Memo – ORISE Health Study 1 SC&A – March 2, 2015

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

MEMO

DATE: March 2, 2015

TO: Rocky Flats Work Group

FROM: Ron Buchanan, SC&A

SUBJECT: SC&A’s Evaluation of NIOSH’s May 30, 2014, Response to the RFP ORISE 

Health Surveillance Document Review

In May 2014, NIOSH provided a response to a petitioner’s concern in the form of a white paper 

titled, Response: Rocky Flats Plant Health Surveillance Document Review. The petitioner 

alleged that Rocky Flats Plant (RFP) dosimetry records cannot be relied upon for dose 

reconstruction. The petitioner refers to a 2006 Oak Ridge Institute for Science and Education 

(ORISE) document, Health Surveillance of Rocky Flats Radiation Workers, and noted that the 

document ‘Summary’ indicates that approximately 10% of these former workers were found to 

have received internal exposures higher than reported in the Health Physics records.

SC&A evaluated NIOSH’s response and found:

 Some Department of Energy (DOE) sites have periodically included in the energy 

employee’s (EE’s) file a list of projected doses to the major organs resulting from a 

bioassay performed at the site at that time.

 These projected doses were derived from local dose models/programs used at the site at 

that time.

 Sometimes the resulting projected doses were zero, because the result of the bioassay was 

at, or below, the minimum detectible activity (MDA). Potentially missed dose was not 

generally considered at that time.

 SC&A has found that NIOSH does not use these projected doses for dose reconstruction 

purposes; instead, to assign a dose to an specific organ, NIOSH has used the results of the 

recorded bioassays, or coworker intake data, to assign intakes and resulting doses, or 

missed doses based on the MDA values applicable at the time of the bioassays (which 

generally results in a greater dose assignment than using the lower detection level of 

recent detection methods).

 Neither the site-generated projected doses nor the ORISE Health Surveillance Report1

results can be compared to the EEOICPA dose reconstruction doses, because the latter is 

more encompassing of the total potential dose in order to be claimant favorable.

 

1 ORISE 2004. Final Report – Former Radiation Worker Medical Surveillance Program at Rocky Flats., 

For Department of Energy Programs. Oak Ridge Institute for Science and Education (ORISE), Arvada, Colorado. 

Provided to DOE on November 8, 2004. SRDB Ref ID: 121677, PDF pp. 24–25.
Memo – ORISE Health Study 2 SC&A – March 2, 2015

NOTICE: This memo has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

 Incidents, such as the one mentioned in the ORISE Health Surveillance Document 

Review, “The records in [the EE’s] Rocky Flats health physics file and in [the EE’s] 

medical file are mute regarding the plutonium contamination incident [the EE] described 

in [the EE’s] interview” (ORISE 2004), would need to be investigated and appropriately 

accounted for during dose reconstruction.

SC&A found that the DR process used by NIOSH under EEOICPA is more encompassing and 

uniform between sites than other methods (as evaluated above) and generally results in more 

claimant-favorable and consistent dose assignments.