REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute of Occupational Safety and Health 

Audit of Case #PIID* from Fernald 

Contract No. 200-2004-03805 

Task Order No. 4 

SCA-TR-TASK4-CNPIID* 

Prepared by 

S. Cohen & Associates 

6858 Old Dominion Road, Suite 301 

McLean, Virginia 22101 

February 2005 

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

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

SCA-TR-TASK4-CNPIID* 

Effective Date: 

February 4, 2005 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 1 

AUDIT OF CASE #PIID* FROM FERNALD Page 2 of 10 

Task Manager: ___________________ Date: 02/04/05 

 U. Hans Behling, PhD, MPH 

Project Manager: _________________ Date: 02/04/05 

 John Mauro, PhD, CHP 

Supersedes: 

Draft Rev. 0 

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

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

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

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

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

2.1 Skin Doses .............................................................................................................. 8 

2.2 Reviewer’s Comments............................................................................................ 8 

References....................................................................................................................................... 9 

Appendix A: IREP Input.............................................................................................................. 10 

Fernald Case #PIID* 3 S. Cohen & Associates 
1.0 SUMMARY BACKGROUND INFORMATION 

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

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

worked at the Feed Materials Production Company (FMPC or Fernald) as a PIID*, PIID*, and 

PIID* for approximately PIID* over two time periods; PIID*. Most of this employment period 

was spent in PIID*. 

As a result of the claimant’s employment, the worker experienced occupational exposures to 

external radiation sources, as well as exposure to internally deposited radioactive material. The 

worker was provided with film badge or TLD dosimeters to measure external exposures to 

gamma and beta radiation. Internal exposures were not evaluated by NIOSH for this case, so 

factors involved in the employee’s internal dose estimates were not evaluated. 

The employee was diagnosed with PIID*. He was also diagnosed with basal cell carcinoma on 

two occasions; PIID* (right temple), and PIID* (cheek). Because skin cancer was involved, 

NIOSH first determined the probability of causation (POC) for the skin cancer due to external 

exposure alone. Annual external beta dose was determined from DOE dosimetry records, and 

the results were input into IREP. Based on a partial dose reconstruction, this case was 

determined to have a POC of 54.23% for the basal cell carcinomas. 

Table 1 presents an overall summary of NIOSH’s dose reconstruction. 

Table 1. Summary of External Exposures as Estimated by NIOSH 

Appendix A 

Exposure Entry No.

Dose 

(rem) 

External Dose: 

 ▪ Electron (>15 keV) 

 Dosimeter Dose 1 – 22 23.697 

 ▪ Photon Dosimeter Dose NC* — 

 ▪ Photon Missed Dose NC* — 

 ▪ Neutron Dosimeter Dose NC* — 

 ▪ Neutron Missed Dose NC* — 

 ▪ Occupational Medical NC* — 

 ▪ Onsite Ambient NC* — 

Internal Dose: NC* — 

Total 23.697 

*NC = Not considered because exposure scenario was not needed to show causation 

Fernald Case #PIID* 4 S. Cohen & Associates 
1.1 AUDIT OBJECTIVES

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

• To determine if NIOSH assigned doses that are consistent with monitoring 

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

report 

• To determine if the dose reconstruction process complied with applicable 

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

well as data/procedures that are site-specific 

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

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

favorable 

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

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

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

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

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

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

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

favorable. 

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

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

1.2 SUMMARY OF AUDIT FINDINGS 

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

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

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

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

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

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

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

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

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

follows.

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

CASE #PIID* PIID* ASSIGNED DOSE: 23.697 rem POC: 54.23% 

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

A. REVIEW OF DATA COLLECTION: 

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

AWE site from any relevant data source? T

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

make a determination with regard to POC? T

B. REVIEW OF INTERVIEW AND DOCUMENTATION PROVIDED BY CLAIMANT 

B.1 Did NIOSH properly address all work history 

dates/locations of employment reported by claimant? T

B.2 Did NIOSH properly address all 

incidents/occurrences reported by claimant? T

B.3 Did NIOSH properly address monitoring/ personal 

protection/work practices reported by claimant? T

B.4 Is the interview information consistent with data used 

for dose estimate? T

C. REVIEW OF PHOTON DOSES 

C.1 Was the appropriate procedure used for determining: 

C.1.1 - Recorded Photon Dose? T T

C.1.2 - Missed Photon Dose? T

C.1.3 - Occupational Medical Dose? T

C.1.4 - Onsite-Ambient Dose? T

C.2 Did the DR properly account for all: 

C.2.1 - Recorded Photon Dose? T T

C.2.2 - Missed Photon Dose? T

C.2.3 - Occupational Medical Dose? T

C.2.4 - Onsite-Ambient Dose? T

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

C.3.1 - Recorded Photon Dose? T

C.3.2 - Missed Photon Dose? T

C.3.3 - Occupational Medical Dose? T

C.3.4 - Onsite-Ambient Dose? T

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

C.4.1 - Recorded Photon Dose? T

C.4.2 - Missed Photon Dose? T

C.4.3 - Occupational Medical Dose? T

C.4.4 - Onsite-Ambient Dose? T

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

D.1 Was the appropriate procedure used for determining: 

D.1.1 - Recorded Shallow/Electron Dose? T T

D.1.2 - Missed Shallow/Electron Dose? T

D.1.3 - Onsite Ambient Dose? T

D.2 Did the DR properly account for all: 

D.2.1 - Recorded Shallow/Electron Dose? T T

D.2.2 - Missed Shallow/Electron Dose? T

D.2.3 - Onsite Ambient Dose? T

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

D.3.1 - Recorded Shallow/Electron Dose? T

 

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

Fernald Case #PIID* 6 S. Cohen & Associates 
CASE #PIID* PIID* ASSIGNED DOSE: 23.697 rem POC: 54.23% 

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

D.3.2 - Missed Shallow/Electron Dose? T

D.3.3 - Onsite Ambient Dose? T

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

D.4.1 - Recorded Shallow/Electron Dose? T

D.4.2 - Missed Shallow/Electron Dose? T

D.4.3 - Onsite Ambient Dose? T

E. REVIEW OF NEUTRON DOSES 

E.1 Was the appropriate procedure used for determining: 

E.1.1 - Recorded Neutron Dose? T

E.1.2 - Assigned Neutron Dose? T

E.1.3 - Missed Neutron Dose? T

E.2 Did the DR properly account for all: 

E.2.1 - Recorded Neutron Dose? T

E.2.2 - Assigned Neutron Dose? T

E.2.3 - Missed Neutron Dose? T

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

E.3.1 - Recorded Neutron Dose? T

E.3.2 - Assigned Neutron Dose? T

E.3.3 - Missed Neutron Dose? T

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

E.4.1 - Recorded Neutron Dose? T

E.4.2 - Assigned Neutron Dose? T

E.4.3 - Missed Neutron Dose? T

F. REVIEW OF INTERNAL DOSE: BASED ON HYPOTHETICAL MODEL 

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

model appropriate, based on the likely POC value? T

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

appropriate/conservative, based on claimant’s 

available bioassay data,? 

T

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

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

G.1 Was the appropriate procedure (or section of 

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

unlikely (<50%), or undetermined POC and 

compensability? 

T

G.2 Are bioassay data sufficiently adequate for internal 

dose reconstruction? T

G.3 Are assumptions pertaining to dates of uptake 

reasonable/conservative? T

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

size, etc.) used for IMBA organ dose estimates 

appropriate? 

T

G.5 Are assigned uncertainties (measurement errors) for 

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

H. Total Number of Deficiencies and Their Combined Potential Significance 4 T

_____________________________ 

1

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

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

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

Fernald Case #PIID* 7 S. Cohen & Associates 
2.0 AUDIT OF EXTERNAL DOSES 

2.1 SKIN DOSES 

Appendix A presents the results of NIOSH’s partial reconstruction of the external annual skin 

doses to the energy employee for the purpose of deriving the probability of causation (POC) 

using IREP. These annual skin doses due to beta radiation were determined by subtracting the 

DOE-reported deep dose equivalent for each year from the DOE-reported shallow dose 

equivalent for that year. The net skin dose was entered as a “constant” value. 

The skin dose is an underestimate of the total dose received, since the photon deep dose and 

dose from internally deposited radionuclides were not considered. The POC for the two basal 

cell carcinomas taken together was determined by NIOSH to be 54.23%. 

2.2 REVIEWER’S COMMENTS 

As part of this audit, SC&A was able to duplicate the skin doses as “defined” by the protocol 

used by NIOSH. SC&A also recognizes that NIOSH may have opted to employ a “simplified” 

dose reconstruction approach that is considered “efficient,” as provided by 42 CFR 82. In 

instances where the POC is likely to exceed 50%, efficiency measures allow for a partial or 

limited dose reconstruction. Thus, SC&A fully accepts a dose reconstruction that is confined to 

the measured external shallow dose for a claim involving skin cancer. 

What SC&A does not consider scientifically appropriate and clearly not “efficient” was 

NIOSH’s decision to unnecessarily subtract the deep dose from the shallow dose for deriving the 

skin dose. When properly calibrated, the shallow dose defines the dose at 7 mg/cm2

, which is the 

appropriate dose that is assigned to the skin. (See Section 6.3.1 of ORAUT-PROC-0006, and 

Attachment A, page 41, of ORAUT-PROC-0006; and the most recently issued procedure 

ORAUT-OTIB-0017, Interpretation of Dosimetry Data for Assignment of Shallow Dose.) The 

shallow dose may be the result of photons, betas, or neutrons, or any combination of these 

radiations. Under normal circumstances, the recorded annual shallow doses would be assumed 

to have an uncertainty, which was not included. In behalf of dose reconstruction efficiency, 

however, the failure to include uncertainty for recorded doses is justified. 

Due to the fact that the partial dose reconstruction that was limited to external film dosimeter 

measurements sufficed in producing a POC >50%, neither internal dose estimates nor other 

external dose estimates were required for this case. 

Fernald Case #PIID* 8 S. Cohen & Associates 
REFERENCES 

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

Revision 1. August 2002. 

Fernald Case #PIID* 9 S. Cohen & Associates 
APPENDIX A: IREP INPUT

Deletions made to the following table -- please see hard copy labeled "#17- Fernald" 

Fernald Case #PIID* 10 S. Cohen & Associates