Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

RESPONSE TO NIOSH’S REVIEW OF SC&A’S NEVADA TEST 

SITE RESUSPENSION ISSUES STATUS REPORT

Contract No. 211-2014-58081 

SCA-TR-2016-SP010, Revision 0 

Prepared by

Lynn Anspaugh, PhD 

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

December 2016

DISCLAIMER

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

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

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

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

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

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

issues.

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: Response to NIOSH’s Review of SC&A’s Nevada Test Site 

Resuspension Issues Status Report

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SP010 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: December 21, 2016

TASK MANAGER: Arjun Makhijani, PhD [signature on file]

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

DOCUMENT 

REVIEWER(S):

John Mauro, PhD, CHP [signature on file]

John Stiver, MS, CHP [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 12/21/2016 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 5

1.0 Introduction ......................................................................................................................... 7

2.0 SC&A Comments on Nevada Test Site Resuspension Issues ............................................ 9

2.1 Comment 1 .............................................................................................................. 9

2.1.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 1, page 7............................................................................................................9

2.1.2 NIOSH (2016) Response, Part 1, page 1 .....................................................9

2.1.3 SC&A Resolution Comments, Part 1...........................................................9

2.1.4 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 2, pages 7–8 ......................................................................................................9

2.1.5 NIOSH (2016) Response, Part 2, page 1 ...................................................10

2.1.6 SC&A Resolution Comments, Part 2.........................................................10

2.1.7 SC&A Recommendations to the Nevada Test Site Work Group ..............10

2.2 Comment 2 ............................................................................................................ 11

2.2.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 1, page 8..........................................................................................................11

2.2.2 NIOSH (2016) Response, Part 1, page 2 ...................................................11

2.2.3 SC&A Resolution Comments, Part 1.........................................................12

2.2.4 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 2, page 8..........................................................................................................12

2.2.5 NIOSH (2016) Response, Part 2, page 3 ...................................................12

2.2.6 SC&A Recommendations to the Nevada Test Site Work Group ..............13

2.3 Comment 3............................................................................................................ 13

2.3.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 1, page 8..........................................................................................................13

2.3.2 NIOSH (2016) Response, Part 1, pages 3–4 ..............................................13

2.3.3 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 2, pages 8–9 ....................................................................................................13

2.3.4 NIOSH (2016) Response, Part 1, page 3 ...................................................14

2.3.5 SC&A Recommendations to the Nevada Test Site Work Group ..............14

2.4 Comment 4 ............................................................................................................ 14

2.4.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

page 9 ...................................................................................................................14

2.4.2 NIOSH (2016) Response, pages 4–6 .........................................................14

2.4.3 SC&A Resolution Comments ....................................................................15
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2.4.4 SC&A Recommendations to the Nevada Test Site Work Group ..............16

2.5 Comment 5 ............................................................................................................ 16

2.5.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

page 9 ...................................................................................................................16

2.5.2 NIOSH (2016) Response, pages 6–8 .........................................................16

2.5.3 SC&A Resolution Comments ....................................................................18

2.5.4 SC&A Recommendations to the Nevada Test Site Work Group ..............28

2.6 Comment 6 ............................................................................................................ 29

2.6.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 1, pages 9–10 ..................................................................................................29

2.6.2 NIOSH (2016) Response, Part 1, page 8 ...................................................29

2.6.3 SC&A Resolution Comments, Part 1.........................................................29

2.6.4 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 2, page 10........................................................................................................30

2.6.5 NIOSH (2016) Response, Part 2, pages 8–10 ............................................30

2.6.6 SC&A Resolution Comments, Part 2.........................................................31

2.6.7 SC&A Recommendations to the NTS Work Group ..................................31

2.7 Comment 7 ............................................................................................................ 31

2.7.1 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 1, page 10........................................................................................................31

2.7.2 NIOSH (2016) Response, Part 1, page 10 .................................................32

2.7.3 SC&A Resolution Comments, Part 1.........................................................32

2.7.4 SC&A (2015) Original Statement as Taken from the Executive Summary, 

Part 2, page 10........................................................................................................32

2.7.5 NIOSH (2016) Response, Part 2, pages 10–12 ..........................................33

2.7.6 SC&A Resolution Comments, Part 1.........................................................33

3.0 Summary of Recommendations to the Nevada Test Site Work Group ............................ 34

4.0 References ......................................................................................................................... 35
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

Am americium

Be beryllium

Bq becquerel

CF correction factor

Ci curie

Co cobalt

Cs cesium

DOE U.S. Department of Energy 

ER evaluation report 

ET extra-thoracic region

Eu europium 

HHS U.S. Department of Health and Human Services 

IMBA Integrated Modules for Bioassay Analysis

LN lymph node 

MDA minimum detectable activity

MeV mega-electron volt 

mR milliroentgen

NIOSH National Institute for Occupational Safety and Health

NRDS Nuclear Rocket Development Station

NTS Nevada Test Site

ORAUT Oak Ridge Associated Universities Team

ORERP Off-Site Radiation Exposure Review Project 

OTIB ORAUT technical information bulletin

pCi picocurie 

Pu plutonium 

RIDP Radionuclide Inventory and Distribution Program 

SEC Special Exposure Cohort 

Sr strontium 

SRDB Site Research Database

TBD technical basis document 
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TH thoracic

U uranium 

WG Work Group 
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1.0 INTRODUCTION

SC&A, Inc., has had an ongoing task to assist the Advisory Board on Radiation and Worker 

Health (ABRWH) and its Nevada Test Site (NTS) Work Group (WG) in evaluating site-profile 

(also known as technical basis documents [TBDs]) and other issues related to the NTS. This 

process began with SC&A’s (2005) review of the initial (2004) versions of the National Institute 

for Occupational Safety and Health (NIOSH)/Oak Ridge Associated Universities Team 

(ORAUT) six-part TBD. The many issues discussed by SC&A (2005) were summarized in an 

issue-resolution matrix (SC&A 2006). 

Over the years, many of the original issues have been resolved through the addition of two 

classes of employees to the Special Exposure Cohort (SEC) and by improvements in the NTS 

site-profile documents (or TBDs). SEC Petition No. 55 was approved and became effective on 

July 26, 2006, for NTS workers from January 27, 1951, through December 31, 1962, who 

worked an aggregate of at least 250 work days (HHS 2006). SEC Petition No. 84 was approved 

and became effective on May 5, 2010, for NTS workers from January 1, 1963, through 

December 31, 1992, who worked an aggregate of at least 250 work days (HHS 2010). SEC 

Petition No. 84 did not have an easy path to approval. The initial petition evaluation report 

(NIOSH 2007) was against approval. After extensive discussions among persons from the NTS 

WG, NIOSH, ORAUT, and SC&A, the NTS WG (ABRWH 2009b) voted to recommend that the 

ABRWH approve SEC Petition No. 84. The final NIOSH evaluation report was in favor of 

approval (NIOSH 2010) and was forwarded to the members of the ABRWH. The members of 

the ABRWH unanimously approved SEC Petition No. 84 (ABRWH (2010). 

The technical volumes of the NTS site profile (TBDs) have undergone as many as three 

revisions. At the June 2012 meeting of the ABRWH, SC&A was tasked with updating the NTS 

issue resolution matrix. The matrix, along with extensive discussion, was published as SC&A 

(2012). Twenty-six issues were identified in this update; some, but by no means all, of the issues 

were noted to have been closed by the granting of the SEC petitions or by other means. One 

outstanding issue was Issue 5 related to resuspension, and it was noted that several other matrix 

issues depended on resolution of Issue 5. 

The most recent meeting of the NTS WG (ABRWH 2014) was held on December 3, 2014, with 

the goal of resolving the matrix issues. Several of the issues were closed, but Issue 5 on 

resuspension could not be closed satisfactorily and it was again noted that several issues 

depended on the resolution of Issue 5. SC&A was tasked with reviewing the resuspension issue 

and the information on that subject contained in Revision 03 to the occupational environmental 

dose volume of the NTS site profile, ORAUT-TKBS-0008-4 (ORAUT 2012). A general 

conclusion has been that it is not possible to consider resuspension issues related to persons 

actively working in dust-enhancing conditions (such as running a bulldozer), but it would be 

necessary to concentrate only on general dust loading in the absence of worker-specific 

activities. It was also concluded that these general resuspension issues could be treated only for 

the time period after the cessation of atmospheric testing. 

The continuing concern about resuspension and other issues remains despite the approval of SEC 

Petitions 55 and 84. But it is understood that any procedures of dose reconstruction are meant to 

apply only to claimants who do not meet the criteria for inclusion in the SEC. The primary area 
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of application would be for claimants who do not have presumptive diseases that would 

automatically enroll them in the SEC.

SC&A published its latest status report on resuspension issues in July 2015 (SC&A 2015). Eight 

comments (issues) were identified, which are discussed in detail below. NIOSH (2016) 

responded with replies to the eight comments; further, NIOSH produced “white papers” on 

Comment 5 (Strenge 2016) and Comment 8 (Rollins 2016). 

The purpose of this current report is to discuss the responses received from NIOSH and its 

contractors with a goal of finding a clear path to closure of the resuspension issue. SC&A will 

conclude the discussion of each comment with a clear recommendation to the members of the 

NTS WG.

Finally, SC&A notes that there are several other issues in the NTS issue matrix that have not 

been resolved (ABRWH 2014) and will not be resolved with the closure of the resuspension 

issue. SC&A has not been tasked to consider any issue other than resuspension. 
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2.0 SC&A COMMENTS ON NEVADA TEST SITE RESUSPENSION 

ISSUES

2.1 COMMENT 1

2.1.1 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 1, 

page 7

On Page 12, Section 4.1.2 of the TBD (ORAUT 2012), the following statement is 

made:

“Therefore, dose reconstructions for individuals employed at NTS 

during the period from 1951 through December 31, 1992, but who 

do not qualify for inclusion in the SEC, can be performed using 

these data as appropriate.”

We have concern with this statement because the TBD actually provides a 

protocol for reconstructing the internal doses from resuspension of radionuclides 

from January 1, 1963, through December 31, 1992. This statement should be 

corrected.

2.1.2 NIOSH (2016) Response, Part 1, page 1

NIOSH agrees that additional clarification should be added to ORAUT-TKBS0008-4 (the NTS environmental TBD) to instruct dose reconstructors to include 

environmental inhalation and ingestion intakes as prescribed in Sections 4.2.1.2 

and 4.2.2, respectively, beginning on January 1, 1963.

2.1.3 SC&A Resolution Comments, Part 1

It is clear that occupational environmental dose cannot be reconstructed back to 1951, although 

that might have been the original intent. A more important question (also addressed below for

Comments 2 and 5) is whether occupational environmental dose should be extrapolated back to 

July 1962. The method specified in ORAUT (2012) is based on measurements of concentration 

of plutonium in air starting in 1971 and measurements of radionuclides in soil in the 1980s with 

extrapolation of air concentrations back to January 1, 1963, based on a time-dependent 

resuspension model. A stated goal has been to calculate occupational environmental dose back to 

the end of atmospheric testing, which ended on July 17, 1962 (DOE 2000). Thus, there is no 

reason why this method cannot be applied back to the period when atmospheric testing ended.

2.1.4 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 2, 

pages 7–8

We also have a concern with the following statement made in Appendix A of the 

TBD:

“If an internal exposure was suspected, bioassay was performed.

Managing radioactive material in the form of devices was episodic 
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and limited to a few workers (e.g., radiation safety and industrial 

hygiene personnel, miners, and experimenters). These workers are 

identified on the rosters that were published before the event, and 

these workers are likely to have bioassay results in the DOE 

records.” 

It is our understanding that an SEC was granted in part because there were 

inadequate bioassay data and many employees were exposed in situations where 

there were no rosters, thereby precluding the ability to develop a co-worker 

model. This topic was discussed thoroughly during the NTS WG meetings on 

October 29, 2008 (ABRWH 2008); April 23, 2009 (ABRWH 2009a); and 

December 15, 2009 (ABRWH 2009b). 

2.1.5 NIOSH (2016) Response, Part 2, page 1 

NIOSH agrees and will make the following change to the Attachment A text: 

“These workers are usually identified on the rosters that were published before 

the event, and these workers are likely to have bioassay results in the DOE 

records.” 

2.1.6 SC&A Resolution Comments, Part 2

The NIOSH response about workers on rosters being likely to have bioassay results in the U.S. 

Department of Energy (DOE) records is directly contradicted by NIOSH’s own final analysis of 

SEC Petition No. 84 (NIOSH 2010, page 68): 

Upon completion of this review, there are still remaining data gaps and concerns 

associated with NTS internal monitoring data that bring into question NIOSH’s 

ability to bound all NTS internal exposures. NIOSH believes that there is 

insufficient information to adequately support bounding internal dose 

(reconstructing internal dose with sufficient accuracy) for the portion of the 

SEC-00084 NTS class who worked during the period of testing from 1963 through 

1992. 

2.1.7 SC&A Recommendations to the Nevada Test Site Work Group 

1. Change the time period for the reconstruction of occupational environmental dose to 

July 17, 1962, through December 31, 1992. The same method can be used as NIOSH is 

now doing for a start period of January 1, 1963. Such a change would be substantively 

more claimant favorable and can be performed using scientifically valid methodologies 

for time periods that extend back to the latter half of 1962. 

2. Change the statement about rosters and bioassay results to a more valid statement:

“These workers may have been identified on the rosters that were 

published before the event, and these workers may have had bioassay 

results in the DOE records.” 
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2.2 COMMENT 2

2.2.1 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 1, 

page 8

A method for analyzing chronic environmental exposures associated with 

resuspension processes is provided for the time period beginning in January 1, 

1963, approximately 6 months after the “last above ground test.”3 Inspection of 

the Anspaugh et al. (2002) resuspension-factor equation reveals that by 180 days 

after deposition, the resuspension factor drops down to about 5 × 10-9

/m. For 

earlier times, closer to the end of above ground testing, the resuspension factors, 

according to the Anspaugh model, are orders of magnitude greater. SC&A 

believes that it is possible to back extrapolate the dose reconstruction to mid1962, at the end of above ground testing. Such calculations would be more 

complete and will likely reveal substantially higher doses from resuspension 

during that 6-month period. The intended time period of coverage for these 

calculations should be discussed and agreed upon with the members of the NTS 

WG. There is no reason that the important time period of July 1962 to 

December 31, 1962, is not included in the material in the TBD....

3 ORAUT (2012) repeatedly refers to Small Boy (July 14, 1962, “low” yield) as the last 

above ground test. Actually, the last above ground test was Little Feller I (July 17, 1962, “low” 

yield). Other above ground, surface, or cratering tests during the month of July 1962 were Sedan 

(July 6, 1962, 104 kt, fission yield less than 30%); Little Feller II (July 7, 1962, “low” yield), and 

Johnnie Boy (July 11, 1962, 500 t). Sedan and Johnnie Boy were cratering events. The Sedan 

event was the most important event in terms of release of radionuclides. The event data are taken 

from DOE (2000).

2.2.2 NIOSH (2016) Response, Part 1, page 2

The evaluation report for SEC-00055 (SRDB Ref ID: 150574) [NIOSH 2006], 

which covers the time period of 1/27/51 – 12/31/62, specifically discusses the 

inability to reconstruct doses between the cessation of testing in July of 1962 and 

the end of that year. The last paragraph of section 4.5 states:

“Above-ground testing at the NTS began on January 27, 1951, and 

concluded on July 17, 1962. NIOSH considers reconstruction of 

internal doses at the NTS feasible for periods after cessation of 

atmospheric testing beginning on January 1, 1963. During the 

period of atmospheric testing, the source term to which workers 

were exposed changed with each detonation, due mainly to 

re-suspension and mixing of fallout caused by the blast waves. 

After the final above-ground test, NIOSH considers the 

radiological source term to be sufficiently stable so as to allow 

assumptions adequate for dose reconstruction. The extension of the 

SEC period through December 31, 1962, approximately six months 

after the last atmospheric test, allows time for the stabilization of 
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the source term and for decay of the shorter-lived radionuclides 

associated with the final atmospheric tests.” 

In addition, the ER for SEC-0084 (SRDB Ref ID: 77699) [NIOSH 2007] describes 

a model for the reconstruction of environmental internal doses beginning on 

1/1/63. Thus, the ERs for the SECs are clear on the time period for which 

environmental doses can be reconstructed. 

2.2.3 SC&A Resolution Comments, Part 1

In the comments above, NIOSH has relied on the evaluation report (NIOSH 2006) for SEC 

Petition 55 and the initial evaluation report (NIOSH 2007) for SEC Petition 84. Each of these 

two reports indicated that NIOSH had the ability to reconstruct internal dose beginning from 

January 1, 1963, through December 31, 1992. However, the final evaluation report (NIOSH 

2010) found that NIOSH could not reconstruct internal dose from January 1, 1963, through 

December 31, 1992, and SEC Petition 84 was approved. Thus, the conclusion that internal dose 

could not be reconstructed was valid for January 27, 1951, through December 31, 1992, and 

there is no longer a dividing line at January 1, 1963. The real question then becomes, “Where is 

the logical dividing line for the reconstruction of occupational environmental dose?” It seems 

clear that this dividing line should be the end of atmospheric testing, as frequently suggested in 

ORAUT (2012). 

As the method in ORAUT (2012) is just as applicable back to July 1962 as it is back to 

January 1, 1963, failure to calculate occupational environmental dose back to July 1962 would 

be unfair to claimants who worked during the latter half of 1962. 

2.2.4 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 2, 

page 8 

Further confusion on this point arises from the following statement on Page 42 of 

the TBD under Instruction to Dose Reconstructors: 

“With the exception of cases that can be worked using the 

bounding assumption in ORAUT-OTIB-0018 (ORAUT 2005 

[“OTIB-0018”]), environmental inhalation and ingestion intakes 

listed in Tables 4-7 and 4-11, respectively, shall be applied 

starting in 1964.”

OTIB-0018 seems to be an inappropriate reference within the context of outdoor 

chronic exposures at the NTS. OTIB-0018 is more appropriately employed 

indoors at sites that have a comprehensive health physics and airborne 

monitoring program, which is not the case for the NTS. 

2.2.5 NIOSH (2016) Response, Part 2, page 3 

The referenced exception does not infer that OTIB-0018 intakes would be applied 

instead of environmental intakes. OTIB-0018 intakes are typically applied as an 

efficiency method to obviate the need to assess negative (less than MDA) bioassay 
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data for non-compensable cases. When OTIB-0018 intakes are applied, the 

addition of environmental intakes is unnecessary because the OTIB-0018 intakes 

envelope the environmental intakes.

NIOSH also recently provided two white papers on this subject. Strenge (2016) addresses 

Comment 5 (discussed in Section 2.5 below) but also includes the same information as above as 

to why the start time for the reconstruction of occupational environment dose should be January 

1, 1963. Rollins (2016) addresses Comment 8 (addressed by SC&A in a memorandum dated 

December 16, 2016) and includes NIOSH’s justification for using OTIB-0018. 

2.2.6 SC&A Recommendations to the Nevada Test Site Work Group 

The recommendation to extend the period of reconstruction of occupational environmental dose 

to July 17, 1962, is already Recommendation 1 under Comment 1. 

Comments and recommendations about the use of OTIB-0018 are addressed in SC&A’s (2016) 

memorandum about Comment 8. 

2.3 COMMENT 3

2.3.1 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 1, 

page 8 

It is important that the time period to be covered be carefully considered by the 

members of the NTS WG. SC&A believes that the logical time period to be 

covered is July 1962 through December 31, 1992. 

2.3.2 NIOSH (2016) Response, Part 1, pages 3–4 

See response to Issue 2 above. [Regarding the July 1962 start date]

2.3.3 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 2, 

pages 8–9 

The method of environmental occupational dose reconstruction is strongly based 

upon measurements of the concentrations of Pu-239/240 in air samples starting in 

1971. SC&A was originally concerned that the air-sampling locations were not 

representative of the locations where workers were exposed. We originally 

detailed these concerns in the Anspaugh report dated October 21, 2008 

(Anspaugh 2008). At that time, these concerns were based on the assumption that 

our interest was in “active environments” where operational activities were 

ongoing. However, within the context of using these air-sampling data as a means 

to characterize airborne Pu-239/240 concentrations during relatively quiescent 

conditions, referred to as chronic environmental exposure, these concerns are 

greatly diminished. It is important to note that the current scope of dose 

estimation from residual radioactivity is limited to environmental dose not 

associated with work activities. Exposure during work-related activities that 

disturb soil is not included within the scope of the TBD.
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2.3.4 NIOSH (2016) Response, Part 1, page 3

NIOSH agrees with this observation.

2.3.5 SC&A Recommendations to the Nevada Test Site Work Group

The recommendation to extend the period of reconstruction of occupational environmental dose 

to July 17, 1962, is already Recommendation 1 under Comment 1.

2.4 COMMENT 4

2.4.1 SC&A (2015) Original Statement as Taken from the Executive Summary, page 9

The soil radionuclide inventory data collected in the 1980s by the Radionuclide 

Inventory and Distribution Program (RIDP) (Kordas and Anspaugh 1982; 

McArthur 1991) characterized soil contamination at the site during the 1980s.

However, the TBD extrapolates back in time to derive the soil contamination 

levels that were present on January 1, 1963,4 so that doses could be reconstructed 

from the resuspension process during early years following the end of 

aboveground testing. One of the limitations of the back extrapolation process 

used in the TBD is there is evidence that some areas were decontaminated 

(McArthur 1991, p. 34) before the RIDP measurements were made. Also, 

significant contamination occurred in Areas 20 and 30 from Plowshare activities 

after 1963, and the Baneberry event in 1970 produced major contamination in 

Areas 8 and 12. These concerns need to be addressed in terms of the degree to 

which the TBD remains scientifically sound and claimant favorable, 

notwithstanding these events....

4 SC&A believes that this back extrapolation should be to July 1962.

2.4.2 NIOSH (2016) Response, pages 4–6

In order to assure that intakes and resultant doses from environmental intakes 

was not underestimated, NIOSH used the highest measurement of airborne 

plutonium to calculate reasonable intakes for all other years and all other areas. 

The highest measured airborne concentration measured in any area was in 1972 

in Area 9 of 4.3 x 10-3 pCi/m3. To determine the intake, exposure to this 

concentration was assumed to be 2,400 m3 per year which resulted in a calculated 

intake of 0.381 Bq/yr. To determine bounding intakes for other radionuclides 

measured in the NTS soils but not measured by air sampling (e.g., Am-241, 

Pu-238, Co-60, Cs-137, Sr-90 and Eu-152, 154, and 155), the maximum ratio of 

these radionuclides to Pu-239 for all areas was used. These methods would 

mitigate the effects of decontamination venting in later years. In section 3.1 of the 

Resuspension Issue Status Report (Status Report on Resuspension Issues at the 

Nevada Test Site, Contract No. 211-2014-58081, Rev, S.Cohen & Associates, 

Vienna, VA, July 2015), on page 19, the following statement is made: 
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“For example, by selecting the location and year with the highest 

annual average airborne plutonium concentration for the purposes 

of partial dose reconstruction, there is a level of assurance that 

reconstructed internal exposures are claimant favorable for all 

workers during those time periods, and also for earlier time 

periods where back-extrapolation was required. One could also 

argue that this strategy would be reasonable for earlier time 

periods and locations, even for locations that were cleaned-up 

prior to the commencement of the air-sampling program.” 

In Section 3.1, on page 21 of the Resuspension Issue Status Report, the following 

statements appear: 

“The TBD acknowledges that the portion of the NTS where the 

RIDP data are provided is limited to only about one-third of the 

entire area of the NTS. However, the areas selected for the RIDP 

were those with measurable levels of contamination in soil above 

ubiquitous background. Hence, it certainly appears that a 

combination of the air-sampling data and the RIDP soil-inventory 

data can be used to assign chronic intakes of these nine 

radionuclides to workers. In addition, if high-end air-sampling and 

soil-inventory data are used, reconstructed doses associated with 

the chronic inhalation of these nine radionuclides would seem to 

be reasonably bounding. As presented in Table 4-6 of the TBD, 

this is, in fact, the approach adopted in the TBD to reconstruct 

radionuclide intake rates.” 

For these reasons, NIOSH believes the maximum intakes provided in Table 4-6 of 

the NTS environmental TBD to be scientifically sound and claimant favorable 

even if specific consideration is given to decontamination activities and loss of 

containment incidents.

2.4.3 SC&A Resolution Comments

As stated in SC&A (2015), SC&A agrees with NIOSH that the RIDP data have been used as 

well as possible, and that the prior cleanup of a few areas has generally been compensated for by 

the application method. There are, however, lingering concerns about the data for the Nuclear 

Rocket Development Station (NRDS). These areas had been extensively cleaned up before the 

RIDP program made measurements. There are other issues about the NRDS that have not been 

resolved; these issues were highlighted in the December 14, 2012, version of the NTS issue 

matrix (SC&A 2012). 

Also, there are still concerns about subsequent heavily contaminating events that occurred in 

Areas 20 and 30 from Plowshare activities after 1963 and the Baneberry event in 1970 that 

produced major contamination in Areas 8 and 12. Baneberry remains one of the unresolved 

issues from the December 2012 NTS matrix (SC&A 2012). 
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2.4.4 SC&A Recommendations to the Nevada Test Site Work Group 

None regarding resuspension issues. 

2.5 COMMENT 5

This is one of the more complex issues and goes well beyond the brief statement given in the 

Executive Summary of SC&A (2015). Generally, this issue encompasses the method of 

correction for the presence of short-lived radionuclides that were not measured by the RIDP and 

includes the method of calculation of dose from inhalation. The discussion here about Comment 

5 spills over into the discussion about Comments 6 and 7, but Comments 6 and 7 will also be 

discussed separately below.

First, the original SC&A Comment 5 is presented below (Section 2.5.1), as well as the matrix 

reply from NIOSH (Section 2.5.2). NIOSH also provided a white paper (Strenge 2016) that 

addresses the issues within Comment 5. The NIOSH response and the Strenge report are 

addressed in the SC&A resolution comments in Section 2.5.3 below. 

2.5.1 SC&A (2015) Original Statement as Taken from the Executive Summary, page 9 

Derivation of the concentration of relatively short-lived radionuclides in soil for 

January 1, 1963, employed the Hicks’ tables (Hicks 1982) for the Small Boy event 

that occurred on July 14, 1962. In fact, the contamination in soil on January 1, 

1963, reflects fallout from numerous tests that resulted in surface contamination, 

such as the Sedan test on July 6, 1962, and Little Feller II on July 7, 1962, which 

occurred shortly before Small Boy, and Little Feller I that occurred after Small 

Boy on July 17, 1962. As such, NIOSH should address whether tests shortly 

before and after Small Boy on July 14, 1962, could also have contributed 

substantively to the fallout levels in soil derived for January 1, 1963. In a related 

matter, the protocol used in the TBD to account for fractionation is overly 

simplistic and appears to rely primarily on the Small Boy event. NIOSH will need 

to demonstrate that the approach used to account for fractionation does not 

substantively underestimate doses. 

2.5.2 NIOSH (2016) Response, pages 6–8 

Soil radionuclide concentrations corrected to 1963 (see Table 4-5 of the NTS 

environmental TBD) [ORAUT 2012] only included radionuclides that are 

persistent in the environment (e.g., Am-241, Pu-238, Co-60, Cs-137, Sr-90 and 

Eu-152, 154, and 155).[1

1 SC&A notes that Pu-239/240 is the only other radionuclide on that list.

]

 These radionuclides would include those deposited as a 

result of all atmospheric test and loss of containment incidents prior to the 1980s. 

The persistent radionuclides deposited after January 1, 1963 were still decay 

corrected back to January 1, 1963 so their contribution to the soil concentrations 

corrected to January 1, 1963 would have been overestimated since these incident 

related radionuclides would not have existed in the environment on January 1, 

1963. The same overestimate would occur for any persistent radionuclides 

 
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deposited as a result of the Plowshare program. Thus the soil radionuclide 

concentrations corrected to January 1, 1963 likely represent overestimates of the 

actual soil concentrations present at the time. 

In Section 3.4, page 25, of the NTS resuspension issues report, the following 

statement was made: 

“The Hicks’ tables that were used by NIOSH to support the 

reconstruction of environmental exposures onsite were actually 

originally derived for the purpose of evaluating offsite exposures. 

As a result, the Hicks’ tables understate the relative abundance of 

refractory elements onsite and overstate the presence of volatile 

elements.” 

In Section A.6, page 68, of the NTS environmental TBD [ORAUT 2012], the 

process of adding the refractories back into the mix is discussed in some detail. 

The discussion also includes a description of how the nearfield (i.e., NTS soils) 

was enriched with the refractories. Specifically, the NTS TBD [ORAUT 2012]

states the following: 

“Because the Hicks data were developed to estimate offsite levels 

of fallout and resultant dose, fractionation effects were simulated 

in these data by the removal of a fraction of the refractory nuclides 

from the calculated abundances. In general, air drops were 

assumed to be unfractionated and offsite fallout from surface and 

cratering tests was assumed to have 0.4 of the refractory elements. 

For all other types of tests, offsite fallout was assumed to have 0.5 

of the refractory elements present. Therefore, the refractory 

elements in the Hicks data must be adjusted to produce the best 

estimate of their enriched abundances in the onsite environment to 

which workers could have been exposed. Adjustment factors for 

each radionuclide were determined from data in Hicks (1984); this 

report provided relative abundances of radionuclides assuming no 

fraction, 50% fraction, and 90%[2] fraction of refractory elements. 

2 SC&A notes that this is an error. Hicks (1984) gives values for 100%, 50%, and 10% presence of refractories.

From these data, ratios were developed for the 50% fractionation 

case (Table A-8). These ratios were used to deplete the refractory 

elements in the far-field (i.e., offsite) environment to estimate doses 

to offsite individuals. Therefore, to enrich the near-field (i.e., 

onsite) environment, the inverse of these ratios was applied to the 

Hicks SMALL BOY data (see below). These inverse ratios were 

applied twice because the Hicks SMALL BOY data were provided 

to estimate fallout in the offsite environment. The first application 

results in the data that represent no fractionation while the second 

 
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application results in data that are enriched with refractory 

elements.’

NIOSH believes that the methods described above represent a reasonable 

treatment of refractories in the nearfield environment. However, NIOSH is 

continuing to research the methods used in the Hicks (1984) report for 

appropriateness for use in the NTS environmental TBD to assure that these 

methods are claimant favorable. 

2.5.3 SC&A Resolution Comments

NIOSH also provided a white paper (Strenge 2016) related to “short-lived radionuclide issues 

raised in Comment 5.” According to Strenge (2016, page 2), “This white paper describes the 

analysis method used to estimate the environmental dose from short-lived radionuclides during 

the period 1963 to 1972 at the Nevada Test Site (NTS). Results of the analysis method are 

presented to illustrate the impact of various assumptions.” 

Strenge (2016) starts by again stating that the occupational environmental dose cannot be 

calculated for the time period from the cessation of atmospheric testing (July 1962) to the end of 

that year. The usual arguments related to obsolete statements given in the evaluation report for 

SEC Petition 55 (NIOSH 2006) and the initial evaluation report for SEC Petition 84 (NIOSH 

2007) are the only reasons given. No mention is made of the final evaluation report for SEC 

Petition 84 (NIOSH 2010), and no scientific reason is provided why such doses cannot be 

calculated. The lack of the extension to July 1962 is unfair to any claimant who worked at the 

NTS during the latter half of 1962. 

ORAUT (2012) made use primarily of the Hicks’ tables for the Small Boy shot that occurred on 

July 14, 1962, and which had a “low” yield, and was “slightly above ground” (DOE 2000). 

Strenge (2016) also made additional calculations related to Little Feller I, which was the last 

atmospheric test at the NTS. Little Feller I occurred on July 17, 1962, had a “low” yield, and was 

also “slightly above ground.” SC&A (2015) had recommended examination of data for the Sedan 

event that occurred on July 6, 1962. The Sedan device was emplaced underground, but the depth 

of burial was not designed for containment of fallout. By design, the Sedan event produced a 

crater, which was 1,280 feet in diameter and 300 feet deep (DOE 2000). Sedan was also unique 

in that it had a large yield of 104 kt with at least 70% of that yield from fusion. In that regard 

Sedan was quite different from the other “atmospheric” shots at NTS, and that is why SC&A had 

recommended a specific look at the Sedan event. As an example, the normalized amount of some 

radioisotopes of tungsten was five orders of magnitude greater for Sedan than for Small Boy 

(Hicks 1981a). 

The calculations in ORAUT (2012) depend upon measured concentrations in air of 

plutonium-239/240 (Pu-239/240) beginning in 1971 with samplers in 15 locations and with six 

additional stations added in 1978. The calculations in ORAUT (2012) proceed with use of the 

maximum measured concentration of Pu-239/240 of 4.29 × 10-3 pCi m-3 recorded in Area 9 in 

1972. This is a very conservative assumption. With the assumption of 2,400 m3 year-1, that leads 

to an intake of Pu-239/240 of 0.381 becquerel (Bq) year-1. The next step in ORAUT (2012) was 

to obtain ratios of Pu-239/240 to other radionuclides that had been measured by the RIDP in the 
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1980s and decay corrected to 1963. This was possible as the RIDP measured not only 

Pu-239/240, but also americium-241 (Am-241), Pu-238, cobalt-60 (Co-60), cesium-137 

(Cs-137), strontium-90 (Sr-90), europium-152 (Eu-152), Eu-154, and Eu-155.3 These ratios 

allowed for the inference of the maximum airborne concentration of nine radionuclides based on 

the measurement of airborne Pu-239/240 and the ratios of the other eight radionuclides based on 

the ratios in soil. The remaining question was how to account for the short-lived radionuclides 

that were no longer present in soil in the 1980s. This is where the Hicks (1981a) tables come in. 

The Hicks tables do not tabulate the amount of Pu-239/240 created or spilled, but they do have 

values of Sr-90 for all tests. Thus, the RIDP soil data are used to infer airborne concentrations of 

Sr-90 based on the ratio in soil of Pu-239/240 to Sr-90, and the Hicks tables are then used to 

infer the airborne concentrations of many short-lived radionuclides based on the ratio of Sr-90 to

other radionuclides. 

3 ORAUT (2012) states that McArthur (1991) provided values for these radionuclides in soil as of 1991. This is a 

minor error, as McArthur clearly states that the values were decay corrected to January 1, 1990.

The Hicks tables were not created by or for NIOSH. They were created for DOE’s Off-Site 

Radiation Exposure Review Project (ORERP) (Church et al. 1990). Hicks’ (1982) calculations 

used the ORIGEN code (RSIC 1979) and Lawrence Livermore National Laboratory’s tabulated 

fission yields (Nethaway and Barton 1973) for fission spectrum or 14 MeV neutrons to calculate 

152 products from fission of uranium-233 (U-233), U-235, U-238 and/or Pu-239/240 depending 

on the specific features of a given device. Hicks also used data on device characteristics to 

calculate 25 activation products from device materials or other nearby material masses. These 

basic calculations were for unfractionated debris and are given as a function of time post 

detonation.4

 “The phenomenon of fractionation is due to both chemical and physical separation 

of the radionuclides” (Hicks 1982). It is well known that fractionation of volatile (at 1,500 °C) 

versus refractory elements does occur, and fallout debris downwind of a surface or near surface 

explosion is enriched in volatile elements.

4 Hicks gives three sets of tables for each explosion: values for 0–21 hours; 1–300 days, and 1–50 years.

The goal of the ORERP was to calculate external and internal dose downwind of explosions that 

occurred at the NTS. A major set of data available for these calculations was measured values of 

external gamma-exposure rate in the nearby states. The purpose of the Hicks data was to convert 

these exposure-rate measurements into the ground deposition of up to 177 fission and activation 

products. To converge the two sets of data, it was necessary to know the external gammaexposure rate per unit areal deposition for each of the 177 fission or activation products. The 

latter data were supplied by Beck (1980). 

The final form of the Hicks tables for unfractionated debris was in the form of the ground 

deposition for up to 177 radionuclides normalized to an external gamma-exposure rate of 

1 mR hour-1 at 12 hours post deposition (commonly referred to as mR hour-1 at H+12).

To account to fractionation downwind, Hicks assumed that 50% of refractory elements for tower 

shots were present, 40% for surface or near-surface events, and 100% for shots on balloons or air 

drops. For the Small Boy event, which was slightly above ground and with a low yield, the Hicks 

tables indicate clearly that the assumption was that 40% of refractories were considered for the 

downwind areas. After Hicks had removed 60% of the refractory elements, he then normalized 

 
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the data to an external gamma-exposure rate of 1 mR hour-1 at H+12. This renormalization is 

important in order to give the proper relationships among the radionuclides. 

To accomplish the wish of NIOSH to use the Hicks tables for Small Boy, the following steps are 

necessary

a. Starting with the calculation for 40% of refractors present in Hicks (1981a), add back in 

the 60% of refractory radionuclides missing to create an unfractionated source term. 

b. Renormalize the unfractionated source term to 1 mR hour-1 at H+12.

c. Starting with the now unfractionated source term, add in the 60% of refractory 

radionuclides that are presumed to have been left behind on the NTS. 

d. Renormalize the refractory-enriched source term to an external gamma-exposure rate of 

1 mR hour-1 at H+12.

These renormalizations cannot be done with the information provided in the Hicks tables alone.

It is necessary, as done by Hicks, to use the Beck (1980) data, or some more recent compilation 

of exposure rate per unit deposition, in conjunction with the Hicks tables. There is no indication 

this was done by either ORAUT (2012) or Strenge (2016). 

Strenge (2016, page 5) remarks of the Hicks tables that “Application of the refractory fraction is 

the only treatment of deposition of activity as the analysis did not include any atmospheric 

transport or deposition calculation.” This statement indicates that Strenge missed the key point 

that no calculations of atmospheric transport or deposition are needed for the ORERP, as the 

measured values of external gamma-exposure rate made along the downwind path of fallout have 

already defined both the atmospheric transport and deposition of radionuclides. Examples of 

how the Hicks tables fit into the calculation of internal doses from ingestion for the ORERP are 

given in Ng et al. (1990); examples for the calculation of external doses are given in Henderson 

and Smale (1990). 

ORAUT (2012, page 68) indicates that NIOSH calculated correction factors (Steps a and c 

above), but for the case of 50% (rather than the correct 40%) missing refractories based on Hicks 

(1984). However, Hicks (1984) deals with very large thermonuclear tests of up to 15,000 kt fired 

in the Pacific Islands. There can be no assurance that very large thermonuclear tests would 

provide the same mix of radionuclides as that from a small, presumably fission, test. And the use 

of the wrong value of missing refractories is significant. There is no reason why the data from 

large thermonuclear test should have been used. The correction factors derived in ORAUT 

(2012) are provided in Table A-8.5

5 ORAUT (2012), p. 69.

Strenge (2016) takes a different approach; his Table 1 simply lists the far field “Refractory 

Fraction Ratio” as either 0.4, 1.0, or other values for a few radionuclides that behave as a mixture 

of refractory and volatile elements. Strenge (2016) states that the data in table A-8 of ORAUT 

(2012) are shown in his Table 1. This is clearly not the case. For example, the value for

beryllium-7 (Be-7) in Table A-8 is given as 0.68, but it is 0.4 in Table 1. In fact, the bases of the 

 
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two tables are not the same; if Table A-8 had been expressed in the same manner as Table 1, 

Be-7 would have had a value of 0.5. As noted above, the correct value should be 0.4—the value 

stated by Strenge.

Strenge corrected for the missing refractories by dividing the values for refractory elements in 

Hicks’ tables for Small Boy and Little Feller I by 0.4 twice.6 However, there is no indication that 

Strenge renormalized the values, and he does not provide the reader with his new version of the 

“Hicks’ tables.” This is not an enormous task. Hicks’ original tables were provided for 0 to 21 

hours in five pages; 1 to 300 days in four pages; and 1 to 50 years in one page. 

6 Mass chains 91, 140, and 141 are treated specially, as they have both refractory and volatile elements. Values for 

volatile elements were not changed from those in Hicks (1981a).

From this point on, the description of how doses were calculated is murky in both ORAUT 

(2012) and Strenge (2016), and not enough intermediate information is provided in either 

document so that the reader (in this case, SC&A) can follow and verify the calculations. 

The central idea in both documents is that there is a measured air concentration of Pu-239/240 

starting in 1971. Then the RIDP data can be used to derive a “maximum scaling factor” of Sr-90 

to Pu-239/240, and then scaling factors of short-lived radionuclides to Sr-90 based on Hicks’ 

tables. Time-dependent corrections can be made using the Anspaugh et al. (2002) resuspension 

model.7 This straightforward idea becomes very complex in its application, when the process 

gets to the point of calculating doses from the shorter-lived radionuclides. 

7 An improved “modified Anspaugh model” is given in Maxwell and Anspaugh (2011).

Both documents indicate that it is necessary to calculate the dose from the inhalation (and 

subsequently ingestion) of Sr-90 as a function of time following deposition. Then, the relative (to 

Sr-90) dose for the up to 176 other radionuclides is calculated. Strenge (2016) states,

The relative activity of each radionuclide for a specific time (from five days to 

10 years) is entered into a spreadsheet that evaluates the relative dose from each 

radionuclide using inhalation or ingestion dose factors. The list of radionuclides 

excludes the radionuclides included in Table 4-7[8] (Am-241, Pu-238, Pu-239/240, 

Co-60, Cs-137, Sr-90, Eu-152, Eu-154, and Eu-155, except for strontium-90, 

because the dose from these radionuclides is included in other parts of the dose 

evaluation and assignment. 

8 From ORAUT (2012), p. 27.

The relative dose from strontium-90 is evaluated for times from 5 days to 3650 

days (10 years) for all internal organs of interest (and for which dose-conversion 

factors are available.) The array of relative dose values is entered into a 

spreadsheet that evaluates the correction factors for specific organs for each year 

of the 10-year period. The starting time is January 1, 1963, using the data offset 

from the time of the shot to the end of 1962, as in Table 2. [pages 13–14]

What is not clear from the above two paragraphs is the meaning of the evaluation time of “from 

five days” to 10 years. Does the five days start from the time of deposition? Or from January 1, 

1963, which is implied by the paragraph immediately above? If so, why should there be a lag 

 
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time of five days? It does not make much of a difference if the start date is January 1, 1963, but 

this is confusing regarding what was really done. Strenge (2016, pages 14–15) continues, 

The curve of relative dose from strontium-90 is integrated for each annual period, 

using the curve fit by Excel as either linear or polynomial (quadratic). The 

integral value is averaged over a 365-day period. The inverse of this integral is 

the correction factor to be used to estimate the dose from strontium-90 and 

associated short-lived fission and activation products. 

The correction factors are next used to estimate the internal dose from the shortlived fission and activation products. The IMBA program was used to calculate 

the internal dose to each organ from the intake of 1 Bq of strontium-90 type F 

material during a 1-year period. The dose from just the short-lived radionuclides 

is then calculated as shown in Equation 1. 

Equation 1. Annual dose from short-lived radionuclides based on Sr-90 intake 

rates.

Dosesl(year,i) = DCFi * [CF(year,i)-1] * IntakeSr-90(year)

Where, 

Dosesl(year,i) = dose to organ i from short-lived radionuclides during a 

given year based on intake of strontium-90, rem, 

DCFi = strontium-90 dose conversion factor for 1-year intake 

of 1 Bq, to organ i, rem/Bq, 

CF(year,i) = factor giving the dose from strontium-90 and shortlived radionuclides to organ i during a specific year, and 

IntakeSr90(year) = intake of strontium-90 for a specific year from 

Table 4-7, Bq/year. 

Note that the correction factor, CF(year,i) includes the dose from strontium-90 

and is always greater than or equal to 1.0. The subtraction of 1 in the equation 

removes the strontium-90 dose. The dose from strontium-90 is included when the 

intakes of Table 4-7 of the NTS TBD are applied in a dose reconstruction. 

This evaluation of dose is different from the method used in the previous analysis. 

Previously, the correction factors were applied to the dose commitment from 

strontium-90 in years after the first year. However, the dose factors for the shortlived radionuclides are 50-year dose commitments and include all possible dose 

from each radionuclide for the year of intake. The correction factors are 

developed for the year of intake. 

Unfortunately, Strenge does not provide results of the intermediate steps in these calculations 

and goes directly to his Table 3, which contains his “Dose Correction Factors for Various Organs 
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Based on Deposition from Event Small Boy.” These values are CF(year,i) as defined above and 

are given for each year from 1963–1972. More details were given in ORAUT (2012), which 

Strenge says in the paragraph above have been superseded. 

Nevertheless, it is useful to consider some of the material from ORAUT (2012) to help 

understand this complicated process. Figure 1 is a copy of Figure A-2 from ORAUT (2012). 

NIOSH states that it gives the fraction of the total dose to the lungs from Sr-90 at various times 

after detonation.

Figure 1. Reproduction of Figure A-2 from ORAUT (2012), p. 70 

It also shows the linear fit to the data as discussed by Strenge and ORAUT. From the information 

presented, it is difficult to know whether this curve really starts at time zero, or if it has an offset 

of 172 days as suggested in Strenge’s Table 2 (not reproduced here). As one might expect, the 

dose from Sr-90 becomes an increasingly larger fraction of dose as the short-lived radionuclides 

decay. SC&A’s understanding is that similar curves were constructed for 26 organs/tissues, and 

that necessitated Integrated Modules for Bioassay Analysis (IMBA) runs for up to 177 

radionuclides for several time periods from five minutes to 10 years. If that is what was done in a 

spreadsheet format, this was an enormous undertaking—almost incomprehensible.

Another important question is how the dose correction factors were calculated. A passage from 

Strenge quoted above states that yearly correction factors were calculated by integrating the 

curve fits as shown in Figure 1 and then averaging the integral over 365 days. This does not 

seem logical. Further confusion comes from statements within ORAUT (2012). There, the 

equation for Sr-90 fraction of dose to the lung is given as 

y = 0.0001x + 0.0074 , 

which does not quite match the equation shown in Figure 1. ORAUT (2012) goes on to say, 
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Integrating Equation A-2 [the equation shown in the paragraph above] for 

SMALL BOY from 0 to 365 days and dividing the result by 365 (the value that 

represents the integrated total dose for 1 year), it was determined that for the first 

year after detonation the lung dose from 90Sr represented 0.0000738 or about 

0.00738% of the dose from all 177 radionuclides. [page 70]

There are two problems with this.9 The first is the implication that time zero is the time of the 

last detonation (i.e., July 1962), but this appears to be impossible, given that the authors show in 

their Table A-910 that the relative dose to the thyroid is the same as for 17 other organs. Due to 

the affinity of the thyroid for short-lived radioiodines, this cannot be correct. 

9 The discussion in this and the following two paragraphs was first presented in SC&A (2015), p. 26.

10 ORAUT (2012), Table A-9, is reproduced in this document as Table 1.

The second problem is the integration. The following equation is a reproduction of what the 

authors said they did: 

026.0

365

0074.0

2

0001.0

365

d)0074.00001.0(

365

0

365 2

0 =

+

=

+ ∫ x

x

x x

The calculated value of 0.026 is obviously very different from 0.0000738. The above equation is, 

in fact, the classic definition of an average of the function over the 365-day period, and 

according to the authors’ Figure A-2, which is reproduced here as Figure 1, the average value has 

to be about midway between 0.00 and 0.05. The authors’ contention that they have calculated an 

integrated total dose does not match the reproduction of what they said they did. 

In a response to Comment No. 7, NIOSH (2016) stated that 

The difference between these numbers is a factor of 365. The factor of 0.0000738 

is actually the average dose for one day—not one year as stated in the NTS 

environmental TBD. This will be corrected in the next TBD revision. [page 11]

This response is wrong, as the value of 0.026 is clearly the average dose for one day, and not the 

integral dose it should be. Dividing again by 365 simply means that the calculations are wrong 

by a factor of 3652 = 133,225. However large this error is, it does not matter if the doses from 

Sr-90 and other short-lived radionuclides are calculated in the same way; the mistaken values of 

365 or 3652 simply cancel out. It would be much less confusing to the reader if such distractions 

were not in the NIOSH contractor’s reports. Strenge (2016, page 14) simply states that “The 

integral value is averaged over a 365-day period.” 

The results of ORAUT’s calculations of the correction factors are shown in Table 1. Strenge’s 

calculations, which he states have avoided double counting the doses from Am-241, Pu-238, 

Pu-239/240, Co-60, Cs-137, Sr-90, Eu-152, Eu-154, and Eu-155, are shown in Table 2. 

 
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Comparison of Tables 1 and 2 indicates that Strenge’s calculations are higher than those from 

ORAUT for 1963 and 1964 but then become lower. Strenge’s values are a factor of 16 lower for 

1972. 

Table 1. Reproduction of Table A-9 from ORAUT (2012) (inhalation “correction factors” 

calculated from event Small Boy) 

Organ Fission and activation product correction factor

Year 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972

Skin Adrenals

Thymus SI

Spleen Skin

Muscle Uterus

Pancreas Kidneys

Breast Testes

Esophagus Ovaries

Brain Stomach

Thyroid Gall bladder

730 364 242 182 145 121 104 90.7 80.6 72.5

ULI 458 179 99.2 64.0 45.0 33.4 25.9 20.6 16.8 14.0

Urinary bladder 335 149 91.3 63.6 47.5 37.2 30.1 24.9 21.0 18.0

Lungs 34,900 14,200 7,960 5,150 3,630 2,700 2,100 1,660 1,360 1,130

ET ET1 ET2 LN(TH) 

LN(ET) 1,570 827 598 492 438 412 412 412 412 412

LLI 420 142 70.8 42.4 28.2 20.1 15.1 11.7 9.4 7.6

Colon 390 148 79.4 50.0 34.5 25.2 19.3 15.2 12.3 10.2

Liver 9,260 4,620 1,540 1,190 988 858 769 706 661 629

Red bone marrow 37.9 18.2 12.8 10.4 10.4 10.4 10.4 10.4 10.4 10.4

Bone surfaces 78.5 40.1 28.1 22.4 22.4 22.4 22.4 22.4 22.4 22.4

Source: Reproduced from ORAUT (2012), p. 72, Table A-9, “Organ-Specific Inhalation Dose Fission and Activation Product 

Correction Factors.”

Table 2. Reproduction of Table 3 from Strenge (2016) (inhalation “correction factors” 

calculated from event Small Boy) 

Organ 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972

Skin, Adrenals, Thymus, 

Small Intestine, Spleen, 

Muscle, Uterus, 

Pancreas, Kidneys, 

Breast, Testes, 

Esophagus, Ovaries, 

Brain, Stomach, Thyroid, 

Gall Bladder 

1,500 477 231 136 79 26 14 8.8 6.2 4.5

Upper Large Intestine 784 250 120 70 46 19 12 8.8 6.6 5.1 

Urinary Bladder 499 170 84 50 33 23 6.0 3.9 2.8 2.1 

Lungs 54,201 16,814 7,865 4,515 2,920 2,041 482 322 232 175 

Extra Thoracic Regions 1,258 428 214 151 87 57 40 29 23 18 

Lower Large Intestine 439 144 70 41 27 13 8.3 5.9 4.4 3.4 

Colon 525 173 85 50 33 31 18 12 8.4 6.3 

Liver 13,459 6,631 4,399 3,292 2,630 1,660 626 350 228 162 

Red Bone Marrow 82 23 12 7.8 5.4 3.9 3.0 2.3 1.9 1.6 

Bone Surface 192 78 43 28 19 14 11 8.8 7.1 5.9

Source: Reproduced from Strenge (2016), p. 17, Table 3, “Annual Inhalation Dose Correction Factors for Various Organs Based 

on Deposition from Event Small Boy.”

Of more interest are the calculated doses from inhalation with use of the source term from the 

Small Boy event. The results of calculations from ORAUT (2012) are reproduced in Table 3. 
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Most of the doses are very low, except for the liver, bone surface, lower large intestine, extrathoracic region (ET), and ET1. 

Similar values as given by Strenge are shown in Table 4. Strenge only gives values for doses 

above 5×10-4 rem.

All doses, whether from ORAUT (2012) or Strenge (2016), are very low, except for ET1. 

Unfortunately, neither ORAUT nor Strenge give intermediate values of their calculations so that 

the dose values could be verified. Of course, if this evaluation process were extended to include 

the last half of 1962, the doses would be much higher by factors of several hundred. 

Table 3. Reproduction of Doses from Inhalation Calculated with the Use of the Small Boy 

Source Term, as Given in Table A-10 from ORAUT (2012) 

Year 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972

Adrenals 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Bladder 1.86E-04 6.99E-05 3.45E-05 2.26E-05 1.81E-05 1.51E-05 1.29E-05 1.12E-05 9.73E-06 8.53E-06 

Brain 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Breast 2.08E-07 3.57E-08 1.65E-08 1.37E-08 1.18E-08 1.01E-08 8.70E-09 7.50E-09 6.49E-09 5.58E-09 

Gall 

bladder 2.08E-07 3.57E-08 1.65E-08 1.37E-08 1.18E-08 1.01E-08 8.70E-09 7.50E-09 6.49E-09 5.58E-09 

Heart wall 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Kidney 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Liver 1.93E-03 8.57E-04 3.71E-04 2.70E-04 2.33E-04 2.07E-04 1.85E-04 1.67E-04 1.52E-04 1.39E-04 

Muscle 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Ovaries 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Pancreas 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Testes 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Thyroid 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

RBM 4.08E-04 7.00E-04 6.65E-04 6.09E-04 5.59E-04 5.18E-04 4.84E-04 4.57E-04 4.35E-04 4.16E-04 

Bone 

surface 1.23E-03 2.03E-03 2.00E-03 1.91E-03 1.83E-03 1.77E-03 1.72E-03 1.69E-03 1.66E-03 1.64E-03 

Stomach 1.69E-04 7.22E-05 4.14E-05 3.02E-05 2.57E-05 2.26E-05 2.01E-05 1.81E-05 1.63E-05 1.47E-05 

SI 1.85E-04 7.67E-05 4.36E-05 3.15E-05 2.68E-05 2.35E-05 2.09E-05 1.87E-05 1.69E-05 1.53E-05 

ULI 4.70E-04 1.36E-04 5.98E-05 3.59E-05 2.73E-05 2.19E-05 1.81E-05 1.52E-05 1.29E-05 1.11E-05 

LLI 1.38E-03 3.26E-04 1.24E-04 6.66E-05 4.74E-05 3.63E-05 2.90E-05 2.37E-05 1.98E-05 1.67E-05 

Skin 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Spleen 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Thymus 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Uterus 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

ET 2.22E-03 6.97E-04 3.78E-04 2.60E-04 2.32E-04 2.19E-04 2.17E-04 2.15E-04 2.14E-04 2.13E-04 

Lung 7.67E-03 2.96E-03 1.55E-03 1.08E-03 8.84E-04 7.46E-04 6.40E-04 5.52E-04 4.80E-04 4.18E-04 

Colon 7.82E-04 2.08E-04 8.57E-05 4.85E-05 3.57E-05 2.78E-05 2.26E-05 1.86E-05 1.57E-05 1.34E-05 

ET1 1.63E+00 4.74E-01 2.48E-01 1.64E-01 1.46E-01 1.38E-01 1.38E-01 1.38E-01 1.38E-01 1.38E-01 

ET2 5.83E-04 2.24E-04 1.30E-04 9.60E-05 8.63E-05 8.10E-05 7.92E-05 7.78E-05 7.66E-05 7.55E-05 

LN(ET) 3.27E-04 1.50E-04 9.15E-05 7.03E-05 6.34E-05 5.95E-05 5.77E-05 5.63E-05 5.51E-05 5.40E-05 

LN(TH) 3.27E-04 1.50E-04 9.15E-05 7.03E-05 6.34E-05 5.95E-05 5.77E-05 5.63E-05 5.51E-05 5.40E-05 

Esophagus 1.52E-04 6.76E-05 3.92E-05 2.89E-05 2.47E-05 2.17E-05 1.94E-05 1.74E-05 1.57E-05 1.42E-05 

Source: Reproduced from ORAUT (2012), p. 76, Table A-10, “Inhalation Dose from Short-Lived Fission and Activation 

Products (rem).” 
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Table 4. A Reproduction of Doses from Inhalation Calculated with the Use of the Small 

Boy Source Term, as Given in Table 4 of Strenge (2016) 

Organ 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972

Liver 0.003 0.001 Negla Negl Negl Negl Negl Negl Negl Negl

Bone Surface 0.003 0.001 Negl Negl Negl Negl Negl Negl Negl Negl

Lower Large 

Intestine 0.001 Negl Negl Negl Negl Negl Negl Negl Negl Negl

ETb(ET2), LNc(ET), 

LN(THd) 0.002 Negl Negl Negl Negl Negl Negl Negl Negl Negl

Lung 0.012 0.002 0.001 Negl Negl Negl Negl Negl Negl Negl

ET1 1.305 0.243 0.088 0.050 0.029 0.018 0.013 0.009 0.007 0.006 a Negl means the dose is less than 0.0005 rem and is negligible. 

b ET=extra-thoracic region. c LN=lymph node. 

d TH=thoracic.

Source: Reproduced from Strenge (2016), p. 18, Table 4, “Annual Inhalation Dose (Rem) from Short-Lived Activity from Event 

Small Boy.”

Strenge (2016) compared correction factors and doses that are calculated using the source term 

from Little Feller I, which was the last atmospheric test, to those calculated using the source term

from the Small Boy event. The results for Little Feller I are shown in Tables 5 and 6. There is a 

substantial difference between the values calculated with the Little Feller I source term and those 

using that of Small Boy. SC&A (2015) had suggested that NIOSH should examine the results 

from tests other than Small Boy, as each event is different.11 SC&A continues to recommend that 

calculations also be performed with the source term from Sedan, which was a cratering event just 

eight days before Small Boy. Sedan was a quite large thermonuclear event and was quite 

different from Small Boy or Little Feller I.

11 Hicks (1982, 1990) pointedly made separate calculations for every atmospheric test at the NTS. Many devices 

were one-of-a-kind experiments.

SC&A has not attempted to follow the calculations for ingestion. Virtually the same problems 

exist in that it is impossible to follow the calculations without the provision of intermediate 

results.

 
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Table 5. Reproduction of Table 5 from Strenge (2016) (values shown are inhalation 

correction factors as computed with the Little Feller I source term)

Organ 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972

Skin, Adrenals, Thymus, 

Small Intestine, Spleen, 

Muscle, Uterus, Pancreas, 

Kidneys, Breast, Testes, 

Esophagus, Ovaries, 

Brain, Stomach, Thyroid, 

Gall Bladder 

432 159 77 45 29 20 6.5 4.8 3.7 2.9

Upper Large Intestine 165 58 30 18 12 8.7 6.6 5.1 4.1 3.4

Urinary Bladder 646 176 56 26 15 5.2 3.4 2.4 1.8 1.4

Lungs 15,794 4,801 2,175 1,223 780 171 105 71 52 39

Extra Thoracic Regions 500 160 76 44 29 13 9.5 7.1 5.5 4.4

Lower Large Intestine 108 41 22 14 9.8 7.2 5.6 4.4 3.6 3.0

Colon 105 41 22 14 9.8 7.2 5.6 4.4 3.6 3.0

Liver 3,804 1,866 1236 297 108 58 37 25 19 14

Red Bone Marrow 25 19 4.8 3.5 2.8 2.3 2.0 1.7 1.5 1.3

Bone Surface 29 13 7.8 5.4 4.1 3.2 2.6 2.2 1.9 1.6

Source: Reproduced from Strenge (2016), p. 19, “Annual Inhalation Dose Correction Factors for Various Organs Based on 

Deposition from Event Little Feller I.” 

Table 6. A Reproduction of Doses from Inhalation Calculated with the Use of the Little 

Feller I Source Term, as Given in Table 6 from Strenge (2016) 

Organ 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 

Liver 0.001 Negl Negl Negl Negl Negl Negl Negl Negl Negl 

Bone Surface/Red 

Bone Marrow Negl Negl Negl Negl Negl Negl Negl Negl Negl Negl 

Lower Large Intestine Negl Negl Negl Negl Negl Negl Negl Negl Negl Negl 

ETa(ET2), LNb(ET), 

LN(THc) 0.001 Negl Negl Negl Negl Negl Negl Negl Negl Negl 

Lung 0.003 0.001 Negl Negl Negl Negl Negl Negl Negl Negl 

ET1 0.519 0.090 0.031 0.014 0.009 0.004 0.003 0.002 0.001 0.001 a ET=extra-thoracic region. b LN=lymph node. 

c TH=thoracic.

Source: Reproduced from Strenge (2016), p. 20, Table 6, “Annual Inhalation Dose (Rem) from Short-Lived Activity from Event 

Little Feller I.”

2.5.4 SC&A Recommendations to the Nevada Test Site Work Group 

SC&A’s Recommendation 1 (above) is to change the time period for the reconstruction of the 

occupational environmental dose to July 17, 1962, through December 31, 1992. Additional 

recommendations are as follows:

3. NIOSH and contractors should redo the calculations for correction of fractionation to 

include all steps a through d given above. This essentially requires the additional steps of 

renormalizing the source term after each addition of refractory elements.

4. NIOSH and contractors should be very specific about how their calculations were made 

and provide the results of all intermediate calculations so that SC&A can verify the 
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calculations. This may require that one or more DVDs be provided, as the intermediate 

data are likely too voluminous to be inserted into a report or spreadsheets may be much 

too large to fit on a page. 

5. NIOSH and contractors should also consider the source term for the Sedan event, which 

was a relatively large thermonuclear event.

2.6 COMMENT 6

Much of the material regarding Comments 6 and 7 has been covered above in the material on 

Comment 5. Nevertheless, the procedure followed above for other comments is followed here. 

2.6.1 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 1, 

pages 9–10 

The levels of contamination observed in soil by the RIDP performed in the 1980s 

captured some contamination that occurred many years subsequent to the 

termination of aboveground testing. This is a concern that needs to be addressed, 

because the TBD is based on the assumption that all radionuclides observed in 

soil in the 1980s were as a result of aboveground testing that occurred in July 

1962. However, some of the contamination was deposited many years later. 

NIOSH should explain how this affects the dose reconstruction process. 

2.6.2 NIOSH (2016) Response, Part 1, page 8 

The persistent radionuclides deposited after January 1, 1963 were still decay 

corrected back to January 1, 1963 so their contribution to the soil concentrations 

corrected to January 1, 1963 would have been overestimated since these 

radionuclides would not have existed in the environment on January 1, 1963. The 

same overestimate would occur for any persistent radionuclides deposited as a 

result of the Plowshare program. Thus the soil radionuclide concentrations 

corrected to January 1, 1963 likely represent overestimates of the actual soil 

concentrations present at the time. 

2.6.3 SC&A Resolution Comments, Part 1

SC&A is not concerned solely with the persistent radionuclides deposited in soil. The primary 

concern is with the many events (for example, Baneberry [REECo 1973])12 that deposited shortlived radionuclides on soil. These deposits of short-lived radionuclides could have produced 

significantly larger doses in the 1963–1970 period than those presently being calculated in 

ORAUT (2012) or Strenge (2016). 

 

12 Further information on contaminating events after 1962 is given in Anspaugh (2008).
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2.6.4 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 2, 

page 10 

In a related manner, the TBD makes use of the Anspaugh equation to derive 

resuspension factors in order to calculate airborne mass loadings and associated 

intake rates after January 1, 1963. NIOSH needs to discuss how these 

resuspension factors might be affected if there are locations where soil 

contamination occurred well after January 1, 1963. 

2.6.5 NIOSH (2016) Response, Part 2, pages 8–10 

The resuspension factors derived from the Anspaugh equation were not used to 

calculate airborne mass loadings. Rather they were used to develop correction 

(normalization) factors that could be applied to intakes derived from the highest 

airborne concentration of Pu-239 measured at the NTS (i.e, Area 9, 1972). 

With the exception of the Plowshare program (which was conducted at a 

relatively small, remote area where personnel access would have been difficult) 

soil contamination occurring after 1963 was primarily the result of loss of 

containment incidents. For each of these events, DOE attempted to identify all 

workers that had a potential for exposure to radioactive material. Those that were 

identified as having been possibly exposed were subjected to external and internal 

monitoring. In addition, except for operational activities, access to these newly 

contaminated areas was controlled. Therefore, estimating the potential exposure 

of individuals to airborne radioactive materials resuspended from the newly 

contaminated soils would involve the introduction of large uncertainties. 

However, NIOSH believes the use of high-end air-sampling data (i.e. the highest 

air sample concentrations ever measured at the NTS) and soil-inventory data in 

reconstructing environmental doses associated with the chronic inhalation of 

radioactive material provides reasonable assurance that the assigned intakes and 

resultant doses are not underestimated. 

Also, in section 5, page 29, of the resuspension issues report, the statement is 

made that “...a mass loading of 0.168 mg/m3

 gives the same dose as the 

resuspension method, and (3) 1 mg/m3 is reasonable and would be more claimant 

favorable.” Table 7-1 of OCRWM (2003) provides ranges of mass loading factors 

for various conditions in the Armargosa Valley where the NTS is located. For 

inactive outdoor conditions, the table provides a triangular distribution with a 

minimum of 0.025 mg/m3, a maximum of 0.100 mg/m3 and a mode of 0.060 

mg/m3. These data do not support a mass loading of 1 mg/m3 but do suggest that 

the implied mass loading factor of 1.68 mg/m3 [sic][13] is sufficiently claimant 

favorable.” 

 

13 SC&A presumes that NIOSH intended to state 0.168 mg/m3 rather than 1.68 mg/m3

. 
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2.6.6 SC&A Resolution Comments, Part 2

The Anspaugh resuspension equation was used by NIOSH and contractors to back-extrapolate 

airborne concentrations of Pu-239/240 from the measurement in 1972 back to the beginning of 

1963. This is clear from material contained in ORAUT (2012) on pages 66–67. 

The Plowshare program was not just conducted at a “relatively small, remote area.” Plowshare 

activities were conducted in Areas 10, 18, 20, and 30. Four of the six Plowshare events released 

more than 106 Ci at H+12 (Schoengold et al. 1996).14 Two of the events (Sedan and Palanquin) 

released more than 107 Ci at H+12.

14 Many of the details concerning these events are described in more detail in Anspaugh (2008).

There were not just a few vents at the NTS during the 1963–1970 period. According to 

Schoengold et al. (1996), there were 225 shots that vented, including planned and unplanned 

releases and plutonium dispersal tests. Twenty-six of these vents were detected off site, so it 

cannot be presumed that DOE identified all involved workers and controlled access to the 

contaminated sites.

It is sometimes forgotten that tests were also being made of nuclear rocket engines and nuclear 

ramjet engines. Some of these tests produced substantial local contamination, especially at the 

Nuclear Rocket Development Station (Areas 25 and 26). The fallout from some of these tests 

was detected off site.

As a matter of geography, the NTS is not located in the Armargosa Valley, as stated by NIOSH.

2.6.7 SC&A Recommendations to the NTS Work Group

6. The impacts of hundreds of releases of large quantities of short-lived radionuclides 

should be considered in a more serious manner so that exposures to claimants are 

considered fairly.

2.7 COMMENT 7

2.7.1 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 1, 

page 10 

In order to prepare tables of doses to each organ and from each radionuclide as a 

function of time [which would have required an enormous number of Integrated 

Modules of Bioassay Analysis (IMBA) runs], NIOSH elected to prorate all doses 

based on the intake rate of Sr-90 beginning on January 1, 1963, and moving 

forward in time as the resuspension factors decline according to the Anspaugh 

equation and the radionuclide concentrations decline by radioactive decay.

 
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2.7.2 NIOSH (2016) Response, Part 1, page 10 

In the NTS resuspension issues report in Section 3.5, page 26, the following 

statement is made: 

“There are two problems with this. The first is the implication that 

time zero is the time of the last detonation (i.e., July 1962), but this 

appears to be impossible, given that the authors show in their 

Table A-9 that the relative dose to the thyroid is the same as for 17 

other organs. Due to the affinity of the thyroid for short-lived 

radioiodines, this cannot be correct.” 

It should be noted that Table A-9 does not provide relative doses. Rather, the 

table provides correction factor which when multiplied by the annual Sr-90 dose 

(to a particular organ) will account for short-lived fission and activation 

products. In other words, the correction factors given in Table A-9 are indicators 

of the relative importance of dose from Sr-90 (to a particular organ) to the total 

annual dose from short-lived fission and activation products. The reason the 

thyroid is grouped with the other 17 organs in Table A-9 is because the annual 

dose from the annual intakes of Sr-90 are similar for all 18 organs. The thyroid 

does not have an affinity for Sr-90. 

2.7.3 SC&A Resolution Comments, Part 1

The above NIOSH description of Table A-9 from ORAUT (2012) is, in fact, the definition of 

doses relative to that from Sr-90. The major point is that NIOSH’s Figure A-2, which is 

reproduced above as Figure 1, implies that the integration started from time zero after detonation, 

and not at January 1, 1963. This is also the implication given in the description in ORAUT 

(2012, page 70) of the integration of their equation starting at time zero. If they had integrated 

from time zero after detonation, then the “correction factor” for the thyroid would have been 

much larger than for skin, adrenals, thymus, small intestine, spleen, muscle, uterus, pancreas, 

kidneys, breast, testes, esophagus, ovaries, brain, stomach, and gall bladder due to the 

preferential incorporation of short-lived radioiodines into the thyroid. 

The NIOSH comment that the thyroid does not have an affinity for Sr-90 does not help in 

addressing SC&A’s fundamental concern. Strenge (2016) has made it clear that NIOSH does not 

plan to reconstruct doses during the last half of 1962. SC&A believes that doses associated with 

this time period can be reconstructed and should be reconstructed because these doses will be 

large as compared to the doses post January 1, 1963. 

2.7.4 SC&A (2015) Original Statement as Taken from the Executive Summary, Part 2, 

page 10 

A review of the methods used to perform these calculations, as provided in 

Appendix A of the TBD, reveals that errors have been made in its use of equation 

A-2, which could profoundly affect the dose fractions provided in Figures A-5 
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through A-11, and the doses calculated and reported in Tables 4-9, 4-14, and 

A-10. 

2.7.5 NIOSH (2016) Response, Part 2, pages 10–12 

In a related matter, the issues report [SC&A 2015] also stated the following: 

“The second problem is the integration. The calculated value of 

0.026 is obviously very different from 0.0000738.” 

The difference between these numbers is a factor of 365. The factor of 0.0000738 

is actually the average dose for one day – not one year as stated in the NTS 

environmental TBD. This will be corrected in the next TBD revision. 

However, it should be noted that the integration of equation A-2 from Figure A-2 

is not used in any way to calculate doses. The slope of the lines shown in 

Figures A-2, A-3 and A-4 of the NTS environmental TBD are what were used to 

demonstrate the relative importance of the lung dose from Sr-90 to the total dose 

from short-lived fission and activation products. The lower the slope, the lower 

the relative dose from Sr-90 when compared to the total dose from short-lived 

fission and activation products. The slope of the trend lines that predict the 

relative importance of 90Sr dose was determined to be 0.0001x for STORAX 

SMALL BOY, 0.0002x for STORAX LITTLE FELLER I (Figure A-3) and TEAPOT 

TURK (see Figure A-4). Because the slope of the trend line is directly 

proportional to the relative importance of the Sr-90 dose to total dose (i.e., the 

larger the slope, the larger the relative importance of Sr-90 dose), the tests with 

the smallest slopes result in the highest multiplicative correction factors for 

fission and activation products. Therefore, to ensure the organ dose from shortlived fission and activation products is not underestimated, the Hicks (1984) data 

for the STORAX SMALL BOY test were selected to be used to determine the 

fission and activation product dose correction factor. This assumption is justified 

by the fact that the test was very near the last atmospheric test (i.e., STORAX 

LITTLE FELLER I) and would therefore have been the test most likely to produce 

the short-lived fission and activation product intakes for workers at NTS after 

1962 (the period for which organ dose from environmental intakes is calculated). 

2.7.6 SC&A Resolution Comments, Part 1

This issue has already been discussed and recommendations made above for Comment 5. 
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3.0 SUMMARY OF RECOMMENDATIONS TO THE NEVADA TEST 

SITE WORK GROUP

1. Change the time period for the reconstruction of occupational environmental dose to 

July 17, 1962, through December 31, 1992. The same method can be used as NIOSH is 

now doing for a start period of January 1, 1963. Such a change would be substantively 

more claimant favorable and can be performed using scientifically valid methodologies 

for time periods that extend back to the latter half of 1962. 

2. Change the statement about rosters and bioassay results to a more valid statement:

“These workers may have been identified on the rosters that were 

published before the event, and these workers may have had bioassay 

results in the DOE records.” 

3. NIOSH and contractors should redo the calculations for correction of fractionation to 

include all steps a through d given above. This essentially requires the additional steps of 

renormalizing the source term after each addition of refractory elements.

4. NIOSH and contractors should be very specific about how their calculations were made 

and provide the results of all intermediate calculations so that SC&A can verify the 

calculations. This may require that one or more DVDs be provided, as the intermediate 

data are likely too voluminous to be inserted into a report or spreadsheets may be much 

too large to fit on a page. 

5. NIOSH and contractors should also consider the source term for the Sedan event, which 

was a relatively large thermonuclear event.

6. The impacts of hundreds of releases of large quantities of short-lived radionuclides 

should be considered in a more serious manner so that exposures to claimants are 

considered fairly.
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