table 2.1-12. Sample Data for Deep-Dose Equivalent and 95% Confidence Limits 

for Operation CROSSROADS 

(Source: NRC 1989) 

Film Badge Exposure 

(R) 

Best Estimate of Deep-Dose 

Equivalent (rem) 

95% Confidence Limits fro DeepDose Equivalent (rem) 

0.04 (MDL) 0.03 (0.00, 0.07) 

0.05 0.03 (0.01, 0.08) 

0.06 0.04 (0.02, 0.09) 

0.07 0.05 (0.02, 0.10) 

0.08 0.05 (0.03, 0.11) 

0.09 0.06 (0.03, 0.12) 

0.10 0.07 (0.03, 0.13) 

0.12 0.08 (0.04, 0.15) 

0.14 0.09 (0.05, 0.17) 

0.16 0.11 (0.06, 0.20) 

0.18 0.12 (0.07, 0.22) 

0.20 0.13 (0.07, 0.24) 

>0.20 0.67 E (0.37 E, 1.20 E) 

 where E is the film badge exposure (R) 

Issue 7: Uncertainty Distributions 

Section 5.0 of OCAS-IG-001 describes the need to assess the uncertainty of the total organ dose, 

which may involve annual doses (and their uncertainties) from dosimeter readings, missed dose, 

medical dose, and environmental doses. 

The following guidance is provided in OCAS-IG-001, Section 5.2: 

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The compiled distribution is likely to be either normally or log normally 

distributed. The tendency will most likely be highly dependent on the ratio 

between the missed dose (log-normal distribution) and the dosimeter dose 

(normal distribution). Therefore some statistical test should be applied to 

determine which distribution is more appropriate. The statistical test can be 

conducted manually using any variety of methods or by using standard 

statistical software such as SAS®, StatGraphics® or SYSTAT®. Since the 

sampled dose distribution is likely not to fall strictly into one distribution or 

another, some professional judgment should be used to determine the best fit to 

the data. [Emphasis added.] 

First, the option to apply “some statistical test” raises the question of consistency, and it is 

questionable whether the average dose reconstructor is sufficiently knowledgeable and 

experienced to “. . . exercise some professional judgment.” 

More importantly, there is no need for the dose reconstructor to manually compile a composite 

dose distribution. The Interactive RadioEpidemiological Program (IREP) allows for independent 

distributions and point estimates to be entered for doses, including dosimeter dose, missed dose, 

occupational medical dose, and onsite ambient dose. 

Review Objective 7.0

There are numerous instances in which OCAS-IG-001 provides data and guidance that are of 

questionable value/significance, impractical, and excessively time-consuming, when viewed in 

the context of process efficiency. For illustration, the following two examples are provided. 

Example 1: Conversion of Monitored Dose to Organ Dose 

Section 4.0 of OCAS-IG-001 describes the basis and methods for converting monitored dose to 

the organ dose of interest. OCAS-IG-001 states that “. . . most early monitoring data was [sic] 

reported in the units of exposure and not a deep dose at 10 mm . . . .” Thus, at DOE facilities, 

the recorded dose was principally in the unit of R and in later years as a 10 mm deep dose 

in rem. Nevertheless, Section 4.1.1.2 describes the method from converting the deep dose

(HP(10)) and the ambient dose equivalent (H*(10)) to free-air kerma, a unit that is not normally 

used in personnel monitoring. 

Table 4.1 of OCAS-IG-001 also provides factors that allow converting exposure to the ambient 

deep dose equivalent (H*(10)) and the free-air kerma (Ka) to the ambient deep dose equivalent 

(H*(10)). The unit of ambient dose equivalent is also not a unit that the DOE used for personnel 

monitoring. 

Section 4.1.1.2 states that “Once the dose is converted to free-air kerma, the organ dose is a 

straight forward multiplication of the dose conversion (DT/Ka) listed in Table A.2-A.20 of ICRP 

74 (1996).” 

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Reviewer’s Comments 

If the OCAS-IG-001 requires the dose reconstructor to make use of ICRP 74 Tables A.2 through 

A.20 for converting the recorded dose (R or rem) to organ dose, the 19 tables contained in ICRP 

74 for organ-specific DCFs should have been provided in the document for timeliness and dose 

reconstruction efficiency. However, their use would require the dose reconstructor to know or 

assume the specific photon energy for the recorded exposure. 

This problem is recognized, and the use of ICRP 74 tables is subsequently discouraged in 

Section 4.1.3, which states that “Since ICRP 74 lists the dose conversion factor for multiple 

energies [for a total of 23 photon energies], some simplification is needed for dose reconstruction 

under EEOICPA. . . . Appendix B lists the simplified dose conversion factors by reporting unit 

(exposure, ambient dose (H*(10)), or deep dose equivalent (HP(10) for the three photon 

energy bands.” [Emphasis added.] 

This is one of many examples where data are presented that have little value to the dose 

reconstructor and at best may be regarded as window dressing that could more appropriately be 

introduced in an appendix, as discussed above under Review Objective 1.0. 

Example 2: DCF Simplification 

The simplification for deriving organ doses from recorded doses by means of DCFs found in 

Appendix B is also puzzling. As stated in the OCAS-IG-001, “. . . personnel dosimeters 

commonly recorded doses in either air exposure (R) or in deep dose equivalent at 10 mm

expressed in rem.” Yet, Appendix B defines organ-specific DCFs in behalf of two other units: 

air kerma and ambient dose equivalent (H*(10)). 

To the best of this reviewer’s knowledge, neither air kerma nor ambient dose equivalent is 

commonly used in operational settings for the calibration and measurement of personnel 

exposures and ambient dose rates. In fact, a search of standard operational health physics 

reference texts fails to even identify or define the unit of ambient dose equivalent. Its 

definition, as given in ICRU 39–1983, ICRU 43–1988, and ICRP 51–1988 and cited below, 

provides no meaningful insight regarding its use in operational health physics. 

The dose equivalent that would be produced by the corresponding aligned and 

expanded field, in the ICRU sphere at a depth, d, on the radius opposing the 

direction of the aligned field . . . . 

Thus, while the units of kerma free in air and ambient dose equivalent may have their value in 

select laboratory environments, their use in operational health physics and, therefore, dose 

reconstruction is questionable. Moreover, inspection of the four different DCFs cited in 

Appendix B for a given organ shows differences that range from less than 1% to a few percent, 

which in the overall scheme of dose uncertainty is insignificant. 

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It appears that the level of detail and scientific sophistication displayed in Section 4 and 

Appendix B are prime examples that demonstrate the failure of the procedures to (1) balance 

precision against efficiency, (2) limit dose reconstruction to reasonable estimates, and (3) support 

a timely resolution of claims. 

The limited need to provide DCFs for four different units of radiation measurement is further 

supported by the fact that even the units of R and rem have historically been used 

interchangeably and considered equivalent. For example, in reviewing historical radiological 

safety practices during the period of atmospheric tests of nuclear weapons, the Defense Nuclear 

Agency (DNA) in its 1982 report offered the following (pages 94 and 95): 

The radsafe criteria measuring units were the roentgen (R) and the rem. 

The roentgen, a measure of radiation in air, denotes an exposure intensity. The 

rem is a unit of radiation dose, i.e., a measure of radiation energy deposited 

within the body that takes into account its capability of causing an effect. . . . 

Another unit often used in discussing radiation doses is the rad. The rad is a 

measure of radiation energy deposited in any material; for biological tissue, a 

rad of low-quality radiation such as from gamma- or X-rays essentially equals a 

rem. 

At the time of the CASTLE series [1954] the distinction was usually not 

made between exposure (properly expressed in units of roentgens) and absorbed 

dose (properly expressed in units of rem, although at the time often expressed in 

roentgens); presumably external whole-body exposure and absorbed dose were 

assumed equivalent. This history expresses the measured data in exposure units 

(roentgens). Although the original references often referred to dose, there is no 

evidence that whole-body energy deposition was determined, nor that dose was 

indeed measured. [Emphasis added.] 

The practice of using R, rad, rem interchangeably was equally recognized (and accepted) by the 

Nuclear Regulatory Commission for decades. In 10 CFR Part 20 regulations that existed until 

the early 1990s (at which time select changes were made), the following regulatory standards 

were given under 10 CFR 20.4, Units of Radiation Dose, which discusses/defines the units R, 

rad, and rem: 

10 CFR 20.4(c): 

For the purpose of the regulations in this part, any of the following is considered 

to be equivalent to a dose of 1 rem: 

(1) A dose of 1 r due to X- or gamma radiation; 

(2) A dose of 1 rad due to X- or gamma radiation; 

(3) A dose of 0.2 rad due to neutrons or high energy protons; . . .

For neutrons, Appendix B of OCAS-IG-001 provides organ DCFs for neutron exposures 

measured in (1) ambient dose equivalent and (2) deep dose equivalent and for calculated neutron 

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exposure defined by neutron fluence (i.e., n/cm2). Here too, the value of providing neutron 

DCFs for ambient dose equivalent is questionable; even more questionable is the likely need for 

dose reconstructors to calculate neutron dose based on source term(s), shielding, distance, and 

time-in-area for routine exposure in workers who were either not monitored or whose dosimetry 

records are missing. It is highly unlikely that, for the thousands of claims that will be evaluated, 

there will be even a single instance where a neutron dose is reconstructed based on source term. 

2.2 OCAS-PR-003 — PERFORMING AND REPORTING DOSE 

RECONSTRUCTION 

The review of OCAS-PR-003, Performing and Reporting Dose Reconstruction, Rev. 0, dated 

September 24, 2002, was prepared by U. Hans Behling, PhD, MPH, and approved by John 

Mauro, PhD, CHP, on January 11, 2005. 

2.2.1 Purpose of Procedure 

The stated purpose of this procedure “is to provide guidance for OCAS staff and its technical 

support contractors in the performance, review, and documentation of dose reconstructions for 

covered employees with cancer per the requirements of 42 CFR Part 82, Methods for Radiation 

Dose Reconstruction Under the Energy Employees Occupational Illness Compensation Program 

Act of 2000.” 

2.2.2 Review Protocol 

SC&A’s evaluation of OCAS-PR-003 is summarized in Table 2.2-1 below. Table 2.2-1 is a 

checklist containing the objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

2.2.3 General Comments 

Section 5.0 of this procedure summarizes the stated policy, structure of the dose reconstruction 

process, and specific requirements that must be met for its completion, as defined in 42 CFR Part 

82, Subpart C, Dose Reconstruction Process, and Subpart D, Reporting and Review of Dose 

Reconstruction Results. 

Key elements cited in Section 5.0 of this procedure include (1) the need to be conservative such 

that uncertainties concerning data quality or dose are handled in a manner favorable to the 

claimant, (2) an iterative process that expedites the processing of claims in instances where an 

initial dose evaluation suggests a POC that is highly likely to be either well above or far below

the 50% value, and (3) the need for a detailed/comprehensive and technically defensible dose 

reconstruction in instances where the POC is not evidently clear. 

Attachment 1 of the procedure depicts the decision logic and algorithm that is to be employed in 

the conduct of dose reconstruction. 

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Section 6.0 represents the main body of this procedure and provides an itemized step-by-step 

outline of the dose reconstruction process that starts with the receipt of a claim (Section 6.1) and 

ends with the distribution of the final report (Section 6.18) and the closing of the claim 

(Section 6.19). 

Table 2.2-1. Procedure Review Outline/Checklist 

Document No.: OCAS-PR-003 Effective Date: 09/24/2004

Document Title: Performing and Reporting Dose Reconstruction

Reviewer: U. Hans Behling

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

3 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

3 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

3 See Review 

Comments 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 

3 See Review 

Comments 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) 3 See Review 

Comments 

3.2.2 In vivo/In vitro bioassays 3 See Review 

Comments 

3.2.3 Missing dosimetry data 2 See Review 

Comments 

3.2.4 Unmonitored periods of exposure 2 See Review 

Comments 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 3 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 4 See Review Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 4 See Review Comments 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 4 See Review Comments 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

1 See Review 

Comments 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 1 See Review Comments 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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2.2.4 Review Comments 

Review Objective 1.1

There is a significant amount of ambiguity regarding the individual(s) who is responsible for the 

various steps of the dose reconstruction process. Section 4.0 of OCAS-PR-003 identifies only 

(1) the records management team leader, (2) the health physicist(s), and (3) the OCAS Health 

Science Administrator. Clearly, other individuals/groups of individuals are involved in the 

process as outlined in the procedure. 

Additionally, it is unclear who is referenced as the “health physicist” in terms of affiliation (i.e., 

NIOSH/OCAS versus ORAU and its contractors). It would appear that the health physicists 

whose responsibilities are defined in Section 6.2, Evaluate Available Data/Information, are 

OCAS health physicists, while responsibilities defined in Sections 6.7, 6.8, 6.9, 6.10, 6.11, and 

6.12 belong to health physicists affiliated with ORAUT. 

Review Objective 1.2

Several subsections of Section 6 of OCAS-PR-003 appear out of order. For example, Section 

6.6.1 on page 11 identifies the step in which the OCAS Health Science Administrator “. . . 

assigns claim to Health Physicist for evaluation” who in turn “. . . ensures that . . . the claimant 

meets the definition of a covered employee . . . ” [Emphasis added.] 

For efficiency, this step should precede the extensive investment of effort and time required of 

the health physicist to evaluate available data/information as defined earlier in Section 6.2 

(pages 7-10). 

Review Objective 1.3

OCAS-PR-003, Section 3.0 (page 4), identifies only five references that assumedly apply to this 

procedure. A review of the listed references reveals that both OCAS and ORAU have prepared 

numerous procedures that have direct applicability to dose reconstruction, which should be cited 

in the list of references and acknowledged in the text of this procedure. 

Among the more important documents and procedures that should be acknowledged are the Site 

Profiles, procedures defining the interview process (ORAUT-PROC-004; ORAUT-PROC-005; 

and ORAUT-PROC-006), and ORAUT’s detailed procedures for performing internal and 

external dose reconstruction, as defined in ORAUT-PROC-0003 and ORAUT-PROC-0006, 

respectively. (It is the opinion of this reviewer that, on the basis of the improved guidance 

provided by ORAUT-PROC-0003 and ORAUT-PROC-0006, there is a questionable need for 

OCAS-PR-003.) 

Lastly, Reference 3.4 should be updated. It identifies 42 CFR Part 82 as the “Interim Final Rule 

with Request for Comments” [Emphasis added]. 

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Review Objectives 1.4 and 1.5

When compared to guidance provided by ORAUT-PROC-0003 and ORAUT-PROC-0006, 

OCAS-PR-003 suffers from a limited number of inconsistencies, but more importantly, it lacks 

the level of detail and structure related to dose reconstruction contained in these two procedures. 

Review Objective 2.0

OCAS-PR-003, Sections 6.9 and 6.10 (pages 12 and 13), provide only a limited verbal 

description as guidance for conducting dose assessments that potentially yield a low or high 

POC. Here too, when compared to guidance provided in Attachment D of ORAUT-PROC-0006, 

the procedural guidance provided in OCAS-PR-003 is sparse/insufficient. 

Review Objective 3.1

OCAS-PR-003, Section 6.3 (page 10), briefly identifies the interview with the claimant and its 

intended objectives but makes no references to the scope, method(s), and conduct of the claimant 

interview. The procedure’s deficiencies regarding the interview process are readily explained by 

the fact that the effective date for OCAS-PR-003 is given as September 24, 2002. This date 

precedes the issue dates for the interview procedures ORAUT-PROC-0004, -0005, and -0007. 

Review Objective 3.2

In instances where the POC is not evidently clear, the iterative process may require a highly 

detailed and exhaustive dose reconstruction process. This type of claim will maximally 

challenge the dose reconstruction and require the largest amount of time. This category of 

claims is only briefly mentioned in Section 6.11, Refining Dose Reconstruction. As such, less 

than one-half page is less than adequate. 

Many of the elements that are likely to be used in such an exhaustive dose reconstruction process 

are inappropriately identified in Subsections 6.2.8 through 6.2.15. These subsections, however, 

are part of Section 6.2, which deals with the initial evaluation of available data/information 

following the receipt of a claim. As examples, Subsections 6.2.8.3, 6.2.8.4, 6.2.8.5, and 6.2.8.6 

identify incident investigation reports, performance characteristics of dosimeters for different 

radiation types, dosimeter exchange frequencies, and area radiation survey measurements, etc., 

but provide limited guidance for employing such data in instances of (1) missing dosimetric data 

or (2) unmonitored periods of exposure. 

While it is recognized that in most instances such site-specific data may be available in the Site 

Profiles, there are exceptions. A review of the SRS Profile and discussions with the authors of 

the Site Profile revealed that many of these data are not provided in the SRS Site Profile. 

According to the authors, they excluded these data because the Site Profiles generally contain 

only that information needed to assist in the reconstruction of doses for select categories of 

workers, and because additional site data will be incorporated into the Site Profile as needed to 

support dose reconstruction. 

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Review Objective 4.0

OCAS-PR-003 makes reference to 42 CFR Part 82 and Implementation Guides 001 and 002. 

Although these documents clearly define the need to adhere to a prescriptive process and a 

hierarchical process for dose reconstruction, Section 6.2 of OCAS-PR-003 fails to prioritize 

dosimetric data in the dose reconstruction process. 

Review Objective 5.0

Sections 5.0 and 6.0 of OCAS-PR-003 make reference to the use of worst-case assumptions and 

claimant-favorable assumptions as if these two terms were interchangeable. A strong distinction 

should be made when worst-case values are selected solely for process efficiency in claims 

predetermined as noncompensable, as opposed to the unconditional use of worst-case 

assumptions in instances of unknowns. Only the latter case qualifies as claimant favorable. 

SC&A notes that other OCAS and ORAUT procedures equally misuse the term claimant 

favorable when used for process efficiency in noncompensable claims. 

In summary, it is this reviewer’s opinion that a distinction should be made when worst-case 

assumptions are employed for reasons of expediency, as opposed to their surrogate and truly 

claimant-favorable use in instances of unknowns. 

Review Objective 6.0

OCAS-PR-003 only mentions the need to address the uncertainty of dose estimates in the 

following statements, but provides no further guidance that is considered useful to the dose 

reconstructor. For example, Section 5.2 (page 5) states the following: 

Dose reconstructions will be performed in a conservative manner such that 

uncertainties concerning data quality or dose are handled in a manner favorable 

to the claimant. 

Section 6.12.2.8 (page 20) merely states: 

The estimate of annual dose will be characterized with a probability distribution 

that accounts for the uncertainty of the estimate. 

Review Objective 7.0

Subsections 6.2.8.1 through 6.2.8.15 identify an extensive list of potential sources of data that 

may be used for dose reconstruction. However, their conditional use, as stated in Section 6.2.8, 

minimizes the value of this document as a functional procedure in dose reconstruction: 

Obtain the type of information described in this section for dose reconstruction, 

as necessary and available. [Emphasis added.] 

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2.2.5 Conclusions 

This procedure is among the first issued by OCAS and, therefore, predates many subsequent 

procedures that provide more definitive guidance on dose reconstruction. On a relative scale, 

OCAS-PR-003 provides at best an overview of the reconstruction process without the necessary 

guidance provided by other/subsequent procedures. Its current value and use in dose 

reconstruction is, therefore, questionable. 

2.3 ORAUT-PROC-0006 — EXTERNAL DOSE RECONSTRUCTION 

The review of ORAUT-PROC-0006, External Dose Reconstruction, Rev. 00, dated June 28, 

2003, was prepared by U. Hans Behling, PhD, MPH, and approved by John Mauro, PhD, CHP, 

on January 11, 2005. 

2.3.1 Purpose of Procedure 

As stated in Section 1.0 of ORAUT-PROC-0006: 

The purpose of this procedure is to implement the requirements of 42 CFR 82 and 

provide guidance for technical support contractors of the Office of Compensation 

Analysis and Support (OCAS) in the performance of external dose reconstructions 

under the Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA). For each covered employee under this program, the dose 

reconstructions are performed using the data provided by the United States 

Department of Energy (DOE) and the Department of Labor (DOL) along with 

other supplementary records or information. This procedure provides specific 

steps and instructions for performing dose reconstructions based on the 

principles contained in OCAS-IG-001, External Dose Reconstruction 

Implementation Guideline (IG). [Emphasis added.] 

2.3.2 Review Protocol 

The evaluation of ORAUT-PROC-0006 is summarized in Table 2.3-1 below. Table 2.3-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

2.3.3 General Comments 

To a large extent, this procedure includes general/technical background information that is 

verbatim or closely parallels information presented in OCAS-IG-001. For this reason, some of 

SC&A’s technical concerns given in behalf of OCAS-IG-001 apply equally to ORAUT-PROC0006. For expediency, these comments are not repeated here but are merely noted in Table 1. 

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A major difference between OCAS-IG-001 and ORAUT-PROC-0006 is an improved format and 

the inclusion of Attachment D, Desk Instructions for External Dose Reconstruction. Attachment 

D provides specific, step-by-step instructions for performing dose reconstructions by providing 

seven separate sets of instructions that differ on the basis of (1) the claim’s potential for 

compensability, (2) the availability of monitoring data, and/or (3) the type of exposure. Step-bystep desk instructions are provided in Attachments D-1 through D-7 for the following categories 

of claims: 

 Attachment D-1: Likely >50% POC Cases

 Attachment D-2: Likely <50% POC Cases for Monitored Covered Employees

 Attachment D-3: Likely <50% POC Cases for Unmonitored Covered Employees

 Attachment D-4: Certain Skin Cancer Cases

 Attachment D-5: Cases Not Pre-Classified as Likely >50% POC or Likely <50% POC 

and for Which Monitoring Data Exist

 Attachment D-6: Cases for Which Monitoring Data Do Not Exist but Co-Worker Data 

Are Available

 Attachment D-7: Special Cases Requiring Unique Dose Reconstruction Approaches

Attachments D-1 through D-7 provide specific instructions that greatly enhance the efficiency

and timeliness in completing a dose reconstruction and satisfy several concerns raised under 

SC&A’s Review Objectives 1, 2, and 7. ORAUT-PROC-0006 further states that “. . . the list of 

individual desk instructions that have been developed for use by External Dose Reconstructors is 

likely to be modified as the project progresses and each desk instruction will be periodically 

revised as necessary.” 

User efficiency has also been improved by eliminating the fragmented format of OCAS-IG-001 

(as noted by SC&A). ORAUT-PROC-0006’s improved format has consolidated all relevant 

topics in a logical sequence and within a single section. Thus, essential topics for photon 

dosimetry are contained in Section 6.1, while those for neutrons and electrons are presented in 

Section 6.2 and Section 6.3, respectively. 

A side-by-side comparison between ORAUT-PROC-0006 and OCAS-IG-001 shows that several 

technical issues of concern that SC&A raised in behalf of the IG were also addressed in 

ORAUT-PROC-006. For example, Section 5.2 of this procedure conditionally includes the eye

as a target organ in instances of high-energy electron exposures; and Section C.2 of 

Attachment C acknowledges the potential difficulty and subjective nature for the assignment of a 

distribution (i.e., normal versus lognormal) to the final organ dose by informing the dose 

reconstructor that “. . . additional instructions will be provided in a separate procedure that 

describes the preparation of data for, and operation of, the IREP codes.” 

ORAUT-PROC-006 also stresses the role and importance of site-specific data and acknowledges 

that “. . . due to the complexity of dose reconstruction, the methods provided in site-specific 

Technical Basis Documents may supercede the methods provided in this procedure.” 

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Table 2.3-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0006, Rev. 00 Effective Date: 06/28/2003 

Document Title: External Dose Reconstruction 

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 

See Review Comment 

1.1 in behalf of 

OCAS-IG-001 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 

See Review Comment 

1.3 in behalf of 

OCAS-IG-001 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

3 

See Review Comment 

1.4 in behalf of 

OCAS-IG-001 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 

See Review Comment 

1.5 in behalf of 

OCAS-IG-001 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) 

3 

See Review Comment 

3.2.1 in behalf of 

OCAS-IG-001 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data 5 

3.2.4 Unmonitored periods of exposure 5 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 4 

See Review Comment 

4.0 in behalf of 

OCAS-IG-001 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 5 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

4 

See Review Comment 

6.0 in behalf of 

OCAS-IG-001 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 3 

See Review Comment 

6.0 in behalf of 

OCAS-IG-001 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 3 

See Review Comment 

7.0 in behalf of 

OCAS-IG-001 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 3 

See Review Comment 

7.0 in behalf of 

OCAS-IG-001 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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2.3.4 Review Comments 

Because of similarities between ORAUT-PROC-0006 and OCAS-IG-001, review comments 

considered relevant to ORAUT-PROC-0006 were stated in behalf of OCAS-IG-001, as noted 

above in Table 2.3-1. 

2.4 ORAUT-OTIB-0010 — A STANDARD COMPLEX-WIDE CORRECTION 

FACTOR FOR OVERESTIMATING EXTERNAL DOSES MEASURED WITH 

FILM BADGE DOSIMETERS 

The review of ORAUT-OTIB-0010, A Standard Complex-Wide Correction Factor for 

Overestimating External Doses Measured with Film Badge Dosimeters, Rev. 00, dated 

January 12, 2004, was prepared by U. Hans Behling, PhD, MPH, and approved by John Mauro, 

PhD, CHP, on January 11, 2005. 

2.4.1 Purpose of Procedure 

The following statements are in the procedure’s foreword and define its purpose: 

This technical information bulletin (TIB) presents external radiation dose 

assumptions that may be applied to dose reconstructions involving cases for 

which dose estimates may be prepared based on recorded deep and/or shallow 

dose that incorporate dose monitoring information during the later film badge 

era. Information in this TIB supports radiation dose estimates for complex-wide 

cases covering the time period of 1970 and after. 

 It is possible to apply reasonable, overestimating complex-wide assumptions for 

interpreting recorded photon dose for select cases. The methodology described 

below will generate a reasonable overestimate of external radiation dose for 

cases that are likely non-compensable. In accordance with the process of 

efficiencies discussed in 42 CFR 82, use of an overestimated dose allows the 

expeditious processing of likely non-compensable cases. [Emphasis added] 

2.4.2 Review Protocol 

The evaluation of ORAUT-OTIB-0010 is summarized in Table 2.4-2 below. Table 2.4-2 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

2.4.3 General Comments 

In brief, the expeditious dose reconstruction for noncompensable claims contains three 

elements for maximizing organ doses in behalf of claimants monitored after 1970 by means of a 

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four-element film badge and whose exposure reflect photon energies between 30-250 keV. 

These three elements are summarized below: 

(1) For missed dose (i.e., zero dose recordings), assume the LOD of 40 mrem and multiply 

the LOD times the assumed monthly exchange frequency. 

(2) Use a standard correction factor of 2 to “. . . compensate for uncertainty from potential 

variance in site-specific exposure conditions and calibration practices . . . [and] to convert 

the dose as measured from site to site to a standard value of Hp(10) . . . .” 

(3) Select an organ DCF from Appendix B of IG-001 that involves the exposure (R)-to-organ 

(HT) DCF unless that value is less than unity, in which case the DCF will be assumed to 

have a value of 1. 

Section 4.0 (page 9) of ORAUT-OTIB-0010 states the following: 

Standard values for energy distribution, missed dose, organ dose conversion 

factors and exchange frequencies are given in Table 4-1 below. These may be 

applied to recorded doses from the late film badge era.

Table 4-1, as it appears on page 9 of ORAUT-OTIB-0010, is reproduced below as Table 2.4-1 

and will be referenced in review comments that follow. 

Table 2.4-1. Standard Assumptions for Overestimating Dose Measured with Film Badges 

Period of 

applicability 

Photon energy 

range (keV) 

Missed 

dose per 

cycle 

Standard 

correction 

factor 

Exposure-toOrgan (Ht) 

DCF 

Assumed 

exchange 

frequency 

1970 onward 100% 30–250 0.040 2.0 ≥ 1a Monthly a

 From Appendix B of the OCAS-IG-001, External Dose Reconstruction Implementation Guideline: a value of 1.0 

 or the table value (typically assume 100% AP geometry), whichever is greater. 

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Table 2.4-2. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0010 Effective Date: 01/12/2004 

Document Title: A Standard Complex-Wide Correction Factor for Overestimating External 

Doses Measured with Film Badge Dosimeters

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

4 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? N/A 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 3 See Review Comments 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

3 See Review 

Comments 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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2.4.4 Review Comments 

Review Objective 1.1

In select areas, the information and guidance contained in this procedure are ambiguous, and 

even after several careful readings, several unanswered issues remain about its proper use, 

including those discussed below. 

Issue 1: Missed Dose 

It is assumed that for missed dose the LOD value of 40 mrem is used for each cycle. It is 

unclear, however, by how many cycles the 40 mrem/cycle should be multiplied. Table 4-1 

suggests that the dose reconstructor assumed a monthly exchange frequency, which for a full

year would result in a maximum missed photon dose of 480 mrem. Such an assumption would 

imply that there was no recorded dose for the year (i.e., 12 recorded monthly doses of zero). 

Thus, the procedure provides no guidance for treating dosimetry data in which the number of 

zero readings is fewer than 12 in any given year. Although it is further assumed that any missed 

dose based on LOD (as opposed to LOD/2) represents the 95th percentile value and, therefore, 

requires no uncertainty input value for IREP, this procedure fails to acknowledge this to the dose 

reconstructor. 

Issue 2: Evaluation of Shallow Dose 

The procedure contains the following statements that appear contradictory: 

 Page 7, Foreword of ORAUT-OTIB-0010: 

This technical information bulletin (TIB) presents external radiation dose 

assumptions that may be applied to dose reconstructions involving cases for 

which dose estimates may be prepared based on recorded deep and/or shallow 

dose . . . [Emphasis added] 

 Page 9, Section 5.0 of ORAUT-OTIB-0010: 

This TIB is not to be used for evaluation of shallow doses. (Note: for breast and 

testicular cancer cases, this TIB can be used for calculating the deep dose 

component only.) 

Review Objective 1.2

The TIB provides a substantial body of background information in Section 2.0 that gives 

technical support for the methodology used to maximize external dose data, as summarized in 

Table 2.4-1 above. The dose reconstructor, therefore, must read through page 8 of the procedure 

before encountering procedural guidance for maximizing doses, as defined by post-1970 fourelement film dosimeters. 

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Furthermore, a substantial part of these background data involves deficiencies and performance 

characteristics of the two-element film dosimeters, which are not relevant to the implementation 

of this procedure (i.e., the implementation of this procedure is limited to “later film badge era”) 

that is defined by the four-element film dosimeter. 

For improved efficiency in the routine use of this TIB by dose reconstructors, Section 4.0 and 

Table 4-1 should be relocated to the front of the procedure. 

Review Objectives 1.3 and 1.5

This reviewer interprets the “standard correction factor” identified in Table 2.4-1 above as a 

simple multiplier that is to be used only for any recorded photon dose. Thus, in behalf of this 

procedure, a monthly dosimeter reading of 50 mrem would be multiplied by 2 for an assigned

dose of 100 mrem. An unresolved question about the standard correction factor is its use when 

the recorded dosimeter dose is greater than zero but less that LOD (i.e., 40 mrem). A statement 

that the use of the standard correction factor eliminates the need for identifying the uncertainty 

as parameter #2 of the IREP input code is also missing. 

Review Objective 1.4

Multiple options exist in terms of procedures that a dose reconstructor may follow. For claims 

that are prejudged as noncompensable (i.e., likely < 50% POC), the dominant procedure is 

ORAUT-PROC-0006, Attachment D-2: External Dose Reconstruction Desk Instruction for 

Likely < 50% POC Cases for Monitored Covered Employees. This procedure states that: 

In general, this instruction applies to maximizing assumptions for both recorded 

and potentially unrecorded doses to ensure that the covered employee’s dose and 

probability of causation (POC) are not underestimated. 

And, 

This instruction applies to claims that were pre-classified “likely < 50% POC” 

and considers only those cases for which routine external dose monitoring data 

are available. [Emphasis added.] 

A comparison of ORAUT-PROC-0006 with ORAUT-OTIB-0010 shows the following 

differences: 

(1) For recorded film dosimeter photon doses, ORAUT-PROC-0006 provides the following 

guidance in Section 5.0: 

— Multiply dosimeter dose(s) with exposure (R) to organ dose values from 

Attachment B and assign a DCF of 1.0 if table value is < 1.0. 

— “Apply an appropriate uncertainty factor . . .” to the above derived organ dose. 

(Note: ORAUT-PROC-0006 does not employ a standard correction factor.) 

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(2) For post-1970 four-element film dosimeter data, ORAUT-OTIB-0010 uses the standard 

correction factor of 2 as a multiplier for recorded dosimeter readings, an organ DCF that 

is similar to that recommended by ORAUT-PROC-0006 but with no uncertainty. 

Review Objective 4.2

The TIB does not identify its hierarchical position among other competing procedures/ 

documents that could be used in its place or could require this TIB’s support. Questions 

regarding the use of this TIB for dose reconstruction include the following: 

(1) Does the use of ORAUT-OTIB-0010 for dose reconstruction require that the claim be 

preclassified as “likely <50% POC” (as is the case for ORAUT-PROC-0006)? 

(2) For claims with recorded exposures that meet the conditions specified in ORAUT-OTIB0010, does the dose reconstructor have the option to use either the desktop instructions 

provided in Attachment D-2 of ORAUT-PROC-0006 with site-specific data or use the 

generic default value provided in ORAUT-OTIB-0010? 

Review Objective 6.0

Issue 1: Uncertainty 

Although the TIB does not contain any explicit statement, SC&A has interpreted the use of the 

standardized correction factor of 2 as a “worst-case” assumption for which there is no further 

assignment of uncertainty. Given that NIOSH’s assessment of dosimeter uncertainty does not 

address the contribution of radiological and environmental uncertainty (see SC&A’s comments 

pertaining to Review Objective 6.0 in behalf of OCAS-IG-001), the standardized correction 

factor of 2 that the TIB describes as one “. . . that takes a large number of programs and features 

into account [and] must admit a great deal of error into any estimate it modifies” [emphasis 

added] does not appear excessively conservative (and claimant favorable) or result in an 

extreme/improbable value. A review of the 1989 NRC report, which assessed film badge 

uncertainty for all 19 atmospheric nuclear test operations, reveals that the 95th percentile deep 

dose equivalent value was routinely twice the best estimate of the deep dose equivalent. 

The TIB’s description of this standardized correction factor as claimant favorable is also highly 

conditional and, therefore, misleading. In Section 1.0, Introduction, the TIB initially states that 

the error of overestimating the dose “. . . is permissible under the claimant’s favor. Specifically, 

any error must overestimate rather than reduce the claimant’s probability of causation” 

[emphasis added], but concludes with the following statement, which reveals the true purpose, 

“. . . As the intent is to overestimate the dose to take advantage of an efficiency progress [sic], 

this methodology proposed here is useful only for likely noncompensable claims” [Emphasis 

added]. 

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The use of overestimated dose(s) to expedite a claim is fully endorsed by SC&A, but when 

restricted to claims that have been firmly established as noncompensable, a reference to being 

“claimant favorable” is misleading. 

Issue 2: Limits of Detection 

Section 3.2 of ORAUT-OTIB-0010 discusses the LOD of film dosimeters and references the 

1989 NRC with the following statements: 

A typical value of film sensitivity is 0.5 NOD units per 400 milliroentgens 

exposure CETS 1989. This translates to a lower limit of detection of between 10 

and 20 milliroentgens for films with this sensitivity, for photons above a few 

hundred keV . . . For the purpose of overestimating, the typical value of 40 

mrem as listed in the CETS 1989 reference will be assumed. [Emphasis added.] 

The extent to which the assumed film dosimeter LOD value of 40 mrem is highly conservative 

and represents an overestimation is questionable for the following reasons: 

(1) The above-cited quotation (regarding the 0.5 NOD as equivalent to a 40 mR value, which 

translates to a 10 to 20 mR LOD) does appear in the 1989 NRC report on page 17. 

However, this range of values corresponds to controlled laboratory conditions of film 

exposure, which avoids laboratory and environmental uncertainties discussed in 

Chapter 5 of the 1989 NRC report. More importantly, however, is that these low LODs 

are restricted to “. . . photon above a few hundred keV.” ORAUT-OTIB-0010, however, 

applies to photon energies between 30 and 250 keV. 

(2) The 1989 NRC report cites 40 mR as the standard MDL value for all 19 test operations 

that start with Project Trinity (1945) and end with Operation Dominic II (1962). 

In brief, a default LOD value of 40 mR is more likely a typical value than an overestimate, even 

after 1970. What remains conservative in overestimating the missed dose for the post-1970 filmbadge era is the TIB’s recommendation not to divide the LOD by a factor of 2. 

2.4.5 Conclusions 

Although the intent and general scientific basis for this procedure are endorsed by SC&A, this 

procedure lacks structure, clarity, and consistency. A good indication about the effectiveness of 

a procedure is its successful application. At the time of this review, SC&A (under Task 4) had 

the opportunity to review the first 20 dose reconstructions selected by the Advisory 

Board/NIOSH for audit, and 15 of the 20 claims involved non-Atomic Weapons Employer 

facilities for which procedures under SC&A’s review apply. For the dose reconstruction of 

Claim 006290, a key procedure was ORAUT-OTIB-0010. Errors and misinterpretation of 

ORAUT-OTIB-0010 by the dose reconstructor illustrate some of SC&A’s concerns raised in this 

review, as explained below. 

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For missed dose, the dose reconstructor provided the following explanation in the Dose 

Reconstruction Report: 

Based on information provided in Technical Information Bulletin: 

Overestimating External Doses Measured with Film Badge Dosimeters,8 the total 

number of dosimeter cycles assigned was 252 for photons. This number was 

based on a claimant-favorable assumption of 12 badge exchanges each full or 

partial year of employment and was maximized to ensure that all possible 

instances of a zero badge reading were accounted for in this dose reconstruction. 

Based on information provided in the Technical Information Bulletin: 

Overestimating External Doses Measured with Film Badge Dosimeters,8 this 

results in a maximum potential missed dose . . . [for claimant] of 21.363 rem from 

photons. For the purpose of calculating probability of causation, this value was 

divided by 2 in accordance with the External Dose Reconstruction 

Implementation Guideline. 

In behalf of uncertainty, the dose reconstructor provided the following: 

Uncertainty

Except for missed dose, point estimates (constant values) were used for organ 

dose input into the NIOSH-Interactive RadioEpidemiological Program (NIOSHIREP). Missed doses were divided by 2 and a lognormal distribution was applied 

in accordance with the NIOSH External Dose Reconstruction Implementation 

Guideline.3

SC&A’s audit of Claim 006290 identified four misinterpretations of ORAUT-OTIB-0010, as 

summarized below: 

(1) In addition to using the LOD of 40 mrem x 12 monthly cycles/year, the dose 

reconstructor erroneously also applied the standard correction factor of 2. 

(2) The dose reconstructor corrected the first error by subsequently dividing the abovederived value by 2 “. . . in accordance with the NIOSH External Dose Reconstruction 

Implementation Guideline.” 

(3) For the IREP input, the dose reconstructor erroneously defined values derived in step 2 as 

values defined by a lognormal distribution and assigned a geometric standard deviation 

(GSD) of 1.52 for parameter 2 in the IREP input code. (Note: Since LOD defined the 

95th percentile value of a missed dose, there is no need to include uncertainty.) 

(4) In behalf of Claim 006290, the dose reconstructor applied the ORAUT-OTIB-0010 

methodology for a period of 20 years starting in 1973 through 1993. ORAUT-OTIB0010, however, states that this procedure only applies to the “late film badge era” that is 

defined by the four-element film badge. For Claimant 006290, who was employed at 

ORNL, the four-element film badge was replaced by a site-specific TLD in 1976. Thus, 

the procedure ORAUT-OTIB-0010 can only be applied for 1973, 1974, and 1975; 

starting with 1976 through 1993, the dose reconstructor should have employed ORAUTNOTICE: This document has been reviewed for Privacy Act information, 

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OTIB-0008, Technical Information Bulletin for a Standard Complex-Wide 

Conversion/Correction Factor for Overestimating External Doses Measured with 

Thermoluminescent Dosimeters. 

The fact that these errors were consistently claimant favorable is fortunate but does not negate 

SC&A’s concern about the quality/user-friendliness of this (and other) procedures used in dose 

reconstruction. 

2.5 ORAUT-OTIB-0008 — TECHNICAL INFORMATION BULLETIN FOR A 

STANDARD COMPLEX-WIDE CONVERSION FACTOR FOR 

OVERESTIMATING EXTERNAL DOSES MEASURED WITH 

THERMOLUMINESCENT DOSIMETER 

The review of ORAUT-OTIB-0008, Technical Information Bulletin for a Standard ComplexWide Conversion Factor for Overestimating External Doses Measured with Thermoluminescent 

Dosimeter, Rev. 00, dated November 7, 2003, was prepared by U. Hans Behling, PhD, MPH, 

and approved by John Mauro, PhD, CHP, on January 11, 2005. 

2.5.1 Purpose of Procedure 

The purpose of this procedure is provided in the following statements contained in the foreword 

to the TIB: 

The present document is intended to provide assumptions to apply to a limited set 

of cases for specific sites only during delimited periods of applicability. 

Specifically, this technical information bulletin (TIB) presents external radiation 

dose assumptions that may be applied to dose reconstructions involving cases for 

which dose estimates may be prepared based solely on recorded deep and/or 

shallow dose that incorporate dose monitoring information only from years when 

monitoring was performed with TLDs. [Emphasis added.] 

In brief, the expeditious protocol for dose reconstruction of noncompensable claims contains the 

following elements for maximizing organ doses in behalf of claimants who were monitored for 

external exposure to photons by TLDs: 

 Missed Dose. For missed dose (i.e., zero-dose recordings), assume a LOD value for 

TLDs of 30 mrem/cycle. A monthly exchange frequency may be assumed, but the actual 

exchange frequency should be considered. The procedure further states, “Additional 

claimant-favorability may be applied at the discretion of the dose reconstructor by 

(1) applying the missed dose to all badge cycles in addition to the recorded value, and 

(2) not applying the ‘LOD/2’ approach to missed dose described in the OCAS-IG-001 

(NIOSH 2002).” [Emphasis added.] 

 Recorded TLD Dose. For a recorded deep dose(s) by a TLD, a standard 

overestimating conversion/correction factor of 2 should be used as a multiplier. 

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 HP(10)-to-organ Dose Conversion Factor (DCFMax). To maximize the photon organ 

dose, a single generic DCF of 1.100 should be assigned. 

Table 5-2, as it appears on page 13 of ORAUT-OTIB-0008, is reproduced below as Table 2.5-1 

and summarizes key elements for maximizing organ doses for noncompensable claims in behalf 

of TLD-monitored persons. 

Table 5-2. Standard Overestimating Correction/Conversion (C/C) Factor 

and Standard Missed Dose for TLDs 

Period of 

Applicability 

(by site) 

Missed Dose Per 

Cycle (rem) 

Assumed Exchange 

Frequency 

Standard 

Overestimating C/C 

Factor 

From Table 5-3 0.03 Monthly 2 

2.5.2 Review Protocol 

The evaluation of ORAUT-OTIB-0008 is summarized in Table 2.5-2 below. Table 2.5-2 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

2.5.3 General Comments 

This procedure applies to recorded exposures by means of TLDs and closely parallels the intent 

of ORAUT-OTIB-0010, A Standardized Complex-wide Correction Factor for Overestimating 

External Doses Measured with Film Badge Dosimeters. Therefore, several comments previously 

submitted in behalf of ORAUT-OTIB-0010 also apply to this procedure and will be reiterated 

only briefly as part of the Procedure Review Checklist and associated comments that follow. 

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Table 2.5-2. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0008 Effective Date: 11/07/2003 

Document Title: Technical Information Bulletin for a Standard Complex-Wide Conversion Factor for 

Overestimating External Doses Measured with Thermoluminescent Dosimeter 

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

3 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? N/A 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 

N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 5 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 4 See Review Comments 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

4 See Review 

Comments 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

2.5.4 Review Comments 

Review Objective 1.1

This procedure lacks clarity. A full understanding of the guidance presented in this procedure 

and its proper implementation required multiple readings by several SC&A reviewers. In 

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support of this contention, the conclusions of this review provide an example of how one NIOSH 

dose reconstructor misinterpreted/misapplied this procedure in behalf of a claimant. 

Review Objective 1.2

Sections 2.0, 3.0, and 4.0 of this procedure provide a substantial body of background information 

that provides technical support for the choice of parameters used to maximize the dose, as 

defined in the final Section 5.0. Thus, the dose reconstructor must read through page 11 of the 

procedure before encountering implementation guidance. 

While SC&A recognizes the value of relevant background information, for improved efficiency 

in the routine use of this procedure, Section 5.0 should be relocated near the front of this 

procedure. 

Review Objective 1.4

Multiple options exist in terms of procedures that a dose reconstructor may follow. For claims 

that are prejudged as noncompensable (i.e., likely < 50% POC), the dominant procedure is 

ORAUT-PROC-0006, Attachment D-2, External Dose Reconstruction Desk Instruction for 

Likely < 50% POC Cases for Monitored Covered Employees. 

Key differences between ORAUT-PROC-0006 and ORAUT-OTIB-0008 involve (1) the use of a 

standard overestimating correction/conversion factor, (2) selection and value of the dosimeter-toorgan DCF, (3) selection/value of the TLD LOD, and (4) options for selecting dosimeter 

exchange frequency. 

Because the TIB does not identify its hierarchical position among other competing 

procedures/documents that could be used in its place or require this TIB’s support, questions 

regarding the use of the TIB for dose reconstruction include the following: 

(1) Does the use of ORAUT-OTIB-0010 for dose reconstruction require that the claim be 

preclassified as “likely <50% POC” (as is the case for ORAUT-PROC-0006)? 

(2) For claims with recorded exposures that meet the conditions specified in ORAUT-OTIB0010, does the dose reconstructor have the option to use either the desktop instructions 

provided in Attachment D-2 of ORAUT-PROC-0006 with site-specific data or use the 

generic default value provided in ORAUT-OTIB-0010? 

Review Objective 6.1

Although the dose reconstructor should conclude that the use of the standard overestimating 

correction/conversion factor for recorded TLD dose (i.e., the use of nLOD for missed dose) 

obviates the need for uncertainty, the procedure should nevertheless provide a statement to this 

effect as a reminder. This is particularly true since the procedure also permits missed dose to be 

derived by means of nLOD/2, in which case uncertainty must be defined for IREP. 

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2.5.5 Conclusions 

Although the intent and general scientific basis for this procedure are endorsed by SC&A, there 

is a need to improve the procedure’s structure, clarity, and consistency with other procedures. 

Under Task 4, SC&A had the opportunity to review the first 20 dose reconstructions selected by 

the Advisory Board/NIOSH for audit, and 15 among the 20 claims involved non-Atomic 

Weapons Employer facilities for which procedures under SC&A’s review apply. For the dose 

reconstruction of Claim 008121, a key procedure was ORAUT-OTIB-0008. Errors and 

misinterpretations of ORAUT-OTIB-0008 by the dose reconstructor illustrate some of SC&A’s 

concerns raised in this review. 

For TLD recorded dosimeter and missed dosimeter dose, the dose reconstructor provided the 

following explanation on page 5 of the dose reconstruction report: 

To ensure that the estimated dose has been maximized, a multiplication factor of 2 

has been applied to the reported and missed annual doses. Application of this 

multiplication factor overestimates dose to account for uncertainty in dosimeter 

response and in variability for the dose conversion factor across all organs. . . . 

 Missed dose was assigned to each actual or potential dosimeter cycle to 

maximize the external dose estimate. Missed dose represents the dose that may 

have been received but not recorded because of dosimeter detection limits or site 

reporting practices. Based on the Technical Information Bulletin: 

Overestimating External Doses Measured with Thermoluminescent Dosimeter,8

the total number of dosimeter cycles assigned was 60 for photons. This number 

was based on a claimant-favorable assumption of 12 badge exchanges each full 

or partial year of employment to ensure that all possible instances of a zero badge 

reading were accounted for in this dose reconstruction. Based on information 

provided in the Technical Information Bulletin: Overestimating External Doses 

Measured with Thermoluminescent Dosimeter,8

 this results in a maximum missed 

dose of 3.600 rem from photons. For the purpose of calculating probability of 

causation, this value was divided by 2 in accordance with the External Dose 

Reconstruction Implementation Guideline.

3

 [Emphasis added.]

Misinterpretation of ORAUT-OTIB-0008

Recorded Dose. SC&A reviewed the TLD records for Claim 008121 and verified the total 

recorded deep dose of 240 mrem. In compliance with guidance contained in ORAUT-OTIB0008, the dose reconstructor applied the standard overestimating correction/conversion factor of 

2 and thus doubled the recorded dose of 240 mrem to 480 mrem. Doubling the dose eliminates 

the need to include an estimate of uncertainty. For input to IREP, ORAUT-OTIB-0008 also 

identifies a single generic HP(10)-to-organ dose conversion factor (DCFMax) of 1.1, which the 

dose reconstructor did not apply. However, the substitution of 1.0 for 1.1 as the DCF represents 

a minor error. 

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Missed Dose. According to Table 5-2 of ORAUT-OTIB-0008, missed dose may be calculated 

by multiplying the LODTLD value (assumed at 30 mrem) for each cycle in which the dose is 

recorded as zero. In the absence of site-specific data, a monthly exchange frequency may be 

assumed. Accordingly, an annual missed photon dose of nLOD corresponds to 12 cycles x 30 

mrem/cycle or 360 mrem/yr. In the absence of site-specific data, the claimant’s 5-year 

employment corresponds to a missed photon dose of 1800 mrem. 

In applying ORAUT-OTIB-0008, the dose reconstructor misinterpreted/misapplied the 

following: 

 The dose reconstructor erroneously applied the standard overestimating C/C factor of 2 

and derived the above-cited total of 3.600 rem: 

Total Missed Dose = (30 mrem/cycle)(12 cycles)(5 years)(2) 

 = 3.600 rem 

 Next the dose reconstructor cancels the first error (i.e., the misuse of the standard 

overestimating factor of 2) by dividing the dose estimate by 2 and explains this by the 

following statement, “. . . for the purpose of calculating probability of causation, this 

value was divided by 2 in accordance with the External Dose Reconstruction 

Implementation Guideline.3” (Note: OCAS-IG-001 provides standard guidance for 

missed dose expressed as nLOD/2 and a GSD of 1.52 for uncertainty; OCAS-IG-001 is 

not intended to be combined with ORAUT-OTIB-0008.) 

 The use of LOD (as opposed to LOD/2) for estimating missed dose per cycle represents 

the 95th percentile value and, therefore, precludes the need to incorporate uncertainty in 

the dose estimate. The dose reconstructor erroneously applied the GSD of 1.52 for 

uncertainty to a dose derived by LOD. 

 The assumption of 12 cycles per year applies to situations in which data are lacking. 

Dosimetry records provided by DOE in behalf of Claim 008121 clearly indicate that the 

individual was monitored on a quarterly (not monthly) basis. 

While the combination of procedural misinterpretations had only marginal impacts on assigned 

dose and clearly did not significantly affect the POC (and the compensability of the claim), it 

does demonstrate various difficulties associated with the implementation of this procedure. 

2.6 ORAUT-OTIB-0007 — TECHNICAL INFORMATION BULLETIN: 

OCCUPATIONAL DOSE FROM ELEVATED AMBIENT LEVELS OF 

EXTERNAL RADIATION 

The review of ORAUT-OTIB-0007, Technical Information Bulletin: Occupational Dose from 

Elevated Ambient Levels of External Radiation, Rev. 00, dated November 12, 2003, was 

prepared by U. Hans Behling, PhD, MPH, and approved by John Mauro, PhD, CHP, on 

January 11, 2005. 

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2.6.1 Purpose of Procedure 

The purpose of this procedure is to acknowledge that in select instances the dose of record 

associated with personnel film dosimeters and TLDs represents a net dosimeter readout that may 

have resulted in underestimating the true occupational exposure of the monitored person. This 

underestimation occurs because a standard practice for recording individual doses associated 

with film dosimeters and TLDs involves subtraction of “background radiation recorded on 

control dosimeters.” While natural background radiation is justifiably not considered 

occupational exposure, background radiation that may have resulted from elevated ambient 

levels of external radiation (i.e., EALER) due to site operations would, in fact, be considered 

occupational exposure. 

The need to account for EALER as occupational exposure is largely based on the relative 

location of the control dosimeter(s) (i.e., where was it stored?) and the assigned personnel 

dosimeter (i.e., where was the individual monitored?) relative to any EALER. Thus, if the 

control badges were stored at a location unaffected by EALER, there is no need to adjust the 

individual’s dose; but when control badges were subjected to EALER and such exposures were 

wrongly subtracted from personnel dosimeters, such exposures must be viewed as missing 

exposure and accounted for as occupational exposure. 

2.6.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0007 is summarized in Table 2.6-1 below. Table 2.6-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

2.6.3 General Comments 

The need to account for EALER-associated occupational doses that were wrongly subtracted by 

means of EALER-exposed control dosimeters is based on (1) the regulatory requirement to 

account for all occupational exposures that may have been received by a claimant, and (2) their 

potential for significant contribution to total occupational exposure. 

As pointed out in Section 2.0 of ORAUT-OTIB-0007, EALER exposures “. . . could have been 

as high as a few millirem per day in some cases . . . [and] at Hanford as high as 36 mrad/day, 

averaging 8.5 mrad/day between April 1952 and November 1954.” 

However, the functional value and use of this procedure to the dose reconstructor is limited as 

indicated in Table 2.6-1 and explained in comments to specific review objectives that follow. 

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Table 2.6-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0007 Effective Date: 11/12/2003 

Document Title: Technical Information Bulletin: Occupational Dose from Elevated Ambient Levels of 

External Radiation 

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

1 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

N/A 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 

N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 4 See Review Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 4 See Review Comments 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 4 See Review Comments 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 2 See Review 

Comments 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 2 See Review Comments 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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2.6.4 Review Comments 

Review Objective 1.0

Unaccounted doses to EALER are likely to have involved exposures to ground contamination, 

transient plume immersion, and/or cloudshine that reflect site-specific activities/events. In turn, 

resultant exposures may have been chronic, episodic, and highly variable by location. 

From the foregoing, it is clear that extensive site-specific data are required to account for missed 

EALER doses. Such data are currently not provided in this procedure and may only partially be 

available in Site Profiles. (At this time, SC&A did not review Site Profiles to ensure their 

adequacy for this use.) Section 4 of this TIB concludes only that “. . . subsequent revision to this 

document will provide specific dates for each site establishing when it is known that control 

badges were stored in appropriate locations, which will allow for environmental doses to not be 

evaluated for certain sites prior to 1980.” [Emphasis added.] 

In summary, the procedure in its current form is incomplete and does not provide sufficient data 

to account for EALER missed doses. 

Review Objective 4.1

Beyond identifying EALER as a potential area of missed occupational dose, ORAUT-OTIB0007 provides no specific instructions on processing such data for amending a claimant’s 

occupational exposure record. For example, given that a monthly control badge subjected to 

EALER would record a time-integrated dose representing about 720 hours, what fraction of the 

control badge dose should be added to the claimant’s monthly dose of record? On the 

assumption of a chronic EALER exposure, a realistic approach would assume that the worker 

maymight have been exposed for about 170 hours/month, which corresponds to about 24% of the 

dose recorded by the control badge. In contrast, a more conservative, but not improbable 

scenario, would assume that the EALER dose represented a brief episodic exposure and mandate 

that 100% of the control dosimeter dose be added to the claimant’s monthly dose of record. 

A second issue that requires clarification concerns the issue of skin dose (i.e., shallow dose or 7 

mg/cm2

 dose). EALER involving plume immersion and/or exposure to ambient ground 

contamination involving beta and low energy photon emitters are unlikely to have been recorded 

by control badges, because ambient dosimeters typically recorded only the dose from penetrating 

radiation and not the shallow dose. Hence, since the shallow dose is generally significantly 

larger than the deep dose, adding in the dose from ambient dosimeters to account for EALER 

could result in a significant underestimate of the shallow dose. This potential deficiency may 

affect claims involving skin cancers and to a lesser extent select surficial tissues such as the eye, 

testes, etc. 

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Review Objective 7.0

A procedural approach to amend occupational exposure from EALER as suggested by the 

currently incomplete ORAUT-OTIB-0007 could require extensive site-specific data over several 

decades pertaining to (1) site operations, (2) environmental releases/incidents, (3) environmental 

monitoring data and practices, and (4) health physics practices pertaining to control badge 

storage practices. 

Assuming that such data are even available, monthly dose corrections for EALER would be 

time-consuming and require a substantial effort by the dose reconstructor. This reviewer 

believes that such an effort would significantly undermine the efficiency of the dose 

reconstruction process while contributing a questionable improvement for technical precision. 

An efficient and claimant-favorable approach might involve the use of claimant-favorable 

default values or the addition of a fixed monthly EALER dose to all film dosimeters and TLDs 

processed prior to 1970 (or 1980) that is site specific and reflects onsite environmental 

monitoring data, as described in Section 5.1.4 of ORAUT-PROC-0006. 

2.7 ORAUT-OTIB-0006 — DOSE RECONSTRUCTION FROM OCCUPATIONALLY 

RELATED DIAGNOSTIC X-RAY PROCEDURES 

The review of ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related 

Diagnostic X-Ray Procedures, Rev. 2, dated December 29, 2003, was prepared by U. Hans 

Behling, PhD, MPH, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

2.7.1 Purpose of Procedure 

Under EEOICPA, diagnostic x-rays, specifically chest x-rays, were required as a condition of 

employment and are included as part of the total occupational radiation exposure to the atomic 

worker. This document was published by ORAUT as a TIB to be used for DOE and Atomic 

Weapons Employer sites relating to “...detailed methodology for dose reconstruction from 

diagnostic medical x-rays that were sustained by workers as a condition of employment, and 

provides the technical basis for dose reconstruction in the absence of specific dose measurements 

or records of technique factors.” This TIB further states that “this report supplements and 

expands upon the guidance provided in . . . OCAS-IG-001.” 

2.7.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0006 is summarized in Table 2.7-1 below. Table 2.7-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

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Table 2.7-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0006 Effective Date: 12/29/2003 

Document Title: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures 

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

3 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review 

Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2= Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). NA indicates not applicable.

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

5 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 3 See Review 

Comments 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 3 See Review Comments 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

2.7.3 Review Comments 

Review Objectives 1.0 and 7.0

For a procedure to support a dose reconstruction process that is expeditious and timely, the 

procedures should prioritize its content with the most important/relevant information presented 

first, followed by technical support data and data that are interesting but not essential. 

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Section 2.0 of this TIB provides a lengthy and detailed technical explanation regarding various 

parameters (i.e., beam kilovoltage, current, filtration, collimation, exposure time, distance, and 

waveform) that affect the beam output and, if known, can be used to estimate the potential air 

dose to a patient for a given diagnostic x-ray. 

However (and not surprisingly), the TIB acknowledges the unlikely availability of such data 

(i.e., kVp, mA, filtration, distance, and exposure time), but not until Section 3.0, page 12, of the 

TIB, which states the following: 

X-ray output measurements are likely to be unavailable, particularly prior to 

about 1980 [when occupational x-rays probably ceased to be required for 

employment]. In the absence of suitable measurement data, medical diagnostic 

x-ray dose reconstruction can be accomplished using technique factors along 

with published output data that provide beam intensity per mAs as a function of 

kVp, filtration, and distance. [Emphasis added.] 

The unlikely availability of beam measurement data is restated several more times: 

 Section 3.1, page 12: 

Although beam output measurements may typically be unavailable, diagnostic 

medical x-ray dose reconstruction using actual measurement data is the preferred

method for determining the dose to the worker from this source, so much so that 

special effort to determine if such measurements have been made is justifiable. 

[Emphasis added.] 

 Section 3.1, page 13: 

If the actual beam quality is unknown, as is likely the case, to ensure claimant 

favorability, a higher rather than lower HVL should be assumed. [Emphasis 

added.] 

 Section 3.2, page 17: 

When beam measurement data are unavailable, as is likely to be the case, 

technique factors can be used to obtain reasonable estimates of exposure. The 

basic data required are kVp, filtration, exposure in mAs, and distance. Beam 

output data are available from a number of publications, including NCRP Report 

No. 102 (NCRP, 1989). Table B.3 in this report (p. 99) provides average air 

kerma rates for medical diagnostic x-ray equipment operating at various kVps 

with 2.5 mm Al filtration at distances from 30 to 182 cm from the source. 

Correction for different thickness of Al filtration can be made by reference to 

Table 2.6-1. Alternatively, Figure B.1 (p. 109) in NCRP Report No. 102 provides 

a graphical representation of air kerma at 100 cm for various values of kVp and 

filter thickness > 2.5 mm Al. Using theses tables, a reasonable estimate of beam 

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output and hence entrance kerma can be obtained. Once the entrance kerma has 

been determined, organ doses are determined in the manner described above for 

reconstruction using measurement data. [Emphasis added.] 

The difference between measurement data and technique factors for deriving dose estimates is 

trivial, since both techniques require knowledge about kVp, mA, filtration, distance, and 

exposure time that the procedure warns “are unlikely to be available.” By far, the most probable 

method for estimating medical occupational exposures will involve the use of default values, 

which the procedure does not address until the very end. 

In summary, this document is poorly structured and reads more like an introductory reference 

text on medical x-rays than a procedure. It not only presents an excess of background 

information that is well understood by a dose reconstructor, but is also of limited use since the 

required data are “unlikely to be available.” In spite of the unlikely availability of data, the 

procedure, nevertheless, justifies the need for the dose reconstructor to make “. . . that special 

effort to determine if such measurements have been made. . . .” 

The large investment of time and effort required to pursue the unlikely existence of such data is 

difficult to justify in context with a dose reconstruction process that is expected to strike a 

balance between the need for technical precision and process efficiency. 

Reconstruction by means of default values as given in Section 3.3 of this procedure appears 

adequate and claimant favorable. As such, Section 3.3 should have been the principal 

component of this procedure. 

Review Objectives 4.0

There is some ambiguity regarding the use of default values. Table 3.3-1 identifies a default 

value of 3.0 cGy entrance kerma for photofluorographic chest examination, and proceeds to 

apply this value to default organ dose values given in Table 4.0-1 of Section 4.0. Section 5.0 of 

the TIB provides some historical dose data in behalf of photofluorography that include a 1959 

study of Hanford by Rising and Soldat. Here, air upper-bound entrance skin exposure (ESE) 

for photofluoroscopic chest examination of 1.53 R is identified with the following 

recommendation: 

Thus, although the Hanford measured value is likely an upper limit and hence an 

overstatement of the actual exposure from photofluorography to the average 

patient, this 1.53 R ESE value should be used in the absence of data to ensure 

claimant favorability.

Thus, the TIB provides two default values for photofluorography, which differ by a factor of 2 

(i.e., 3.0 cGy entrance kerma versus 1.53 R (ESE)). This raises two questions: (1) is the 1.53 R 

default value uniquely applicable to Hanford and (2) if so, is there a defensible explanation for a 

two-fold higher value for all other DOE/AWE sites? The absence of a defensible explanation 

clearly raises the question regarding consistency of the dose reconstruction process. 

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2.8 OCAS-TIB-006 — INTERPRETATION OF EXTERNAL DOSIMETRY 

RECORDS AT THE SAVANNAH RIVER SITE (SRS) 

The review of OCAS-TIB-006, Interpretation of External Dosimetry Records at the Savannah 

River Site (SRS), Rev. 1, dated February 20, 2004, was prepared by U. Hans Behling, PhD, 

MPH, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

2.8.1 Purpose of Procedure 

As stated in Section 1.0, Purpose, of this TIB, 

The purpose of this Technical Information Bulletin (TIB) is to provide guidance 

on the interpretation of Savannah River Site, dosimetry from 1973 through 1988. 

In addition, guidance on how the shallow dose should be reconstructed is also 

included. 

2.8.2 Review Protocol 

SC&A’s evaluation of OCAS-TIB-006 is summarized in Table 2.8-1 below. Table 2.8-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

2.8.3 General Comments 

This brief procedure addresses two issues: 

(1) It alerts the dose reconstructor that the SLHP3 form contains dosimetry data from 

archived records, which in turn only provide dosimetry data for monitoring cycles for 

which the dosimeter yielded a positive reading (i.e., > LOD). In the absence of a positive 

dosimeter reading between 1973 and 1988, it should not therefore automatically be 

assumed that a given individual was not monitored. 

(2) It identifies a potential underresponse of SRS dosimeters (used between 1954-1980) to 

low-energy photons due to the presence of aluminum filtration on the SRS dosimeter, 

and provides “guidance on how the Low Energy photon dose should be determined for 

workers primarily exposed to plutonium.” 

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Table 2.8-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-006 Effective Date: 02/20/2004 

Document Title: Interpretation of External Dosimetry Records at the Savannah River Site (SRS) 

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

N/A 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

3 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review 

Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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2.8.4 Review Comments 

Review Objectives 1.1, 1.4, and 1.5

Regarding the need to correct the response of SRS dosimeters with aluminum filtration for the 

period 1954-1981, the TIB provides the following guidance: 

 Shallow Dose Interpretation

 During the period 1954-1981, aluminum filtration on the SRS dosimeter may have 

diminished the deep dose response to low energy (< 30 keV) photons. This could 

have affected dose for plutonium workers at 321-M, 221-HP, 221-FB, Plutonium 

Storage, 772-F, 235-F, 773-A and 736-A. For this period, low energy (< 30 keV) 

photon dose should be determined by subtracting the reported deep dose from the 

shallow dose. In order to maintain consistency, the shallow dose quantity should 

be corrected using the HP (1)) correction factor (1.119). The deep dose quantity 

during this period should be classified as intermediate energy photons (30 – 250 

keV). For the period 1982 – present, the guidance provided in Savannah River 

Site Technical Basis Document should be used to determine the photon energy 

distribution of the deep dose (i.e., 25% < 30 keV and 75% 30-250 keV). 

Inclusion of the shallow dose quantity for this time period would not be needed 

unless the energy employee had testicular, breast, or skin cancer. In these cases 

the shallow dose (without deep dose subtracted would by [sic] categorized as < 

30 keV photons.)

The above-cited procedural guidance is confusing in terms of its instructional content. It is also 

uncertain as to which dosimetry data require this refinement (i.e., is it limited to the above-cited 

work locations where exposure is known/suspected to be dominated by Pu, or does it apply to 

any dosimeter data in which the ratio of the open-window (or 7 mg/cm2

) shallow dose to the 

1000 mg/cm2

 deep dose suggests a large contribution of low-energy photons?). 

It is also uncertain whether the above-cited guidance replaces guidance provided in Section 

5.4.3.1 of the SRS Site Profile/Technical Basis Document, ORAUT-TKBS-003. Guidance 

provided in TBD ORAUT-TKBS-003, Section 5.4.3.1, only identifies the “two-element film 

dosimeter” and includes the following statements: 

Based on the collective information, SRS dosimeters are expected to reasonably 

measure the Hp(10) under all SRS workplace radiation fields. The SRS historical 

practice, for the two-element film dosimeter in plutonium facilities characterized 

by predominant photon energies < 100 keV, to calculate the total whole-body 

deep dose by summing the shallow dose from the open window film response 

based on a 16 keV fluorescent x-ray calibration and the deep dose from the 1 mm 

silver filtered film response based on a Ra-226 calibration, will result in a overestimate of the actual HP(10) dose. . . . The respective SRS dosimeters have 

filtration of approximately 1000 mg/cm2

 (i.e., nearly equivalent to 1 cm depth in 

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tissue) for those regions of the dosimeter used to measure the whole body dose. . . 

As such, a reasonable estimate of deep dose, compared to HP(10) is expected for 

SRS beta/photon workplace radiation. [Emphasis added.] 

Additionally, Section 5.3.3.1 (as well as Section 5.4.1) of ORAUT-TKBS-0003 identifies the 

need for additional HP(10) correction factors as given in the following statements: 

. . . Taylor et al. (1995) describes adjustments to SRS recorded dose estimate 

HP(10) based on SRS preparations for DOELAP performance testing in the mid1980s. At that time, it was concluded that: 

 Prior to January 1986 the recorded dose of record (i.e., photon) dose 

should be multiplied by a factor of 1.119 (11.9%). 

 Prior to January 1987 recorded dose of record (i.e., photon) should be 

multiplied by a factor of 1.039 (3.9%). 

Lastly, there is a question regarding the specified timeframe during which the shallow dose 

requires interpretation. As stated in the above quotation, the need to interpret shallow dose 

covers the period 1954-1981 and is the result of “aluminum filtration on the SRS dosimeter 

[that] may have diminished the deep dose response to low energy (< 30 keV) photons.” 

[Emphasis added.] A review of dosimeters employed at SRS between 1954-1981 (as given in 

Attachment A of ORAUT-OTIB-008) identifies four different dosimeters with the following 

filters: 

Years Dosimeter Filter

’51-‘58 ORNL Two Element Film Badge OW, Cd 1 mm 

’59 SRS Two Element Film Badge OW, Cd 1 mm 

’59-‘70 Multi-Element Film Badge OW Al Ag 

’70-‘81 SRS TLD multiple filters 

Only the multi-element film badge used between 1959-1970 specifies aluminum filtration. 

In summary, the implementation of this procedure is complex, confusing, and provides 

insufficient guidance for amending SRS dosimeter data in select instances of surficial target 

tissues in which the shallow dose component from low-energy photons is a significant 

component of the HP(10) deep dose. 

Since the purpose of this procedure is limited to amending dosimetry data that are specific for 

SRS, perhaps a more efficient and appropriate approach would simplify the guidance provided 

and incorporate this TIB into Section 5.0, Occupational External Dosimetry, of the Technical 

Basis Document for the Savannah River Site, ORAUT-TKBS-0003. 

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2.9 OCAS-PER-001 — MISINTERPRETED DOSIMETRY RECORDS RESULTING 

IN AN UNDERESTIMATE OF MISSED DOSE IN SRS DOSE 

RECONSTRUCTION 

The review of OCAS-PER-001, Misinterpreted Dosimetry Records Resulting in an 

Underestimate of Missed Dose in SRS Dose Reconstruction, Rev. 0, dated September 8, 2003, 

was prepared by U. Hans Behling, PhD, MPH, and approved by John Mauro, PhD, CHP, on 

January 11, 2005. 

2.9.1 Purpose of Procedure 

This document evaluates the programmatic effect of the misinterpreted dosimetry records that 

resulted in an underestimate of the missed dose for workers at the SRS. This error pertains to 

SRS dosimetry records between 1973 and 1988 on Form SLHP3 only containing positive 

dosimeter readings (either shallow or deep) for a given dosimeter wear cycle. Since only 

positive dosimeter readings are cited on the SLPH3 form, there is a risk that the absence of cycle 

dosimeter data may be falsely interpreted to mean that the individual was not monitored when, in 

fact, he/she was monitored, but had a net dosimeter reading below LOD. The result of this 

misinterpretation would result in missed dose for the years 1973-1988. 

During the time period of 1973-1988, personnel monitoring involved (1) the SRS TLD dosimeter 

(with the laboratory minimum detection level (MDL) of 15 mrem) for the period 1970-1983, and 

(2) the Panasonic TLD (with the laboratory MDL of 5 mrem) for the period 1984-1988. Based 

on the LOD/2 accounting method for missed dose, the annual missed doses for the two time 

periods involved 90 mrem and 30 mrem, respectively. 

Section 2.0 of this document, OCAS-PER-001, identifies a second error, as given in the 

following statements: 

During August 2003, the ORAU team recognized that the SRS Technical Basis 

Document (ORAUT-TKBS-0003, Rev. 0) contained a significant overestimate of 

the onsite ambient dose between 1974 and 1998. Since this error resulted in an 

overestimate of the energy’s employee’s onsite ambient dose (claimant friendly), 

no formal Program Evaluation Report (PER) was written. These values were 

corrected and noted in the revision of ORAUT-TKBS-0003, Rev. 01, approved on 

August 21, 2003. [Emphasis added.] 

These two opposing errors were evaluated by ORAU with regard to their magnitude and to their 

net impacts on the POC for the top 10 cancer claims for SRS. The procedures concluded that, in 

combination, the two errors have the net effect of nearly canceling each other, with a slight bias 

in a claimant-favorable direction (i.e., higher POC value), and no further evaluation was 

necessary. 

The approach to resolution/corrective action for this combination of errors was twofold: 

(1) revise the SRS TBD, and (2) provide additional guidance as set forth in OCAS-TIB-0006, 

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issued September 8, 2003. This TIB provides guidance on the interpretation of the SRS 

dosimetry Form SLHP3. SC&A’s review of guidance contained in OCAS-TIB-0006 is 

presented next. 

2.9.2 General Comments 

OCAS-PER-001 is a program evaluation report (PER) and, therefore, does not serve the purpose 

of a procedure. A PER formally acknowledges potential deficiencies that may have affected the 

dose reconstruction process and evaluates the potential impact(s) on previously assessed claims. 

SC&A critically evaluated the approach taken in OCAS-PER-001 for quantifying the magnitude 

of these errors and their impacts and concludes that the analysis is technically correct and fair to 

the claimant. 

SC&A does not consider it appropriate to further evaluate OCAS-PER-001 by means of its 

Procedure Review Outline/Checklist. 

2.10 OCAS-TIB-007 — NEUTRON EXPOSURES AT THE SAVANNAH RIVER SITE 

The review of OCAS-TIB-007, Neutron Exposures at the Savannah River Site, Rev. 0, dated 

September 17, 2003, was prepared by U. Hans Behling, PhD, MPH, and approved by John 

Mauro, PhD, CHP, on January 11, 2005. 

2.10.1 Purpose of Procedure 

This procedure provides supplemental guidance pertaining to potential neutron exposure at SRS 

for workers under the following conditions: 

(1) The energy employee worked at SRS prior to the implementation of the 

thermoluminescent neutron dosimeter (TLND) in 1971; 

(2) The energy employee (prior to 1971) was monitored with Type A (NTA) film, which 

underresponded to neutrons below 500 keV; 

(3) The energy employee may have been “intermittently” exposed to neutrons post-1971 and 

after the implementation of TLND, but not monitored because the “general criteria” 

between 1970 and 1980 was to only monitor personnel exposed to neutron fields in 

excess of 1 mrem/hr. As a result “. . . non routine workers might or might not have been 

adequately monitored.” 

2.10.2 Review Protocol 

SC&A’s evaluation of OCAS-TIB-007 is summarized in Table 2.10-1 below. Table 2.10-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

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2.10.3 General Comments 

This procedure attempts to satisfy the regulatory requirement under 42 CFR 82.15, 42 CFR 

82.16, and 42 CFR 82.17 for a complete accounting of neutron exposure that a claimant may 

have experienced as a result of deficiencies/limitations of personnel dosimeters and monitoring 

practices. 

The guidance provided in this TIB is far too complex, excessively detailed, and time-consuming 

to be of efficient use to those dose reconstructors who are not thoroughly familiar with SRS 

facility operations that span several decades; secondly, the guidance places an undue burden on 

the dose reconstructor to make subjective decisions; thirdly, select guidance presented in this 

TIB is incomplete and in some cases contradictory; lastly, and perhaps most relevant, dose 

reconstructors are not currently making use of NTA neutron data prior to 1971. Due to the 

unreliability of NTA dosimeters, neutron doses prior to 1971 are currently estimated based on 

neutron to photon ratios and contradict Section 4.0 of this TIB. Specific examples of these 

deficiencies are provided in the checklist comments that follow Table 2.10-1. 

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Table 2.10-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-007 Effective Date: 09/17/2003 

Document Title: Neutron Exposures at the Savannah River Site 

Reviewer: U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 3 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

3 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

3 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review 

Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for identifying 

a potentially high probability of causation as part of an initial 

dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic as 

well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 4 See Review Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can reasonably 

be accounted for by the dose reconstructor? 3 See Review Comments 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 3 See Review Comments 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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2.10.4 Review Comments 

Review Objectives 1.0 and 7.0

Section 2.1 of the TIB identifies numerous locations within the 100, 200, 300, and 700 Areas as 

work locations where neutron dose should be included for the conditions cited above. For 

example, in behalf of the five reactors (i.e., Reactors C, K, L, P, and R) in the 100 Area, the TIB 

cautions that “Only certain occupations [are] involved in neutron exposure, see section 2.2 for 

further guidance.” These “certain occupations” for the 100 Area are assumedly identified in 

Section 2.2.2 and include the occupation defined as “etc. . .,” as given in the following statement: 

Neutron exposures should only be considered for energy employees who might 

have been involved in maintenance activities in the crane wash areas of the 

reactors. These occupations would include mechanics, pipefitters, electricians, 

carpenters, sheetmetal workers, etc... There is also a potential for neutron 

exposures for radiological control technicians, health physicist and possibly 

reactor operators, since these individuals were generally responsible for 

workplace safety. [Emphasis added.] 

Section 2.2 addresses the condition in which the work area is unknown or not clear and 

provides the following subjective guidance that in some cases is contradictory: 

When the work area is not known or is not clear, a Health Physicist should use 

professional judgment to determine whether neutron exposures should be 

included. Thrse is no single definitive source document that can be used to 

determine whether an energy employee was exposed to neutron, however, from 

the weight of evidence investigation, a Health Physicist should be able to 

determine the neutron exposure potential. The Health Physicist should keep in 

mind the claimant favorable approach to dose reconstruction under EEOICPA 

and when there is equal evidence of potential exposure, the approach should be to 

include the neutron exposure. Listed below is some general guidance that can be 

used to assist in determining whether an individual was potentially exposed to 

neutrons. [Emphasis added] 

The “general guidance” to be followed by the dose reconstructor includes three conditions given 

in Section 2.2.1, General Indications of Potential Neutron Exposure. Condition 2 states the 

following: 

External dosimetry records indicate the 17 keV calibration curve was used for 

interpretation of the shallow dose. This is an indication of exposure to plutonium 

and therefore neutrons. This indicator could be for work in the 100, 200, or 300 

areas.

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In Section 2.2.2, the dose reconstructor is cautioned about the limited value/use of the high 

shallow to deep dose ratio when applied to the 200 and 300 Areas, as given in the following two 

statements: 

The high shallow to deep dose ratio is not always a clear indicator of neutron 

exposure in the 200 area. For example, if there is numerous enriched uranium 

bioassay measurements in the 200 area, the energy employee most likely worked 

on the A lines and would have received little to no neutron exposure. The high 

shallow dose is the result of beta exposure from uranium daughter products.

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And, 

Generally this area was a uranium fuel fabrication area. There were certain 

campaigns (time periods), however, in which plutonium-aluminum (Pu-Al) targets 

were manufactured in the 321-M facility. These Pu-Al targets emitted neutrons. 

Generally, there will also be indications that the 17 keV calibration curve was 

used to interpret the shallow dose. The use of this calibration curve is an 

indicator of potential neutron exposure. Currently research is being conducted to 

better determine the time periods in which the 300 area manufactured Pu-Al 

targets. Research to date has indicated this work was conducted in late 1964 

through at least 1967. This work was most likely conducted in later time periods 

as well, however this information has not been located. 

The TIB concludes with the following guidance, as contained in Section 5.0, Summary: 

For further information on whether neutron dose should or should not be 

included in the Savannah River Dose reconstructions, documents listed in the 

reference section of this bulletin provide additional details of SRS operations and 

associated neutron exposures. [Emphasis added.] 

2.10.5 Conclusions 

The principal objective of this procedure is to account for unmonitored/unrecorded neutron doses 

during specific time periods in behalf of select workers who may have been intermittently

exposed to neutrons at dose rates of less than 1 mrem/hr. On the basis of this objective, it is 

reasonable to conclude that such doses are likely to have been small relative to recorded

external whole-body photon doses and neutron doses, and internal exposures. 

To achieve this objective, the successful implementation of this procedure requires either (1) a 

high degree of personal familiarity with historic SRS facility operations that predate 1971, or 

(2) an extensive and time-consuming research effort on the part of the individual dose 

reconstructor. Even when all potential data are available, this procedure still requires the dose 

reconstructor to make numerous subject decisions and data interpretation in behalf of doses that 

are likely to have limited relevance to a claim. Additionally, the subjective treatment of data by 

different dose reconstructors is also likely to raise questions about the consistency of the dose 

reconstruction process and fairness to the claimant. 

It is, therefore, SC&A’s opinion that a detailed accounting of neutron exposure as suggested by 

the guidance contained in this procedure is excessive and inconsistent with regulatory directives 

for NIOSH to apply methods that yield “reasonable estimates” that are “consistent, fair and as 

timely as possible” and “which may differ substantially from those that would be produced 

under a scientific research protocol when the principal objective is to produce maximally 

complete and precision estimates.” 

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For consistency, fairness, and timeliness, a simplified process that provides a surrogate approach 

would assign a neutron dose to any intermittently exposed worker who, on the basis of job 

description, work location, and employment period, had the potential for a neutron exposure at 1 

mrem/hr level. Additional model assumption might include the use of a triangular distribution 

that defines a range and mode (e.g., 0 to 1000 mrem/yr with a mode of 200 mrem/yr). 

Lastly, this site-specific procedure should be integrated into Section 5 of the SRS Site Profile, 

ORAUT-TKBS-0003. 

2.11 OCAS-PER-002 — ERROR IN SURROGATE ORGAN ASSIGNMENT 

RESULTING IN AN UNDERESTIMATE OF X-RAY DOSE IN SRS DOSE 

RECONSTRUCTION 

The review of OCAS-PER-002, Error in Surrogate Organ Assignment Resulting in an 

Underestimate of X-ray Dose in SRS Dose Reconstruction, Rev. 1, dated December 15, 2003, 

was prepared by U. Hans Behling, PhD, MPH, and approved by John Mauro, PhD, CHP, on 

January 11, 2005. 

2.11.1 Purpose of Procedure 

This document is a PER, which alerts dose reconstructors of an error contained in various 

approved and draft Technical Basis Documents specific for various DOE sites. For OCAS-PER002, the error involves the assignment of the ovary dose as a surrogate organ for the liver, gall 

bladder, and spleen for exposures involving collimated medical chest x-ray examination. 

Based on anatomical proximity, the more appropriate choice for a surrogate organ dose is the 

lung. The revised surrogate use of the lung dose corresponds to the following additional doses to 

the liver, gall bladder, and spleen per x-ray exam: 

 Pre-1971 — 43 mrem 

 1972-1985 — 27 mrem 

 1986-present — 20 mrem 

2.11.2 General Comments 

The revised use of lung dose as a surrogate for the liver, gall bladder, and spleen in instances of 

medical occupation exposures from chest x-ray exams is technically correct and claimant 

favorable. 

An assessment of potential adverse impacts on past claims that were evaluated prior to this 

procedure revealed three claims involving one liver and two gall bladder cancers. In all three 

cases, the additional assignment of organ doses resulted in a net average increase of 0.5% in the 

POC without affecting the decision for compensation. 

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However, as part of the resolution/corrective action, this PER instructs ORAUT to revise all 

Technical Basis Documents and ensure that the lung is assigned as the surrogate organ for the 

liver, gall bladder, and spleen. 

SC&A initially reviewed this PER regarding the magnitude of the error, its associated impacts, 

and OCAS’ proposed resolution/corrective action. SC&A has concluded that this PER properly 

evaluated past claims that may have been adversely affected by this error and has taken 

corrective actions that are biased in favor of the claimant. 

Because a PER is not intended to provide procedural guidance for dose reconstruction, it is not 

subjected to SC&A’s procedure review process that includes the Procedure Review 

Outline/Checklist. 

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Fix, J. J, E. S. Gilbert, and W. V. Baumgartner, 1994, An Assessment of Bias and Uncertainty in 

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Spiers, F.W., 1946, British Journal of Radiology 9: 52. 

Spiers, F.W., 1949, British Journal of Radiology 22: 521. 

Watson, E. C., 1959, A Review of the NTA (Fast Neutron) Film Program, HW-61008, General 

Electric, Richland, WA. 
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 3.0 INTERNAL DOSIMETRY PROCEDURES/DOCUMENTS 

3.1 OCAS-IG-002 — INTERNAL DOSE RECONSTRUCTION IMPLEMENTATION 

GUIDELINE 

The review of OCAS-IG-002, Internal Dose Reconstruction Implementation Guideline, Rev. 0, 

dated August 2002, was prepared by Joyce Lipsztein, PhD, and approved by John Mauro, PhD, 

CHP, on January 11, 2005. 

3.1.1 Purpose of Procedure 

According to the preface, the stated purpose of this guide is: 

. . . to provide basic information on the methods employed in reconstructing doses 

under the Energy Employees Occupational Illness Compensation Program Act of 

2000. The intent of this guide is to assist a qualified health physicist in 

determining annual organ dose from exposure to various sources of internal 

radiation. Because not all possible exposure scenarios can be foreseen, this 

guide does not provide step by step instructions for how the dose reconstruction 

should be performed. It is recognized there will be situations for which the 

methods outlined in this guide result in underestimates or overestimates of a 

claimants actual dose. In these cases, care must be exercised that the doses are 

conservative (claimant friendly) but reasonable for the claimant’s exposure 

scenario. [Emphasis added.]

The introduction states: 

 The purpose of this document is to provide guidance on the methods and 

approaches that can be used to reconstruct occupational radiation dose from 

internally deposited radionuclides in support of the Energy Employees 

Occupational Illness Compensation Program Act (EEOICPA, 2000). . . . The end 

result of the internal dose reconstruction will be the dose, expressed in cSv (rem), 

received in individual calendar years to the organ of interest along with the 

uncertainty associated with the dose. 42 CFR part 82 (2002) governs the process 

of reconstructing doses to individuals.

3.1.2 Review Protocol 

S. Cohen & Associates’ (SC&A’s) evaluation of OCAS-IG-002 is summarized in Table 3.1-1 

below. Table 3.1-1 is a checklist containing objectives that SC&A developed under the first 

phase of Task 3 to evaluate whether the procedure adequately supports the dose reconstruction 

process, as described in the introduction to this report. 

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Table 3.1-1. Procedure Review Outline/Checklist 

Document No.: OCAS-IG-002 Effective Date: August 2004 

Document Title: Internal Dose Reconstruction Guideline 

Reviewer: Joyce Lipsztein 

No. Description of Objective Rating 

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review 

Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

5 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 5 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating 

1-5*

Comments

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) NA 

3.2.2 In vivo/In vitro bioassays 5 

3.2.3 Missing dosimetry data 5 

3.2.4 Unmonitored periods of exposure 5 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 3 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 5 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

3 See Review 

Comments 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 3 See Review 

Comments 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

3=Sometimes, 4=Frequently, 5=Yes (Always). NA indicates not applicable. 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.1.3 Review Comments 

Review Objectives 1.1 and 1.5

Objectives 1.1 and 1.5 were designed to assess whether a procedure is unambiguous and 

sufficiently prescriptive to minimize subjective decisions. SC&A fully understands that, due to 

the complexity of internal dosimetry and the limitations and uncertainties surrounding bioassay 

measurements, subjective decisions are an inherent part of the interpretation of results for 

internal dose calculations. They are also inherent to the process of determining whether the 

exposure to radiation is at least as likely as not to have caused a particular cancer. Therefore, it 

is important that OCAS-IG-002 clearly identifies those circumstances that may require 

professional judgment. SC&A’s review of the implementation guide has identified some 

sections in which the writing style is not clear and ambiguous. Section 6.0, Preliminary Dose 

Estimates, and Section 7.0, Detailed Dose Estimates, of OCAS-IG-002 do not provide clear, 

straightforward instructions on how to conduct an internal dose reconstruction. The example 

given in Section 8.0, Example Dose Estimates, of OCAS-IG-002 shows how difficult it is to 

follow the guidance in Sections 6.0 and 7.0 without making subjective decisions. For example, 

the following paragraphs are cited under OCAS-IG-002, Section 8.3, High Dose Potential 

Preliminary Estimate, pages 35 and 36: 

An underestimate can be accomplished by estimating the dose received from the 

large intake during the 1/20/73 incident alone. In determining the amount of the 

acute intake on 1/20/73, it is indicated that the concentration in the urine should 

drop off much faster than the data show. While the cause of this is unclear, all 

that matters is that there are credible reasons for the observations, such as the 

incident contaminated the work area enough to deliver a chronic intake each day 

for some time. With that assumption stated, the underestimate was performed 

by modeling the intake as two back-to-back chronic exposures. The first of 

2000 pCi per day from 2/7/73 to 4/17/73 and the second of 1000 pCi per day 

from 4/18/73 to 8/7/73. . . . [Emphasis added.] 

. . . Had the probability been below the compensation level, the estimate could be 

refined easily by adding another chronic exposure to account for the time frame 

when he received several detectable intakes. [Emphasis added.] 

It is not clear how the two values of 2,000 and 1,000 pCi per day were calculated and when 

chronic intake should be assumed. There is also no clear indication of methods for refining the 

estimate and which doses to add. The dose reconstructor is left to make subjective decisions 

without clear, straightforward instructions on conducting the dose reconstruction. 

As a further example, the following paragraphs are cited under OCAS-IG-002, Section 8.5, High 

Dose Potential Preliminary Estimate, pages 39 to 41: 

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Intake #1: . . . Subsequently, the two samples were averaged and assigned a date 

of 2/6/70 . . . the intake date and amount was adjusted to achieve a good fit with 

the two points (12/6/69 & 2/6/70). [Emphasis added.] 

Intake #2: . . . The two that were nearly zero could not be reconciled with any 

possible scenario associated with intake #1. This led to the decision to disregard 

these near zero samples and concentrate on the remaining samples. [Emphasis 

added.] 

Intake #3: . . . Due to the fast clearance, intake #3 was assumed to be acute and 

to have occurred near the sample date of 8/21/70. The intake amount and date 

could not be adjusted to align the two points (8/81 & 9/11) but it was adjusted so 

that the second point was less than the detection limit. [Emphasis added.] 

Intake #5 through Intake #13: . . . With no second point to help determine the 

timing of the intakes, the midpoint between samples was assumed as a starting 

point. With this date the amount of the intake could not be adjusted to keep 

samples on 8/15/71 & 11/26/71 below the detection limit. The date and amount 

were then adjusted to achieve this goal. [Emphasis added.] 

Page 39 of 48: 

Intake #15: . . . At this point it was noted that the predicted value of the sample 

on 5/26/72 & 12/1/72 were considerably higher than the actual result. The date 

and quantity of intake #14 and #15 were adjusted to minimize these points but no 

acceptable combination could be found. These intakes were then modeled as 

chronic exposures using various intake dates and quantities. Eventually a 

suitable combination was found that allowed the predicted result for 12/1/72 to 

drop below the detection limit, however, the sample on 5/26/72 was still above. 

Since the results of the sample on 5/26/72 was 0.0 pCi, it was believed that the 

sample could be flawed and the results were rejected The results of intake #14 

and #15 were again changed as a result of evaluating the next intake. The details 

are discussed under intake #16 . . . . [Emphasis added.] 

Intake #16, #17, and #18: Intake #16 and #17 were then modeled using various 

combinations of acute and chronic exposures but all failed to reconcile with the 

sample on 12/1/72. An additional exposure was then added but it too failed to 

reconcile the difference. At that point the sample on 12/1/72 was rejected. Since 

this sample led to several decisions pertaining to intake #14 and #15, the analysis 

was redone starting with intake #14 but without the sample results for 12/1/72. 

This led to intakes #14 and #15 being reevaluated as acute exposures with the 

final values listed above. [Emphasis added.] 

Intakes #16 and #17 were then evaluated simultaneously. Since the 12/1/72 

sample was rejected, an attempt was made to model these intakes so that the 

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predicted value matched the actual value on 11/25/72. The final results indicated 

an acute exposure of 43000 pCi and 23000 pCi on 5/11/72 and 8/26/72 for 

intakes #16 and #17 respectively. This then required an additional intake (#18) 

to match the data on 1/12/73 and 1/22/73. This was modeled as an acute intake 

on 12/30/72 in order for the predicted line to match both samples. The intake 

quantity was 17000 pCi. [Emphasis added.] 

Since the samples on 1/12/73 & 1/22/73 were only slightly higher than the sample 

on 11/25/72, it was realized that these three samples could actually represent 

statistical uncertainty of one predicted line. This scenario was explored by 

eliminating intake #18 and adjusting the date and quantity of intakes #16 and 

#17 in order to minimize the residuals of these three samples. This scenario 

resulted in no change to intake #16 while intake #17 was 40000 pCi on 8/24/72. 

Notice that this exactly matches the total of the original intake #17 and #18 

(23000 + 17000). [Emphasis added.] 

In an attempt to further reduce the residuals by “flattening out” the predicted line 

through the three samples (11/25/72, 1/12/73, & 1/22/73), intake #16 was moved 

back as far as possible to the day of the previous sample (3/31/72 since 5/26/72 

was rejected). This resulted in intake #16 being a 53000 pCi intake. When only 

intake #17 was added the residuals were minimized when intake #17 occurred on 

8/24/72 with 35000 pCi. The last scenario to explore was to reconsider the two 

intakes (#17 & #18) with intake #16 consisting of 53000 pCi on 3/31/72. This 

resulted in intake #17 being 23000 pCi on 8/26/72 with intake #18 being 13000 

pCi on 12/30/72. . . . The dose reconstructor is left with subjective decisions to 

make and no clear, straightforward instructions on how to conduct the dose 

reconstruction. [Emphasis added.] 

In the sentences cited above, SC&A has emphasized those circumstances that may require 

subjective judgment and decisions. Subjective decisions are an inherent part of the interpretation 

of results for internal dose calculations. The dose reconstructor must not be mislead and should 

be informed clearly that professional judgment is necessary in many instances and that 

conclusions pertinent to one case may not be applicable to other cases. 

The conclusion of this particular example (total intake is not sensitive to the actual intake date) is 

misleading, since it does not explicitly show that it is only pertinent to this special case and 

cannot be generalized. The following paragraphs were taken from Section 8.5, page 41 of 48, of 

OCAS-IG-002: 

. . . This yielded a total of 36000 pCi (23000 + 13000) compared to 35000 pCi for 

the one intake scenario. This indicated that while it was not clear which scenario 

was correct, the final outcome was comparable. Also note that the total intake 

from all four scenarios yielded results of intakes of 89000, 88000, 83000, and 

83000 pCi. Even moving intake #16 back 41 days changed the total intake by 

<10%. [Emphasis added.] 

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This information implies that the total intake is not very sensitive to the actual 

intake date. The primary objective is to match data as closely as possible by 

some non-subjective means (such as residuals) regardless of the chosen 

scenario. [Emphasis in document.]

This conclusion contradicts Section 7.1, Estimate of Intake Date, page 26 of 48, of OCAS-IG002: 

The time of intake is an important parameter in assessing bioassay data. Based 

on one positive sample, the intake could have occurred anytime since the last nondetectable sample. The difference in a calculated intake, based on assuming the 

intake occurred at either the beginning or the end of this period, can vary by 

orders of magnitude. [Emphasis added.] 

As stated in International Atomic Energy Agency (IAEA) Safety Report Series 37, Methods for 

Assessing Occupational Radiation Doses due to Intakes of Radionuclides (2004), a principal 

source of uncertainty in the interpretation of bioassay data is the determination of the time of 

intake. A reasonable estimate of the time of intake is vital for the proper interpretation of 

bioassay data. 

 

This particular case relates to intakes of Pu, in a mixture of type M and type S solubility 

compounds. If the dose reconstructor were evaluating a uranium exposure case, for example, the 

conclusions would have been completely different: 

 For a 30-day monitoring interval in the collection of urine samples from workers,

assuming that a single intake of type M compounds occurred in the middle of the 

monitoring interval (day 15 of this monitoring period), a positive result will lead to a 

calculated intake 54 times higher than if it was assumed that exposure occurred 1 day 

before the date the sample was taken (day 29). 

 For type F uranium compounds, the assumption that the intake occurred in the middle of 

the monitoring interval (day 15) will lead to a calculated intake 100 times higher than if it 

was assumed to have occurred 1 day before the date the sample was collected (day 29). 

For type F uranium compounds, the assumption that the exposure occurred in the middle 

of the monitoring interval (day 15) leads to a calculated intake that is 40% of the intake 

calculated, assuming that exposure occurred in the beginning of the monitoring interval 

(30 days before sampling). 

 For chronic intakes, 5 days a week, 8 hours per day, the difference between collecting a 

urine sample before or after the weekend is very important. 

 For type M uranium compounds, the daily intake calculated based on a result from a 

urine sample assumed to have been submitted on the last day of the weekend will be 75% 

higher than if it was assumed that the same activity concentration in urine was a result 

from a sample collected on the last day of the work week. 

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 For type F uranium compounds, the intake calculated assuming that the sample was taken 

after the weekend is approximately 4 times higher than when assuming that it was taken 

before the weekend for the same activity concentration in urine. 

In addition, the instructions provided in Section 7.2, Uncertainty, provide no clear indication of 

the methodology for calculating internal dose estimate uncertainties. For example, the following 

two paragraphs are cited under OCAS-IG-002, Section 7.2, page 29: 

It is important to note that, while the uncertainty of an internal dose estimate can 

be dominated by the uncertainty in determining the intake, this is not always the 

case. The intakes for individuals that submit many detectable bioassay samples 

may have their total intake calculated fairly accurately. However, this intake is 

based on a particular biokinetic model. Any inaccuracies or biases produced by 

this model must be considered. 

Uncertainties associated with the biokinetic models are difficult to assess. While 

some attempts have been made to evaluate the uncertainty of the overall models, 

(NCRP, 1998; Till et al., 2000), it is important to tailor the uncertainty 

assessment to the specific situation at hand.

The International Commission on Radiological Protection (ICRP) does not recommend 

determining uncertainties based on its biokinetic models, which were developed for a reference 

individual. Independent of this ICRP recommendation, uncertainties in biokinetic models are 

very difficult to consider, and no straightforward instructions are given on this subject. 

The example given in Section 8.7, Uncertainty, of OCAS-IG-002, demonstrates the lack of 

precise instructions in Section 7.2. The following paragraphs are cited from Section 8.7, page 

45: 

The error is relatively small as can be expected when a large number of 

detectable samples are submitted. This relative error is applicable to the intake 

amount only; it assumes the biokinetic model is accurate. With an intake error 

this low, it is necessary to assess the uncertainty of the biokinetic model in order 

to develop a realistic uncertainty for this individual’s dose. . . . 

. . . In the case of probability of causation values less than 50%, a more detailed 

analysis will be required. It may be necessary to reproduce the biokinetic model 

in a Monte Carlo calculation with known values given as constants. The results 

of this calculation can then be used to describe a detailed probability 

distribution of the organ dose. [Emphasis added.]

There are no clear instructions on how to assess the uncertainty. How should the dose 

reconstructor reproduce the biokinetic model? Which values should be used as constants? In the 

biokinetic models, more than 100 parameters may be modified. Which parameters are 

important? How do they relate to each specific case? 

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Review Objective 1.3

OCAS-IG-002 identifies the applicable ICRP publications that are needed to perform dose 

reconstruction involving internal exposure. However, the implementation guide is incomplete in 

the following areas: 

(1) There is no specification on the treatment of daughter radionuclides. (A more detailed 

discussion is provided in Section 3.1.4 of this report.) 

(2) The model to be used for Ca and Cm should be the updated to ICRP 71 (1995). 

(3) The treatment of gases and vapors is not mentioned. 

Review Objective 4.1

OCAS-IG-002 does not provide clear and unambiguous instructions for performing a 

preliminary internal dose estimate and the calculation of associated uncertainties, as described in 

Sections 6.0 and 7.0. 

Review Objectives 6.1 and 6.2

Section 7.2 of OCAS-IG-002 discusses uncertainty associated with detailed (as opposed to 

preliminary) internal dose estimates. This section, however, only briefly addresses the issues 

surrounding uncertainty and does not provide adequate guidance for selecting probability 

distributions, random sampling, and other tasks. 

3.1.4 Technical Issues 

OCAS-IG-002 provides basic information on the methods to be employed in reconstructing 

internal dose. The end result of this internal dose reconstruction should be a claimant-favorable, 

reasonable estimate of the dose equivalent received by the worker, in individual calendar years, 

to the organ of interest, as well as the uncertainty associated with the dose. In order to comply 

with these directives, OCAS-IG-002 should provide more clarity in the following areas: 

(1) Section 2.1, Figure 2, page 7: Figure 12 in Section 2.1, General Models, of this 

implementation guide depicts the ICRP 66 lung model with a description of the various 

lung regions. Within the extra thoracic region, ET2 is described as consisting of the 

posterior nasal passages, pharynx, and larynx. The ET2 portion of the extra thoracic 

region should also include the mouth. This is important in terms of the assignment of an 

ICRP organ to the primary cancer site. 

(2) Section 2.2, page 9: Section 2.2, Specific Models, discusses biokinetic models of selected 

radionuclides that have been updated since the publication of ICRP 30. Table 1 in 

Section 2.2 specifies the ICRP model that is to be used for reconstructing energy 

employee dose. This section, however, does not specifically address the treatment of 

daughter radionuclides (independent kinetics from decay products formed within the 

body following the intake of radioisotopes of tellurium, radium, thorium, and uranium (as 

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specified in ICRP 71), and shared kinetics (same as parent) for decay products of other 

nuclides). This is important in terms of organ doses, especially in the treatment of the 

unspecified tissues (other tissues) for different chain members. 

 

Table 1 of Section 2.2 should also include the models for Ca and Cm, which were 

updated in ICRP 71 (1995). 

(3) Section 4.1.2, page 13: 

Comment 1: Section 4.1.2, Ingestion, states the following: “Ingestion and clearance of 

insoluble compounds through the gastrointestinal (GI) tract delivers a dose for only a few 

days, and soluble compounds that are readily absorbed are eliminated fairly quickly.” It 

is inaccurate to assume that soluble compounds that are readily absorbed are eliminated 

fairly quickly. Cesium, for example, always forms soluble compounds (type F for 

inhalation), f1=1; thus, it is readily absorbed but not rapidly eliminated. In fact, organ 

doses associated with Cs-137 are in general higher for ingestion than from inhalation. 

Table 3.1-2 below, taken from the ICRP Database of Dose Coefficients: Workers and 

Members of the Public, available on CD-ROM, is used to compare 50-year committed 

equivalent organ dose coefficients from inhalation and ingestion of Cs-137. 

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Table 3.1-2. 50-Year Committed Equivalent Organ Dose Coefficients 

from Inhalation and Ingestion 

INHALATION 

AMAD 5 micron

(Sv/Bq intake) 

INGESTION 

f1=1 

(Sv/Bq intake) 

Time after Intake 50 years 50 years 

Adrenals 6.70E-09 1.40E-08 

Bladder Wall 6.90E-09 1.40E-08 

Bone Surface 6.60E-09 1.40E-08 

Brain 5.70E-09 1.20E-08 

Breast 5.40E-09 1.10E-08 

Esophagus 6.30E-09 1.30E-08 

St Wall 6.30E-09 1.30E-08 

SI Wall 6.70E-09 1.40E-08 

ULI Wall 6.90E-09 1.40E-08 

LLI Wall 8.00E-09 1.70E-08 

Colon 7.40E-09 1.50E-08 

Kidneys 6.50E-09 1.30E-08 

Liver 6.50E-09 1.30E-08 

Muscle 6.00E-09 1.20E-08 

Ovaries 6.90E-09 1.40E-08 

Pancreas 6.90E-09 1.40E-08 

Red Marrow 6.30E-09 1.30E-08 

ET Airways 1.30E-08 1.30E-08 

Lungs 6.10E-09 1.30E-08 

Skin 5.20E-09 1.10E-08 

Spleen 6.50E-09 1.30E-08 

Testes 6.00E-09 1.20E-08 

Thymus 6.30E-09 1.30E-08 

Thyroid 6.30E-09 1.30E-08 

Uterus 6.90E-09 1.40E-08 

Remainder 9.50E-09 1.20E-08 

Effective dose 6.70E-09 1.30E-08 

Depending on the number of years between exposure and the diagnosis of the cancer, a 

dose to the colon or to the lower large intestine (LLI) wall might be greater using the 

ingestion model, even for radionuclides for which f1 does not equal 1. 

Comment 2: In discussing the ingestion pathway, Section 4.1.2 states the following: 

. . . While the fraction of material ingested often results in relatively 

minimal dose, it can produce bioassay data comparable to a larger 

inhalation dose. This implies that the erroneous assignment of a fraction 

of the bioassay data to ingestion can significantly bias the assigned dose. 

In some cases, this effect can result in doses that are several orders of 

magnitude low. Because of this, caution must be used before assuming 

any bioassay data is the result of ingestion. However, what appears to be 

conflicting bioassay data must be evaluated. For example, a fecal sample 

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for Th-232 indicated a large dose when assumed to be the result of 

inhalation while an in vivo measurement indicated no detectable Th-232 in 

the lungs. If both samples are valid, and some evidence exists that 

indicates ingestion is possible, this dose can be assigned, at least in part, 

as ingestion since that is the only way to reconcile the two valid 

measurements. [Emphasis added.] 

This example is technically flawed when referring to “. . . an in vivo measurement [with] 

no detectable Th-232 in the lungs” as a “valid” sample. Th-232 is a pure alpha emitter, 

which is not readily detected by in vivo bioassay techniques. Therefore, the absence of a 

positive lung count can confirm neither the presence nor the absence of Th-232 in the 

lung. (Note: A positive in vivo bioassay could only result if Th-232 had been inhaled 

along with its radioactive decay daughter Ra-228 (half-life of 6.7 years) and gamma 

emitting radioactive daughter Ac-228 (half-life of 6.13 hours). In such a case, the 

question of pathways may be apparent if equilibrium is assumed and the exposure is high 

enough to exceed the detection limit of the in vivo method that was used.) In general, the 

detection limit of both excreta and in vivo monitoring techniques should be considered in 

the comparison of results. 

The potential for ingestion should be investigated in relation to hygienic habits (existing 

rules for cigarette smoking, eating and drinking in the radiation area or radiation adjacent 

areas, placing contaminated hand or glove in the mouth).

(4) Section 4.3, page 15: Section 4.3, Solubility Class, indicates that the solubility of a 

radionuclide is one of the most important parameters in determining the internal radiation 

dose. In order to accurately determine the solubility class, this section also states: 

The most accurate means of evaluating the solubility class is by 

examining multiple bioassay samples after an intake. This has the 

potential of providing an accurate determination of solubility for the 

particular material. However, inhaled material often exhibits more than 

one solubility class. A plot of multiple bioassay samples can produce a 

curve that appears to show a soluble compound when in fact it is only the 

soluble portion of the inhaled material that is actually being followed. 

The slowly changing insoluble portion may not be noticeable. Therefore, 

consideration must be given to the potential presence of more insoluble 

compounds whenever bioassay samples are used to determine solubility. 

Figure 4 demonstrates this effect. As can be seen, a mixture of solubility 

class S and M plutonium produces a clearance curve with virtually the 

same slope as that of pure class M material. [Emphasis added.] 

Determining the solubility type by multiple bioassay samples is a very complex process. 

When this method is used, the results may be misleading, as discussed in Section 4.3 and 

depicted in Figure 4 of OCAS-IG-002. This is one example in which the guide shows 

part of the problem but does not provide guidance on its resolution, yet states that it is 

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the most accurate means of evaluating the solubility class. OCAS-IG-002 omits the 

fact that the activity excreted on a daily basis varies significantly, often depending on the 

liquid or food ingested (as in the case of uranium), or on the daily exposure condition 

(differences in working condition or exposures from day to day). 

Furthermore, OCAS-IG-002 does not mention that activities excreted in urine are also 

dependent on the individual metabolism, and that no worker is expected to behave like 

the standard man. 

(5) Section 7.4, page 33: The last sentence in Section 7.4 of OCAS-IG-002 states, “Since the 

risk factors in NIOSH-IREP are based on WLMs, and a WLM is defined only for 

progeny, any exposure to Rn-222 gas (without its accompanying progeny) will have to be 

calculated as a dose and input into NIOSH-IREP as a dose instead of a WLM.” 

The guide does not explain how to calculate doses from Rn gas itself, without the 

daughters. ICRP does not recommend any strategy for this calculation. 

3.2 ORAUT-PROC-0003 — INTERNAL DOSE RECONSTRUCTION 

The review of ORAUT-PROC-0003, Internal Dose Reconstruction, Rev. 00, dated May 1, 2003, 

was prepared by Joyce Lipsztein, PhD, and approved by John Mauro, PhD, CHP, on January 11, 

2005. 

3.2.1 Purpose of Procedure 

The stated purpose of this procedure is “to provide guidance in the performance of internal 

dose reconstructions under the Energy Employees Occupational Illness Compensation 

Program Act (EEOICPA). This procedure specifies steps taken to assure that internal 

dose reconstructions are sufficiently complete, correct and consistent for determining 

probability of causation of a covered employee’s specified cancer(s).”

3.2.2 Review Protocol 

SC&A’s evaluation of ORAUT-PROC-0003 is summarized in Table 3.2-1 below. Table 3.2-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

3.2.3 General Comments 

According to the scope of the procedure, 

“This procedure applies to ORAU Team (ORAUT) personnel and contractors who 

are reconstructing and reviewing internal doses in support of the National 

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

Analysis and Support (OCAS).” 

It defines responsibilities among the Principal Internal Dosimetrist, Internal Dosimetry 

Supervisor, Internal Dose Reconstructor, External Dose Reconstructor, Lead Dose 

Reconstructor, and Support Dose Reconstructor. 

Table 3.2-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0003 Effective Date: 05/01/2003 

Document Title: Internal Dose Reconstruction

Reviewer: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 

1.2 Is the procedure written in a manner that presents the 

data in a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., 

does not reference other sources that are needed for 

additional data)? 

4 See Review Comments 

1.4 Is the procedure consistent with all other procedures that 

are part of the hierarchy of procedures employed by 

NIOSH for dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to 

minimize the need for subjective decisions and data 

interpretation? 

4 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as 

part of an initial dose evaluation of a claim? 

3 See Review Comments 

2.2 Conversely, for claims with suspected cumulative low 

doses, does the procedure provide clear guidance in 

defining worst-case assumptions? 

3 See Review Comments 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, 

and is it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as 

required under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses 

generic as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) It addresses generic data. 

3.2.2 In vivo/In vitro bioassays It addresses generic data. 

3.2.3 Missing dosimetry data It addresses generic data. 

3.2.4 Unmonitored periods of exposure It addresses generic data. 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations.

4.1 Does the procedure support a prescriptive approach to 

dose reconstruction? 4 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant.

5.1 Is the procedure claimant favorable in instances of 

missing data? See Review Comments 

5.2 Is the procedure claimant favorable in instances of 

unknown parameters affecting dose estimates? See Review Comments 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? See Review Comments 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates.

6.1 Does the procedure provide adequate guidance for 

selecting the types of probability distributions (i.e., 

normal, lognormal)? 

2 See Review Comments 

6.2 Does the procedure give appropriate guidance in the use 

of random sampling in developing a final distribution? 2 See Review Comments 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency.

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its 

POC? 

5 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.2.4 Review Comments 

Review Objectives 1.1 to 1.5

Objectives 1.1 to 1.5 were designed to determine the degree to which the procedure supports a 

process that is expeditious and timely for dose reconstruction. 

Objective 1.3 seeks to determine if the procedure is complete in terms of required data. 

Appropriately, ORAUT-PROC-0003 refers to several other NIOSH documents. However, the 

references do not include ICRP 30, 56, 67, 69, 71, 72, and 78, although they are necessary to 

understand Table 1 of the procedure. 

Objective 1.5 was designed to determine if the procedure is sufficiently prescriptive to minimize 

subjective decisionmaking and data interpretation. Dose reconstruction and data interpretation 

always depend on some subjective decisions. The note following item 6.5.4 on page 9 of 

ORAUT-PROC-0003 is an example of the need for subjective decisionmaking and data 

interpretation: “It may sometimes be possible to use the bioassay data to determine some of the 

parameter values, but there must be sufficient data of good quality in order to make this 

assertion. A few positive results are not sufficient.” [Emphasis added.] The dose reconstructor 

must decide which results may be considered “sufficient data of good quality,” and how many 

results are necessary to have useful data (“a few positive results are not sufficient”). 

The document provides some direction on making subjective decisions as an inherent part of the 

interpretation of results for internal dose calculations. On page 12, item 6.8.2, of ORAUTPROC-0003, for example, the following advice is given: “. . . select possible values based on 

reasonable and scientific assumptions. If this yields multiple choices, select those representing 

the worst-case (claimant-favorable) assumptions.” 

Review Objectives 2.1 and 2.2

Objectives 2.1 and 2.2 were designed to determine whether the procedure provides adequate 

guidance to be efficient in cases in which a more detailed approach to dose reconstruction would 

not affect the outcome. ORAUT-PROC-0003 provides adequate guidance for identifying a 

potentially high probability of causation (POC) as part of the initial dose evaluation of a claim, 

as well as for claims with suspected cumulative low doses. The procedure also provides clear 

guidance in defining worst-case assumptions. However, certain problems with Table 1 may 

detract from this guidance (see Section 3.5.2, item 3). 

Review Objective 4.1

Objective 4.1 was designed to determine whether the procedure supports a prescriptive approach 

to dose reconstruction. Since dose reconstruction and data interpretation require some subjective 

judgments, SC&A believes that the procedure is as prescriptive as can be expected given its 

objectives. 

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Review Objectives 5.1 to 5.3

Objectives 5.1, 5.2 and 5.3 were designed to assess whether procedure decisions are claimant 

favorable in cases of missing data, unknown parameters affecting dose estimates, and in which 

the claimant was not monitored. In general, those items are only addressed generically in the 

document. With regard to the assignment of a date for an intake, the approach recommended in 

ORAUT-PROC-0003 is not necessarily claimant favorable and requires further justification. 

Review Objectives 6.1 and 6.2

Objectives 6.1 and 6.2 were designed to evaluate the procedure for its ability to adequately 

account for the uncertainty of dose estimates. Although the document recommends consulting 

OCAS-IG-002 to estimate intake and dose for likely noncompensable cases and advises that the 

Interactive RadioEpidemiological Program (IREP) should be run at regular intervals to 

determine if the POC is greater than 50%, it does not mention the issue of uncertainty. 

3.2.5 Technical Issues 

(1) Section 6.3.1.2, page 8 of 14: The last sentence should read, “The cancer will most likely 

be in an organ that does not concentrate the radionuclide(s) . . . .” 

(2) Section 6.5.1, page 9 of 14: The usual approach for chronic intakes is to consider the 

whole period between the two samples: 

For an acute intake, the use of the midpoint between the date of two 

consecutive monitoring results, to indicate the date of the intake, might lead to 

errors of several orders of magnitude, depending on the type of bioassay 

method used. Those errors are not claimant favorable. 

(3) Table 1, page 10 of 14: The deposition sites from Table 1 present some problems. 

— The deposition sites are actually systemic deposition sites, and the table should refer 

to them as such. 

— The soft tissues compartments are present in all new physiologically based biokinetic 

models (Sr, Ra, U, Th, Np, Pu, Am, Cm) and represent the compartments of the body 

that are not considered to be the main ones. It does not mean that all tissues of the 

body should be looked upon as special concentration sites for those radionuclides. 

— The behavior of decay product nuclides produced in the body must be taken into 

consideration and may lead to the introduction of other compartments that may result 

in relatively high equivalent doses, such as the equivalent dose to the kidneys and 

spleen for Ra-226. 

— The deposition sites contain several errors: 

The liver should be included for Ra. 

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The kidneys should be included for Th. 

The kidneys and red bone marrow should be included for Np, Pu, and Am. 

The gonads, kidneys, and red bone marrow should be included for Cm. 

Table 1, which is very important for dose reconstruction, must be reviewed using the 

information that describes the behavior of the radionuclides, as given in the appropriate 

ICRP publications. 

3.3 OCAS-TIB-008 — USE OF ICRP 66 TO CALCULATE RESPIRATORY TRACT 

DOSES 

The review of OCAS-TIB-008, Use of ICRP 66 to Calculate Respiratory Tract Doses, Rev. 00, 

dated September 29, 2003, was prepared by Joyce Lipsztein, PhD, and approved by John Mauro, 

PhD, CHP, on January 11, 2005. 

3.3.1 Purpose of Procedure 

The stated purpose of this guide is to provide “. . .guidance on selecting an appropriate tissue to 

serve as the surrogate for the internal dose to specific organs/tissues associated with or near the 

respiratory tract.” 

The background section of OCAS-TIB-008 also states, “. . . This TIB attempts to designate the 

appropriate ICRP calculated organ/tissue dose to use for various ICD-9 coded cancers associated 

with the respiratory tract.” 

3.3.2 Review Protocol 

SC&A’s evaluation of OCAS-TIB-008 is summarized in Table 3.3-1 below. Table 3.3-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

3.3.3 General Comments 

As stated in the purpose and background sections of OCAS-TIB-008, this document represents 

the primary source of technical support for “. . . selecting an appropriate tissue to serve as the 

surrogate for the internal dose to specific organs/tissues associated with or near the respiratory 

tract.”

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Table 3.3-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-008 Effective Date: 09/29/2003 

Document Title: Use of ICRP 66 to Calculate Respiratory Tract Dose 

Reviewer: Joyce Lipsztein 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 See Review 

Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 4 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 4 See Review Comments 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

3.3.4 Review Comments 

Review Objectives 1.1, 1.3, and 1.5

Objectives 1.1, 1.3 and 1.5 were designed to assess whether a procedure is unambiguous and 

sufficiently prescriptive to minimize subjective decisions. 

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SC&A’s review of this technical document has identified that the explanations on the use of 

certain organs as surrogates isare not always clear. For example, the explanation in Section 4.2, 

page 3, regarding the use of nonmodeled organs for the mouth, is complex but not clear. 

Several paragraphs of ICRP 66 are referenced and discussed in the document, but the procedure 

is not always sufficiently prescriptive. In cases in which large differences exist among 

nonmodeled organs, the dose reconstructor must make subjective decisions on which organ to 

use, as specified on page 3, Section 4.1, of the document: 

It is conceivable that a situation could arise where a photon emitting radionuclide 

causes a large difference in doses delivered to non-modeled organs. In 

accordance with the Internal Dose Reconstruction Implementation Guideline, it is 

acceptable in these situations to base the dose on an organ that is not the highest 

non-modeled organ. The choice in these cases should be based on the proximity 

of the surrogate organ to the organ of interest. 

Review Objective 4.1 

Section 4.1, Highest Non-Mmodeled Organ, of OCAS-TIB-008, does not provide clear 

instructions on which organ to use in cases involving large differences among nonmodeled 

organs. 

Review Objective 4.2

SC&A’s review has identified that the procedure does not comply with the requirements in Title 

42, Section 82.2, of the Code of Federal Regulations (42 CFR 82.2) to use the ICRP 66 model. 

In Section 4.2 of OCAS-OTIB-008, the following statement is made: “. . . As a result of this 

discussion, it is evident that the mouth was not considered in assessing the dose to the ET2 

region and therefore should be treated as unmodeled tissue.” The assignment of the mouth as the 

highest nonmodeled organ does not comply with ICRP 66 recommendations. 

3.3.5 Technical Issues 

In general, OCAS-TIB-008 is straightforward on the assignment of the appropriate tissue to 

serve as the surrogate when determining the internal dose to specific organs/tissues associated 

with or near the respiratory tract. However, the assignment of the mouth as the highest 

nonmodeled organ is not appropriate since the ICRP specifically lists the mouth as part of ET2. 

3.4 ORAUT-PROC-0002 ― USE OF INTEGRATED MODULES FOR BIOASSAY 

ANALYSIS 

The review of ORAUT-PROC-002, Use of Integrated Modules for Bioassay Analysis, Rev. 01, 

dated August 14, 2003, was prepared by Kathleen Behling, and approved by John Mauro, PhD, 

CHP, on January 11, 2005. 

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3.4.1 Purpose of Procedure 

The stated purpose of this procedure is “. . . to provide ORAU Team dose reconstructors an 

overview of running the IMBA (Integrated Modules for Bioassay Assessment) software and to 

specify IMBA documentation and file creation requirements for the NIOSH Dose Reconstruction 

Project.” 

3.4.2 Review Protocol 

Our evaluation of ORAUT-PROC-002 is summarized in Table 3.4-1. Table 3.4-1 is a checklist 

containing objectives that SC&A developed under the first phase of Task 3 to evaluate whether 

the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

3.4.3 General Comments 

The IMBA software program is designed to perform the complex calculations of estimating a 

worker’s intake of radioactive materials and converting this intake to an annual dose to a 

designated target organ or tissue in a form suitable for input to the Interactive 

RadioEpidemiological Program (NIOSH-IREP). 

The procedure describes the mechanics of running the IMBA software under routine or standard 

case evaluations (not when non-default assumptions are necessary) and specifies documentation 

requirements. The reader is cautioned that this procedure is neither designed to specify all 

operational steps necessary to use IMBA nor evaluate nonstandard internal dose reconstructions. 

Running the IMBA software will also require the use of information provided in the IMBA 

Expert user manual. In addition, this procedure does not provide guidance on performing a dose 

estimate. More detailed information for performing a dose estimate is provided in ORAUTPROC-0003, Performing Internal Dose Reconstructions. 

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Table 3.4-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0002 Effective Date: 8/14/2003 

Document Title: Use of Integrated Modules for Bioassay Analysis (IMBA)

Reviewer: Kathleen Behling

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 See Review 

Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays 5 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 5 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? 5 

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

5 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5 

___________________________ 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

3.4.4 Review Comments 

Review Objective 1.1

The IMBA software program is comprised of three primary screens: (1) the main screen, (2) the 

bioassay calculations screen, and (3) the dose calculations screen. Each of these screens or 

windows is further divided into functional portions (i.e., the intake scenario portion of the main 

screen) that allow for the input of required data. Due to the visual complexity of the IMBA 

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windows and amount of data that is required to be entered in each of the functional portions of 

the three screens, it is important that the procedure provide enough detail to point the reader to 

appropriate locations on the screen for entering necessary parameters and executing operations. 

In a few instances, the procedure lacks clear descriptions for the locations of various functional 

buttons. For example, Section 6.2 describes the process for entering the host of data necessary 

for calculating intakes and/or predicting bioassay results in the Bioassay Calculations screen. 

This window is divided into three functional areas and requires entering data into table and 

graphic sub-screens. When all necessary data has been entered, the procedure simply states 

under Section 6.2.10: “Calculate intake by clicking Start Calculations.” Due to the ‘busy 

nature’ of this window, it would be helpful to the user of IMBA to indicate that the ‘Start 

Calculation’ button is located in the center of the screen under the ‘Calculation’ area. 

The clarity of the procedure could also be improved in Section 6.2.12. This section specifies: 

“Click on the first tool button under BIOASSAY QUANTITY once again to open the window 

containing bioassay data.” However, based on previous procedural instructions, clicking on the 

tool button will actually open the ‘graphic’ tool window rather than the ‘table’ tool window. The 

user should be reminded to ensure that the ‘table’ radio button under the Bioassay Quantity 

portion of the screen is first selected. 

Review Objective 1.3

Due to the complexity of running even routine evaluations using the IMBA software, ORAUTPROC-0002 should provide some assistance to the user in evaluating results of the bioassay 

calculations. In Section 6.2, the procedure describes how to enter data into IMBA for estimating 

worker intakes and/or predicting bioassay results. However, the procedure does not provide any 

guidance on evaluating the fit of the data (Section 6.2.11) other than stating “. . . modify 

assumptions if necessary, in accordance with ORAUT-PROC-0003, Internal Dose Estimation.” 

(It should be noted that the title of ORAUT-PROC-0003 is Internal Dose Reconstruction, not 

Internal Dose Estimation.) The SC&A reviewer read the entire recommended procedure (i.e., 

ORAUT-PROC-0003) and was unable to glean much additional useful information that 

specifically addressed modifying the IMBA assumptions in order to arrive at a better fit. 

Review Objective 1.5

SC&A fully understands that, due to the complexity of internal dosimetry and the limitations and 

uncertainties surrounding bioassay measurements, subjective decisions are an inherent part of the 

interpretation of results for internal dose calculations. As was stated under Review Object 1.3 

and is equally appropriate under this objective, the IMBA procedure could have provided the 

IMBA user with more guidance in areas requiring professional judgment, such as modifying 

bioassay input assumptions in order to establish a better fit of the data. 

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3.5 OCAS-TIB-002 — TRITIUM CALCULATION WITH IMBA 

The review of OCAS-TIB-002, Tritium Calculation with IMBA, Rev. 00, dated April 22, 2003, 

was prepared by Joyce Lipsztein, PhD, and approved by John Mauro, PhD, CHP, on January 11, 

2005. 

3.5.1 Purpose of Procedure 

The stated purpose of this technical information bulletin is to provide “. . . guidance on the use of 

IMBA to calculate tritium doses.”

3.5.2 Review Protocol 

SC&A’s evaluation of OCAS-TIB-002 is summarized in Table 3.4-1 below. Table 3.4-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 

3.5.3 General Comments 

In the background section, this document provides a method to calculate internal doses due to 

exposure to various tritium compounds: 

The ICRP has specified five different categories of tritium compounds. Many of 

these compounds are categorized as gases or vapors. While the IMBA program 

currently includes tritium, it does not yet handle gases and vapors. It is, however, 

possible to utilize IMBA to calculate doses for these compounds. This Technical 

Bulletin provides instructions for performing these calculations. 

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Table 3.5-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-002 Effective Date: 04//22/2003 

Document Title: Tritium Calculation with IMBA

Reviewer: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

N/A 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 5 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.5.4 Review Comments 

Review Objective 1.3

Objective 1.3 was designed to determine the degree to which the procedure is complete in terms 

of required data (i.e., does not reference other sources for additional data). SC&A’s review has 

identified that ICRP 88 is listed as a reference but, although used, is not mentioned in the text. 

ICRP 30 and 66 are mentioned in the text but are not listed in the references. ICRP 71 is listed in 

the references but is not mentioned in the text. 

3.5.5 Technical Issues

SC&A tested the instructions on bypassing problem with the integrated modules for bioassay 

analysis (IMBA) of not handling gases and vapors. SC&A compared the results obtained by 

following the instructions in OCAS-TIB-002 with those obtained using software that handles 

gases and vapors and calculates intakes and doses exactly as recommended by the ICRP. Results 

were similar. However, although the instructions are correct, it is cumbersome for the dose 

reconstructor to use this software for the following reasons: 

(1) For tritiated water (HTO), the IMBA calculations window includes indicated activity 

per day instead of activity per liter. For both inhalation and ingestion routes of 

intake, the dose reconstructor should use injection. 

(2) For inhalation of elemental tritium (HT), the dose reconstructor must specify 

inorganic tritium and injection as the route of intake. To calculate intake from a 

bioassay result, the dose reconstructor must divide the intake generated by IMBA by 

10,000. However, the doses calculated are correct. If the dose reconstructor is 

calculating dose from airborne concentrations, he/she must divide the HT intake by 

10,000 to obtain the correct dose. 

(3) For inhalation of tritiated methane, the dose reconstructor must specify inorganic 

tritium and injection as the route of intake. To calculate intake from a bioassay 

result, the dose reconstructor must divide the intake generated by IMBA by 100. 

However, the doses calculated are correct. If the dose reconstructor is calculating 

dose from airborne concentrations, he/she must divide the tritiated methane intake 

by 100 to obtain the correct dose. 

(4) For inhalation of organically bound tritium (OBT), the dose reconstructor must 

specify injection as the route of intake.

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3.6 ORAUT-OTIB-0002 — MAXIMUM INTERNAL DOSE ESTIMATES FOR 

CERTAIN DOE COMPLEX CLAIMS 

The review of ORAUT-OTIB-0002, Maximum Internal Dose Estimates for Certain DOE 

Complex Claims, Rev. 01, dated January 10, 2004, was prepared by Joyce Lipsztein, PhD, and 

approved by John Mauro, PhD, CHP, on January 11, 2005. 

3.6.1 Purpose of Procedure 

The stated purpose of this technical information bulletin (TIB) is to provide a method to facilitate 

timely processing of claims under EEOICPA which involve cancer to an organ with little or no 

reported internal dose from internally deposited radionuclides that might be associated with work 

at U.S. Department of Energy (DOE) complex sites. 

3.6.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0002 is summarized in Table 3.6-1 below. Table 3.6-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

3.6.3 General Comments 

In this document, the methods provided to assign internal doses are based upon the “largest 

reasonably possible value” of the source term comprised of radionuclides that are/were typically 

the more significant radionuclides (by either preponderance or by internal dose significance) on a 

site. This worst-case estimate of internal dose assumes that the covered employee had an acute 

inhalation intake of each of the radionuclides in the source term on the first day of the first year 

of employment. 

Additional assumptions to develop this method are: 

 All intakes are inhalations of standard 5 micrometer activity median aerodynamic 

diameter (AMAD), except for I-131, which is assumed to be in vapor form (class SR-1). 

 The most soluble form of the radionuclide specified in ICRP 1994a was used to 

maximize dose to systemic organs, except as noted below; the dose to the lung is not 

germane to this exercise. 

 Because maximum permissible body burdens (MPBBs) were the metric (actually uptake) 

for so many years, the assumed implausible uptake was based on a percent of the 

radionuclide-specific MPBB for soluble chemical forms, as defined by the National 

Committee on Radiation Protection and Measurements (NCRP 1959). It was assumed 

that an intake resulting in 10% of an MPBB would not likely occur to an unmonitored 

worker or would likely produce a readily noticeable bioassay result in a monitored 

worker, readily noticeable air sample, or other indicators of personnel contamination. In 

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other words, an event providing the possibility of an intake resulting in a body burden 

exceeding 10% of the MPBB would not have gone unnoticed, and there would be some 

sort of indication in the worker’s records. This assumption applies to bona fide DOE 

sites and national laboratories with active radiation protection programs, not to Atomic 

Weapons Employers (AWEs). The current ICRP methodology is used to calculate doses 

from these implausible intakes. 

 For type F and M materials, the associated derived intake (i.e., intake resulting in a 10% 

MPBB) was assumed to be 10 and 20 times the 10% MPBB, respectively. The factors of 

10 and 20 come from the current ICRP models and the differences between an intake and 

the activity that is present in the body after the initial clearance of the short-term 

compartments. These factors are used to relate the historical quantity of control, body 

burden (which was based on ICRP 2 methods), to the present quantity of control, intake, 

(which is based on current ICRP methods). 

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Table 3.6-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0002 Effective Date: 01/10/2004 

Document Title: Maximum Internal Dose Estimates for Certain DOE Complex Claims

Reviewer: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 2 See Review 

Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3 See Review 

Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

2 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

2 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 5 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 2 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 3 See Review Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3 See Review Comments 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 3 See Review Comments 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A No mention of a 

statistical procedure 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A No mention of a 

statistical procedure 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? NA 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.6.4 Review Comments 

Review Objectives 1.1 to 1.5

Objectives 1.1 to 1.5 were designed to determine the degree to which the procedure supports a 

process that is expeditious and timely for dose reconstruction. 

SC&A’s review has identified that, in several sections, the writing style is not clear and 

unambiguous and the information is not given in a logical sequence, making the document not 

easy to understand. It is difficult to accept the reasons to use 10 and 20 times the 10% MPBB as 

the maximum intakes. The logic behind the recommended procedures is also very challenging to 

follow and understand. 

The procedure is not complete in terms of required data. The document references and uses data 

from documents that need to be known in order to understand the procedures described. 

The procedure is not consistent with all the others that are part of the hierarchy of procedures 

employed by NIOSH for dose reconstruction. The standard procedures use new ICRP models 

for interpreting results. It is also not consistent with the procedure used in ORAUT-OTIB-0001. 

The procedure is sufficiently prescriptive to minimize the need for subjective decisions. 

However, the technical derivation of the procedure is very difficult to understand and accept. 

Review Objectives 4.1 and 4.2

The procedures described are difficult to understand and reproduce. 

Review Objectives 5.1, 5.2, and 5.3

Objectives 5.1, 5.2, and 5.3 were designed to assess whether procedure decisions are claimant 

favorable in instances of missing data, unknown parameters effecting dose estimates, and in 

which the claimant was not monitored. The procedure is difficult to understand. 

The assumption that the intakes are 10 to 20 times the 10% MPBB is not always justifiable in 

terms of the new ICRP models. For many nuclides, this is not a claimant-favorable approach. In 

addition, the method for choosing the solubility types is not always claimant favorable. These 

findings are exemplified in Section 3.6.5 of this review. 

The procedure is designed to reconstruct doses for employees who were not included in a 

bioassay program. The design of the procedure is not always claimant favorable. 

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3.6.5 Technical Issues

Calculation of the Intake (pages 4 to 5 of 20, Section 3.1.1) 

The TIB provides the following description as the basis for assigning an intake as the MPBB: 

. . . It was assumed that an intake resulting in 10% of a MPBB would not have 

likely occurred to an unmonitored worker or would have likely resulted in a 

readily noticeable bioassay result in a monitored worker, readily noticeable air 

sample, or other indicators of personnel contamination. In other words, an event 

providing the possibility of an intake resulting in a body burden exceeding 10% of 

the MPBB would not have gone unnoticed and there would be some sort of 

indication in the worker’s records. 

 

For type F and M materials, the associated derived intake (i.e., intake resulting in 

a 10% MPBB) was assumed to be 10 and 20 times the 10% MPBB, respectively. 

The factors of 10 and 20 come from the current ICRP models and the differences 

between an intake and the activity that is present in the body after the initial 

clearance of the short-term compartments. These factors were estimated from 

tables in the November 2002 issue of Health Physics that give the intake retention 

fraction (IRF) for the whole body (without the ET region) as a function of time 

after acute intake for different elements and inhalation types.

The review identified the following specific issues: 

 

 Instead of using an arbitrary number such as 10 or 20 times MPBB, the intake is more 

correctly estimated using IMBA or even the table from Health Physics, cited above, 

which was used to exemplify the derivation of the factors 10 and 20. 

 The fractional retentions in Table 3.1.1-1 are incorrect. They are the fractional retention 

values from the tables in the November 2002 issue of Health Physics. Those fractions 

refer to the stable element. Each value must be corrected with a decay factor for the 

specific radionuclide in question. Depending on the radionuclide’s half-life, the 

necessary correction could be significant. 

 For example, if applied with the decay correction, the fractional retention in whole body 

for type M Nb-95 would be equal to 0.015 at 60 days and equal to 0.007 at 90 days. The 

corresponding factor to multiply the intake would be 67 (60 days) and 144 (90 days), not 

20 as was used (Table 3.1.1-2).

 As another example, if applied with the decay correction, the fractional retention in 

whole body for type M Co-58 would be equal to 0.023 at 60 days and equal to 0.014 at 

90 days. The corresponding factor to multiply the intake would be 43 (60 days) and 71 

(90 days), not 20 as was used (Table 3.1.1-2). (As stated in Section 3.1.1, immediately 

after Table 3.1.1-1, “The assumption of type S for Co-58 and Co-60 is used . . . . the 

fractional retention in the whole body is similar for type M and type S at 60 and 90 days, 

so the derived intake is estimated as 20 times the 10% MPBB.”) 

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 It is arbitrary to use 3-4 days post intake to calculate the fractional retention in whole 

body for inhalation type F and 60 and 90 days for type M to account for the rapid 

clearance components from the lung. (As stated in the last bullet before Table 3.1.1-1, 

“Because initial deposition in the lung was usually not considered by the ICRP (1959) to 

be part of the ‘body burden,’ the retention fractions used allowed some time for the rapid 

clearance components.”)

Choice of the Solubility Types (page 5, Section 3.1.1) 

The assignment of solubility types, based on the criterion of choosing the solubility type that 

produces the larger doses to systemic organs, is not correct for many nuclides. For example: 

 As stated in Section 3.1.1, immediately after Table 3.1.1-1, “The assumption of type S for 

Co-58 and Co-60 is used because it results in larger doses to the systemic organs because 

of the high-energy photons.” From the organs cited in Table 3.1.1-4, the application of 

type M instead of type S to Co-58 results in larger doses to the bladder wall, brain, uterus 

and stomach. From the organs cited in Table 3.1.1-4, the application of type M instead of 

type S to Co-60 results in larger doses to the bladder wall, brain, uterus, and colon. 

 As stated in the third bullet after Table 3.1.1-1, “Mn-54 type M has a larger dose 

conversion factor for most organs/tissues and was generally more claimant favorable than 

type F.” From the organs cited in Table 3.1.1-4, the application of type F instead of type 

M to Mn-54 results in larger doses to the adrenals, brain, colon, muscle, pancreas, skin, 

stomach, bladder wall, and uterus. 

Minor Corrections 

 Pages 8 and 14: The organs listed on page 14 include the thyroid, but it is not included in 

Table 3.1.1-4. 

 Page 8 of 20, Section 4.0: Table 3.1.1-2 should be mentioned instead of Table 3.1.1-1. 

3.7 ORAUT-OTIB-0005 — IMBA ORGAN, EXTERNAL DOSIMETRY ORGAN, 

AND IREP MODEL SELECTION BY ICD-9 CODE 

The review of ORAUT-OTIB-0005, IMBA Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, Rev. 01, dated January 23, 2004, was prepared by Joyce Lipsztein, 

PhD, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

3.7.1 Purpose of Procedure 

The stated purpose of this TIB is to provide “guidance on selecting appropriate ICRP modeled 

organs/tissues in the Integrated Modules for Bioassay Analysis (IMBA) software program to 

estimate the internal dose for specific ICD-9 codes, the appropriate organs/tissues to estimate 

external dose, and the appropriate model in the Interactive RadioEpidemiological Program 

(IREP).” 

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3.7.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0005 is summarized in Table 3.7-1 below. Table 3.7-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

3.7.3 General Comments 

This document provides a table for the correlation of “ICD-9 codes to the appropriate 

organ/tissue selection in IMBA, the appropriate organ/tissue selection for external dose estimate, 

and the appropriate IREP model,” as stated in Section 3.0. Section 4.1 states, “The dose estimate 

for a number of tissues is based on the highest non-metabolic organ dose, designated as ‘Highest 

non-met org/tiss’ in the table. Metabolic organs are those that are specifically modeled by the 

ICRP for a particular element.” 

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Table 3.7-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0005 Effective Date: 01/23/2004 

Document Title: IMBA Organ, External Dosimetry Organ, and IREP Model Selection by 

ICD-9 Code

Reviewer: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

4 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 

N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, 

 and is it free of bias? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 3 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 3 See Review Comments 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.7.4 Review Comments 

Review Objective 1.4

Objective 1.4 was designed to determine the degree to which the procedure is consistent with all 

other procedures that are part of the hierarchy of procedures employed by NIOSH for dose 

reconstruction. 

SC&A’s review has identified that this document is not consistent with ICRP 66. According to 

this publication, the oral cavity is part of the ET2 region of the respiratory tract. The IMBA 

applicable organs assigned for this organ are the highest nonmetabolic organ and tissue, instead 

of ET2. There is no reason to assign oral cavity as a nonmetabolic organ. 

Review Objectives 1.5, 4.1, and 7.1

The procedure is not sufficiently prescriptive and requires levels of detail that cannot reasonably 

be accounted for by the dose reconstructor. Identification of the IMBA applicable organs for 

several types of cancers is missing and requires revision. 

3.7.5 Technical Issues 

Page 3 of 19 — ICD-9 (144 and 145) 

The IMBA applicable organ assigned for the mouth should be ET2 (ICRP 66, 1993) instead of 

the highest nonmetabolic organ and tissue. According to ICRP 66, the oral cavity is part of the 

ET2. The epithelial layer of all compartments of ET2 is constantly renewed by cell division and 

differentiation, originating from stem cells located in the basal layer of the tissue. The mucous 

membrane of the oral cavity and pharynx is covered with a mucous layer produced by numerous 

salivary glands located in the submucosal connective tissue and is well supplied with nerves, 

blood, and lymph vessels. The oropharynx and larynx surfaces consist of the same tissue — 

stratified squamous epithelium. There is no reason to assign the oral cavity as a nonmetabolic 

organ. 

 

3.8 ORAUT-OTIB-0001 — MAXIMUM INTERNAL DOSE ESTIMATES FOR 

SAVANNAH RIVER SITE (SRS) CLAIMS 

The review of ORAUT-OTIB-0001, Maximum Internal Dose Estimates for Savannah River Site 

(SRS) Claims, Rev. 00, dated July 15, 2003, was prepared by Joyce Lipsztein, PhD, and 

approved by John Mauro, PhD, CHP, on January 11, 2005. 

3.8.1 Purpose of Procedure 

The stated purpose of this guide is to provide a method to be used in the assignment of internal 

doses to “employees who were monitored but had no detectable activity (‘positive’) in their 

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samples and to employees who were not included in the bioassay program, because there is some 

amount of intake and associated dose that is not detectable by an internal dosimetry program.” 

3.8.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0001 is summarized in Table 3.8-1 below. Table 3.8-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

3.8.3 General Comments 

In this document, the method provided to assign internal doses is based upon a hypothetical 

intake with the following characteristics: 

 All radionuclides for which internal deposition by inhalation was calculated 

by the Savannah River Site were reviewed, except for tritium, which is 

addressed separately. 

 The amount of inhalation intake for each radionuclide is the average (mean) 

of the five largest documented intakes, or the average of all intakes if there 

were fewer than five intakes reported for a radionuclide. 

 An acute inhalation intake was assumed to have occurred on January 1 in the 

first year of employment. 

 ICRP 66 and 68 modeling and default parameter values were used to 

determine dose. 

 The material type resulting in the largest dose to the organ or tissue of interest 

was used. This was typically the most soluble form of the material because it 

would clear from the lung more rapidly than insoluble material, thus 

depositing in the organ or tissue sooner. 

. . . Intakes and doses at SRS were calculated using regulatory-prescribed ICRP 

30 methodologies rather than the newer ICRP methodology prescribed for this 

dose reconstruction effort. The material classes used in the calculations were 

based on workplace source term information or the class that provided the best fit 

to the bioassay data; the most claimant favorable class was not necessarily 

selected.

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Table 3.8-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0001 Effective Date: 07/15/2004 

Document Title: Maximum Internal Dose Estimates for Savannah River Site Claims 

Reviewer: Joyce Lipsztein 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 2 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 2 See Review Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

2 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

2 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 2 See Review 

Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 5 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? NA 

3.1.4 Is the interview process sensitive to the claimant? NA 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? NA 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) NA 

3.2.2 In vivo/In vitro bioassays NA 

3.2.3 Missing dosimetry data 4 See Review 

Comments 

3.2.4 Unmonitored periods of exposure 3 See Review 

Comments 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 3 See Review Comments 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 3 See Review 

Comments 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 3 See Review 

Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 2 See Review 

Comments 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 2 See Review 

Comments 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

1 See Review 

Comments 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 1 See Review Comments 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 2 See Review Comments 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 2 See Review Comments 

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). NA indicates not applicable. 

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3.8.4 Review Comments 

Review Objectives 1.1 to 1.5

Objectives 1.1 to 1.5 were designed to determine the degree to which the procedure supports a 

process that is expeditious and timely for dose reconstruction. SC&A’s review has identified 

that, in several sections, the writing style is not clear and unambiguous. The document is not 

complete, and it is very difficult to understand. For example: 

 Data for Tables 1 and 2 are not referenced, and it is impossible to verify or relate the data 

to specific jobs. 

 There is insufficient information to reproduce the relative intakes in Tables 3 and 5. 

 It is difficult to accept the reasons to use the ICRP 30 calculated intakes as the worst-case 

estimates when the procedure underestimates the ICRP 68 calculated intakes for several 

radionuclides. 

 The calculation of annual organ doses from hypothetical intakes for Table 2 nuclides is 

not clear. 

 The use of surrogate radionuclides is not well explained, including the use of type F 

nuclides as surrogates to types M and S. The choice of surrogate nuclides is very 

subjective, as are the comparisons on Tables 3 to 10. 

The document is difficult to understand. For example, it does not mention that the Savannah 

River Site (SRS) doses were recalculated using ICRP 30 methodology in 1987 for active workers 

and in 1992 for inactive workers. This information is important for understanding the use of 

ICRP 30 methodologies to calculate the recorded intakes dating before the publication of ICRP 

68. In addition, the procedure for the assignment of tritium dose should be complemented by the 

information contained in ORAUT-OTIB-0003. 

The document is not consistent with other procedures that are part of the hierarchy of procedures 

employed by NIOSH for dose reconstruction, specifically: 

 The standard procedures in 42 CFR Part 82 and OCAS-IG-002 recommend the use of 

new ICRP models for interpreting bioassay; however, the document uses ICRP 30 

models to calculate intakes. 

 The approach for calculating maximum dose estimates is particular to SRS and differs 

from the approach recommended for other similar DOE facilities (ORAUT-OTIB-0002). 

For certain radionuclides, such as uranium, the maximum plausible intakes, based on a 

fraction of the MPBB, are 5,000 nCi of U-234 and 500 nCi of U-238, which are much 

higher than the values recommended in ORAUT-OTIB-0001 (i.e., 105.4 nCi of U-234 

and 20.95 nCi of U-238). 

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Review Objectives 3.2.3 and 3.2.4

The document is relevant for employees who have no detectable activity in their monitoring 

results and for employees who were not included in the bioassay program. It does not explicitly 

refer to unmonitored periods of exposure and missing dosimetry data. For tritium, missing 

dosimetry data are addressed in ORAUT-OTIB-0003. 

Review Objectives 4.1 and 4.2

The procedures described are confusing and difficult to understand and reproduce. There is no 

clear description of the data that were used to derive the hypothetical intakes. SC&A’s review 

could not determine if the procedure adheres to the hierarchical process, as defined in 42 CFR 

82.2. Based on Table 3-10, it appears that urine bioassay was used for assigning intakes for Pu, 

Am, U, Np, Cm, Sr and that in vivo methods were used for Co and Cs. There is no description 

of the method that was used to calculate intakes from Ce, Cf, Nb, Ru, Zn, and Zr. 

Review Objectives 5.1, 5.2, and 5.3

Objectives 5.1, 5.2, and 5.3 were designed to assess whether procedure decisions are claimant 

favorable in instances of missing data, unknown parameters affecting dose estimates, and in 

which the claimant was not monitored. The procedure described in the document is not clear and 

does not apply the same claimant-favorable approach for all radionuclides. Specifically, 

 The use of ICRP 30 models, instead of the current ICRP models, to calculate the 

hypothetical intakes is not claimant favorable for most radionuclides. 

 The choice of the average of the five largest intakes is very subjective. Why were the 

five largest intakes chosen instead of the largest intake? 

 The procedure recommended for the use of surrogate radionuclides is not claimant 

favorable. 

 In addition, doses due to OBT are ignored. 

Review Objectives 6.1 and 6.2

The document does not mention a statistical procedure to account for the uncertainty in dose 

estimates. 

Review Objectives 7.1 and 7.2

The procedure does not provide the details needed to evaluate the degree to which the methods 

are scientifically valid and claimant favorable. 

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3.8.5 Technical Issues 

ORAUT-OTIB-0001 provides basic information on the methods to be employed in assigning 

maximum internal dose estimates to SRS employees who were monitored but had no detectable 

activity (“positive”) in their samples and to employees who were not included in the bioassay 

program. 

SC&A’s review of the document ORAUT-OTIB-0001 has identified some serious problems with 

the procedure used for establishing the maximum internal dose estimates, as follows: 

(1) Hypothetical intakes (page 3, ORAUT-OTIB-0001): Hypothetical intakes were based on 

recorded intakes at SRS. There is no mention on the calculation of those intakes, upon 

which data they were based, and if they should be used indiscriminately for all SRS 

operations and facilities. In addition, there is no mention of chronic intakes, 

corresponding internal doses, and comparisons with the hypothetical intake doses. 

(2) Use of ICRP 30 methodology to calculate hypothetical intakes (pages 3-8, ORAUTOTIB-0001): Hypothetical intakes were calculated using ICRP 30 methodologies rather 

than the newer ICRP methodology prescribed for this dose reconstruction effort. The 

justification given by NIOSH for the use of these intakes is technically flawed; the use of 

ICRP 30 models do not produce intake values that are higher than the ones using the new 

ICRP models for the majority of the relevant nuclides cited in the document.

The following definition of the hypothetical intake is cited under ORAUT-OTIB-0001, 

page 3 of 14: 

These hypothetical intakes were based on recorded internal doses at SRS 

and were assumed to be composed of the radionuclides contributing the 

majority of the recorded internal dose at the Savannah River Site, except 

for tritium (assignment of tritium dose is discussed at the end of this 

paper). 

The hypothetical intake internal dose was assigned based upon a hypothetical 

intake with the following characteristics: 

 All radionuclides for which internal deposition by inhalation was 

calculated by the Savannah River Site were reviewed, except for 

tritium, which is addressed separately. 

 The amount of the inhalation intake for each radionuclide is the 

average (mean) of the five largest documented intakes, or the average 

of all intakes if there were fewer than five intakes reported for a 

radionuclide. 

 An acute inhalation intake was assumed to have occurred on 

January 1 in the first year of employment.

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 ICRP 66 and 68 modeling and default parameter values were used to 

determine dose. [Emphasis added.] 

 The material type resulting in the largest dose to the organ or tissue 

of interest was used. This was typically the most soluble form of the 

material because it would clear from the lung more rapidly than 

insoluble material, thus depositing in the organ or tissue sooner. 

[Emphasis added.]

The largest inhalation intakes reported by SRS are summarized in Tables 

1 and 2, and include the material classes used in the SRS calculations. 

Several complicating factors arose in the use of the intake amounts to be 

applied to these cases. Intakes and doses at SRS were calculated using 

regulatory-prescribed ICRP 30 methodologies rather than the newer 

ICRP methodology prescribed for this dose reconstruction effort. The 

material classes used in the calculations were based on workplace 

source term information or the class that provided the best fit to the 

bioassay data; . . . [Emphasis added.]

Pages 5 to 8 provide a long explanation for using intakes calculated with ICRP 30 models 

instead of the new models, as prescribed in 42 CFR Part 82: 

 Because these values are being applied as a large overestimate of the dose 

likely received by the Covered Employee, it is not necessary to use the 

exact values determined by SRS but it must be shown that the values are 

indeed a likely overestimate. To demonstrate this, the intake retention 

fractions (IRFs) for the radionuclides of interest from ICRP 30 and ICRP 

68, for the applicable material classes/absorption types, are compared for 

several times following an intake. Tables 3 through 10 list the intake 

retention fractions for five specified times following an acute inhalation 

intake for the material type assumed here for dose reconstruction purposes 

and the material class(es) applied for the SRS-calculated intakes in Tables 

1 and 2. [Emphasis added.] 

The solubility types in the comparisons were not paired by the same solubility (type F compared 

to class D, type M compared to class W, and type S compared to class Y). Instead, the ICRP 68 

solubility types were chosen as “the most soluble form of the material because it would clear 

from the lung more rapidly than insoluble material, thus depositing in the organ or tissue 

sooner.” The ICRP 30 classes, on the other hand, were chosen using “the material class(es) 

applied for the SRS-calculated intakes in Tables 1 and 2.” 

There is a fundamental problem with the comparisons of these IRFs from ICRP 30 and ICRP 68. 

In general, when intakes are used to calculate organ doses, the choice of the most soluble type is 

claimant favorable for doses calculated to systemic organs. When bioassay results are used to 

calculate organ doses, the assignment of the most insoluble material type often results in a higher 

dose for systemic organs, as illustrated by the following example: 

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 A 24-hour urine sample is collected five days after a single inhalation intake of Pu-238. 

The bioassay result is 1 becquerel (Bq) of Pu-238. Using the ICRP 67 model for Pu, the 

calculated intakes are: 

— For Pu-238, type S: intake of 2.2 E6 Bq (50y committed bone surface dose is 75 

sieverts (Sv), 50y committed dose to colon is 0.053Sv, 1y committed dose to the 

colon is 0.006 Sv) 

— For Pu-238, type M: intake of 2.6 E4 Bq (50y committed bone surface dose is 24 Sv, 

50y committed dose to colon is 0.042Sv, 1y committed dose to the colon is 0.002 Sv) 

The use of Pu-238, type S, results in a higher intake than the use of type M Pu (and in higher 

doses to systemic organs): 

 Using ICRP 30 IRF from Table 3, page 6, of ORAUT-OTIB-0001, the same bioassay 

result of 1 Bq of Pu-238 in a 24-hour urine sample, taken five days after a single intake, 

corresponds to intakes of: 

— For class Y: intake of 3.5 E5 Bq (ICRP30) (50y committed bone surface dose is 

12 Sv, 50y committed dose to colon is 0.33Sv, 1y committed dose to the colon is 

0.037 Sv) 

— For class W: intake of 1.9 E4 Bq (ICRP30) (50y committed bone surface dose is 

17.5 Sv, 50y committed dose to colon is 0.03 Sv, 1y committed dose to the colon is 

0.0015 Sv) 

Thus, it is neither scientifically correct nor claimant favorable to compare the IRFs derived using 

the ICRP 68 most soluble form of material (material type) with those derived using the ICRP 30 

methodology and the material classes applied for SRS calculated intakes. The relative intakes in 

Table 3, page 6, of ORAUT-OTIB-0001 would not have been obtained if type M were assigned 

to nuclides classified as class W and type S were assigned to nuclides classified as class Y. The 

use of ICRP 30 models for Pu-238 to calculate the intake does not result in an overestimate of 

the intake. 

The tables below compare the relative intakes for all radionuclides listed in Tables 1 and 2, pages 

4 and 5, of ORAUT-OTIB-0001 that are derived using ICRP 30 and ICRP 68 IRFs. Intakes 

were calculated assuming a constant bioassay monitoring result (e.g., unitary bioassay result) 

measured at different times after intake.

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Table 3.8-2. Comparison of Pu Relative Intakes (ICRP 30/ICRP 68), Assuming Intakes 

Were Calculated from Urine Bioassay Data 

Radionuclide: Pu-238 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 2.30E-04 2.83E-04 8.13E-01 1.23E+00 

5 3.90E-05 5.39E-05 7.24E-01 1.38E+00 

10 1.50E-05 2.54E-05 5.91E-01 1.69E+00 

50 8.50E-06 1.45E-05 5.86E-01 1.71E+00 

100 6.80E-06 1.11E-05 6.13E-01 1.63E+00 

180 5.60E-06 8.50E-06 6.59E-01 1.52E+00 

200 5.10E-06 7.85E-06 6.50E-01 1.54E+00 

300 4.20E-06 5.80E-06 7.24E-01 1.38E+00 

360 3.85E-06 4.90E-06 7.86E-01 1.27E+00 

The intakes from Pu, type M, are underestimated using ICRP 30 methodology. 

Radionuclide: Pu-238, Pu-239, Pu-241 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type S Class Y 

ICRP68 ICRP30 Intakes 30/60 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF 

1 2.30E-06 1.55E-05 1.48E-01 6.74E+00 

5 4.50E-07 2.87E-06 1.57E-01 6.38E+00 

10 2.20E-07 1.29E-06 1.71E-01 5.86E+00 

50 1.70E-07 7.56E-07 2.25E-01 4.45E+00 

100 1.60E-07 6.97E-07 2.30E-01 4.36E+00 

180 1.60E-07 7.25E-07 2.21E-01 4.53E+00 

200 1.60E-07 7.34E-07 2.18E-01 4.59E+00 

300 1.60E-07 7.75E-07 2.06E-01 4.84E+00 

360 1.70E-07 7.80E-07 2.18E-01 4.59E+00 

The intakes from Pu, type S, are underestimated using ICRP 30 methodology. 

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Table 3.8-3. Comparison of Am Relative Intakes (ICRP 30/ICRP 68), Assuming Intakes 

Were Calculated from Urine Bioassay Data 

Radionuclide: Am-241 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

ICRP 68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 1.80E-03 6.66E-03 2.70E-01 3.70E+00 

5 7.20E-05 5.24E-05 1.37E+00 7.28E-01 

10 4.90E-05 4.97E-05 9.86E-01 1.01E+00 

50 2.00E-05 3.48E-05 5.75E-01 1.74E+00 

100 1.50E-05 2.22E-05 6.76E-01 1.48E+00 

180 1.10E-05 1.25E-05 8.80E-01 1.14E+00 

200 1.00E-05 9.70E-06 1.03E+00 9.70E-01 

300 8.00E-06 5.47E-06 1.46E+00 6.84E-01 

360 7.20E-06 4.50E-06 1.60E+00 6.25E-01 

For Am, type M, ICRP 30 methodology may underestimate the intakes, depending on when 

samples are taken after the intake. 

Radionuclide: Am-241 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Am-241 in matrix of 

Type S compounds of Pu Type S Class Y 

ICRP 68 ICRP30 Intake 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF 

1 3.01E-05 3.76E-04 8.01E-02 1.25E+01 

5 1.40E-06 2.21E-06 6.33E-01 1.58E+00 

10 9.90E-07 1.87E-06 5.29E-01 1.89E+00 

50 5.28E-07 1.91E-06 2.76E-01 3.62E+00 

100 4.59E-07 1.97E-06 2.33E-01 4.29E+00 

180 4.30E-07 2.04E-06 2.11E-01 4.74E+00 

200 4.27E-07 2.06E-06 2.07E-01 4.82E+00 

300 4.18E-07 2.13E-06 1.96E-01 5.10E+00 

360 4.14E-07 2.15E-06 1.93E-01 5.19E+00 

The intakes from Am, type S, are underestimated using ICRP 30 methodology. 

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Table 3.8-4. Comparison of U Relative Intakes (ICRP 30/ICRP 68), Assuming Intakes 

Were Calculated from Urine Bioassay Data 

Radionuclide: U-234 - U-235 - U-238 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type F Class D 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 1.80E-01 1.87E-01 9.63E-01 1.04E+00 

5 4.20E-03 1.31E-02 3.21E-01 3.12E+00 

10 2.70E-03 7.26E-03 3.72E-01 2.69E+00 

50 3.00E-04 6.67E-04 4.50E-01 2.22E+00 

100 1.00E-04 1.11E-04 9.01E-01 1.11E+00 

180 4.40E-05 4.40E-05 1.00E+00 1.00E+00 

200 2.40E-05 5.15E-06 4.66E+00 2.15E-01 

300 8.90E-06 1.80E-06 4.94E+00 2.02E-01 

360 6.00E-06 1.70E-06 3.53E+00 2.83E-01 

The intakes from U, type F, are underestimated using ICRP 30 methodology for samples taken 

up to 180 days after the intake. It is very unlikely that samples for type F are taken more than 

180 days after exposure. 

Radionuclide: U-234 - U-235 - U-238 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 2.30E-02 4.13E-02 5.57E-01 1.80E+00 

5 7.30E-04 2.69E-03 2.71E-01 3.68E+00 

10 5.40E-04 1.75E-03 3.09E-01 3.24E+00 

50 1.90E-04 4.80E-04 3.96E-01 2.53E+00 

100 1.10E-04 2.43E-04 4.53E-01 2.21E+00 

180 7.00E-05 7.00E-05 1.00E+00 1.00E+00 

200 5.80E-05 7.49E-05 7.74E-01 1.29E+00 

300 3.20E-05 2.33E-05 1.37E+00 7.28E-01 

360 2.30E-05 1.00E-05 2.30E+00 4.35E-01 

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ICRP 30 underestimates U type M intakes for all reasonable times of collecting samples after an 

intake has occurred. 

Radionuclide: U-234 - U-235 - U-238 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type S Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF 

1 7.00E-04 2.23E-03 3.14E-01 3.19E+00 

5 2.20E-05 1.31E-04 1.68E-01 5.95E+00 

10 1.60E-05 8.42E-05 1.90E-01 5.26E+00 

50 5.70E-06 2.34E-05 2.44E-01 4.11E+00 

100 4.10E-06 1.87E-05 2.19E-01 4.56E+00 

180 3.45E-06 1.83E-05 1.89E-01 5.29E+00 

200 3.20E-06 1.81E-05 1.77E-01 5.66E+00 

300 2.80E-06 1.83E-05 1.53E-01 6.54E+00 

360 2.68E-06 1.83E-05 1.47E-01 6.81E+00 

The intakes from U, type S, are underestimated using ICRP 30 methodology. 

Table 3.8-5. Comparison of Np Relative Intakes (ICRP 30/ICRP 68), Assuming Intakes 

Were Calculated from Urine Bioassay Data 

Radionuclide: Np-237 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Type S 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 6.20E-03 3.42E-03 1.81E+00 5.52E-01 

5 3.40E-04 3.02E-05 1.13E+01 8.88E-02 

10 1.30E-04 2.56E-05 5.08E+00 1.97E-01 

50 6.20E-05 1.78E-05 3.48E+00 2.87E-01 

100 4.20E-05 1.13E-05 3.72E+00 2.69E-01 

180 2.75E-05 6.50E-06 4.23E+00 2.36E-01 

200 2.40E-05 4.97E-06 4.83E+00 2.07E-01 

300 1.60E-05 2.82E-06 5.67E+00 1.76E-01 

360 1.30E-05 2.40E-06 5.42E+00 1.85E-01 

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The intakes from Np are underestimated using ICRP 68 methodology. 

Table 3.8-6. Comparison of Cm-242 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from Urine Bioassay Data 

Radionuclide: Cm-242 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W

ICRP 68 ICRP 30

Time (d) after intake Urine IRF Urine IRF Intakes 30/68 IRF 30/68 

1 1.80E-03 6.63E-03 2.71E-01 3.68E+00 

5 7.00E-05 5.13E-05 1.36E+00 7.33E-01 

10 4.70E-05 4.77E-05 9.85E-01 1.01E+00 

50 1.60E-05 2.81E-05 5.69E-01 1.76E+00 

100 9.80E-06 1.45E-05 6.76E-01 1.48E+00 

180 6.24E-06 7.20E-06 8.67E-01 1.15E+00 

200 4.40E-06 4.15E-06 1.06E+00 9.43E-01 

300 2.20E-06 1.53E-06 1.44E+00 6.95E-01 

360 1.50E-06 1.53E-06 9.80E-01 1.02E+00 

For Cm-242, type M, ICRP 30 methodology may underestimate the intakes, depending on when 

samples are taken after the intake. 

Table 3.8-7. Comparison of Cm-244 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from Urine Bioassay Data 

Radionuclide: Cm-244 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

TYPE M Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF 

1 1.77E-03 6.63E-03 2.67E-01 3.75E+00 

5 7.17E-05 5.24E-05 1.37E+00 7.30E-01 

10 4.85E-05 4.97E-05 9.75E-01 1.03E+00 

50 2.02E-05 3.46E-05 5.84E-01 1.71E+00 

100 1.48E-05 2.20E-05 6.74E-01 1.48E+00 

180 1.08E-05 1.52E-05 7.11E-01 1.41E+00 

360 6.80E-06 7.07E-06 9.62E-01 1.04E+00 

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For Cm-244, type M, ICRP 30 methodology underestimates the intakes most of the time. 

Table 3.8-8. Comparison of Sr-90 Relative Intakes (ICRP 30/ICRP 68), Assuming Intakes 

Were Calculated from Urine Bioassay Data 

Radionuclide: Sr-90 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type F Class D 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRFUrine IRF

1 6.80E-02 8.57E-02 7.93E-01 1.26E+00 

5 9.20E-03 2.45E-02 3.76E-01 2.66E+00 

10 4.10E-03 1.04E-02 3.94E-01 2.54E+00 

50 3.30E-04 1.94E-04 1.70E+00 5.88E-01 

100 9.80E-05 1.26E-04 7.78E-01 1.29E+00 

180 6.40E-05 8.40E-05 7.62E-01 1.31E+00 

200 5.00E-05 7.42E-05 6.74E-01 1.48E+00 

300 2.90E-05 5.04E-05 5.75E-01 1.74E+00 

360 2.20E-05 4.02E-05 5.47E-01 1.83E+00 

400 1.80E-05 3.71E-05 4.85E-01 2.06E+00 

For Sr-90, type F, ICRP 30 methodology underestimates the intakes for most of the times that 

samples are taken. 

Radionuclide: Sr-90 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type S Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 8.10E-04 1.34E-03 6.04E-01 1.65E+00 

5 1.30E-04 4.22E-04 3.08E-01 3.25E+00 

10 6.10E-05 1.87E-04 3.26E-01 3.07E+00 

50 8.70E-06 1.62E-05 5.37E-01 1.86E+00 

100 4.40E-06 1.55E-05 2.84E-01 3.52E+00 

180 3.40E-06 1.51E-05 2.25E-01 4.44E+00 

200 3.00E-06 1.50E-05 2.00E-01 5.00E+00 

300 2.40E-06 1.48E-05 1.62E-01 6.17E+00 

360 2.20E-06 4.65E-06 4.73E-01 2.11E+00 

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For Sr-90, type S, ICRP 30 methodology underestimates the intakes. 

Table 3.8-9. Comparison of Co-60 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from In Vivo Bioassay Data (Whole Body Counting) 

Radionuclide: Co-60 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intakeWB IRF WB IRF 

1 4.90E-01 5.66E-01 8.66E-01 1.16E+00 

5 9.10E-02 2.06E-01 4.42E-01 2.26E+00 

10 7.20E-02 1.63E-01 4.42E-01 2.26E+00 

50 4.40E-02 9.78E-02 4.50E-01 2.22E+00 

100 3.10E-02 5.77E-02 5.37E-01 1.86E+00 

180 2.30E-02 3.46E-02 6.65E-01 1.50E+00 

200 1.90E-02 2.44E-02 7.79E-01 1.28E+00 

300 1.30E-02 1.40E-02 9.29E-01 1.08E+00 

360 1.06E-02 1.15E-02 9.22E-01 1.08E+00 

For Co-60, type M, ICRP 30 methodology underestimates the intakes. 

Table 3.8-10. Comparison of Cs-137 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from In Vivo Bioassay Data (Whole Body Counting) 

Radionuclide: Cs-137 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type F Type D 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time after intake (d) Tot. Body Tot. Body 

1 6.00E-01 6.22E-01 9.65E-01 1.04E+00 

5 4.30E-01 5.72E-01 7.52E-01 1.33E+00 

10 4.10E-01 5.43E-01 7.55E-01 1.32E+00 

50 3.20E-01 4.19E-01 7.64E-01 1.31E+00 

100 2.30E-01 3.05E-01 7.54E-01 1.33E+00 

200 1.20E-01 1.61E-01 7.45E-01 1.34E+00 

300 6.40E-02 8.55E-02 7.49E-01 1.34E+00 

The intakes from Cs-137 are underestimated using ICRP 30 methodology. 

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Table 3.8-11. Comparison of Ce-144 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from In Vivo Bioassay Data (Whole Body Counting) 

Radionuclide: Ce-144 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF 

1 4.96E-01 5.96E-01 8.32E-01 1.20E+00 

5 9.30E-02 2.44E-01 3.81E-01 2.62E+00 

10 7.97E-02 2.06E-01 3.87E-01 2.58E+00 

50 6.19E-02 1.52E-01 4.07E-01 2.46E+00 

100 5.08E-02 1.13E-01 4.50E-01 2.22E+00 

200 3.78E-02 7.58E-02 4.99E-01 2.01E+00 

300 2.87E-02 5.60E-02 5.13E-01 1.95E+00 

400 2.20E-02 4.26E-02 5.16E-01 1.94E+00 

The intakes from Ce-144 are underestimated using ICRP 30 methodology. 

Table 3.8-12. Comparison of Cf-252 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated From Urine Data 

Radionuclide: Cf-252 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake Urine IRF Urine IRF

1 1.30E-03 3.20E-03 4.06E-01 2.46E+00 

5 1.42E-05 2.68E-05 5.30E-01 1.89E+00 

10 1.32E-05 2.54E-05 5.20E-01 1.92E+00 

50 8.43E-06 1.76E-05 4.79E-01 2.09E+00 

100 5.75E-06 1.12E-05 5.13E-01 1.95E+00 

180 3.72E-06 5.87E-06 6.34E-01 1.58E+00 

360 1.86E-06 2.55E-06 7.29E-01 1.37E+00 

The intakes from Cf-252, type M, are underestimated using ICRP 30 methodology. 

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Table 3.8-13. Comparison of Nb-95 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from In Vivo Data (Whole Body Counting) 

Radionuclide: Nb-95 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD(68) and 1.0 micron AMAD (30) 

Type M Class W 

ICRP68 ICRP 30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF 

1 4.90E-01 5.82E-01 8.42E-01 1.19E+00 

5 8.30E-02 2.11E-01 3.93E-01 2.54E+00 

10 6.10E-02 1.54E-01 3.96E-01 2.52E+00 

50 1.90E-02 4.60E-02 4.13E-01 2.42E+00 

100 5.50E-03 1.17E-02 4.70E-01 2.13E+00 

200 5.20E-04 8.79E-04 5.92E-01 1.69E+00 

300 5.10E-05 7.66E-05 6.66E-01 1.50E+00 

400 5.10E-06 7.17E-06 7.11E-01 1.41E+00 

The intakes from Nb-95, type M, are underestimated using ICRP 30 methodology. 

Table 3.8-14. Comparison of Ru-106 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from In Vivo Data (Whole Body Counting) 

Radionuclide: Ru-106 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD(30) 

Type F Class D 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF

1 5.10E-01 5.35E-01 9.53E-01 1.05E+00 

5 2.10E-01 3.47E-01 6.05E-01 1.65E+00 

10 1.70E-01 2.88E-01 5.91E-01 1.69E+00 

50 8.30E-02 1.39E-01 5.97E-01 1.67E+00 

100 5.50E-02 9.36E-02 5.87E-01 1.70E+00 

180 4.00E-02 2.90E-02 1.38E+00 7.24E-01 

200 3.60E-02 6.13E-02 5.87E-01 1.70E+00 

300 2.70E-02 4.65E-02 5.80E-01 1.72E+00 

360 2.30E-02 3.98E-02 5.78E-01 1.73E+00

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The intakes from Ru-106, type F, are underestimated most of the time using ICRP 30 

methodology. 

Radionuclide: Ru-106 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF 

1 4.90E-01 5.84E-01 8.39E-01 1.19E+00 

5 9.90E-02 2.36E-01 4.20E-01 2.38E+00 

10 8.00E-02 1.91E-01 4.20E-01 2.38E+00 

50 4.70E-02 1.09E-01 4.32E-01 2.31E+00 

100 3.10E-02 6.31E-02 4.91E-01 2.04E+00 

180 2.10E-02 1.52E-02 1.38E+00 7.24E-01 

200 1.70E-02 2.75E-02 6.18E-01 1.62E+00 

300 1.10E-02 1.64E-02 6.70E-01 1.49E+00 

360 9.00E-03 1.31E-02 6.87E-01 1.46E+00 

The intakes from Ru-106, type M, are underestimated using ICRP 30 methodology most of the 

time. 

Radionuclide: Ru-106 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type S Class Y 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF

1 4.90E-01 5.85E-01 8.38E-01 1.19E+00 

5 8.60E-02 1.98E-01 4.34E-01 2.30E+00 

10 7.10E-02 1.63E-01 4.36E-01 2.30E+00 

50 4.70E-02 1.39E-01 3.38E-01 2.96E+00 

100 3.50E-02 1.19E-01 2.95E-01 3.39E+00 

180 2.75E-02 8.69E-02 3.17E-01 3.16E+00 

200 2.50E-02 8.93E-02 2.80E-01 3.57E+00 

300 1.80E-02 6.83E-02 2.63E-01 3.80E+00 

360 1.55E-02 5.76E-02 2.69E-01 3.72E+00 

The intakes from Ru-106, type S, are underestimated using ICRP 30 methodology. 

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Table 3.8-15. Comparison of Zn-65 Relative Intakes (ICRP 30/ICRP 68), Assuming 

Intakes Were Calculated from In Vivo Data (Whole Body Counting) 

Radionuclide: Zn-65 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type S Class Y 

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF 

1 5.39E-01 6.05E-01 8.91E-01 1.12E+00 

5 2.68E-01 3.96E-01 6.77E-01 1.48E+00 

10 2.48E-01 3.66E-01 6.78E-01 1.48E+00 

50 1.80E-01 2.85E-01 6.32E-01 1.58E+00 

100 1.37E-01 2.27E-01 6.04E-01 1.66E+00 

200 8.75E-02 1.50E-01 5.83E-01 1.71E+00 

300 5.67E-02 1.00E-01 5.67E-01 1.76E+00 

400 3.69E-02 6.72E-02 5.49E-01 1.82E+00 

The intakes from Zn-65, type S, are underestimated using ICRP 30 methodology. 

Table 3.8-16. Comparison of Zr-95 Relative Intakes (ICRP 30/ICRP 68), Assuming Intakes 

Were Calculated from In Vivo Data (Whole Body Counting) 

Radionuclide: Zr-95 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type F Class D 

ICRP 68 ICRP 30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF 

1 5.40E-01 5.80E-01 9.31E-01 1.07E+00 

5 2.30E-01 3.76E-01 6.12E-01 1.64E+00 

10 1.80E-01 3.08E-01 5.85E-01 1.71E+00 

50 8.20E-02 1.40E-01 5.85E-01 1.71E+00 

100 4.70E-02 8.06E-02 5.83E-01 1.71E+00 

180 2.10E-02 3.36E-02 6.25E-01 1.60E+00 

200 1.60E-02 2.71E-02 5.91E-01 1.69E+00 

300 5.40E-03 9.09E-03 5.94E-01 1.68E+00 

400 1.80E-03 3.05E-03 5.90E-01 1.70E+00 

The intakes from Zr-95, type F, are underestimated using ICRP 30 methodology. 

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Radionuclide: Zr-95 

Intake: Inhalation 

Aerosol size: 5.0 micron AMAD (68) and 1.0 micron AMAD (30) 

Type M Class W

ICRP68 ICRP30 Intakes 30/68 IRF 30/68 

Time (d) after intake WB IRF WB IRF

1 4.90E-01 0.594 8.25E-01 1.21E+00 

5 8.50E-02 2.03E-01 4.19E-01 2.38E+00 

10 6.60E-02 1.69E-01 3.91E-01 2.56E+00 

50 3.00E-02 7.51E-02 4.00E-01 2.50E+00 

100 1.50E-02 3.24E-02 4.63E-01 2.16E+00 

200 4.30E-03 7.97E-03 5.40E-01 1.85E+00 

300 1.30E-03 2.41E-03 5.39E-01 1.86E+00 

400 4.30E-04 7.85E-04 5.48E-01 1.83E+00 

The intakes from Zr-95, type M, are underestimated using ICRP 30 methodology. 

The ICRP 30 intake retention functions were taken from NUREG/CR-4884, except for Cf-252, 

which is not listed in the document. ICRP 68 intake retention functions were calculated using 

the software AIDE, and the intake retention function for Cf was calculated using ICRP 30 

methodology. 

From these tables, it is possible to conclude that intakes calculated using ICRP 30 methodologies 

were not a “likely overestimate,” as written in page 5 of the document. Pu and Am are not 

“significantly overestimated,” as stated in page 8 of the document. In fact, using the ICRP 30 

methodology instead of the ICRP 68 biokinetic model underestimates the intakes from Zr-95, 

type M and type F; Zn-65, type S; Ru-106, type S; Nb-95, type M; Cf-252, type M; Ce-144; Cs137; Co-60, type M; Sr-90, type S; U, type S; U, types F and M, for all reasonable times of 

collecting samples after an intake occurred; Pu, types M and S; and Am, type S. For Ru-106, 

types M and F, ICRP 30 methods underestimate the intake for most sampling times following 

intake. For Am, type M, ICRP 30 methodology may underestimate the intakes, depending on 

when samples are taken after intake. 

Since the intakes listed in Tables 1 and 2 do not give additional information on the calculation of 

the largest intakes assigned at SRS, and since the ratio from ICRP 30 calculated intakes to the 

ones calculated using ICRP 68 methodology depends on the time samples were taken, the use of 

this document as a reference for dose reconstruction must be considered inappropriate, at least 

until intakes are recalculated using the recommended ICRP methodologies recommended in 42 

CFR Part 82. 

(3) Use of surrogate nuclides (pages 9 and 10, ORAUT-OTIB-0001): The calculation of 

annual organ doses from hypothetical intakes for Table 2 nuclides are not clear. The use 

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of surrogate radionuclide intake is not well explained, including the use of type F 

nuclides as a surrogate for types M and S. 

The methods used to calculate organ doses described on pages 9 and 10 are not explained 

and are not claimant favorable. For example: 

— For the intakes described in Table 12, the 50y committed equivalent dose to the 

adrenals due to the sum of Sr-90, type F; Ru-106, type M; Ce-144, type M; and Nb95, type M is 7.07E-5 Sv. 

— For the intakes described in Table 12, the 50y committed equivalent dose to the 

adrenals due to the sum of Sr-90, type F; Ru-106, type F; Ce-144, type M; and Nb95, type M is 1.41E-4 Sv. 

— Using the procedure described in the TIB, the 50y committed equivalent dose to the 

adrenals due to all four nuclides is 3.19E-5 Sv. 

Thus, the example dose to the adrenals, using the correct ICRP dosimetric and biokinetic 

models for each nuclide, is higher than the dose using the procedure described in the 

document. 

(4) Assignment of tritium dose (pages 10 and 11, ORAUT-OTIB-0001): Doses due to OBT 

are not included in the procedures for calculating tritium doses: “Organically bound 

tritium (OBT) historically has been ignored for occupational dose assessment . . .”

The effective dose per Bq intake of OBT is more than twice the effective dose per Bq 

intake of HTO. The urinary excretion rate is almost the same after the second day of 

exposure. One day after exposure, the activity concentration in urinary excretion for 

OBT is 57% of the HTO activity concentration in urine. As a consequence, for the same 

amount excreted in urine, the intake of OBT would be 77% higher in the first day than 

the one for HTO. Thus, the effective dose calculated for each Bq excreted in urine is four 

times higher because it is due to OBT instead of HTO. The procedure should provide 

methods for deriving doses for OBT and the types of operations where OBT may be an 

issue.

3.9 ORAUT-OTIB-0003 — SAVANNAH RIVER SITE TRITIUM DOSE 

ASSIGNMENT

The review of ORAUT-OTIB-0003, Savannah River Site Tritium Dose Assignment, Rev. 00, dated 

October 3, 2003, was prepared by Joyce Lipsztein, PhD, and approved by John Mauro, PhD, 

CHP, on January 11, 2005. 

3.9.1 Purpose of Procedure 

The stated purpose of this TIB is to provide “guidance on the assignment of tritium or H-3 dose 

for dose reconstructions at the Savannah River Site (SRS), and is based on information provided 

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in the Technical Basis Document for the Savannah River Site to be used for EEOICPA Dose 

Reconstructions, ORAUT-TKBS-0003 Rev. 01.”

3.9.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0003 is summarized in Table 3.9-1 below. Table 3.9-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

3.9.3 General Comments 

As stated in Section 3.0 of the TIB, “Flowcharts that provide the logic for the assignment of 

tritium dose are presented in Figures 1 and 2. These apply to dose reconstructions at the SRS for 

the periods of 1953 through 1983, and 1984 to the present, respectively. Decision criteria are 

provided to identify when it is appropriate to: use tritium doses as recorded in individual case 

records; assign tritium doses based on the potential missed dose (NIOSH 2002); or to evaluate 

the dose using recorded tritium bioassay results and internal dosimetry models.” 

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Table 3.9-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0003 Effective Date: 10/03/2003 

Document Title: Savannah River Site Tritium Dose Assignment

Auditor: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 2 See Review 

Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 4 

It references other 

related NIOSH and 

ORAUT document, 

but this is not a 

problem. 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 5 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is 

 it free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays 5 

3.2.3 Missing dosimetry data 5 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 5 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 5 For HTO 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5 For HTO 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5 For HTO 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.9.4 Review Comments 

Review Objectives 1.1 to 1.5

Objectives 1.1 to 1.5 were designed to determine if the procedure is written in a style that is clear 

and unambiguous. SC&A’s review has identified that the flowcharts are not self- explanatory. 

This document describes an approach to assign the missed dose for H-3. ORAUT-OTIB-0001 

describes another approach. It is difficult to distinguish the cases for which the dose 

reconstructor should use ORAUT-OTIB-0003 or ORAUT-OTIB-0001.

Review Objectives 5.1, 5.2, and 5.3

Objectives 5.1, 5.2, and 5.3 were designed to assess whether procedure decisions are claimant 

favorable in instances of missing data, unknown parameters affecting dose estimates, and in 

which the claimant was not monitored. Doses due to OBT are not included in the procedures for 

calculating tritium doses.

3.9.5 Technical Issues 

The document assumes that workers were only exposed to HTO compounds. It does not mention 

exposures to OBT or metal tritides. The effective dose per Bq intake of OBT is more than twice 

the effective dose per Bq intake of HTO. The urinary excretion rate is almost the same after the 

second day of exposure. One day after exposure, the activity concentration in urinary excretion 

for OBT is 57% of the HTO activity concentration in urine. As a consequence, for the same 

amount excreted in urine, the intake of OBT would be 77% higher than the one for HTO ion the 

first day. Thus, the effective dose calculated for each Bq excreted in urine is four times higher 

since it is due to OBT instead of HTO.

3.10 ORAUT-OTIB-0004 — TECHNICAL BASIS FOR ESTIMATING THE 

MAXIMUM PLAUSIBLE DOSE TO WORKERS AT ATOMIC WEAPONS 

EMPLOYER FACILITIES 

The review of ORAUT-OTIB-0004, Technical Basis for Estimating the Maximum Plausible 

Dose to Workers at Atomic Weapons Employer Facilities, Rev. 02, dated December 4, 2003, was 

prepared by Joyce Lipsztein, PhD, and approved by John Mauro, PhD, CHP, on January 11, 

2005. 

3.10.1 Purpose of Procedure 

The purpose of this document is to provide guidance for estimating the maximum plausible dose 

to workers at AWEs. There were approximately 109 AWE facilities that handled only natural 

uranium in support of the atomic weapons program. The processes employed at these facilities 

included reduction, recasting, rolling, machining, and extruding of uranium; fuel element 

fabrication; scrap recovery; and recovery of uranium from phosphoric acid. 

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This document describes an efficient process that may be used to expedite the processing of 

claims requiring dose reconstruction under EEOICPA. The exposure matrix in this document is 

designed for estimating the maximum plausible annual dose in all organs with the exception of 

the lung, skin, breast, eye, and testes, except when the testes dose is used as an analog for 

the prostate. 

3.10.2 Review Protocol 

SC&A’s evaluation of ORAUT-OTIB-0004 is summarized in Table 3.10-1 below. Table 3.10-1 

is a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

3.10.3 General Comments 

As noted above, this procedure excludes the lung and several surficial tissues from 

consideration. Its chief purpose is to expedite the processing of AWE claims that may involve 

various metabolic cancers with POCs that are unlikely to be compensable even under 

assumptions of high uranium intakes and conservative biokinetic mode parameters. 

Demonstration of noncompensability under worst-case (or highly conservative) assumptions is 

efficient, since it reduces the effort that would normally be required for a more realistic dose 

reconstruction. This approach to efficiency is also encouraged under 42 CFR 82.10(k)(2). 

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Table 3.10-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-OTIB-0004 Effective Date: 12/04/2003 

Document Title: Technical Basis for Estimating the Maximum Plausible Dose to Workers at Atomic 

Weapons Employer Facilities 

Reviewer: Joyce Lipzstein 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 3 See Review Comments 

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

2 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

2 See Review 

Comments 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for identifying 

a potentially high probability of causation as part of an initial 

dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity, and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

3.2 Assess whether the procedure adequately addresses generic as 

well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 2 See Review Comments 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3 See Review Comments 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 2 See Review Comments 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal/lognormal)? 5 Constant Distribution

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can reasonably 

be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 2 See Review 

Comments 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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3.10.4 Review Comments 

Review Objectives 1.1 to 1.5

Objectives 1.1 to 1.5 were designed to determine the degree to which the procedure supports a 

process that is expeditious and timely for dose reconstruction. 

SC&A’s review has identified that, in several sections, the writing style is not clear. For 

example, the procedure is not explicit on how to add ingestion and inhalation doses. 

The procedure is not complete in terms of required data. The adopted assumptions for maximum 

levels of exposure were derived based on data not provided in the document. 

The procedure is not consistent with all others that are part of the hierarchy employed by NIOSH 

for dose reconstruction. It is not consistent with the procedures used in ORAUT-OTIB-0001, 

ORAUT-OTIB-0002, and ORAUT-OTIB-0005. 

Review Objective 1.4

Table 5 of this TIB identifies annual organ doses due to the assumed annual diagnostic chest xray. These derived doses are high and inconsistent. Thus, for example, the lung and liver 

doses/examination are given as 133 mrem and 101 mrem, respectively, which is not consistent 

with data contained in ORAUT-OTIB-0006. 

A minor inconsistency also exists with respect to statements contained in OCAS-PER-002, Error 

in surrogate organ assignment resulting in an underestimate of x-ray dose in SRS dose 

reconstruction. As previously noted in SC&A’s review, Section 1.0 of OCAS-PER-002 states, 

“For organs not directly listed in ICRP 34, surrogate organs based on anatomical location are 

assigned for calculation of doses from collimated x-ray examinations. . . . the choice of surrogate 

organ for the liver, gall bladder, and spleen. . . . is the lung.” [Emphasis added.] 

For purpose of consistency with OCAS-PER-002, this TIB should have identified a maximum 

liver dose that was equal to the lung dose. It should be noted that SC&A fully recognizes the 

small difference in dose and its unlikely impact on POC values. 

Review Objectives 5.1, 5.2, and 5.3

Objectives 5.1, 5.2, and 5.3 were designed to assess whether procedure decisions are claimant 

favorable in instances of missing data, unknown parameters affecting dose estimates, and in 

which the claimant was not monitored. 

The adopted assumptions for maximum levels of exposure were derived based on data not 

provided in the document. Thus, it is not possible to judge if the exposure data is claimant 

favorable. 

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The procedure is not claimant favorable in instances of unknown parameters affecting dose 

estimates. The breathing rate used to evaluate the intake is not claimant favorable. 

The procedure may be not claimant favorable in instances where the claimant was not monitored. 

The adopted assumptions for maximum levels of exposure were derived based on data not 

provided in the document. Thus, it is not possible to judge if the exposure data is claimant 

favorable. 

Review Objective 5.2

For estimating exposure to residual contamination, ORAUT-OTIB-0004 assumes that 

normal/operational removal mechanisms reduce residual contamination at 1% per day. This 

value was not based on empirical study data and appears to be nonconservative/unrealistic. 

Studies pertaining to postoperational residual contamination at commercial nuclear power plant 

facilities could be used as surrogate data for a more defensible value. 

Review Objective 7.2

It is difficult to judge the significance of the procedure with respect to the final dose estimate and 

its POC due to an inadequate description of the bases for the guidelines. 

The adopted assumptions for maximum levels of exposure were derived from data not provided 

in the document. The rate and amount of air breathed through the nose versus the mouth should 

be better estimated. These details should be evaluated based on the workers’ level of effort, 

according to the job and workplace temperature and humidity for each installation. 

3.10.5 Technical Issues 

 

(1) Page 2 of 13, Section 1.0: The document states the following: 

The purpose of this document is to provide guidance for estimating the 

maximum plausible dose to workers at Atomic Weapons Employers (AWEs). 

The exposure matrix in this document is designed for estimating the maximum 

plausible annual dose in all organs with the exception of lung, skin, breast, 

eye, and testes except when the testes dose is used as an analog for the 

prostate. Because the current ICRP model does not calculate a dose to the 

prostate, the dose to the testes is reconstructed and used to determine the 

probability of causation for prostate cancer. This is considered a claimantfavorable approach. 

The use of the testes as an analog for the prostate is only recommended for external 

exposure in ORAUT-OTIB-0005. 

(2) Page 3 of 13, Section 2.0: The choice of 100 as the maximum allowable concentration 

(MAC) is arbitrary. Of the facilities cited to justify the choice of 100 MAC, the Vulcan 

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Crucible (Aliquippa Forge) is the only AWE facility listed in the appendix and referenced 

in the text (second paragraph). 

...surveys by the NYOO indicated that out of 648 exposed workers at these 

plants, 9% were exposed to uranium air concentrations greater than 125MAC 

(> 6250 g/m3), 9% were exposed at 25-125 MAC (1250-6250 g/m3), and 

82% were exposed to less than 25 MAC (< 1250 g/m3). . . . 

Vulcan Crucible (Aliquippa Forge) was a steel mill that contracted with the 

AEC to roll uranium billets into rods on a part-time basis from 1948 to 1949. 

The contract (AEC Contract No. AT-(30-1)-407) stated that the plant was to 

arrange to spend ‘at least two consecutive weeks out of every five consecutive 

weeks’ performing the AEC contract work. Four of the most exposed workers 

in the 1949 study were from this plant. 

Thus, without other information, such as the level of exposure at Vulcan Crucible 

(Aliquippa Forge), the choice of 100 MAC cannot necessarily be considered 

claimant favorable. 

(3) Page 4 of 13, item 2.0: The choice of 1.2 m3/h may not be justified. This breathing rate 

is characteristic of the ICRP-classified “light worker” (time budget distributed between 

5.5h light exercise and 2.5h sitting). The rate and amount of air breathed through the 

nose versus the mouth should be better estimated. These details should be evaluated for 

the workers’ level of effort, according to the job and workplace temperature and humidity 

for each installation. 

(4) Page 5 of 13: The ingestion section should be updated according to OCAS-TIB-009, 

Estimation of Ingestion Intakes. 

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4.0 INTERACTIVE RADIOEPIDEMIOLOGICAL PROGRAM (IREP) 

REQUIREMENTS/ISSUES 

4.1 OCAS-TIB-001 ― IREP ISSUES 

The review of OCAS-TIB-001, IREP Issues, Rev. 0, dated March 4, 2003, was prepared by 

Joyce Lipsztein, PhD, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

4.1.1 Purpose of Procedure 

The stated purpose of this Technical Information Bulletin (TIB) is to provide “clarification for 

three issues related to using the Interactive Radioepidemiological Program (IREP).” 

4.1.2 Review Protocol 

Our evaluation of OCAS-TIB-001, IREP Issues, is summarized in Table 4.1-1 below. Table 

4.1-1 is a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 

4.1.3 General Comments 

In this document, three individual issues are discussed: 

 

 Choice of "Exposure Type" for radon

 Leukemia and thyroid latency

 Correct use of the" Should alternate cancer be run" field.

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Table 4.1-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-001 Effective Date: 03/04/2003 

Document Title: IREP Issues

Reviewer: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

5 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? 5 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 5 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

___________________________ 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

4.1.4 Review Comments 

OCAS-TIB-001 is straightforward and relates to giving specific instructions in the use of IREP. 

SC&A has no significant review comments in behalf of this document. 

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4.2 OCAS-TIB-003 ― INTERACTIVE RADIOEPIDEMIOLOGICAL PROGRAM 

REQUIREMENTS FOR MULTIPLE CANCERS 

The review of OCAS-TIB-003, Interactive Radioepidemiological Program Requirements For 

Multiple Cancers, Rev. 0, dated April 30, 2003, was prepared by Joyce Lipsztein, PhD, and 

approved by John Mauro, PhD, CHP, on January 11, 2005. 

4.2.1 Purpose of Procedure 

The stated purpose of this TIB is to provide “. . . a summary of issues associated with multiple 

primary cancers, and cases in which no primary cancer is provided, including updated dose 

reconstruction (DR) requirements for various claim scenarios.” 

4.2.2 Review Protocol 

Our evaluation of OCAS-TIB-003, Interactive Radioepidemiological Program Requirements 

For Multiple Cancers, is summarized in Table 4.2-1 below. Table 4.2-1 is a checklist containing 

objectives that SC&A developed under the first phase of Task 3 to evaluate whether the 

procedure adequately supports the dose reconstruction process, as described in the introduction 

to this report. 

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Table 4.2-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-003 Effective Date: 04/30/2003 

Document Title: IREP Requirements for Multiple Cancers

Auditor: Joyce Lipsztein

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

5 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? 5 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5* 

Comments 

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? 5 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5 

___________________________ 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

4.2.3 Review Comments 

OCAS-TIB-003 is straightforward and relates to giving specific instructions in the use of IREP 

for cases involving multiple primary cancers. SC&A has no significant review comments in 

behalf of this document. 

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4.3 OCAS-TIB-005 ― DOSE RECONSTRUCTION CANCER DATA 

REQUIREMENTS 

The review of OCAS-TIB-005, Dose Reconstruction Cancer Data Requirements, Rev. 0, dated 

September 5, 2003, was prepared by Joyce Lipsztein, PhD, and U. Hans Behling, PhD, MPH, 

and approved by John Mauro, PhD, CHP, on January 11, 2005. 

4.3.1 Purpose of Procedure 

The purpose of this TIB is to define “. . . the NIOSH OCAS Claims Tracking System (NOCTS) 

requirements and organizational business rules governing the cancer data required to perform 

dose reconstructions and conduct IREP runs at OCAS and ORAU. Cancer data requirements 

will ultimately apply to data management (i.e., entered and quality assured) in NOCTS, as well 

as general data requirements necessary to perform dose reconstructions and run IREP.” 

4.3.2 Review Protocol 

Our evaluation of OCAS-TIB-005, Dose Reconstruction Cancer Data Requirements, is 

summarized in Table 4.3-1 below. Table 4.3-1 is a checklist containing objectives that SC&A 

developed under the first phase of Task 3 to evaluate whether the procedure adequately supports 

the dose reconstruction process, as described in the introduction to this report. 

4.3.3 General Comments 

In this document, information is given on Acceptable Dose Reconstruction Case Scenarios, 

Unacceptable Dose Reconstruction Case Scenarios, NOCTS Cancer Data System Requirements, 

and Dose Reconstruction Cancer Data Requirements. These cancer data requirements are 

identified in Sections 2 and 3 of the TIB. However, DOE has lead responsibility to identify and 

code cancers, which are only then forwarded to OCAS for dose reconstruction. Responsibilities 

assigned to OCAS (and possibly ORAU and its contractors) by this TIB are limited to notifying 

the DOE in instances of an obvious error that requires resolution by the DOL, as stated in 

Section 1.1 of the TIB: 

Note: DOE has lead responsibility to identify and code cancers for purposes of 

adjudicating claims. Because of this, cancer data provided by DOE should not be 

reinterpreted by reviewing documents provided by DOL to OCAS upon receipt of 

the claim or claim supplement. Example documents include pathology reports or 

EE medical records. If an obvious error is detected (e.g., a cancer listed as 

secondary with a primary cancer code), these questions are to be forwarded to 

the appropriate OCAS PHA for DOL inquire and resolution. 

Because this TIB does not directly affect the dose reconstruction process, it has only limited 

relevance to SC&A’s procedure review objectives. 
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Table 4.3-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-005, Rev. 0 Effective Date: 09/05/2003 

Document Title: Dose Reconstruction Cancer Data Requirements 

Reviewer: Joyce Lipsztein/U. Hans Behling 

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 5 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

5 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for identifying 

a potentially high probability of causation as part of an initial 

dose evaluation of a claim? 

NA 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? NA 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? NA 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? NA 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? NA 

3.1.4 Is the interview process sensitive to the claimant? NA 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). NA indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? NA 

3.2 Assess whether the procedure adequately addresses generic as 

well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) NA 

3.2.2 In vivo/In vitro bioassays NA 

3.2.3 Missing dosimetry data NA 

3.2.4 Unmonitored periods of exposure NA 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? NA 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? NA 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing 

data? NA 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? NA 

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? NA 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal/lognormal)? NA 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? NA 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can reasonably 

be accounted for by the dose reconstructor? NA 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? NA 

4.3.4 Review Comments 

None.

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). NA indicates not applicable. 

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5.0 TELEPHONE INTERVIEWS 

5.1 ORAUT-PROC-0004 ― SCHEDULING TELEPHONE INTERVIEWS, 

ORAUT-PROC-0005 ― PERFORMING TELEPHONE INTERVIEWS, AND 

ORAUT-PROC-0017 ― REVIEWING TELEPHONE INTERVIEWS 

The review of the following interview procedures and associated documents was prepared by 

Arjun Makhijani, PhD, and Kathryn Robertson-DeMers, CHP, and approved by John Mauro, 

PhD, CHP, on January 11, 2005: (1) ORAUT-PROC-0004, Scheduling Telephone Interviews,

Rev. 00, November 5, 2003, (2) ORAU-PROC-0005, Performing Telephone Interviews, Rev. 00, 

November 6, 2003, (3) ORAUT-PROC-0017, Reviewing Telephone Interviews, Rev. 00, 

November 6, 2003, and (4) OMB-0920-0530, CATI Interview Forms, (Version 1 — employee 

version, and Version 2 — family member version), May 31, 2004. 

5.1.1 Background Information: Interview Objectives 

 

Title 42, Section 82.10(c), of the Code of Federal Regulations (42 CFR 82.10(c)) states the 

following requirements and objectives for the claimant interview process: 

NIOSH will interview the claimant. The interview may be conducted in one or 

more sessions. The purpose of the interview is to: 

(1) Explain the dose reconstruction process; 

(2) Confirm elements of the employment history transmitted to NIOSH by 

DOL; 

(3) Identify any relevant information on employment history that may have 

been omitted; 

(4) Confirm or supplement monitoring information included in the initial 

radiation exposure record; 

(5) Develop detailed information on work tasks, production processes, 

radiologic protection and monitoring practices, and incidents that may 

have resulted in undocumented radiation exposures, as necessary; 

(6) Identify co-workers and other witnesses with information relevant to the 

radiation exposure of the covered worker to supplement or confirm 

information on work experiences, as necessary.

The interview process allows claimants the opportunity to provide the National Institute for 

Occupational Safety and Health (NIOSH) with additional information relating to individual job 

responsibilities, the potential for exposure to various radionuclides and materials, the frequency 

of dosimeter changes, the methods and frequency of various types of bioassay monitoring of 

internal burdens of radionuclides, the type of workplace monitoring, such as air sampling, survey 

and area access controls, and involvement in incidents or unusual events. By design, the 

interview process is, therefore, an integral part of the dose reconstruction process. 

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To ensure completeness of the dose reconstruction process, NIOSH must also conduct a closing 

interview after a draft dose reconstruction has been reviewed by the claimant. The closing 

interview (which may be in one or more sessions) provides the claimant an opportunity to ask 

questions about the dose reconstruction and a final opportunity to provide additional information 

that may be pertinent to the claim. Key elements of the closing interview are specified in 42 

CFR 82.10(l) and (m): 

(l) After providing the claimant with a copy of a draft of the dose reconstruction 

report to be provided to DOL, NIOSH will conduct a closing interview with the 

claimant to review the dose reconstruction results and the basis upon which the 

results were calculated. This will be the final opportunity during the dose 

reconstruction process for the claimant to provide additional relevant 

information that may affect the dose reconstruction. The closing interview may 

require multiple sessions, if the claimant requires time to obtain and provide 

additional information, and to allow NIOSH time to integrate the new 

information into a new draft of the dose reconstruction report. NIOSH will 

determine whether to grant requests for time to provide additional information, 

based on whether the requests are reasonable and the claimant is actively 

seeking the information specified. 

(m) Subject to any additional information provided by the claimant and revision 

of the draft dose reconstruction report under § 82.10(l), the claimant is required 

to return form OCAS-1 to NIOSH, certifying that the claimant has completed 

providing information and that the record for dose reconstruction should be 

closed. Upon receipt of the form, NIOSH will forward a final dose 

reconstruction report to DOL, DOE, and to the claimant. 

5.1.2 Content and Organization 

This portion of the Task 3 report is limited to the review of procedures pertaining to the 

interview of a worker claimant or a family member claimant. This review is represented below 

in Sections 5.2 through 5.8, which are followed by three attachments: 

 Section 5.2 provides a brief description of the procedures under evaluation 

 Section 5.3 identifies those elements of the procedure that SC&A considers positive 

strong points 

 Section 5.4 consists of a summary review of findings (or checklist) 

 Section 5.5 provides review comments regarding CATI Forms 1 and 2 

 Section 5.6 describes significant findings pertaining to applicable procedures 

 Section 5.7 provides summary conclusions 

 Section 5.8 identifies suggestions for improvements 

 Attachment 5-1 is an interview with Denise Brock 

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 Attachment 5-2 is an interview with Ed Walker 

 Attachment 5-3 is an interview with ORAU Claimant Interview Staff 

The format of the checklist in Section 5.4 and the scoring system follows the procedures for this 

task approved by the Advisory Board. 

5.2 OVERVIEW OF PROCEDURES USED IN THE COMPUTER ASSISTED 

TELEPHONE INTERVIEW 

To comply with the objectives specified in 42 CFR 82.10(c), NIOSH developed a formal stepby-step process for conducting a telephone interview, called the Computer Assisted Telephone 

Interview (CATI). The procedures set forth in ORAUT-PROC-0004, -0005, and -0017 have the 

objective of enabling the interviewer to capture a record of the interview on a computer form 

which becomes part of the documentation used to support the reconstruction of employee doses. 

There are also other opportunities for claimants to add to or amend interview records that are part 

of these procedures. Principal among these is the closing interview. Besides its designated 

function of eliciting information from claimants for the purpose of dose reconstruction, the CATI 

is a principal means of an extended interaction between NIOSH and claimants. It is therefore an 

important element in the relationship that NIOSH establishes with the public. 

5.2.1 ORAUT-PROC-0004 — Purpose of Procedure: Scheduling Telephone Interviews 

The purpose of ORAUT-PROC-0004 is to specify the process of scheduling the interview. Each 

claimant receives a letter informing him/her that he/she will be contacted by ORAU to schedule 

an interview (NIOSH Tracking No. 54). The letter includes a copy of the interview form. 

NIOSH and Oak Ridge Associated Universities (ORAU) use two different interview forms — 

one for worker-claimants and the other for family member claimants. For the claimant, the 

interview is voluntary. Since the purpose of the CATI is to provide input into the dose 

reconstruction process, both versions of the letter encourage claimant participation and inform 

the claimant of the following: 

. . . if you choose not to be interviewed, this would hinder NIOSH in conducting 

the dose reconstruction for your claim. Choosing not to be interviewed may also 

result in a dose reconstruction that incompletely or inaccurately estimates the 

radiation dose to which the energy employee named in your claim may have been 

exposed. [EEOICPA Interview Form, page 1]

(Note: The letter and ORAUT-PROC-0004 are audited together in this report.) 

5.2.2 ORAUT-PROC-0005 — Purpose of Procedure: Performing Telephone Interviews 

The purpose of ORAUT-PROC-0005 is to specify the process of conducting the interview. This 

procedure outlines a tightly prescriptive step-by-step process for conducting the interview. This 

procedure provides for updating the CATI so that the claimant has the opportunity to correct any 

information documented during the interview or to provide additional information. NIOSH has 

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two versions of the interview form, OMB-0920-0530, Versions 1 and 2, which are used for 

employee claimants and family member claimants, respectively. 

5.2.3 ORAUT-PROC-0017 — Purpose of Procedure: Reviewing Telephone Interview 

The purpose of ORAUT-PROC-0017 is to set forth an in-house NIOSH review of the CATI. 

This review process is intended to review the technical content of the CATI and to ensure its 

completeness, as well as to allow for updating the information in the interview. 

5.2.4 Closing Interview 

In spite of the regulatory requirements of 42 CFR 82 quoted above for conducting a closing 

interview, to date, NIOSH has not published a procedure for the closing interview. In the 

interim, an internal draft procedure is being used. This draft procedure may or may not 

incorporate suggestions made in this review to connect the closing interview to the CATI 

process. NIOSH has published a flowsheet of the dose reconstruction process on its Web site 

that shows where the closing interview fits into the process (see Figure 5.2-1). This review 

addresses the closing interview to the extent that it is pertinent to the review of the existing three 

CATI procedures and forms cited above. 

5.2.5 Interviews Conducted by SC&A for this Report 

Equally relevant to this review are two independent interviews conducted by Arjun Makhijani 

with a survivor-claimant and a worker-claimant, who have had extensive experience helping 

other claimants and who are, therefore, very familiar with the interview process. These 

interviews are presented in Attachments 5-1 and 5-2. Kathryn Robertson-DeMers also 

conducted an interview with a CATI interviewer with a Claimant Interview Supervisor present. 

SC&A requested an anonymous interview with a CATI interviewer [anonymous to NIOSH and 

ORAU] in order that the CATI interviewer could express themselves freely. However, an 

anonymous interview was not possible, as the ORAU team requested a supervisor be included in 

the interview. Because of their relevance to SC&A’s review of procedures, the reader is strongly 

encouraged to carefully examine Attachments 5-1, 5-2, and 5-3. 

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Figure 5.2-1 

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5.3 STRENGTHS OF ORAUT-PROC-0004, -0005, AND -0017, LETTER (NIOSH 

TRACKING NO. 54), AND CATI FORMS 

The following strengths were noted in the three procedures, the associated letter, and the 

interview forms:1

 The logistical aspects of the scheduling process appear to be appropriately laid out 

(ORAUT-PROC-0004). For instance, a letter (NIOSH Tracking No. 54) is sent to the 

claimant informing him/her that an interviewer will call. The interview form is attached 

to the letter so that the claimant has an opportunity to review it. 

 The scheduling and followup processes appear to be good. Privacy norms are specified 

as part of the scheduling process (ORAUT-PROC-0004). 

 There is a specified procedure for capturing the information provided and recording it in 

a computer database (ORAUT-PROC-0005 and ORAUT-PROC-0017). 

 Appropriate attention is paid to classification issues so far as enabling workers to have 

access to a face-to-face interview with a cleared interviewer (ORAUT-PROC-0005). 

 Adequate Privacy Act protections are built into the interview process. 

 Workers can contact ORAU both before and after the interview. There is a systematic 

way to record additional information and make corrections to the record that would be 

traceable. It appears possible for the well-informed worker to ensure that the information 

he/she has about working conditions, incidents, and other factors is incorporated into the 

dose record. 

 The interviewer checks demographic information of the worker prior to the interview 

(ORAUT-PROC-0005). 

 Having an interview form results in a systematic procedure for entering and updating the 

information, and provides a basis for achieving consistency in the types of information 

elicited from claimants. 

 Provision is made for the review of the data and updates that claimants may provide 

(ORAUT-PROC-0017). 

5.4 SUMMARY REVIEW FINDINGS 

SC&A’s evaluation of ORAUT-PROC-0004, ORAUT-PROC-0005, and ORAUT-PROC-0017 is 

summarized below in Tables 5.4-1, 5.4-2, and 5.4-3, respectively. The tables contain a checklist 

of objectives that SC&A designed under the first phase of Task 3 to evaluate whether the 

procedure adequately supports the dose reconstruction process. 

 1

 Comments apply to all three procedures, the letter, and the CATI forms, unless otherwise specified. 

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Table 5.4-1. ORAUT-PROC-0004 Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0004; letter (Tracking No. 54) Effective Date: 11/05/2003 

Document Title: Scheduling Telephone Interviews, accompanying letter has no title 

Reviewer: Arjun Makhijani 

No. Description of Objective Rating 

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and timely for 

dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 

1.2 Is the procedure written in a manner that presents the 

data in a logical sequence? 4 

1.3 Is the procedure complete in terms of required data 

(i.e., does not reference other sources that are needed 

for additional data)? 

3 

Interview letter sent out without 

adequate dose reconstruction 

information (See Finding 2). 

1.4 Is the procedure consistent with all other procedures 

that are part of the hierarchy of procedures employed 

by NIOSH for dose reconstruction? 

4 

1.5 Is the procedure sufficiently prescriptive in order to 

minimize the need for subjective decisions and data 

interpretation? 

5 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances where a 

more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation 

as part of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low 

doses, does the procedure provide clear guidance in 

defining worst-case assumptions? 

N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures that 

resultant doses are complete and based on adequate data in instances where the POC is not 

evidently clear. 

3.1 Assess quality of data sought via interview: N/A 

3.1.1 Is scope of information sufficiently comprehensive? 

See 

Comment 

Letter lacking in essential content 

especially for family member 

claimants. Score = 4 for 

employee claimants, Score = 2 

for family member claimants.

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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No. Description of Objective Rating 

1-5*

Comments

3.1.3 Does the interview process demonstrate objectivity, 

and is it free of bias? 2 

Procedure is objective in that 

same letter is sent to all 

claimants. However, it has an 

implicit bias in the case of family 

member claimants, who likely 

need more preparation prior to 

receiving interview letter. 

3.1.4 Is the interview process sensitive to the claimant? 3 

Request for telephone interview 

without better claimant 

preparation. 

3.1.5 Does the interview process protect information as 

required under the Privacy Act? 5 

3.2 Assess whether the procedure adequately addresses 

generic as well as site-specific data pertaining to: N/A 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to 

dose reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process 

as defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the claimant. 

5.1 Is the procedure claimant favorable in instances of 

missing data? N/A 

5.2 Is the procedure claimant favorable in instances of 

unknown parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose estimates.

6.1 Does the procedure provide adequate guidance for 

selecting the types of probability distributions (i.e., 

normal, lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the 

use of random sampling in developing a final 

distribution? 

N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and process 

efficiency.

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have 

only limited significance to the final dose estimate and 

its POC? 

N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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Table 5.4-2. Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0005, OMB-0920-0530 Versions 1 and 2 Effective Date: 11/06/2003 

Document Title: Performing Telephone Interviews, and accompanying CATI forms (Versions 1 and 2) 

Reviewer: Arjun Makhijani 

No. Description of Objective Rating 

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and timely for 

dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 4 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional data)? 3 

No reference to Site 

Profile or closing 

interview. 

1.4 

Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

3 

No procedure or 

requirement for coworker 

interview or explanation if 

coworkers not 

interviewed. 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 

See 

Comment 

Procedure is better for 

employee claimants (score 

= 4) than family member 

claimants (score = 2, 

coworker interviews more 

important). 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances where a 

more detailed approach to dose reconstruction would not affect the outcome. 

2.1 

Does the procedure provide adequate guidance for identifying a 

potentially high probability of causation as part of an initial 

dose evaluation of a claim? 

2 

Interviewer not required to 

have incident list, job 

category list, familiarity 

with facility. 

2.2 

Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? 

2 Same as 2.1. 

3.0 

Assess the extent to which the procedure accounts for all potential exposures and ensures that 

resultant doses are complete and based on adequate data in instances where the POC is not 

evidently clear. 

3.1 Assess quality of data sought via interview: 4 

Data sought are relevant 

and appropriate (see row 

below). 

3.1.1 Is scope of information sufficiently comprehensive? See 

Comment 

Score = 3 for employee 

claimant, score = 2 for 

family member claimant. 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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No. Description of Objective Rating 

1-5* 

Comments 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? 2 

Interviewer not required 

to have knowledge of 

facility though some may 

have it. 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? 

See 

comment 

Score = 4 for employee 

claimant, score = 2 for 

family member claimant 

Procedure is formally 

objective but is implicitly 

biased in case of family 

member claimants due to 

deficiencies discussed 

below (e.g. no coworker 

interview requirement 

before denial). This 

deficiency is procedural 

and exists despite 

sensitivity of 

interviewers to claimants 

at a personal level. 

3.1.4 Is the interview process sensitive to the claimant? 3 

Interviewers are trained 

to be sensitive but 

procedure does not 

require facility 

knowledge. This can 

produce apprehension 

that procedure does not 

address. 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? 5 

3.2 Assess whether the procedure adequately addresses generic as 

well as site-specific data pertaining to: 3 

Procedure does not 

require interviewer 

training to elicit sitespecific data. 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) 4 

3.2.2 In vivo/In vitro bioassays 3 In vivo question missing 

3.2.3 Missing dosimetry data 2 Interview contains many 

gaps (see Section 5). 

3.2.4 Unmonitored periods of exposure 2 Interview contains many 

gaps (see Section 5). 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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No. Description of Objective Rating 

1-5* 

Comments 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? 

See 

Comment 

Procedure does not 

provide for explanation if 

information is not used; 

Score = 3 for employee 

claimant, score = 2 for 

family member claimant 

due to coworker 

interview issue. 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 4 

DOE file not required to 

be with interviewer 

during interview. 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the claimant. 

5.1 Is the procedure claimant favorable in instances of missing 

data? 

See 

comment 

Score = 4 for employee 

claimant, score = 2 for 

family member claimant 

Procedure is not claimant 

favorable for family 

member claimants in the 

absence of preparation 

and requirement for 

coworker interview or 

detailed explanation of 

failure to interview. 

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 

See 

comment 

Score = 2 for employee 

claimant, score = 1 for 

family member claimant 

Interviewer training 

appears to be insufficient, 

at least in some cases. 

CATI has many gaps. 

5.3 Is the procedure claimant favorable in instances where claimant 

was not monitored? 

See 

comment 

Score = 3 for employee 

claimant, score = 1 for 

family member claimant; 

see 5.2 comment. No 

coworker interview 

requirement or 

explanation. 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose estimates. 

6.1 Does the procedure provide adequate guidance for selecting the 

types of probability distributions (i.e., normal, lognormal)? N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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No. Description of Objective Rating 

1-5* 

Comments 

7.0 Assess procedure for striking a balance between the need for technical precision and process 

efficiency. 

7.1 Does the procedure require levels of detail that can reasonably be 

accounted for by the dose reconstructor? 

See 

Comments 

Some aspects elicit 

detail while others do 

not; Score = 3 for 

employee claimant, 

score = 2 for family 

member claimant. 

7.2 Does the procedure avoid levels of detail that have only limited 

significance to the final dose estimate and its POC? 5 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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Table 5.4-3. ORAUT-PROC-0017 ― Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0017 Effective Date: 11/06/2003 

Document Title: Reviewing Telephone Interviews 

Reviewer: Arjun Makhijani 

No. Description of Objective Rating 

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and timely for 

dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 2 

Definitions and scope of key terms 

“completeness” and “technical 

content” not given. 

1.2 Is the procedure written in a manner that presents the data 

in a logical sequence? N/A 

1.3 Is the procedure complete in terms of required data (i.e., 

does not reference other sources that are needed for 

additional data)? 

2 

No reference to Site Profile or 

closing interview, no reference to 

dose file of claimant. 

1.4 Is the procedure consistent with all other procedures that 

are part of the hierarchy of procedures employed by 

NIOSH for dose reconstruction? 

3 

No explicit connection to review 

of information in closing 

interview is provided. 

1.5 Is the procedure sufficiently prescriptive in order to 

minimize the need for subjective decisions and data 

interpretation? 1 

No definition of key terms 

“completeness” and “technical 

content.” This can introduce 

arbitrariness and inconsistency. 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances where a 

more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as 

part of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low 

doses, does the procedure provide clear guidance in 

defining worst-case assumptions? 

N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures that 

resultant doses are complete and based on adequate data in instances where the POC is not 

evidently clear. 

3.1 Assess quality of data sought via interview: 3 Reviewer qualifications are not 

specified in the procedure; 

reviewer not required to review 

claimant dose file; coworker 

interviews or explanations for not 

interviewing not required and 

therefore not reviewed. 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 

 2=Borderline Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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No. Description of Objective Rating 

1-5* 

Comments 

3.1.3 Does the interview process demonstrate objectivity and 

 is it free of bias? 

2 Process is implicitly biased 

against family member claimants 

because the standard of 

completeness is implicitly lower. 

This is largely because no 

specifications relate to coworker 

interviews, and there is no 

definition of “completeness” or 

“technical content.” A CATI 

review process that approaches all 

CATIs without these definitions or 

coworker interviews does not 

recognize greater gaps likely to be 

present in family member 

claimant interviews. 

3.1.4 Is the interview process sensitive to the claimant? 4 Review requirement is sound but 

incomplete. 

3.1.5 Does the interview process protect information as 

 required under the Privacy Act? 5 

3.2 Assess whether the procedure adequately addresses 

generic as well as site-specific data pertaining to: 

2 

Reviewer not required to know 

Site Profile or claimant dose 

records. Basis for judging 

completeness and technical 

content of interview is not 

specified. 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to 

dose reconstruction? 1 

Procedure does not specify scope 

of terms “completeness” and 

“technical content.” 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 3 Reviewer not required to review claimant DOE file. 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the claimant. 

5.1 Is the procedure claimant favorable in instances of 

missing data? N/A 

5.2 Is the procedure claimant favorable in instances of 

unknown parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose estimates.

6.1 Does the procedure provide adequate guidance for 

selecting the types of probability distributions (i.e., 

normal, lognormal)? 

N/A 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 

 2=Borderline Unacceptable, 3=Moderate, 4=Good, 5=Excellent.

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No. Description of Objective Rating 

1-5* 

Comments 

6.2 Does the procedure give appropriate guidance in the use 

of random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and process 

efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (Always). N/A indicates not applicable. Alternative interpretation 1=Poor, 2=Borderline 

Unacceptable, 3=Moderate, 4=Good, 5=Excellent. 

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5.5 COMMENTS REGARDING CATI FORMS2

SC&A has evaluated each question identified in the CATI form for its importance in relation to 

the dose reconstruction. Some gaps were identified in the interview questions, which could 

hinder the complete elicitation of information from workers. The implications for improvement 

of the questionnaires are understood. Only the questions on which there are comments are 

shown on Tables 5.5-1 and 5.5-2 below. The other questions are acceptable in their present 

form. 

Table 5.5-1. Reviewer Comments Pertaining to CATI Form — Worker-Claimant 

(OMB-0920-0530, Version 1) 

Question 

# 

Question 

Topic 

Comment and Recommendations 

2 Work hours 

per week 

There is no question about overtime. 

5 Eight-part 

question on 

routine work 

duties 

In the early years of operations, employees may not have been told what radionuclides 

were present in their workplaces. Employees may also have only a partial idea of the 

radionuclides, since they may not be aware of decay chains or contaminants in the 

material processed. The question contains no provision for helping the employee 

remember which of the radionuclides in the list might be relevant, such as directing 

them to the Site Profile Review. 

“Radiation-generating device” is a technical and specific term and may not be 

understandable to some claimants. The question does not provide examples, such as 

portable x-ray units, electron beam welders, radiography sources, etc. 

Workers are often more familiar with the terms Radiological Work Permit (RWP) or 

Special Work Permit (SWP). Facilities also use work packages, which are not 

mentioned in the CATI form. Workers often have to sign security logs to access 

certain areas. Reference to such forms is missing even though such areas are likely to 

have radioactive material stored and under guard. 

7 Internal 

radiation dose 

This question left out in vivo analysis. There is no question regarding details about 

bioassay frequency. This is a serious gap. Employee information on monitoring 

frequency could confirm completeness of a dose record or else indicate gaps in it that 

could be crucial in the dose reconstruction process. 

8 Copies of 

dosimeter and 

bioassay 

records 

The question does not include annual worker radiation reports. 

9 Routine 

frisking 

survey 

Incomplete question, since a Radiological Control Technician is responsible for the 

frisking at some facilities. Inadequate followup to a yes answer. For instance, there is 

no question asking whether the claimant ever had items of clothing or shoes 

confiscated due to contamination discovered during a frisking. 

 2

 This section was initially drafted by and prepared in collaboration with Kathryn Robertson-DeMers, CHP. 

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Question 

# 

Question 

Topic 

Comment and Recommendations 

10 Area rad 

monitoring 

Merge questions 10 and 11 to ask what types of workplace radiological measurements 

were taken. It does not provide a list asking yes or no questions on job-specific air 

samples, lapel air samples, general area air samples, environmental air samples, job 

coverage, contamination surveys, and radiation surveys. Also, the worker is not asked 

about the presence of continuous air monitors and area radiation monitors. These are 

an indication of high potential airborne concentrations and high radiation levels in the 

area. 

11 Rad surveys No details are elicited except for radon at certain facilities. See questions 10 and 12. 

12 Radon 

monitoring 

Technically, all air samples measure ambient radon and thoron daughters. When 

counting air samples, an immediate count and a decayed count are performed. The 

immediate count includes contributions from short-lived radon and thoron daughters. 

The decay count (several days later) represents the air concentrations of the source 

term of interest (e.g., plutonium, strontium, cesium). The question does not ask about 

unapproved practices that could lead to high radon exposure: This may be relevant for 

some sites like Fernald and Mallinckrodt Chemical Works. 

13 Was worker 

ever restricted 

from job? 

There is no followup if worker responds affirmatively. This is a gap in eliciting 

information. This is the place where abnormal practices, such as workers not turning 

in badges when their doses are near the administrative exposure limit could be 

detected. Zero doses were sometimes recorded in such cases.3

 Hence, the 

questionnaire fails to address potentially systemic problems in dosimetry practices. 

14 Sixteen-part 

question 

about 

incidents 

This question is likely to miss critical information. For instance, no specific question 

asks if a nasal smear was taken, which would be an indication of suspected internal 

inhalation exposure. No questions ask whether real-time monitors alarmed or whether 

the employee may be aware of an incident report. 

15 Three-part 

question 

about medical 

x-rays 

No followup regarding photofluorography in case of an affirmative answer. 

18 Coworker 

information 

No commitment to inform employee whether the coworkers identified were 

interviewed and, if not, why not. 

Overall, the employee questionnaire is well structured. However, several important areas have 

gaps with the potential to significantly affect dose reconstruction and/or dose estimates. See 

below for further specific discussion. 

 3 Makhijani, Hu, and Yih, eds. 2000, page. 263. See also Attachment 5-1 to this report. 

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Table 5.5-2. Reviewer Comments Pertaining to CATI Form — Family Member Claimant 

(OMB-0920-0530, Version 2) 

Question 

# 

Question 

Topic 

Comment and Recommendations 

2 Weekly work 

hours 

There is no question about overtime. 

3 Work 

buildings or 

locations 

This information could be very useful, if available. However, it is likely to be 

difficult for the survivor claimant to remember building names or numbers, if he/she 

ever knew them. No descriptive questions solicit information about the kinds of 

activities at work or processes (PUREX) employees may have worked on or names 

of machines (e.g., Rockwell furnaces or N-reactor), or nicknames of buildings such 

as “igloos” (used for plutonium storage at Pantex). 

5 Blank There is no question 5 on the interview. 

6 External rad 

monitoring 

There is no preliminary explanation of the information sought. The question is 

therefore unlikely to elicit useful information in many cases, since many people 

outside the field are not familiar with terms such as “radiation dosimetry badge.” 

7 Internal rad 

monitoring 

This question is also unlikely to elicit useful information in most cases unless prior 

information or an explanation is provided. The letter and form do not contain any 

explanation of terms such as “biological radiation monitoring program.” Again, the 

question fails to ask about in vivo counts. 

9 Was employee 

restricted from 

job? 

Other indicators, such as change of assigned job, may more readily elicit the needed 

information. 

10 Seven-part 

question on 

incidents 

This question is too complex to elicit useful information in most cases without a 

considerable amount of preparation. For instance family member claimants are 

unlikely to know what chelation therapy is (see Attachment 5-1). There are no 

general questions, such as whether employees were sent home or received medical 

examinations due to incidents, or whether coworkers who visited the claimant 

socially ever mentioned any incidents. Evidence regarding any advice to drink lots 

of water or beer after tritium exposure is not reflected in this question. The numbers 

10.4 and 10.5 are repeated in labeling questions. This could lead to problems in 

logging information. The last two parts should be labeled 10.6 and 10.7. 

15 Coworker 

information 

This could be the most important question on the interview for many or most family 

member claimants. Coworkers and supervisors are likely to know more information 

on the exposure conditions of the covered employee than the family. Despite that 

there is no requirement to inform claimants and provide information about coworker 

interviews or reasons if coworkers not interviewed. 

See also Finding 8. 

5.5.1 Gaps in the CATI Forms 

SC&A’s review identified a number of potential gaps in the questionnaires. The first seven 

items listed below are for all claimants. The rest pertain only to the employee questionnaire. 

(Note: All 14 items would also be pertinent in modified form for the coworker questionnaire, if 

one were to be developed.) 

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(1) There is no question about food. Workers often ate in contaminated places and may 

have stored their food in contaminated places. 

(2) There is no question about overtime. 

(3) There is no question about bringing home contaminated clothing or vehicles and how 

regularly this may have occurred. 

(4) There are no questions that relate to exposure from visits to other facilities or from 

subcontractor or construction activities. These records may or may not be available in 

the home facility’s radiation exposure records. 

(5) There is no requirement to connect the closing interview to the CATI in the CATI 

procedures. 

(6) There is no commitment to respond to the claimant regarding the status of coworker 

interviews (results, if interviewed, or reasons for not interviewing, if that is the case). 

(7) There is no interview form specific to coworkers. 

(8) There is no question about control and/or handling of badges (i.e., taking badges home 

or offsite). This could affect badge readings. There is also no question that would elicit 

information about off normal or systemic data logging problems, or about what Denise 

Brock calls “inattentiveness on the part of the company” regarding data. (See Question 

13 in Table 5.5-1 and Attachment 5-1) 

(9) The questions about badges imply that a worker would have worn only one badge 

(except to some extent in that the question asks the respondent to identify the part of the 

body on which the badge was worn). Some workers regularly wore more than one 

badge, for example, when ring and/or wrist badges were used to complement the badge 

normally worn on the pocket of the coveralls. 

(10) There is no question about bioassay monitoring frequency. 

(11) The reference to monitoring of “breath” is too vague to elicit data on breathing zone air 

contamination measurements. Many workers wore portable air samplers. The 

interview form asks the question about monitoring “breath” in the context of biological 

monitoring, such as occurs after an inhalation of radionuclides. This may cause a 

worker to miss mentioning breathing zone measurements, which are not a bioassay 

measurement as such. Breathing zone data could be crucial in determining internal dose 

in some cases, especially where biological monitoring documentation is missing. 

(12) The questions may not reveal the specific ways in which the particular worker may have 

come into contact with radioactive material. For example, workers who stamped 

uranium ingots at Fernald sat on ingots. Hence, the external dose to the gonads can be 

expected to be far higher than recorded on any of the dosimeters worn by the worker. 

(13) The only question about neutrons relates to neutron-generating facilities. This omits 

neutrons from the spontaneous fission of various isotopes, notably Pu-240, which is 

important for workers at several large facilities. 

(14) There is no question about in vivo monitoring. 

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5.6 SIGNIFICANT FINDINGS PERTAINING TO PROCEDURES 

Finding 1: Procedures do not require the CATI interviewer to be knowledgeable about the 

facilities, job descriptions, or the main substantive aspects of the claim for which the 

interview is done. 

The interviewers are only required to check the demographic data for the person and to have 

looked at the application. The interviewers are not required to have knowledge about the facility 

where the worker was employed. The interviewers are not required to read the portion of the 

Site Profile relating to the description of the specific facility or facilities where the claimant 

worked before calling the claimant. Some interviewers may become knowledgeable over time, 

for example, if they happen to interview many employees from the same facility, or if they have 

worked at the facility, but facility knowledge is not a requirement of the procedures. 

Deficiencies in CATI qualifications are of even greater concern when worker claimants do not 

have knowledge of radionuclides at the facility (see below). Many atomic weapons workers 

were not told that they were working with radioactive materials. Many employees may be 

unaware of decay chains of radionuclides, like U-238 or Th-232, or about the contaminants in 

recycled uranium. They may, therefore, be insufficiently knowledgeable and at a loss as to what 

information to provide. 

Family member claimants are at an even greater disadvantage because of the lack of a 

requirement in the procedure for the interviewer to have facility knowledge. They are unlikely to 

be aware of incidents, let alone to have substantive information that can be used in dose 

reconstructions. The interview with Ed Walker (Attachment 5-2) indicates that many claimants 

may not know what a radiation dosimetry badge is. Even when claimants or family members of 

the claimants do have some knowledge, the lack of knowledge on the part of some interviewers 

may constitute a significant barrier to eliciting information that is as reliable and as complete as 

possible under the circumstances. 

Neither ORAUT-PROC-0004 nor ORAUT-PROC-0005 requires the CATI interviewer to review 

work history, plant data, plant processes, incident databases, working conditions, or any other 

matter that pertains to radiological conditions that may be relevant to the claimant’s dose 

reconstruction. SC&A’s interview with Denise Brock, family member of an AWE employee 

who has helped many family member claimants, provides examples of interviewers who were 

not familiar with radionuclide lists, indicating inadequate technical training (see Attachments 5-1 

and 5-3). This is most likely not true of all interviewers (see Attachment 5-3). The point here is 

that the procedure does not require adequate understanding of relevant technical issues and 

operational practices. Evidence suggests that at least some interviewers may not be well enough 

prepared to take additional information in the open-ended questions or to guide claimants when 

they are trying to recall information (see Attachments 5-1 and 5-2). This makes it likely that less 

information is obtained than if the interviewer were more knowledgeable. 

 

The flowsheet (see Figure 5.2-1 on page 5-5) indicates that dose records are collected in parallel 

with the interviews. Hence, no connection appears to exist between the two steps. Further, 

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ORAUT-PROC-0005 does not require interviewer knowledge of the U.S. Department of Energy 

(DOE) dose record. It only requires that the interviewer have opened the claimant file and that 

he/she is familiar with the claimant demographics. This is insufficient to elicit information in 

questions relating to dosimetry practices, administrative restrictions on workers, and incidents. 

Finding 2: Neither NIOSH’s form letter to the claimant nor ORAUT-PROC-0004 and 

ORAUT-PROC-0005 contain provisions that would prepare the interviewee for specific 

questions. This is especially true with regard to family member claimants. 

While the letter informing the claimant about the interview is correct and formal and states that 

the interview is voluntary, it also states that refusal of the interview 

. . . would hinder NIOSH in conducting the dose reconstruction for your claim. 

Choosing not to be interviewed may also result in a dose reconstruction that 

incompletely or inaccurately estimates the radiation dose to which you may have 

been exposed. 

If refusal to take part in the interview process would hinder dose reconstruction, then this 

statement clearly implies that NIOSH places a great deal of value on the answers in the dose 

reconstruction process. 

In the absence of better preparation, there is an implicit element of compulsion that is not 

consistent with the statement that the interview is voluntary (see Attachments 5-1 and 5-2). The 

words quoted above clearly set up an expectation that the goal is to estimate a complete and 

accurate dose, and that the interview is an important part of the estimation procedure. This is not 

in accord with many of the dose reconstructions as they are actually done. Specifically, the form 

letter does not describe the minimum and maximum efficiency procedures that are used in many 

dose reconstructions. This omission can lead to misunderstandings. The element of implicit 

compulsion can be reduced greatly if the interview procedures, especially ORAUT-PROC-0004, 

which sets up the interview, were accompanied by a document that briefly informs the claimants 

or their representatives about the reconstruction process (including efficiency procedures), the 

nature of the facility, and the nature of questions they will be asked. 

NIOSH has created a fact sheet for the claimant, entitled What a Claimant Should Know about 

Radiation Dose Reconstruction. However, the fact sheet does not give any indication of the 

types of procedures employed in dose reconstruction. 

 

Finding 3: The interview procedure does not take adequate account of the stressful nature 

of the interview or recognize the high stakes that many claimants feel are involved in their 

answers.

SC&A’s evaluation of responses by interviewees (i.e., claimants or their representatives) 

suggests that CATI interviewers are “kind and considerate.” In rare instances to the contrary, 

NIOSH appears to take corrective action promptly (See Attachment 5-1). This is a 

commendable and necessary component of the interview process. However, the lack of 

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preparation of claimants creates frustration that CATI interviews and interview procedures do 

not address. Even employee claimants often need preparation. For instance, Denise Brock (the 

daughter of a family member claimant and spokesperson for other claimants) recounted the 

following during SC&A’s interview with her (Attachment 5-1): 

Then a worker came to me with the questionnaire. He began to cry and he said “I 

don’t know what I am going to do with this list [of radionuclides].” I said 

“Please let me help you and see if I can find it [the information about 

radionuclides].” I made 600 copies of the answers and handed them out. 

NIOSH has no procedure to undertake comparable outreach work in the affected communities 

related to the interviews. In the absence of preparation and outreach by someone who is 

knowledgeable, the interview process may make many claimants, especially family member 

claimants, but also employee claimants, ill-at-ease and very stressed (see Attachments 5-1 and 

5-2). Unless the claimant knows the answers to rather complex questions, it will be very difficult 

for the claimant to assess the extent to which his/her specific answers help or hinder dose 

reconstruction. For instance, claimants are not in a position to assess the significance of 

providing “don’t know” as a frequent answer. 

Finding 4: Lack of procedural guidance regarding coworker interviews leaves open the 

possibility of arbitrariness, unevenness in claimant records, and inconsistency. It also 

suggests a lack of accountability to the claimant who provided the information. 

Many claimants are able to provide coworker contact information. Sometimes this may require a 

considerable effort on the part of claimants or those who are assisting them (see Attachments 5-1 

and 5-2). Such information can be especially important to family member claimants because 

coworkers may be able to provide at least some of the information on work assignments and 

hazards, as well as on incidents for which family member claimants may not have information. 

The interview form does inform claimants that coworkers may or may not be interviewed. 

42 CFR 82.10(c)(6) only requires identification and interviews of coworkers when “necessary.” 

The procedures for CATIs contain no elaboration of this term and therefore no guidelines as to 

when coworker interviews must be carried out. This can lead to arbitrariness and, therefore, to 

unevenness in the kinds of information that are collected. In addition, the procedures and forms 

related to the interviews do not require coworkers to be contacted or even to provide an 

explanation to the claimants if they are not contacted. A failure to contact coworkers after 

eliciting their identity can undermine confidence in the dose reconstruction process, especially 

for family member claimants. There are indications that this may have occurred (see 

Attachments 5-1 and 5-2). It also suggests a lack of accountability to the claimant. Only about 

one dozen interviews have been conducted so far, although NIOSH reports on their web site 

(January 10, 2005) that 6,216 of dose reconstructions have been completed (See Attachment 

5-3). 

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Finding 5: There is no formal published procedure or form for the closing interview. The 

current closing interview process has been in use for only one year (see Attachment 5-3). 

This may have resulted in unevenness and arbitrariness in the closing procedure over time 

and in the connection of the closing interview to the CATI process. 

The closing interview complements the initial telephone interview process because it gives the 

claimant a last opportunity to correct error(s) or to provide more information about the case. At 

this time, the claimant has a draft of the dose reconstruction and can ask questions about it. The 

moment also provides an opportunity for NIOSH to explain how the information in the CATI 

was used in the dose reconstruction process. 

There is no published procedure for the closing interview or even for logging the interview. 

There is no closing interview form. A review of the draft procedure was not part of this task; 

however, the closing interview is connected in a technical sense to the CATI, in that it is 

supposed to elicit information relevant to dose reconstruction. This finding is related to the 

connection between the closing interview and the CATI. 

The procedures do not require the interviewers to be trained/qualified to explain the highly 

technical contents of the claimant’s draft dose reconstruction, despite the requirements of 

42 CFR 82.10(l) that NIOSH should “review the dose reconstruction results and the basis upon 

which the results were calculated” during the closing interview. It appears that no health 

physicist is required to be available in real time. SC&A understands that one is supposed to be 

available, but anecdotal evidence indicates that the application of this internal requirement may 

be less than satisfactory in at least some cases. This is indicated by SC&A’s interview with 

Denise Brock (Attachment 5-1): 

Denise Brock: No, there is no form or letter for the closeout interview. You get 

the results of the dose reconstruction, with a form, OCAS-1. There is a lot of 

information in the dose reconstruction, including a lot of numbers indicating 

dose estimates. Then there is a phone call asking if you’ve read and understood 

the material and if you are ready to sign OCAS-1. 

The person who calls seems like the same type who did the interview. I know 

someone who refused to sign and they said a health physicist will call you. That 

was weeks ago and no one has called yet. I think she should sign because they 

will close out her case if she does not. 

SC&A’s experience in auditing individual dose reconstructions indicates that, at best, the 

standard dose reconstruction report requires a good deal of time and effort even for a wellqualified expert to review it and understand the results, especially in denial cases (where dose 

reconstructions tend to be more complex). This is especially true of the first time a case relating 

to a facility is considered, which is of course automatically true of almost every worker (except 

for family members or employee claimants like Denise Brock and Ed Walker who help other 

claimants and become very familiar with a facility). While many employee claimants would 

have the advantage of knowing the details of their own activities, the details of the draft dose 

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reconstruction are likely to be essentially incomprehensible to most employee claimants or 

family representatives. The lack of a procedural requirement (in ORAUT-PROC-0005) for a 

qualified health physicist to be available during the interview process (both in the CATI and 

closing interview) is likely to be a special problem for most family member claimants. A health 

physicist should be required to be available for consultation during the closing interview to 

explain the draft dose reconstruction. 

Finally, the fact that the closing interview in its present form has apparently been done for only 

1 year (see Attachment 5-3) raises the issue of consistency between recent CATIs and those done 

before the present draft procedure was instituted. An evaluation of various aspects of the closing 

interview including compliance with 42 CFR 82.10(l) is beyond the scope of this review. 

 

Finding 6: The procedures governing the interview contain no element connecting the 

CATI with the stated purpose of 42 CFR 82.10(l), which governs the closing interview. 

The closing interview provides the last opportunity for the claimant to provide information 

relevant to the dose reconstruction: 

(l) After providing the claimant with a copy of a draft of the dose reconstruction 

report to be provided to DOL, NIOSH will conduct a closing interview with the 

claimant... This will be the final opportunity during the dose reconstruction 

process for the claimant to provide additional relevant information that may 

affect the dose reconstruction. The closing interview may require multiple 

sessions, if the claimant requires time to obtain and provide additional 

information, and to allow NIOSH time to integrate the new information into a 

new draft of the dose reconstruction report. 

It is evident that 42 CFR 82.10(l) requires any substantive information provided to be connected 

to the dose reconstruction process. In the absence of information to the contrary, it is presumed 

that any data provided during closing interviews would be used to revise the dose reconstruction 

report as specified above. In the present context, SC&A is only commenting on the lack of a 

published procedure to connect substantive information provided by the claimant at this stage to 

the CATI process. This point is especially important in light of the example provided by Denise 

Brock, quoted above, regarding lack of responsiveness in the closing interview process. 

42 CFR 82.10(l) does not require a formal connection with the CATI process. Therefore, this 

item has been listed under the heading “findings” rather than “procedural and regulatory issues.” 

Finding 7: ORAUT-PROC-0017 does not contain any criteria or checklist for the reviewer 

of the CATI to assess the completeness or technical content of the CATI. 

ORAUT-PROC-0017 contains no definitions of the terms “completeness” and “technical 

content” or a checklist against which the NIOSH in-house reviewer might be guided in his/her 

evaluation. Many claimants may answer “don’t know” to some important questions, with a 

greater likelihood for the family member claimant. Conversely, some claimants may, in fact, be 

able to provide detailed information on these same points. This can lead to inconsistencies 

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between claimants both with regard to completeness of the data and how CATIs are evaluated by 

the in-house NIOSH reviewers. Without a checklist, one reviewer may overlook some gaps, 

while another may address them. Or there may be gaps, such as those discussed in Section 5, 

that simply remain unaddressed even though they may be important for specific claimants. 

Finding 8: The deficiencies in the procedures for the interview process are considerably 

greater for family member claimants than for employee claimants. 

The analysis and findings above lead to the conclusion that the interview procedures are much 

less likely to elicit information useful for dose reconstruction from family member claimants 

than employee claimants. Information such as job categories, special hazards, incidents, and 

examples of a lack of monitoring is more likely to be missed. The following factors contribute to 

this finding: 

 The lack of preparation for the interview regarding facility operations, job categories, etc. 

would likely hinder family member claimants more that employee claimants since the 

former are less likely to know the needed details. 

 Lack of a procedural requirement for the interviewer to have knowledge of the facility 

job descriptions and radionuclide list is likely to hinder the ability of family member 

claimants in particular to provide their input in a way that may be useful for dose 

reconstruction. 

 Due to the complexity of work assignments or, in some cases, classified work 

assignments or locations, family member claimants may not know what the employee 

did. Lack of scientific understanding and lack of sufficient communication with claimant 

in advance of the interview, and difficulty in recollection may compound these problems 

in many cases. 

 Family member claimants are unlikely to have the same type of details about incidents 

and job types as employee claimants. There is no procedure to judge if the gaps are 

important in any particular case, since the CATI reviewer has no checklist. Questions 

that might trigger relevant memories, such as if an employee’s job was changed because 

of overexposure or if he/she was sent for medical examinations for the same reason, are 

not in the family member claimant interview form. (See Table 5.2 above.) 

 NIOSH is not required to contact coworkers to provide information on behalf of the 

claimant or, if the coworker interviews are not performed, to explain why. This gap in 

the procedure especially affects family member claimants because the survivor CATI 

form is (necessarily) less detailed, and coworker data are therefore more essential to 

complement the worker data in the DOE file or the data in the Site Profile. In practice 

NIOSH vary rarely contacts coworkers (See Attachment 5-1, 5-2, and 5-3). 

 There appears to be no requirement for a health physicist to be present during the closing 

interview so that the dose reconstruction can be explained in a manner that could elicit 

additional data. This gap is also likely to disproportionately impact family member 

claimants, since they are less likely to be able to understand the draft dose reconstruction. 

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They are thus less likely to know what kinds of information might be helpful in a re-draft 

of the dose reconstruction. Employee claimants are also adversely impacted by this gap. 

These factors are also more likely to contribute to heightened anxiety for family member 

claimants, resulting in greater frustration, despite the kindness and politeness of the interviewers 

to claimants. Considerations similar to the ones above are also likely to apply to those employee 

claimants who are too ill to answer questions or who simply cannot recall most relevant details, 

necessitating family members to stand in for them. 

Finding 9: ORAUT-PROC-0017 does not require the reviewer of the CATI to be a health 

physicist. 

ORAUT-PROC-0017 requires the reviewer to examine the CATI for “completeness” and 

“technical content” (page 5). This requires a reviewer who is qualified in health physics, a need 

that is accentuated by the lack of sufficient technical training of interviewers regarding sites and 

elements of dose reconstruction. NIOSH has indicated that the “Health Physics Team” is 

responsible for the review. This indicates that the reviewer is qualified in Health Physics. This 

should be made an explicit requirement in ORAUT-PROC-0017. 

 

5.7 SUMMARY AND CONCLUSIONS 

NIOSH procedures, which provide guidance and define the scope of the interview process with 

claimants, can be regarded as functionally adequate overall when (1) the interviewee is the 

employee, (2) the employee has some understanding of radiological issues that characterize 

his/her employment period, and (3) the CATI interviewer and/or the CATI report reviewer are 

knowledgeable enough to elicit the needed information. Even so, there are important gaps in the 

interview form and process that need to be filled.. Conversely, based on the procedures under 

review, the adequacy of the interview process is adversely affected and compromised when the 

claimant is a family member or when the energy employee is not the interviewee, for example 

because the employee is too ill to be interviewed. Lastly, the potential problems in the interview 

process, as an integral part of the dose reconstruction process especially for family member 

claimants, are complicated by the current absence of a published procedure that specifically 

addresses the closing interview and the failure to involve the claim’s dose reconstructor (or a 

qualified health physicist) in the closing interview in real-time. 

The stated objectives of 42 CFR 82.10(c) regarding the interview are to: 

(1) Explain the dose reconstruction process; 

(2) Confirm elements of the employment history transmitted to NIOSH by DOL; 

(3) Identify any relevant information on employment history that may have been 

omitted; 

(4) Confirm or supplement monitoring information included in the initial 

radiation exposure record; 

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(5) Develop detailed information on work tasks, production processes, radiologic 

protection and monitoring practices, and incidents that may have resulted in 

undocumented radiation exposures, as necessary. 

(6) Identify co-workers and other witnesses with information relevant to the 

radiation exposure of the covered worker to supplement or confirm 

information on work experiences, as necessary. 

The ability of ORAUT-PROC-0004, ORAUT-PROC-0005, and the interview forms to 

consistently satisfy the objectives given in 42 CFR Part 82 is questionable with regard to items 

(1), (4), and (5) for employee claimants due to gaps in the interview forms and other issues 

detailed above. 

For family member claimants, the procedures are unlikely to satisfy any of the six objectives of 

42 CFR 82.10(c). With regard to item (6), the deficiency is largely related to the lack of a 

requirement for coworker interviews in the case of family member claimants or a careful 

technical justification if such interviews are not done, especially when claims are denied. 

The procedures reviewed here are also silent on (1) the training of interviewers, especially 

regarding facility knowledge, (2) when coworker interviews should be performed, (3) the 

participation of a health physicist at the time of the closing interview, and (4) integration of the 

closing interview with the CATI, as necessary. As summarized in Section 5.8 below, a 

substantial modification of the procedures and interview forms would be required for a 

consistent and systematic fulfillment of 42 CFR 82.10(c). 

5.8 SUGGESTIONS FOR IMPROVEMENT 

(1) Prior to the interview, claimants should be given selected information about the site that 

would prepare them for the interview. For instance, NIOSH can prepare an easy-tounderstand booklet about the site and processes for distribution to claimants. The Site 

Profiles on the NIOSH Web site are far too complex for this purpose. This booklet can 

be included with the letter informing the claimant that someone will call to schedule an 

interview. The booklet could also contain site maps and names of major facilities 

(including informal site names) for the claimant’s reference. 

(2) NIOSH should hold meetings with groups of claimants/workers before the start of dose 

reconstruction at a given site, if possible. This will allow employees and family members 

to jog one another’s memories about the operations at the facility and other details. This 

could be done as part of NIOSH’s information gathering for revisions of Site Profiles. 

SC&A recognizes, of course, that the dose reconstruction process is well underway. This 

makes it important that the procedures be revised as soon as possible to include such 

meetings and to develop the booklets discussed in recommendation (1) above. 

(3) Knowledgeable/informed third-party contacts should be appointed to serve as liaisons 

between NIOSH and claimants (see Attachments 5-1 and 5-2). This is especially 

important for family member claimants, or employee claimants who are very ill. This 

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addition to the CATI process could be connected to the NIOSH outreach program that has 

already been established. 

(4) ORAU personnel who interview claimants should be required to have an adequate 

understanding pertaining to (1) site-specific facility operations, (2) the nature of 

radionuclides/radioactivity, (3) exposure pathways, (4) radiation monitoring practices, 

and (5) fundamentals in radiation protection. Evidence indicates that present training is 

insufficient in at least some cases to elicit critical information (see Attachment 5-1, 5-2, 

and 5-3). 

(5) There should be a formal requirement in ORAUT-PROC-0017 that the reviewer who is 

responsible for evaluating/determining the completeness and technical content of the 

CATI report be a health physicist. The procedure should also have a checklist regarding 

completeness and technical content. Such a checklist would help the reviewer to identify 

potential deficiencies in the CATI report. 

(6) There should be a formal requirement for a health physicist (possibly the dose 

reconstructor) to be available during the closing interview. It is not necessary for the 

health physicist to be on the line, but to be available during the call, if needed. 

(7) NIOSH should create a form specifically for coworker interviews. The present use of the 

employee interview form (See Attachment 5-3) is problematic. For instance, it does not 

contain questions relating to the knowledge that the coworker has about the covered 

employee, or the details of the working relationships between them. NIOSH should also 

amend its CATI procedures to require information derived from coworker interviews to 

be communicated to claimants. If coworker interviews are not performed, the reasons 

should be provided to the claimant, especially in cases where the claim is denied. This 

could be done at the time of the closing interview. 

(8) The CATI procedures, ORAUT-PROC-0005 and ORAUT-PROC-0017, should be 

modified in order to ensure that any additional data provided during the closing interview 

relevant to dose reconstruction is incorporated into the CATI. 

(9) The CATI forms should be modified to fill in the gaps and amend the deficiencies 

discussed in Section 5.0 above. NIOSH should take a longer view of the Paperwork 

Reduction Act with regard to the interview process, since loss of confidence in the 

process on the part of the claimants may produce more paperwork than obtaining all of 

the relevant information in the first place. 

The adoption of these suggestions would benefit the dose reconstruction program by helping to 

improve the quality and quantity of relevant information gathered. It may also help to reduce the 

anxieties and frustration with the process felt by many claimants, especially family member 

claimants. 

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REFERENCES 

42 CFR Part 82, “Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule,” May 2, 2002. 

EEOICPA Dose Reconstruction Telephone Interview, CATI Form OMB-0920-0530, Version 1 

(employee claimant) and Version 2 (family member claimant) 

Makhijani, Hu, and Yih, eds. 2000. Arjun Makhijani, Howard Hu, and Katherine Yih, eds., 

Nuclear Wastelands: A Global Guide to Nuclear Weapons Production and Its Health and 

Environmental Effects. Cambridge, MA: MIT Press, 2000. 

NIOSH Tracking No. 54, Sample letter to claimant, addressed to John Doe, dated September 16, 

2004, with an attachment consisting of the telephone interview form in two versions – workerclaimant and survivor-claimant. 

OMB, 2004, Office of Management and Budget, CATI Interview Forms, OMB-0920-0530,

Washington, DC. 

 

ORAUT-PROC-0005, Performing Telephone Interviews, Rev. 00, November 6, 2003. 

ORAUT-PROC-0017, Reviewing Telephone Interviews, Rev. 00, November 6, 2003. 

ORAUT-PROC-0004, Scheduling Telephone Interviews, Rev. 00, November 5, 2003. 

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ATTACHMENT 5-1: AN INTERVIEW WITH DENISE BROCK 

(Daughter of an MCW Worker and 

Community Activist Helping Other Claimants)

Presented below is an interview with Denise Brock on September 18, 2004, by Arjun Makhijani, 

SC&A. This interview is further supplemented by a second interview on September 25, 2004, 

which was amended by phone, finalized, and sent to Denise Brock on September 26, 2004. 

Note: This is not a verbatim transcript but paraphrases the conversation in the form of questions 

(denoted below as Q) and answers (denoted below as A), along with a report of the substance of 

what was said. Denise Brock also granted written permission for this interview to be published 

in an e-mail of September 22, 2004, as reproduced at the end of this interview record. 

References to Denise’s third parties have been deleted for privacy reasons. Ms. Brock was 

interviewed primarily because she has helped other claimants. 

Q. Arjun Makhijani: Have you helped workers fill out claimant forms? 

A. Denise Brock: Yes, both families and workers. I’ve also helped with telephone 

interviews. 

Q. Arjun Makhijani: Do you think workers are able to get their information out during the 

interviews? 

A. Denise Brock: With guidance, they can do that. What I do is guide them. I started when 

my mother was sent a questionnaire. Especially as a family member for 

something that was considered as top secret, you look at it and say “my 

god I don’t know any of that!” I did research and helped my mother 

answer the questions. I obtained enough documents so I could do that to 

the best of my ability. 

Then a worker came to me with the questionnaire. He began to cry and he 

said, “I don’t know what I am going to with this list [of radionuclides].” I 

said, “Please let me help you and see if I can find it [the information about 

radionuclides].” I made 600 copies of the answers and handed them out. 

I sit there with them during the interviews. I prepare them prior to the 

interview. Sometimes they are nervous during the interview. For the most 

part the workers are able to get out everything that they need to say. 

Q. Arjun Makhijani: Let’s focus on the workers first and then go on to families and survivors. 

How many workers have you helped by being right there with them when 

they are answering the questions for the CATI? 

A. Denise Brock: Sitting there with them? Probably about 20. 

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Q. Arjun Makhijani: How many times during the interview typically does a worker stop to ask 

you to help? 

A. Denise Brock: They don’t stop during the interview. They are prepared beforehand. If a 

worker were to look at that form and not have anyone say to him regarding 

the radionuclide list, they could not tell you. They get nervous and have to 

say “I don’t know” and “I don’t know” again and again. So if I can’t be 

there I have done everything I can to help them about things beforehand, 

like what radionuclides were there in the building [where they worked]. 

Job descriptions they do wonderfully. 

Q. Arjun Makhijani: Can they describe incidents? 

A. Denise Brock: Yes, they do well with that part of it. 

Q. Arjun Makhijani: How about monitoring history? 

A. Denise Brock: They seem like they can give a really good feedback. 

Q. Arjun Makhijani: Do you feel the questionnaire is complete? 

 

A. Denise Brock: I think it is a good questionnaire. The only thing I would like to make 

sure is that workers feel like they can add to it. I know they are asked 

“have we missed anything?” by the interviewer. A lot of them are 

talkative. 

Q. Arjun Makhijani: Do interviewers come across as knowledgeable about the facilities? 

A. Denise Brock: No. They are kind 98 or 99 percent of the time — kind and courteous but 

when you talk about facilities... For instance, if you have a survivor of a 

worker and the questionnaire asks about isotopes. My survivors would 

answer with the isotope list [that I prepared for them]. They read the list 

to the interviewers and typically CATIs are shocked. They [the 

interviewers] sometimes say they don’t have room on the form for the list 

– but I know they can add pages. Or they may need help spelling the 

radionuclide names. 

Q. Arjun Makhijani: Workers are asked whether they have dose data. Do they have it and if 

they do they give it or withhold it? 

A. Denise Brock: No workers don’t have dose data. They were never given results of 

bioassay. They will say “I have worn a badge.” But no one I have seen 

has any sort of information. No, they were never told anything. I have 

seen people say they would drop a badge into orange oxide and the badge 

would be exposed they would turn it in and no one would say anything 

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[about a high exposure]. One guy would come up red hot and one would 

come up with nothing though they were next to each other. They were 

never told they were hot or given results for anything. 

Q. Arjun Makhijani: Have workers communicated this kind of discrepancy during interviews? 

A. Denise Brock: No, because it is not really a question [in the questionnaire]. They are 

asked “Do you have copies of your dose information?” and they say “no.” 

I tell them to add information [that they know]. 

Q. Arjun Makhijani: During some of the interviews where you’ve been present have they said 

things like the badges were not properly read? 

A. Denise Brock: They say things like badges only read external and did not take into 

account internal doses. Workers would say one was hot and one would 

come up with nothing, so how do the workers know what the dose was? 

They have no way of knowing. At least nobody I’ve seen knows. 

Sometimes, workers would not be allowed to resume a job. I know of a 

case like that when he was not allowed to go back. Sometimes the badge 

would turn up colored and he assumed his badge was hot. Sometimes they 

were told to go to another area for a few days. They were not given 

readings, but the guy next to him would be fine even though he did the 

same thing.... 

Q. Arjun Makhijani: Has any worker told NIOSH that badge readings may be tampered with, 

like the orange oxide item? 

A. Denise Brock: I have told them. During my mother’s phone interview, during other 

interviews, during Advisory Board meetings. I have broached subject 

with them several times. I have sent this in to NIOSH. 

(Denise reading a document.) Exposure printout cards are incorrect, 

internal, external. 0.00 is used where there are no records of exposure 

whereas in many cases no tests were made, etc. 

I said that if NIOSH is using zeros, then that is incorrect. I have 8,000 

documents of my own beyond what others have. I have another one that 

talks about a dust study. 

Q. Arjun Makhijani: Could you please send me a few documents, such as the one showing that 

doses were not properly recorded and that zeros were entered when there 

were no tests made and others like it? This observation about zeros is 

similar to GAO testimony during a 1994 Congressional hearing. 

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A. Denise Brock: Yes. Also there was no isotopic monitoring for protactinium and 

actinium. 

Q. Arjun Makhijani: Do you think NIOSH is getting information regarding bad data and 

possibly fraudulent data entry practices that workers may have in these 

interviews? 

A. Denise Brock: No. I think several things. For one, workers, from what I gather talking 

with them, felt that if there would have been something wrong that surely 

the company would have told them. They assumed that everything was 

okay. Not everyone realized that there was inattentiveness on the part of 

the company. 

There were a few workers who became suspicious, like the one who put 

his badge in orange oxide to see if anyone would notice the high exposure, 

and the foreman who turned his badge in from a high rad area and did not 

hear anything about it. There was the thorium bag bursting and there was 

the terrible explosion. In the explosion case the company paid them off. 

The workers were never told of anything appearing on their urinalysis or 

badge readings. They were just issued a new badge. 

There is no question that is asked during the interview that would jog the 

workers’ mind that they may be looking for instances of bad data. 

Workers are extremely nervous during the interview even though it’s not 

adversarial. But they are uncomfortable. They have never heard of 

chelation therapy. They know that everything that they say — there is 

$150,000 riding on that. They are offended they have to go through the 

process. All they know is that they are sick and their coworkers are 

deceased. They can see that the numbers [of deceased workers] are 

adding up and they answer the questions as they are asked. 

There is nothing in the interview that leads to a worker commenting on 

inattentiveness on the part of the company. For example, I have a lot of 

stuff about unreliability of radon measurements in the breath. I just don’t 

think that anything like that would ever come out unless they were asked, 

“Were you ever told of your readings?” or something like that. Then the 

interview could go down that line of thinking. 

Q. Arjun Makhijani: Now I’d like to turn to the family interview process. Tell me about how 

family members give information to the interviewer. 

A. Denise Brock: You are talking about many years ago. Spouses are elderly, in their 70s 

and 80s. That’s a lot of years later to try to remember. Then again the 

men were secretive because they did not know or they were told not to 

discuss this stuff. Survivors are not aware of what the workers did or what 

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were exposed to. It is very difficult to go through this interview. So I try 

to keep a list of jobs: maintenance, electricians, operators in a particular 

job and they can tell from that if they have the same job descriptions. 

What I did was prepare folders for them and I take a copy of my mom’s 

interview. It was the first I think that came out of Mallinckrodt so it’s a 

little different. I put a copy of that in there; I put an incident report by Leo 

Goodman. I almost sit there and go over it with them before they actually 

have the interview. For someone that doesn’t have help it is very difficult. 

[Description of rude interview] ....And we could hear a snicker and the 

lady was just hateful. When that happens the workers feel defeated and 

their face is red and I have to remove myself and cry. It is like they are 

being deposed [in a lawsuit]. I think they are humiliated. I don’t know 

why they feel that way but they feel humiliated. 

Q. Arjun Makhijani: Is there a way of lodging a compliant? 

A. Denise Brock: Yes and I do it and they take care of it. That’s part of how the process 

works. I don’t know what you could do to make it better. I think the 

interviews are a good thing because it gives workers the opportunity to 

interact and comment on their work. 

Q. Arjun Makhijani: You’ve made lists of job categories to help survivors? 

A. Denise Brock: Yes 

Q. Arjun Makhijani: And you prep them? How do you find out what job they did? 

A. Denise Brock: If they don’t know anything I can’t. That happens. But then I call living 

workers to see if they know the person. They can give me a description 

sometimes and I ask them for information or ask them to call the wife and 

tell them about the work that her husband did. I know there was one 

worker who came during the interview to help a wife and I put him on a 

speaker phone. In one case I had six people here and there were two 

claimants and there was someone with the same job description to help 

with incidents and occurrences that the family could not remember or 

know about. 

A lot of this happens at our house or office. I live in a mobile home and 

we drag chairs and sit on the bed and so on. It got crowded and friends of 

mine now let me use their office. 

Q. Arjun Makhijani: How central is the helper role in the family interview? 

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A. Denise Brock: My role makes them more relaxed. It also helps with chemicals and 

radioisotopes. I make them relaxed and hold their hand and they do 

everything else. 

Q. Arjun Makhijani: Are you being modest and minimizing your role? For example, when you 

prep them does it jog their memory? Have you talked to family members 

who have gone through process without help? 

A. Denise Brock: I don’t know. I am sure I have but if I am not there, I have given them a 

folder. I can’t think of any names. 

Q. Arjun Makhijani: Does NIOSH call coworkers in cases of survivor applicants? 

A. Denise Brock: Not that I know of. But this is because in most cases they are dead. 

Whether the living ones get called I don’t know. 

Q. Arjun Makhijani: Is this the correct procedure, since they ask the names of coworkers? 

A. Denise Brock: I would assume that NIOSH talked to maintenance men and chemical 

operators and would assume they have a list in their computer of all the 

job descriptions. That’s what I try to do and I assume that NIOSH does it 

too. 

Q. Arjun Makhijani: If you can think of someone who hasn’t had help, it would be helpful to 

have a comparison of how they did, to get an idea of your role. 

 

A. Denise Brock: Now I can think of one and I will talk to her. I think she may have done it 

by herself. 

Q. Arjun Makhijani: Do you think it would make a different if the interviewer were more 

scientifically qualified? 

A. Denise Brock: No. 

Q. Arjun Makhijani: Why? 

A. Denise Brock: The worker might get more intimidated. The thing I thought would help if 

you had someone familiar with the site itself. They could help trigger 

memory and they could help ask leading question that would help people 

remember. For an interviewer to know all the radionuclides and how to 

spell them, I don’t think that that would help. 

Q. Arjun Makhijani: So someone more like you? 

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A. Denise Brock: I doubt seriously they would hire me. I love doing this and would do it 

anyway. It would nice for them to pay me to do this though. 

Q. Arjun Makhijani: What else should NIOSH do regarding the interview? 

A. Denise Brock: The one thing I wish they would do prior to the interview would be to 

come in here and do what SC&A did. Group the workers and get as many 

living workers and let them come and talk about their work environment 

and let them do that as a group so that they can trigger each other’s 

memories. That way, they can feel not intimidated or that the $150,000 

depends on that interview. I know it is not that way but the workers feel 

that way. The Site Profile was done without worker input. Things like not 

monitoring for all radionuclides. They [workers] know about stuff on 

their faces and blowouts and explosions and mobility of workers between 

facilities. Someone should have come in and have those descriptions from 

workers. Weldon Springs is not yet done. They can do it there. They 

deserve to be heard and this is a situation that they are nervous. If you put 

them together they are eager to share with one another — that can provide 

more information. Coupled with the phone interview — it would make 

sense to do them both. 

Q. Arjun Makhijani: Do you think if they did this and give applicants copies of the results of 

the group meetings before the interviews, it would help the interview 

process? 

A. Denise Brock: Yes, definitely and it would definitely help survivors. When we did my 

mom’s interview I did not know very much. Now I have met people who 

knew my dad and it would have helped. We practiced for that interview 

for two weeks; she was a nervous wreck when she was going to do that 

interview. They’re not adversaries. But workers feel it is an integral part 

of their dose reconstruction and without briefing before it is scary for 

them. 

Q. Arjun Makhijani: Thanks so much for helping me like this. We will follow up regarding 

that person you said you would contact. Is that okay? 

A. Denise Brock: Yes. 

End 

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Second Interview with Denise Brock on September 25, 2004 

Discussion Topic: Closeout Interviews

Q. Arjun Makhijani: Did you have a closeout interview? 

A. Denise Brock: Yes. 

Q. Arjun Makhijani: Did they send you a letter or form relating to this interview? 

A. Denise Brock: No, there is no form or letter for the closeout interview. You get the 

results of the dose reconstruction, with a form, OCAS-1. There is a lot of 

information in the dose reconstruction, including a lot of numbers 

indicating dose estimates. Then there is a phone call asking if you’ve read 

and understood the material and if you are ready to sign OCAS-1. 

The person who calls seems like the same type who did the interview. I 

know someone who refused to sign and they said a health physicist will 

call you. That was weeks ago and no one has called yet. I think she 

should sign because they will close out her case if she does not. 

End 

Permission from Denise Brock; e-mail of September 22, 2004: 

Hi Arjun! 

Yes, you have my written permission to use my name. Could you please give me a call though, I 

would like to clarify or answer some of the questions that you have asked in the interview draft? 

[Call made on September 26, 2004, and corrections incorporated]. 

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ATTACHMENT 5-2: INTERVIEW WITH ED WALKER 

ON SEPTEMBER 26, 2004 

(Former Bethlehem Steel Employee and 

Community Activist Helping Other Claimants)

Presented below is an interview with Ed Walker, September 26, 2004, by Arjun Makhijani, 

SC&A, supplemented by a brief interview September 27, 2004. Note: This is not a verbatim 

transcript but paraphrases a conversation in the form of questions (denoted below as Q) and 

answers (denoted below as A). These statements were reviewed, corrected, and approved by Ed 

Walker by fax, November 23, 2004. Permission to print this interview with his name on it was 

granted by Ed Walker by fax on November 23, 2004 (reproduced at the end of this attachment). 

Specific references to third parties, including their names, have been deleted for privacy reasons. 

Mr. Walker was interviewed mainly because he has helped other claimants. 

Q. Arjun Makhijani: Have you helped workers fill out claimant forms? 

A. Ed Walker: Yes, I have. 

Q. Arjun Makhijani: About how many? 

A. Ed Walker: Ten or twelve. 

 

Q. Arjun Makhijani: Were they employees or survivors? 

A. Ed Walker: They were all survivors. I don’t believe I’ve helped any worker claimants. 

Q. Arjun Makhijani: Have you helped workers also in some way? I am reviewing both the 

worker interview procedure and the survivor interview procedure. Let’s 

focus on the workers first and then go on to families and survivors. For 

instance, have you helped workers by being right there with them during 

the interview when they are answering the questions for the CATI? 

A. Ed Walker: Partially I did. 

Q. Arjun Makhijani: You hesitated. Why? 

A. Ed Walker: At the time I did my application, we did not have much information. We 

knew that we had worked with uranium, but we did not know much about 

the compensation program. I just looked at that form [again] preparing for 

your call. When I first looked at the questionnaire I was able to tell my 

work experience. Where it asked for your experience I felt at the time of 

that questionnaire, I was able to give them enough information when I was 

interviewed. I felt after my interview that there was no question that I 

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would be compensated. So I felt that I got out the information that I 

wanted to. 

Q. Arjun Makhijani: Did they ask you about incidents and unusual work that you did? 

A. Ed Walker: Yes. But I was not able to give them data on incidents. I did not know 

what incidents were. It is only recently, in the last few months, as I have 

looked at declassified documents that it dawned on me what it meant. At 

that time, I did not have a clue what they were talking about. 

Q. Arjun Makhijani: Do you feel questionnaire is complete in terms of the kinds of information 

it asks you for? 

A. Ed Walker: I think the questionnaire itself is complete if the claimant would be more 

informed. Well, as a claimant and survivor — you were aware that they 

send you a letter. On the second page they tell you that you have a very 

important role in the process [of dose reconstruction]. A lot of people read 

that, and they understand it but they don’t have the information. So they 

[NIOSH] tell them it’s important, but the claimants don’t know the 

information. So they get a little scared. And they are a little tense. 

Obviously, the elderly ones, many don’t have the schooling, and they are 

afraid to say the wrong thing. That’s why I thought for myself, I could 

handle that part of it. 

Q. Arjun Makhijani: In retrospect you felt that you missed giving information that might have 

been useful to your case? 

A. Ed Walker: Yes. With the lack of knowledge about what incidents meant, I could not 

give them that information. 

Q. Arjun Makhijani: Are there other things that you did not say because you did not know 

enough? 

A. Ed Walker: If I had redone it today, I would have stated some things differently, but as 

I know now it would not have made any difference. I would have 

mentioned some of the things that as you know we went through during 

the workers meeting at Hamburg [organized by NIOSH on July 1, 2004]. 

Q. Arjun Makhijani: Let’s talk about the survivors you’ve helped. How did you help them? 

A. Ed Walker: In a lot of cases, I go to their house. They say “I can’t locate anyone who 

worked with my husband, he’s been dead for 20 or 30 years. I don’t 

understand this.” Mostly, it would be the questionnaire. I go and try and 

help them locate someone [who knew the employee] and go and find what 

department he worked for. Or I might locate a friend he talked about to 

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her [the survivor claimant] if she can tell me the name, and then I try to 

trace back the information [about his work] that way. 

As far as the questions about work were concerned they [the survivor 

claimants] don’t really know and I could not help them. If they knew the 

job their husbands did, then I could tell them what they did [specifically]. 

Like if they say “electrical,” I can tell them that he likely worked all 

around the plant. My brother worked there and assigned people to work 

around the plant. So I could tell them what the normal procedure for that 

kind of work meant. In some cases, they were able to locate a relative to 

find out what type of work he [the employee] did. 

Q. Arjun Makhijani: Did you find coworkers in all cases? 

A. Ed Walker: No. We found coworkers in most cases but could not find coworkers in a 

few cases. Someone would call later after my calls and give us 

information. 

Q. Arjun Makhijani: Were you present during the interviews with some of the survivors? 

Many? 

A. Ed Walker: I have attended three or four interviews besides my own. 

Q. Arjun Makhijani: How do you prepare the claimant-survivors for the interviews? 

A. Ed Walker: I tell them to be honest and say what they know. So I encourage them not 

to just say they were in the bar mill but to say what they know and the 

truth. 

One person I know got confused, and I had to interrupt during her 

interview because she was missing things. She would get emotional and 

lose her train of thought. Another person also lost her train of thought 

because the interview triggers memories. It’s hard for them to bring out 

the information. The agent doing the interview was good. When people 

get emotional, I get tied up with it too, and it’s very hard to continue. The 

interviewers are good in such situations. People know the interviewers 

have a job to do, and I don’t feel they can do much about it. They were 

there to listen. They seem to be kind. This last one was exceptionally so. 

They were all kind. I’ve had people tell me that they had cold 

interviewers, but I haven’t seen that. 

Q. Arjun Makhijani: Do interviewers come across as knowing about the facilities? 

A. Ed Walker: Not really. It’s hard to say. I felt they were not fully aware about the facts 

that went on [at the plants]. Like I went over the notes from the Hamburg 

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meeting today. I felt there is an awful lot that they did not know. If I was 

going to handle the interview department, the interviewers would have 

been briefed about the situation. It may have made a difference during the 

interview. 

Q. Arjun Makhijani: What do you mean situation? 

A. Ed Walker: I mean the situation at Bethlehem Steel and what the people went through. 

Had they been briefed about the facility, whether it would have made any 

difference to the analysis of the dose reconstructions, I don’t know. But 

they have to go through the procedure and do what the law tells them. It is 

a complaint that not many people know what went on here at Bethlehem 

Steel. I really think as hard as I’ve worked, there are a few people who 

really know, and I have a job to do to educate elected officials and others. 

But they do listen. 

For the presidential advisory board, one member came up to me and he 

was unaware that we were unaware [at the time of the rollings] that there 

was uranium there. The people have to be informed and that’s my job is. 

Q. Arjun Makhijani: Workers and family members are asked whether they have dose data. Do 

they have it and if they do they give it or withhold it? 

A. Ed Walker: No one here has dose data. A lot of the claimants had questions about film 

badges. We finally explained it to them. They kept mentioning badges, 

and I did not know what a film badge was. People would say I kept my 

dad’s badge. But it was a security badge. 

Q. Arjun Makhijani: Interviewers don’t explain what badge they are referring to? 

A. Ed Walker: It may say film badge but it means nothing to us unless you worked in a 

facility that used them. And children even know less than the wives. 

They were all little. In a lot of cases, their mothers have also passed away. 

Q. Arjun Makhijani: What kind of preparation do you think survivors need to answer the 

questions? Is what you did sufficient? In the cases where you did not find 

coworkers, what happened? 

A. Ed Walker: They went alone. They said, “I wish you would have gone.” They wish 

they would have thought of the answers. Then they would ask me. Some 

took attorneys, which is not much help. So they can’t answer the 

questions. They felt that it wasn’t going to make a difference. These are 

people who did not ask for help and then commented to me about the 

interview. 

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I got two calls yesterday; they did not even know about our group. One 

said, “I went to a hearing, and I did not know anything about uranium.” 

People who do not know about us go to the interviews on their own. 

Maybe our group should explain more. As you know, you can explain 

something and people can get wrong information. Maybe our group 

should push to have more of a process to educate people more. 

Q. Arjun Makhijani: Do you think there should have been an official role for a group like yours 

in the interview? 

A. Ed Walker: Oh yeah. Someone that is going to stand up and be honest and understand 

what is going on. 

Q. Arjun Makhijani: How should that work? 

A. Ed Walker: I would have to give some thought to that, to sleep on it. Give me a 

minute to write that down. 

Q. Arjun Makhijani: Can we talk tonight? This interview process is supposed to feed dose 

reconstruction. How can the imbalance in family and worker claims be 

rectified to some extent? 

A. Ed Walker: One idea is: If NIOSH and ORAU would take one person who is 

knowledgeable about the site. If they [NIOSH] would interview this 

person and make a summary or booklet or something simple that 

claimants can read, it would help a great deal. It would have information 

like what people from my group would know and the booklet would be 

mailed to the [survivor] claimants. So they would have some idea of what 

their husbands did. Some of them come up to me and say “how did this 

[uranium] get there?” and “What did they do with it?” If they just had an 

outline of what the workers were doing of different types. Like 

millwrights, engineers, office workers. If they put that in a packet and 

send it before the interview, say with the letter. 

Q. Arjun Makhijani: Do you think the person who does the interview should know about the 

facility? 

A. Ed Walker: Definitely. If NIOSH and ORAU is going to act on it [the information], 

they should. I will do some more thinking about ways to get people better 

prepared and talk to you later. 

Q. Arjun Makhijani: Can I call you later tonight? 

A. Ed Walker: At nine would be good. 

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Q. Arjun Makhijani: Do you know people who have complained about the process? 

A. Ed Walker: Almost everyone. 

Q. Arjun Makhijani: What kind of complaints have there been? 

A. Ed Walker: Basically they feel, it does not mean anything – it’s just a procedure. 

Q. Arjun Makhijani: Can you explain that to me a little more? 

A. Ed Walker: Most cases they feel that it is just a government bureaucracy, a waste of 

money and a waste of time, and [that the interview] is really not needed 

for dose reconstruction. They feel it’s just a paper to give them another 

process to go through to procrastinate on paying their claims. Most of 

them feel if they spent the money paying the claims they would save 

money. 

Q. Arjun Makhijani: Do you see a difference between the cases where you have helped and 

those where you have not? 

A. Ed Walker: Definitely. They feel better about doing the interview, and if they did not 

get compensation, they are not surprised. Mostly, they don’t feel that the 

interview affects the outcome. One person did get his award, but he does 

not say anything about the interview. He did have a review of his dose 

reconstruction, and we like to think we made a difference. But I don’t 

think they [the claimants] think it [the interview] makes a difference. 

Q. Arjun Makhijani: Does NIOSH call coworkers in case of survivor applicants? 

A. Ed Walker: To date, I have not heard of a single witness [i.e., coworker] that has been 

interviewed. 

Q. Arjun Makhijani: How many names have you supplied [of] witnesses [coworkers]? 

A. Ed Walker: A lot of them. I told people where to find them. I would tell them how to 

find them, and they would tell me we found them. I would say put them 

down for interviews. I think we identified 15 or 20 coworkers. But it has 

been brought out that they have not interviewed witnesses [coworkers]. I 

myself had furnished four coworker witnesses on April 23, 2003. And to 

date, November 23, 2004, not one of them has been contacted by NIOSH. 

We have discussed this in meetings. We have 100 to 200 people in 

meetings, and I have never heard one of them say they that they 

[NIOSH/ORAU] interviewed a witness. 

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Q. Arjun Makhijani: Do you think it would make a difference if the interviewer were more 

scientifically qualified? 

A. Ed Walker: I don’t think interviewers are scientifically qualified. They are there to 

take the story. When they start the interview, we are told they will not 

answer any questions about the dose reconstruction methodology — that 

they are not allowed to talk about it. 

Q. Arjun Makhijani: Can you repeat that? I want to make sure I got it right. 

A. Ed Walker: They say they are not allowed to talk about methodology and that we are 

not allowed to challenge that. That’s the way they put it. I don’t 

remember them telling me that in my case. But now they seem to be 

doing it. First time I heard about it was in February [2004]. Someone also 

brought this out at a meeting of our group [Bethlehem Steel Action 

Group]. 

Q. Arjun Makhijani: Do you think it would help if the interviewers were qualified 

scientifically? 

A. Ed Walker: No. 

Q. Arjun Makhijani: Why? 

A. Ed Walker: I don’t think so because what they could do was argue. If they are just 

taking notes, it wouldn’t make any difference. They send us a letter with 

the qualifications of the person who does the dose reconstruction. But that 

doesn’t do much. How would we know how to pick [a dose reconstructor] 

or know whether they had the right qualifications? 

Q. Arjun Makhijani: But if they were willing to tell you about how dose reconstruction works? 

Would it help? 

A. Ed Walker: No, because most people won’t understand it. I listened to it for two days 

down in Cincinnati. I told Larry Eliot I will tell the group what I learned 

from the dose reconstruction seminar for two days, and it will be very 

condensed. I do understand it better, but I don’t want to give a class on it 

in the near future! 

Q. Arjun Makhijani: Anything else for now? 

A. Ed Walker: No. 

Q. Arjun Makhijani: Let’s talk again later. 

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Interview Followup on September 27, 2004, with Ed Walker 

Discussion Topic: Other Ways to Improve the Process 

Ed Walker: The way they presented the applications can be improved. The 

information that there was a compensation program was on the news and 

people filled out the applications, and they did not have information about 

the program. They should place someone in the community with 

knowledge of the site so that they can help claimants fill out the forms 

properly from the site. The person can be from the community or from the 

government. They would be there to answer questions from the people. 

Arjun Makhijani: This is helpful. Thanks so much. 

End of interview. 

Permission to publish interview, provided by Ed Walker by fax, November 23, 2004, was as 

follows: 

I Edwin Walker give Mr. Arjun Makhijani full permission to publish this interview and the use 

of my name as he pleases. 

Signed 

Edwin Walker 

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ATTACHMENT 5-3: INTERVIEW WITH ORAU CLAIMANT INTERVIEW STAFF 

ON JANUARY 7, 2005 

Presented below is an interview with ORAU Team Claimant Interviewer conducted by Kathryn 

Robertson-DeMers, SC&A, on January 7, 2005, in the presence of a Claimant Interview 

Supervisor. This interview was performed to assess the implementation of the claimant 

interview procedures and verify training. 

Note: This is not a verbatim transcript but paraphrases the conversation in the form of questions 

(denoted as Q) and answers (denotes as A), along with a report of the substance of what was 

said. The Claimant Interviewer who participated in this discussion was selected randomly from 

a list of five. A Claimant Interview Supervisor participated in the interview to answer general 

questions about the program. The names of the individuals participating in this interview have 

been deleted to protect their privacy. 

Q. Kathryn Robertson-DeMers: What is your educational background? 

A. ORAU Staff The Staff member interviewed held a B.S. in Science. This 

is typical of all the interviewers. 

Q. Kathryn Robertson-DeMers: What is your employment background? Have you ever 

worked at a DOE facility or a facility where radioactive 

material was handled? Is your background typical of other 

interviewers? 

A. ORAU Staff The Staff member interviewed indicated that she had 

previously worked at the Fernald site. Seven of the 12 

claimant interviewers had worked at DOE sites, with an 

average of 15 years worked at DOE sites per interviewer. 

Q. Kathryn Robertson-DeMers: What training is provided to you? Does this training include 

radiation protection principles and information on the dose 

reconstruction process? 

A. ORAU Staff ORAU provides interviewers with extensive training, 

including classes in the following topics. 

- Freedom of Information Act 

- Privacy Act 

- Radiological Contamination Regulations and Protection 

Principles (basic principles of radiation and 

radiological regulations) 

- Radiological Protection Fundamental and Protection 

Concepts 

- Effective Communication 

- Effective Telephone Communication 

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- EEOICPA NIOSH Project Overview 

- Biological Effects of Radiation Exposure 

- Methods of Radiation Contamination Measurements 

- Occupational and Environmental Radiation Protection 

Some of those who worked at DOE sites have also completed 

Radiological Worker Training at the DOE site. 

Q. Kathryn Robertson-DeMers: Have terms and phrases such as chelation therapy, incident, 

dosimeter, and radiation-generating equipment been defined 

for you? If so, are you able to define these terms for the 

claimant? 

A. ORAU Staff These terms are defined for the Claimant Interview Staff in 

the training provided to them by ORAU. There are occasions 

where the claimant is not familiar with these terms. In 

general, DOE employees know these terms. Approximately 

half of the AWE employees are familiar with these terms. 

The survivor claimants have difficulty with some of these 

terms and the interviewer has to explain them in layman’s 

terms. 

Q. Kathryn Robertson-DeMers: Are you allowed to ask additional questions outside those on 

the claimant interview forms? If so, are there limitations to 

these questions? 

A. ORAU Staff The interviewer is allowed to ask clarifying or verification 

questions. For example, if the claimant answers yes to 

Question 13, “Were you ever restricted from the workplace 

or certain job duties because you had reached a radiation 

dose limit?,” the interviewer may follow up on this question 

by asking if the energy employee was involved in an 

incident. Typically, the interviewers strictly follow the 

script. There are some questions that they are not allowed to 

ask, such as about an individual’s smoking history. 

Q. Kathryn Robertson-DeMers: Is the claimant work history record available during the 

interview? Is the radiation exposure record available during 

the interview? What other records are made available to you 

for the interview? 

A. ORAU Staff The interviewer has access to the Department of Labor initial 

case file and any correspondence to date. Radiological 

records are available to the interviewer if they have been 

uploaded into the NOCTS system. 

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Q. Kathryn Robertson-DeMers: Do you perform coworker interviews? Is there a procedure 

for coworker interviews? How are coworker interviews 

documented? 

A. ORAU Staff They have completed approximately twelve coworker 

interviews. NIOSH requested all but one of the coworker 

interviews. The other was requested by a Health Physicist. 

Version 1 (covered employee) of the interview is modified 

for the purposes of coworker interviews by putting the 

interview in third person. All coworker interviews 

completed to date have been done on behalf of a survivor. 

Q. Kathryn Robertson-DeMers: Do you perform closing interviews following completion of 

the dose reconstruction? If yes, how are these interviews 

documented? If no, are others responsible for these 

interviews? 

A. ORAU Staff After the claimant receives a copy of the completed dose 

reconstruction, a Closing Interview is performed. There is a 

new draft procedure for this process. The Closing Interview 

process is relatively new and has been implemented within 

the last year. In general, the interviewer uses the dose 

reconstruction report as a guide to conduct these interviews. 

These interviews vary in length depending on the number of 

questions the claimant has. 

Q. Kathryn Robertson-DeMers: Do Health Physicists routinely review interviews? Are 

interviews returned to the interviewers by the 

Health Physicists for correction and/or follow up? What 

other quality assurance is in place to insure 

consistency, accuracy and completeness of interviews? 

A. ORAU Staff: The Health Physics review team is responsible for providing 

quality assurance. The documented interview is provided to 

review team upon completion. This team reviews the 

interview for completeness, accuracy, and editorial error. 

Usually the interviews are referred back to the interviewer 

due to editorial errors. Occasionally there will be a 

clarification question. For example, the Health Physicist will 

want the interviewer to delineate between a direct quote and 

a paraphrased statement. This process is completed prior to 

sending the interview to the claimant for review and 

comment. 

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Q. Kathryn Robertson-DeMers: What percentage of claimants decline the interview? Is this 

primarily energy employees or survivors? 

A. ORAU Staff: Approximately 1% of the energy employees and 7% of the 

survivors decline the interview. These numbers include 

those who initially decline, then later decide they want to 

participate in an interview. For some claimants, the process 

is too emotional. In other instances, survivors do not know 

what the energy employee did as a part of their job. 

Q. Kathryn Robertson-DeMers: Tell me about the 1-800 number and what service it provides. 

A. ORAU Staff: There are two staff members that man the 1-800 numbers. 

Voice mail is available for claimants who are not able to get 

through to ORAU staff immediately. The staff responds to 

these messages as soon as possible. Phone calls are 

documented in the NOCTS phone log. 

 Overall the CATI program is felt to be very consistent. 
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6.0 QUALITY ASSURANCE PLANS 

6.1 ORAUT-PLAN-0001 ― QUALITY ASSURANCE PROGRAM PLAN 

The review of ORAUT-PLAN-0001, Quality Assurance Program Plan, Rev. 0, dated January 

30, 2003, was prepared by Steve Ostrow, PhD, and approved by John Mauro, PhD, CHP, on 

January 11, 2005. 

6.1.1 Purpose of Plan 

The stated purpose of this document is “. . . to provide guidelines to assure quality of program 

activities associated with the ORAU Team NIOSH Dose Reconstruction Project.” 

6.1.2 Review Protocol 

Our evaluation of ORAUT-PLAN-0001, Quality Assurance Program Plan, is summarized in 

Table 6.1-1 below. Table 6.1-1 is a checklist containing objectives that SC&A developed under 

the first phase of Task 3 to evaluate whether the procedure adequately supports the dose 

reconstruction process, as described in the introduction to this report. 

6.1.3 General Comments 

The Quality Assurance Program Plan (QAPP) applies to all corporate and individual participants 

and all aspects of the ORAU-team dose reconstruction project. The QAPP contains sections on 

purpose, project description, scope, references, objectives, organization, responsibilities, 

qualifications, training, document control, non-conformance and corrective action, and 

management assessment and audits. The ORAU QAPP meets the standards for such a 

document. 

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Table 6.1-1 QA Document Compliance Checklist 

Document No.: ORAUT-PLAN-0001, Rev. 0 Effective Date: 1/30/03 

Document Title: Quality Assurance Program Plan

Reviewer: Stephen Ostrow 

No. Question Y/N Comments 

1.0 Quality Assurance Program Plan (QAPP) 

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices? 

Y This document is the 

ORAU Team QAPP. 

Regulatory & guidance 

documents are referenced 

in Section 4. 

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

Y The QAPP identifies team 

members, applies to the 

entire team, and discusses 

organization in Section 6. 

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement? 

Y Quality Assurance 

Manager (Section 7.2) and 

individual task managers 

(Sections 7.3-7.8) 

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education? 

Y Section 8 covers 

personnel qualifications. 

1.4 Are there adequate procedures for training of project 

personnel? 

Y Section 8 covers 

personnel training. 

1.4.1 Have staff training requirements been identified? Y Section 8 covers 

personnel training. 

1.4.2 Has staff received general orientation training? ? Section 8.7.1 requires 

such training. However, 

compliance has not been 

verified. 

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act? 

? Section 8.7.2 requires 

such training. However, 

compliance has not been 

verified. 

1.4.4 Has staff received training in the provisions of the QAPP? ? Section 8.7.3 requires 

such training. However, 

compliance has not been 

verified. 

1.4.5 Is a master record of staff training maintained in project files? ? Section 8.5 requires such 

documentation. However, 

compliance has not been 

verified. 

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No. Question Y/N Comments

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement? 

Y Section 18 lists 

management assessments 

and audit procedures. 

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work 

products and processes? 

Y Section 16 covers nonconformance and 

corrective action. 

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition? 

Y Section 17 covers QA 

records. 

1.8 Are there procedures covering all work activities of the 

project? 

Y Section 3 lists the 

processes governed by the 

QAPP. 

2.0 Individual Procedures and Documents 

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date? 

Y 

2.2 Do the title, document number, revision number, page 

number, and date appear on each page? 

N Title appears only on first 

page; however, the other 

items unambiguously 

identify the document. 

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter? 

 

Y Reviewed and approved 

by Project Director and 

OCAS Administrator. 

2.4 Does the procedure or document include a revision log 

showing revision number, date, and brief description? 

Y 

2.5 Are revisions clearly indicated on affected pages? N/A This document is 

Rev. 0. 

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, 

adequately defined in the text or in a separate section? 

Y In text. 

2.7 Are all scientific and engineering constants, values, 

equations, and assumptions, which may not be known by the 

average reader, clearly presented and referenced? 

N/A Not in QAPP. 

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6.1.4 Review Comments 

The following observations are made about the QAPP: 

(1) Section 4.8: The Privacy Act is incorrectly referenced. The correct citation is “5 U.S.C. 

552a, as amended.” 

(2) Section 4.9: The Freedom of Information Act is incorrectly referenced. The correct 

citation is “5 U.S.C. 552, as amended.” 

(3) Since the QAPP is a high-level procedure, perhaps it should include a list of specific 

implementing procedures that it covers. Section 3 of the QAPP mentions processes 

covered by the QAPP, but not the specific procedures. The list could be included as an 

attachment, which could be revised as required. 

(4) Checklist questions 1.4.2 through 1.4.5 relate to training. The ORAU QAPP covers 

training adequately in Section 8, but the checklist questions ask about implementation of 

the procedures. Answers to these questions would require an audit/inspection of the 

ORAU records, which is not in the scope of this review. 

6.2 ORAUT-PLAN-0002 ― INTERNAL MANAGEMENT REVIEW PLAN 

The review of ORAUT-PLAN-0002, Internal Management Review Plan, Rev. 01, dated March 

6, 2003, was prepared by Steve Ostrow, PhD, and approved by John Mauro, PhD, CHP, on 

January 11, 2005. 

6.2.1 Purpose of Plan 

The stated purpose of this document is “. . . to provide guidance for the conduct of internal 

management reviews of activities associated with the ORAU Team Dose Reconstruction Project 

for NIOSH and to serve as a charter for the project’s Internal Management Review Team.” 

6.2.2 Review Protocol 

Our evaluation of ORAUT-PLAN-0002, Internal Management Review Plan, is summarized in 

Table 6.2-1 below. Table 6.2-1 is a checklist containing objectives that SC&A developed under 

the first phase of Task 3 to evaluate whether the procedure adequately supports the dose 

reconstruction process, as described in the introduction to this report. 

6.2.3 General Comments 

The Internal Management Review Plan provides guidance for conducting semiannual internal 

management reviews, scheduled 1 month in advance of the NIOSH-OCAS semiannual project 

performance reviews. The Plan provides adequate guidance to the review team regarding 

purpose, scope, references, responsibilities, review team membership, meetings, reviews, 

records, and applicable documents. The Plan also includes a four-page checklist, providing 

guidance for internal management reviews. The checklist covers many of the areas of the QAPP. 

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It contains sections on organizational structure, staffing, facilities, equipment, safety 

management, polices and procedures, training, financial management, conflict of interest 

management, privacy act and confidentiality, quality assurance, production, and follow-up of 

previous findings. 

Table 6.2-1 QA Document Compliance Checklist 

Document No.: ORAUT-PLAN-0002, Rev. 01 Effective Date: 3/6/03 

Document Title: Internal Management Review Plan 

Reviewer: Stephen Ostrow 

No. Question Y/N Comments 

1.0 Quality Assurance Program Plan (QAPP) 

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices? 

N/A 

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A 

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement? 

N/A 

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education? 

N/A 

1.4 Are there adequate procedures for training of project personnel? N/A 

1.4.1 Have staff training requirements been identified? N/A 

1.4.2 Has staff received general orientation training? N/A 

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act? 

N/A 

1.4.4 Has staff received training in the provisions of the QAPP? N/A 

1.4.5 Is a master record of staff training maintained in project files? N/A 

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement? 

N/A 

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No. Question Y/N Comments 

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes? 

N/A 

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition? 

N/A 

2.0 Individual Procedures and Documents 

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date? 

Y 

2.2 Do the title, document number, revision number, page number, 

and date appear on each page? 

N Title appears only on 

first page; however, the 

other items 

unambiguously identify 

the document. 

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter? 

 

Y Reviewed and 

approved by Project 

Director and OCAS 

Administrator. 

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description? 

Y 

2.5 Are revisions clearly indicated on affected pages? N/A Revision log notes that 

Rev. 01 is the first 

approved issue. 

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section? 

Y In text. 

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A 

6.2.4 Review Comments 

The Internal Management Review Plan provides adequate guidance for the conduct of such 

reviews. 

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6.3 ORAUT-PLAN-0003 ― INFORMATION SYSTEMS QUALITY ASSURANCE 

PLAN 

The review of ORAUT-PLAN-0003, Information Systems Quality Assurance Plan, Rev. 00, 

dated October 30, 2003, was prepared by Steve Ostrow, PhD, and approved by John Mauro, 

PhD, CHP, on January 11, 2005. 

6.3.1 Purpose of Plan 

The stated purpose of this document is “. . . to provide a framework for attesting to the quality of 

data and information management practices used in activities associated with the ORAU (Oak 

Ridge Associated Universities) Team NIOSH (National Institute of Occupational Safety and 

Health) Dose Reconstruction Project.” 

6.3.2 Review Protocol 

Our evaluation of ORAUT-PLAN-0003, Information Systems Quality Assurance Plan, is 

summarized in Table 6.3-1 below. Table 6.3-1 is a checklist containing objectives that SC&A 

developed under the first phase of Task 3 to evaluate whether the procedure adequately supports 

the dose reconstruction process, as described in the introduction to this report. 

6.3.3 General Comments 

The Information Systems Quality Assurance Plan (IS QA Plan) provides guidance for the 

development of information management practices and procedures to maintain quality of data 

throughout the project processes and to assure that calculations are performed accurately and 

consistently. The plan contains sections on purpose, scope, information systems QA program 

objectives, organization, responsibilities, audits, qualifications and training, QA reports, 

corrective actions, references, and applicable documents. The IS QA Plan provides adequate 

guidance on how to design an effective system of information management. 

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Table 6.3-1 QA Document Compliance Checklist 

Document No.: ORAUT-PLAN-0003, Rev. 00 Effective Date: 10/30/03 

Document Title: Information System Quality Assurance Plan 

Reviewer: Stephen Ostrow 

No. Question Y/N Comments 

1.0 Quality Assurance Program Plan (QAPP) 

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices? 

N/A 

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A 

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement? 

N/A 

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education? 

N/A 

1.4 Are there adequate procedures for training of project personnel? N/A 

1.4.1 Have staff training requirements been identified? N/A 

1.4.2 Has staff received general orientation training? N/A 

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act? 

N/A 

1.4.4 Has staff received training in the provisions of the QAPP? N/A 

1.4.5 Is a master record of staff training maintained in project files? N/A 

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement? 

N/A 

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes? 

N/A 

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition? 

N/A 

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No. Question Y/N Comments 

1.8 Are there procedures covering all work activities of the project? N/A 

2.0 Individual Procedures and Documents 

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date? 

Y 

2.2 Do the title, document number, revision number, page number, 

and date appear on each page? 

N Title appears only on 

first page; however, the 

other items 

unambiguously identify 

the document. 

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter? 

 

Y Reviewed and 

approved by Project 

Director and OCAS 

Administrator. 

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description? 

Y 

2.5 Are revisions clearly indicated on affected pages? N/A Revision log notes that 

Rev. 0 is the first 

approved issue. 

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section? 

Y In text. 

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A 

6.3.4 Review Comments 

The following observation is made about the IS QA Plan: 

Section 5.1: It is not clear whom the position “Quality Assurance Analyst” refers to. The QAPP 

refers to a “QA Manager.” Are the “Quality Assurance Analyst” and the “QA Manager” the 

same person? If so, the title should be amended in the IS QA Plan, and, if not, an explanation 

should be provided. 

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7.0 DOCUMENTATION/RECORDS MANAGEMENT 

7.1 OCAS-TIB-004 ― NAMING CONVENTIONS 

The review of OCAS-TIB-004, Naming Conventions, Rev. 1, dated October 3, 2003, was 

prepared by Kathleen Behling, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

7.1.1 Purpose of Technical Information Bulletin 

The stated purpose of the Technical Information Bulletin (TIB) entitled Naming Conventions, 

OCAS-TIB-004, Rev. 1, is to define “. . . the naming conventions for documents used to create 

the Administrative Record (AR).” 

7.1.2 Review Protocol 

Our evaluation of OCAS-TIB-004, Naming Conventions, is summarized in Table 7.1-1 below. 

Table 7.1-1 is a checklist containing objectives that SC&A developed under the first phase of 

Task 3 to evaluate whether the procedure adequately supports the dose reconstruction process, as 

described in the introduction to this report. 

7.1.3 General Comments 

Naming conventions are used to create a unique identifier for grouping and sorting large 

quantities of information. The primary goal of adopting a naming convention is to easily identify 

the type and purpose of the information, which is typically stored in a database. A practical, 

logical, unambiguous, and consistent set of rules should, therefore, be established for producing 

names for these database elements. In the case of this TIB, naming conventions are required for 

tracking the various types of documents used to create a claimant’s Administrative Record. 

The types of documents included in the Administrative Record (AR) have been categorized into 

five directories: (1) Dose Reconstruction (DR) Files, (2) Correspondence, (3) DOE Files, (4) 

DOL Files, and (5) Appeal Files. Each directory consists of at least one sub-directory, as 

specified below: 

 Dose Reconstruction Files

- Living Energy Employee 

- Survivor to the Energy Employee 

- Survivor to the Energy Employee with Authorized Representative or Power of 

Attorney (POA) 

- Energy Employee with Authorized Representative or Power of Attorney 

- Modification of IEP Files 

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 Correspondence

- Living Energy Employee 

- Survivor to the Energy Employee 

- Survivor to the Energy Employee with Authorized Representative or Power of 

Attorney (POA) 

- Energy Employee with Authorized Representative or Power of Attorney 

 DOE Files

- All Claims 

 DOL Files

- Living Energy Employee 

 Appeal Files

- All Case Types 

Section 1.0 of the Naming Conventions TIB includes definitions and information on 

abbreviations, formatting, version numbers, and dose reconstruction drafts. Section 2.0 defines 

the naming requirements. The remaining sections (3.0 through 6.0) provide examples of names 

that have been assigned to documents included in the AR under the Correspondence, DOE Files, 

DOL Files, and Appeal Files directories. 

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Table 7.1-1. Procedure Review Outline/Checklist 

Document No.: OCAS-TIB-004 Effective Date: 10/03/2003 

Document Title: Naming Conventions 

Reviewer: Kathleen Behling

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 4 See Review 

Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 See Review 

Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

4 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

N/A 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating

1-5*

Comments

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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7.1.4 Review Comments 

The only objectives that are applicable to OCAS-TIB-004 Naming Conventions correspond to 

four of the five questions identified under Section 1.0 of the Table 7.1-1 checklist. Section 1.0 

objectives are designed to “determine the degree to which the procedures support a process that 

is expeditious and timely for dose reconstruction.” Comments associated with the rating of 

applicable questions are presented below: 

Review Objective 1.1

This technical information bulletin is generally written in a concise, clear format. However, it 

was given a rating of 4 (frequently), because it was noted that an acronym identified in the 

Correspondence directory, “PHA,” is not defined under the abbreviations. In addition, the 

“Energy Employee with Authorized Representative or POA” sub-directory is given a “survivor 

identification number,” which does not appear to be necessary and is not used in the naming 

convention. 

Review Objective 1.2

The TIB establishes the requirements for naming applicable AR documents in a manner that 

follows a logical sequence and was given the highest rating of 5 (Always or Yes). 

Review Objective 1.3

The TIB contains all necessary basic information for the reader to establish a logical, unique 

document name for each of the AR sub-directory elements. However, Objective 1.3 was given a 

rating of 4 (Frequently), since (as mentioned in Objective 1.1) the data was incomplete in the 

area of providing all necessary abbreviations, namely “PHA.” 

Review Objective 1.5

Although a TIB is not designed to be as prescriptive as other types of documents, such as a 

procedure, the Naming Conventions TIB contained very limited discussions/descriptions 

regarding its purpose and the examples presented. Therefore, Objective 1.5 was given a rating of 

4 (Frequently), since data interpretation could have been improved by providing a more 

descriptive purpose and a brief opening statement prior to presenting naming convention 

examples. 

7.2 ORAUT-PLAN-004 ― RECORDS AND INFORMATION MANAGEMENT PLAN 

The review of ORAUT-PLAN-004, Records and Information Management Plan, Rev. 00, dated 

January 6, 2004, was prepared by Kathleen Behling, and approved by John Mauro, PhD, CHP, 

on January 11, 2005. 

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7.2.1 Purpose of Plan 

Section 1.0 of ORAUT-PLAN-0004 presents the purpose of this document as follows: 

The purpose of the ORAU Team Dose Reconstruction and Project Records and 

Information Management Plan is to provide the requirements and responsibilities 

for a functional records and information management system with the ORAU 

Team Dose Reconstruction Project. Through implementing procedures, this 

system will govern the functions necessary to identify, collect, receive, process, 

control, retain, protect, and disposition all project records and project 

documents. 

7.2.2 Review Protocol 

Our evaluation of ORAUT-PLAN-0004, Records and Information Management Plan, is 

summarized in Table 7.2-1. Table 7.2-1 is a checklist containing objectives that SC&A 

developed under the first phase of Task 3 to evaluate whether the procedure adequately supports 

the dose reconstruction process, as described in the introduction to this report. 

7.2.3 General Comments 

The Records and Information Management Plan is an upper-tier document that clearly states the 

objectives, organization, responsibilities, and general requirements for managing project records. 

The plan presents all elements necessary for establishing a functional and comprehensive 

information management system, as summarized below: 

 Scope – The records management system will ensure that (1) appropriate records are 

preserved, (2) appropriate records are retained and records that do not require retention 

are disposed of, (3) records are protected from damage, loss, and unauthorized 

disclosure, (4) the distribution of records is controlled, (5) project commitments are 

tracked and monitored, (6) a centralized location is established for maintaining records, 

(7) personnel are trained on records and information management policies and 

procedures, and (8) records are reviewed for compliance with policies and 

procedures. The plan applies to all project records, documents, controlled documents, 

official correspondence generated or received, and commitments to the client. 

 Objectives –To accomplish the goals of the Records Management Program, the plan 

identifies five objectives, summarized as follows: 

(1) Control and protect information that has administrative, legal, research, operational, 

and historical value 

(2) Provide for an effective Records Management Program through personnel 

orientation and training 

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(3) Establish and maintain systems to carry out an effective and efficient Records 

Management Program 

(4) Provide a process for initiation, preparation, review and approval, distribution, 

receipt, revision, and use of controlled project documents 

(5) Ensure that established deliverables and commitments are properly monitored and 

managed 

 Organization – The plan provides an organizational chart consisting of personnel within 

the Records Management Program. 

 Responsibilities – The plan presents a comprehensive list of responsibilities for the 

Project Director, Project Records Manager, Task Managers, Quality Assurance Manager, 

Records Custodians, Project Personnel, and Cincinnati Operations Center (COC) Records 

Center. 

 General Requirements – Requirements are identified for establishing and documenting all 

aspects of the records management system, such as document identification, retention, 

protection, and disposition; personnel training; records safeguards, etc. 

 Applicable Documents – A comprehensive list of applicable Code of Federal Regulations 

and United States Codes is provided. 

 Definitions and Acronyms – Definitions of key terminology and acronyms are presented 

in this section. 

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Table 7.2-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-PLAN-0004 Effective Date: 01/06/2004 

Document Title: Records and Information Management Plan 

Reviewer: Kathleen Behling

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 See Checklist 

Comments Section 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 See Checklist 

Comments Section 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 See Checklist 

Comments Section 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

N/A 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 See Checklist Comments Section 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.
Effective Date: Revision No. Document No. Page No. 

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No. Description of Objective Rating

1-5*

Comments

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing 

data? N/A 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting 

the types of probability distributions (i.e., normal, 

lognormal)? 

N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can 

reasonably be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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has been edited accordingly, and is now cleared for distribution.
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7.2.4 Review Comments 

The only checklist objectives that are applicable to ORAU’s Records and Information 

Management Plan are those listed under Section 1.0 of Table 7.2-1. Objectives addressed in 

Section 1.0 are designed to evaluate the style, clarity, logical sequence, and prescriptive nature of 

the plan. In each of these areas, the plan received the highest rating of 5 (Yes or Always). Our 

review concluded that the plan archives, in a clear and comprehensive manner, the objectives, 

organization, responsibilities, and general requirements for a functional records and information 

management system. 

7.3 ORAUT-PROC-0001 ― DOCUMENT PROGRAM 

The review of ORAUT-PROC-001, Document Program, Rev. 01, dated October 6, 2003, was 

prepared by Kathleen Behling, and approved by John Mauro, PhD, CHP, on January 11, 2005. 

7.3.1 Purpose Of Procedure 

The stated purpose of this procedure is “. . . to provide the process for the development, revision, 

cancellation, and control of documents generated by the ORAUT Team Dose Reconstruction 

Project for NIOSH.” Documents included in the scope of this procedure include plans, 

procedures, technical basis documents, implementation guides, forms, tables and figures, training 

materials, and reports. The procedure does not apply to the NIOSH Report of Dose 

Reconstruction under the Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA) or the NIOSH EEOICPA Dose Reconstruction Telephone Interview report. 

7.3.2 Review Protocol 

Our evaluation of ORAUT-PROC-001, Document Program, is summarized in Table 7.3-1 

below. Table 7.3-1 is a checklist containing objectives that SC&A developed under the first 

phase of Task 3 to evaluate whether the procedure adequately supports the dose reconstruction 

process, as described in the introduction to this report. 

7.3.3 General Comments 

As defined within the scope of Document Program, procedures are “. . . comprehensive step-bystep requirements for accomplishing work activities that typically are well defined.” This 

procedure provides an example of a comprehensive step-by-step set of instructions for 

completing a specific activity, namely the development, revision, cancellation, and control of key 

documents used in the dose reconstruction process. 

To ensure that documents are created, modified, reviewed, and retired in a consistent and 

controlled manner, the procedure addresses the following key elements: 

 Scope – Definitions are provided for the primary types of documents addressed in this 

procedure (i.e., plans, project operating documents, procedures, technical basis 

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documents, implementation guides, forms, tables and figures, reports). This section also 

discusses how to handle documents that have been approved prior to the issuing of this 

procedure. 

 Responsibilities - Four individuals with the functional title of Document Owner, 

Document Coordinator, Subject Expert, and NIOSH Quality Assurance Technical 

Contact are identified as being responsible for meeting the requirements of the Document 

Program procedure. 

 Procedural Instructions – Responsible individuals are given step-by-step instructions for 

the following activities: 

- Establishing a New Document Identification 

- Development of a New Document 

- Revision of an Existing Document 

- Reviewing a Document 

- Resolution of Document Comments 

- Document Approval Process and Issue Preparation 

- Cancellation of a Document 

- Preparation of Document Issue/Revision/Cancellation Notice 

- Conducting Biennial Reviews 

 Records and Applicable Documents – The procedure identifies all documents that are 

relevant to requirements of this procedure, as well as records and standardized forms that 

may be generated as a result of document processes presented in the procedure. 

 Definitions – Definitions are provided for key terminology and functional organizational 

positions (e.g., document coordinator) who are responsible for implementing this 

procedure. 

 Attachments – Four attachments are included in the procedures, which provide 

responsible individuals with (1) a definitive description of the document format for 

procedures, (2) an example of ORAU Team procedures, (3) step-by-step instructions for 

a page change notice, and (4) an example of a page change notice. 

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Table 7.3-1. Procedure Review Outline/Checklist 

Document No.: ORAUT-PROC-0001 Effective Date: 10/06/2003 

Document Title: Document Program

Reviewer: Kathleen Behling

No. Description of Objective Rating

1-5* 

Comments 

1.0 Determine the degree to which the procedure supports a process that is expeditious and 

timely for dose reconstruction. 

1.1 Is the procedure written in a style that is clear and 

unambiguous? 5 See Review 

Comments 

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5 See Review 

Comments 

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 

5 See Review 

Comments 

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction? 

N/A 

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5 See Review Comments 

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances 

where a more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for 

identifying a potentially high probability of causation as part 

of an initial dose evaluation of a claim? 

N/A 

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions? N/A 

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures 

that resultant doses are complete and based on adequate data in instances where the POC 

is not evidently clear. 

3.1 Assess quality of data sought via interview: ---- 

3.1.1 Is scope of information sufficiently comprehensive? N/A 

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? N/A 

3.1.3 Does the interview process demonstrate objectivity and is it 

 free of bias? N/A 

3.1.4 Is the interview process sensitive to the claimant? N/A 

3.1.5 Does the interview process protect information as required 

 under the Privacy Act? N/A 

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

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No. Description of Objective Rating 

1-5*

Comments

3.2 Assess whether the procedure adequately addresses generic as 

well as site-specific data pertaining to: ---- 

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A 

3.2.2 In vivo/In vitro bioassays N/A 

3.2.3 Missing dosimetry data N/A 

3.2.4 Unmonitored periods of exposure N/A 

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of 

claimants’ exposures by time and employment locations: 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction? N/A 

4.2 Does the procedure adhere to the hierarchical process as defined 

in 42 CFR 82.2? N/A 

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the 

claimant: 

5.1 Is the procedure claimant-favorable in instances of missing data? N/A 

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? N/A 

5.3 Is the procedure claimant-favorable in instances where claimant 

was not monitored? N/A 

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose 

estimates. 

6.1 Does the procedure provide adequate guidance for selecting the 

types of probability distributions (i.e., normal, lognormal)? N/A 

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A 

7.0 Assess procedure for striking a balance between the need for technical precision and 

process efficiency. 

7.1 Does the procedure require levels of detail that can reasonably 

be accounted for by the dose reconstructor? N/A 

7.2 Does the procedure avoid levels of detail that have only limited 

significance to the final dose estimate and its POC? N/A 

___________________________ 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable. 

7.3.4 Review Comments 

The only objectives that are applicable to ORAU’s Program Document procedure are those 

listed under Section 1.0 of Table 7.3-1. Objectives addressed in Section 1.0 are designed to 

evaluate the style, clarity, logical sequence, and prescriptive nature of the procedure. In each of 

these areas, the procedure received the highest rating of 5 (Yes or Always). Our review 

concluded that the procedure provides clear, concise, comprehensive, and definitive instructions 

to those individuals responsible for the development, revision, cancellation, review, and tracking 

of key documents generated in behalf of the dose reconstruction process.

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is document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

NOTICE: Th

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