Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

 REVIEW OF ORAUT-PROC-0044: 

SPECIAL EXPOSURE COHORT (SEC), 

REVISION 00, OCTOBER 7, 2005

Contract No. 200-2009-28555 

SCA-TR-PR2012-0011, Rev. 0

Prepared by 

John Mauro, PhD, CHP 

Steven Ostrow, PhD 

Bob Barton 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

October 2012 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

2 of 49

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

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

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

S. Cohen & Associates: Technical Support for the 

Advisory Board on Radiation and Worker Health 

Review of NIOSH Dose Reconstruction Program

Document No. 

SCA-TR-PR2012-0011

Effective Date:

October 15, 2012

Revision No. 

0 – Draft

Review of ORAUT-PROC-0044: 

Special Exposure Cohort (SEC),

Revision 00, October 7, 2005

Page 2 of 49

Task Manager:

______________________ Date: ____________ 

Steve Marschke

Supersedes:

N/A

Project Manager:

______________________ Date: ____________

John Stiver, CHP

Reviewer(s):

 John Stiver

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 10/15/2012 Initial issue
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

3 of 49

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

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

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

TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4

1.0 Introduction..........................................................................................................................6

2.0 Procedural Evaluation..........................................................................................................8

3.0 Technical Evaluation of Qualified SEC Petitions..............................................................15

3.1 General Considerations..........................................................................................15

3.2 Examine Site Profiles, User Guides, and Previous Dose Reconstructions............16

3.3 Examine Personnel and Area/Facility Monitoring Data........................................17

4.0 Checklist ............................................................................................................................19

5.0 References..........................................................................................................................22

Appendix A: Examples of Strategies used by SC&A in Reviewing the Completeness of 

Available Site-Specific Records in an SEC Context .........................................................24

Appendix B: Examples of Strategies Used by SC&A in Analyzing Allegations of Data 

Falsification in an SEC Context.........................................................................................41
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

4 of 49

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

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

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

ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

or the Board

AWE Atomic Weapons Employer 

CATI Computer Assisted Telephone Interview

CFR Code of Federal Regulations

DCAS Division of Compensation Analysis and Support

DOE U.S. Department of Energy 

DWE Daily Weighted Exposure

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

FMPC (Fernald) Feed Materials Production Center (referred to simply as Fernald)

HHS Health and Human Services

IMBA Integrated Modules for Bioassay Analysis

MDA minimum detectable activity

MeV megaelectron-volts

MFP mixed fission product

mg milligram

MI/cc microcuries per cubic centimeter

MIVRML Mobile In Vivo Radiation Monitoring Laboratory

mrem millirem

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH OCAS Claims Tracking System

NTA nuclear track emulsion, type A

NS Nevada Site

NTS Nevadva Test Site

OCAS Office of Compensation Analysis and Support

ORAUT Oak Ridge Associated Universities Team

PER Petition Evaluation Report

PIC personal ionization chamber; pocket ionization chamber

POC probability of causation

QA Quality Assurance

rem roentgen equivalent man
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

5 of 49

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

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

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

REX Radiological Exposure Database

SC&A S. Cohen and Associates (SC&A, Inc.)

SEC Special Exposure Cohort

SMT stable metal tritide

TBD Technical Basis Document

TLD thermoluminescent dosimeter

μg/l microgram per liter
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

6 of 49

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

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

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

1.0 INTRODUCTION

During its meeting held in Santa Fe, New Mexico, June 19–21, 2012, the Advisory Board on 

Radiation and Worker Health (Advisory Board or ABRWH) directed SC&A to perform a review 

of ORAUT-PROC-0044, “Special Exposure Cohort (SEC) Revision 00, October 7, 2005” 

(ORAUT 2005). SC&A’s method for reviewing National Institute for Occupational Safety and 

Health/Division of Compensation Analysis and Support (NIOSH/DCAS1) procedures is 

described in its procedure, A Protocol for the Review of Procedures and Methods Employed by 

NIOSH for Dose Reconstruction, which was approved by the Advisory Board in April 2004 

(SC&A 2004). In addition, since PROC-0044 deals specifically with SEC petition evaluation 

reports, this review also takes guidance from Board Procedures for Review of Special Exposure 

Cohort Petitions and Petition Evaluation Reports, Revision 1 (SC&A 2006). Hence, unlike 

other procedure reviews performed by SC&A, which are concerned primarily with dose 

reconstructions, this review is uniquely concerned with SEC petition evaluation reports. As 

such, the criteria used to evaluate this procedure reflect a hybrid of the two SC&A procedures. 

Nevertheless, SC&A made use of its standard procedure review checklist (appearing in 

Section 4) as applicable to this situation. In addition to assessing the Oak Ridge Associated 

Universities Team (ORAUT) SEC procedure against the formal requirement and guidance 

documents, SC&A made use of its many years of experience as the Advisory Board’s technical 

contractor to inform its review.

The objective of this particular review is to evaluate the degree to which ORAUT-PROC-0044

meets the requirements of 42 CFR Part 83 and sound health physics practice. The procedure 

provides protocols for (1) determining whether an SEC petition qualifies for evaluation, and 

(2) evaluating those qualifying petitions. Item (2) is within the scope of the mission of the 

Advisory Board as defined in the Energy Employee Occupational Illness Compensation Program 

Act of 2000 (EEOICPA), while item (1) is not (as best we understand the mission of the 

Advisory Board). Hence, this review is limited to that portion of the procedure that addresses 

item (2).

ORAUT-PROC-0044, which is a procedure prepared by ORAUT, the technical contractor hired 

by NIOSH, must be reviewed within the context of a hierarchy of documents, beginning with the 

EEOICPA and its implementing regulations, 42 CFR Parts 82 and 83, and DCAS guidelines, 

specifically DCAS-PR-004, OCAS-IG-001, and OCAS-IG-002. Hence, our review tries to 

address two questions:

(1) Does the procedure materially follow the provisions of the statute, its implementing 

regulations, and DCAS guidelines?

(2) Are the guidelines scientifically sound and claimant favorable?

Following this introduction, Sections 2 and 3 address these questions. 

 

1

Formerly known as OCAS (Office of Compensation Analysis and Support).
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

7 of 49

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

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

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

As described in Section 6.2 of the ORAUT procedure, qualified petitions are evaluated under one 

of two provisions of Part 83, as follows:

First, a 42 CFR 83.13 petition is filed when the petitioner is not a claimant for 

whom NIOSH has already found that it cannot complete a dose reconstruction. 

Second, a 42CFR 83.14 petition is filed when the petitioner is one for whom 

NIOSH could not complete a dose reconstruction.

ORAUT-PROC-0044 and this review address both types of qualified petitions.

Our review does not attempt to evaluate every statement made in every section of ORAUTPROC-0044, but is limited to those guidelines considered to be essential to a scientifically sound 

and claimant-favorable SEC petition evaluation report and the degree to which the procedure 

faithfully follows Part 83 in significant procedural areas. It should be noted that Part 83 refers 

only to NIOSH, which will be taken here as referring to the NIOSH operating unit, DCAS. It is 

assumed that ORAUT is acting on behalf of or supporting DCAS in fulfilling many of its duties, 

so responsibilities flow down to ORAUT from DCAS in most instances.

Section 2.0 of this report evaluates ORAUT-PROC-0044 for procedural compliance, and 

Section 3.0 for technical compliance to Part 83 regulations and DCAS-PR-004 guidelines. As 

mentioned previously, Section 4.0 consists of an SC&A-developed and Board-approved 

checklist, which is adapted for review of the ORAUT procedure.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

8 of 49

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

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

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

2.0 PROCEDURAL EVALUATION

ORAUT-PROC-0044 provides step-by-step instructions to ORAUT for evaluating SEC petitions 

in accordance with 42 CFR Part 83 and DCAS-PR-004, which are superior to it in the hierarchy 

of regulations and guidance related to SEC petitions and flowing down from EEOICPA. This 

section assesses the degree of compliance of PROC-0044 to the procedural steps delineated in 

Part 83 and DCAS-PR-004 (which provides guidance on compliance with the requirements of 

Part 83). This assessment will examine closely the DCAS procedure from the point of view of 

whether the ORAUT procedure complies with its guidance; the DCAS procedure itself, however, 

will not be assessed for its compliance with Part 83. This assessment will begin at the point after 

a petition is found qualified, which corresponds to 43 CFR 83.12, Section 6.2 of DCAS-PR-004, 

and Section 6.1.12 of ORAUT-PROC-0044. 

42 CFR 83.12

Since both ORAUT-PROC-0044 and DCAS-PR-004 generally follow the order of topics 

covered in 42 CFR Part 83, this review will begin with the first applicable section of the latter, 

namely §83.12, “How will NIOSH notify petitioners, the Board, and the public of petitions that 

have been selected for evaluation?,” which prescribes how NIOSH will notify petitioners, the 

Advisory Board, and the public of petitions that have been selected for evaluation. As such, all 

of this section’s provisions can be categorized as “procedural,” rather than “technical.” For 

convenience, the document review is summarized in Table 1. All relevant material in DCASPR-004 is found in Section 6.2, and all relevant material in ORAUT-PROC-0044 is found in 

Section 6.1.12 and Attachment A (a flowchart).

Table 1: Compliance with 42 CFR Part 83.12

42 CFR 83.12 Requirement DCAS-PR-004 

Section

ORAUT-PROC0044 Section Comments

§83.12: How will NIOSH notify petitioners, the 

Board, and the public of petitions that have been 

selected for evaluation?

6.2 6.1.12 and 

Attachment A 

(page 10)

(a) NIOSH will notify the petitioner(s) in writing 

that it has selected the petition for evaluation. 

NIOSH will also provide the petitioner(s) with 

information on the steps of the evaluation and 

other processes required pursuant to these 

procedures.

6.2.1 6.1.12.2

(b) NIOSH will combine separate petitions and 

evaluate them as a single petition if, at this or at 

any point in the evaluation process under §§83.13 

and 83.14, NIOSH finds such petitions represent 

the same class of employees.

6.2.3 6.1.12.3
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

9 of 49

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

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

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

Table 1: Compliance with 42 CFR Part 83.12

42 CFR 83.12 Requirement DCAS-PR-004 

Section

ORAUT-PROC0044 Section Comments

(c) NIOSH will present petitions selected for 

evaluation to the Board with plans specific to 

evaluating each petition. Each evaluation plan 

will include the following elements:

(1) An initial proposed definition for the class 

being evaluated, subject to revision as 

warranted by the evaluation conducted 

under §83.13 or §83.14; and 

(2) A list of activities for evaluating the 

radiation exposure potential of the class 

and the adequacy of existing records and 

information needed to conduct dose 

reconstructions for all class members under 

42 CFR part 82.

6.2.3 6.1.12.3

(d) NIOSH may initiate work to evaluate a 

petition immediately, prior to presenting the 

petition and evaluation to the Board.

6.2.4 N/A “Permission” is given to 

DCAS, which then might 

direct ORAUT to 

perform work.

(e) NIOSH will publish a notice in the Federal 

Register notifying the public of its decision to 

evaluate a petition.

6.2.5 6.1.12.4

N/A 6.2.6 6.1.12.1 DCAS 6.2.6 requires 

posting notice of the 

decision on the NIOSH/

DCAS website as well.

As seen from Table 1, ORAUT-PROC-0044 complies fully with the requirements of 

42 CFR 83.12, with the note that the procedure could mention that DCAS might ask ORAUT to 

begin preparing the Petition Evaluation Report (PER) before the petition is presented to the 

Board. The flow diagram of Appendix A (page 10) of the former procedure adequately reflects, 

in summary, the steps of the procedure’s text.

42 CFR 83.13

The next section of 42 CFR Part 83 that contains procedural requirements applicable to ORAUT 

is Section 83.13, “How will NIOSH evaluate petitions, other than petitions by claimants covered 

under §83.14?” Petitions covered under this section are those where the petitioner is not a 

claimant whose claim NIOSH has already evaluated and determined that it cannot perform a 

dose reconstruction. This section contains technical items in addition to procedural items; only 

the latter will be examined here. Most relevant material in DCAS-PR-004 is found in 

Section 6.4, and all relevant material in ORAUT-PROC-0044 is found in Section 6.2 and is 

summarized in the Attachment C flowcharts. Table 2 summarizes SC&A’s assessment of 

ORAUT-PROC-0044’s compliance with requirements of the higher level documents. 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

10 of 49

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

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

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

Table 2: Compliance with 42 CFR Part 83.13

42 CFR 83.13 Requirement DCAS-PR004 Section

ORAUT-PROC0044 Section Comments

§83.13: How will NIOSH evaluate petitions, other 

than petitions by claimants covered under §83.14?

6.4

(primarily)

6.2 and 

Attachment C

(a) NIOSH will collect information on the types 

and levels of radiation exposures that potential 

members of the class may have incurred as 

specified under 42 CFR 83.14, from the following 

potential sources, as necessary:

Eight sources of information follow. In summary: 

(1) the petition; (2) DOE and AWE facility records; 

(3) potential members of the class and their 

survivors; (4) labor organizations; (5) witnesses 

present during the relevant period of employment at 

the facility; (6) NIOSH records from 

epidemiological research on DOE populations and 

from 42 CFR 82 dose reconstructions; (7) Records 

from research, dose reconstructions, medical 

screening programs, etc.; and (8) other sources.

6.4.11 (also, 

6.4.1, 6.4.4, 

6.4.6, 6.4.7, 

6.4.8) 

6.2.1, 6.2.2, 6.2.3, 

6.2.4, 6.2.5

The DCAS procedure 

mentions data sources 

in several sections; 

Section 6.4.11 

explicitly addresses 

the eight sources of 

information in

§83.13(a). 

The ORAUT 

procedure explicitly 

lists the Part 83 

sources in Section 

6.2.4.1.

(b) The Director of OCAS may determine the 

records and/or information requested from DOE, 

an AWE, or another source[s] to evaluate a petition 

is not, or will not be, available on a timely basis. 

Such a determination will be treated, for the 

purposes of the petition evaluation, as equivalent to 

a finding that the records and/or information 

requested are not available.

6.3.1.3, 

6.4.10

N/A This section is not 

applicable to ORAUT.

(c) NIOSH will evaluate records and information 

collected to make the following determinations:

(1) Is it feasible to estimate the level of radiation 

doses of individual members of the class with 

sufficient accuracy?

(2) How should the class be defined, consistent 

with the findings of the analysis discussed 

under paragraph (c)(1) of this section?

(3) Is there a reasonable likelihood that such 

radiation dose may have endangered the 

health of members of the class?

6.4

6.4.1ff

6.4.16

6.4.15

6.2

6.2.7

6.2.6

6.2.8 Both discrete and nondiscrete radiation 

events

(d) NIOSH will submit a report of its evaluation 

findings to the Board and to the petitioner(s). The 

report will include the following elements:

Five elements follow: (1) identification of petition; 

(2) proposed class definition; (3) justification for 

including groups who were not specified in original 

petition; (4) summary of findings concerning 

adequacy of records and information for 

reconstructing doses under 42 CFR Part 82; and 

(5) for a class for which it is not feasible to estimate 

doses with sufficient accuracy, a summary of the 

6.6, 6.7, 6.8, 

6.9, 

Attachment 1

6.2.10
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

11 of 49

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

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

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

Table 2: Compliance with 42 CFR Part 83.13

42 CFR 83.13 Requirement DCAS-PR004 Section

ORAUT-PROC0044 Section Comments

basis for establishing the duration of employment 

requirement with respect to health endangerment.

(e) The NIOSH report under paragraph (d) of this 

section shall be completed within 180 calendar 

days of the receipt of the petition from NIOSH. The 

procedure for computing this time period is 

specified in §83.5(c). In addition, the computing of 

180 calendar days shall not include any days 

during which the petitioner may be revising the 

petition to remedy deficiencies identified by NIOSH 

under §83.11(a) or (b), nor shall it include any days 

during which the petitioner may request a review of 

a proposed finding under §83.11(c) or during the 

conduct of such a review under §83.11(d).

6.3, 6.7.1 – The ORAUT 

procedure does not 

appear to include the 

requirements of the 

CFR and DCAS 

documents related to 

establishing a timeline for completion of 

the Petition 

Evaluation Report.

As seen from Table 2, ORAUT-PROC-0044 complies with the requirements of 42 CFR 83.13, 

with the exceptions noted in the following paragraphs. The flowcharts of Attachment C of the 

former procedure adequately reflect, in summary, the steps of the procedure’s text.

Finding 1: ORAUT-PROC-0044 Section 6.2 states:

As seen in OCAS-PR-004, Section 6.3.1, the feasibility evaluation process is 

guided by 42 CFR 83.13(b)(1). The rule states that doses can be estimated with 

sufficient accuracy if NIOSH has established that it has access to sufficient 

information to estimate the maximum radiation dose that could have [been] 

incurred in plausible circumstances by any member of the class. Sufficient 

information may also be needed to estimate the radiation doses of members of 

the class more precisely than an estimate of the maximum radiation dose.

DCAS-PR-004 (Rev. 1), Section 6.3.1 does not refer to the feasibility evaluation process; 

this incorrect citation may be due to the fact that the ORAUT procedure predates the 

Rev. 1 DCAS procedure. However, a more important observation is that the referenced 

Part 83 section, 42 CFR 83.13(b)(1), also does not treat the feasibility evaluation process;

rather, it deals with the role of the Director of OCAS. Hence, the citation to Part 83 in the 

quoted ORAUT-PROC-0044 section should be corrected.

Finding 2: As noted in Table 2, ORAUT-PROC-0044 does not appear to include the 

requirements of 40 CFR 83.13(e) and DCAS-PROC-004 Sections 6.3 and 6.71 related to 

establishing and maintaining a timeline for completion of the Petition Evaluation Report.

42 CFR 83.14

The next section of 42 CFR Part 83 that contains procedural requirements applicable to ORAUT 

is Section 83.14, “How will NIOSH evaluate a petition by a claimant whose dose reconstruction 

NIOSH could not complete under 42 CFR part 82?” The requirements contained therein relate 

to steps that are taken when DCAS determines that it is not feasible to reconstruct doses with 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

12 of 49

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

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

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

sufficient accuracy for members of the class. Table 3 summarizes and lines up the Part 83 

requirements, the DCAS guidelines (Section 6.5), and the ORAUT compliance (primarily, 

Section 6.2.9).

Table 3: Compliance with 42 CFR Part 83.14

42 CFR 83.14 Requirement DCAS-PR004 Section

ORAUT-PROC0044 Section Comments

§83.14: How will NIOSH evaluate a petition by a 

claimant whose dose reconstruction NIOSH could not 

complete under 42 CFR part 82?

6.5 6.2.9

(primarily), 

Attachment C

(a) NIOSH may establish two classes for evaluation, to 

permit the timely adjudication of the existing cancer 

claim:

(1) A class of employees defined using the research 

and analyses already completed in attempting the 

dose reconstruction for the employee identified in 

the claimant’s petition; and

(2) A class of co-workers similar to the class defined 

under paragraph (a)(1) of this section, to be 

defined by NIOSH on the basis of further 

research and analysis, using the procedures 

under §83.13.

6.5.1, 6.5.3 6.2.9

(b) NIOSH will determine the health endangerment 

criteria for adding the class under paragraph (a)(1) of 

this section to the Cohort, using the procedures under 

§83.13. NIOSH will report to the Board and to 

petitioner(s) the results of this determination, together 

with its finding under 42 CFR part 82 that there was 

insufficient information to complete the dose 

reconstruction. HHS will consider this finding under 

42 CFR part 82 sufficient, without further consideration, 

to determine that it is not feasible to estimate the levels 

of radiation doses of individual members of the class 

with sufficient accuracy.

6.5.2, 6.6 6.2.8, 6.2.9

(c) NIOSH will evaluate the petition as it may concern a 

class of co-workers, as described under paragraph 

(a)(2) of this section, according to the procedures under 

§83.13.

6.5.4, 6.6 6.2.9 ORAUT-PROC0044 

Section 6.2.10 

covers reporting 

evaluation 

findings. 

As seen from Table 3, ORAUT-PROC-0044 complies with the requirements of 42 CFR 83.14. 

The flowcharts of Attachment C of the former procedure adequately reflect, in summary, the

steps of the procedure’s text.

42 CFR 83.15, 83.16, 83.17, 83.18. 83.19

Part 83 continues past Part 83.14 with: 

 83.15: How will the Board consider and advise the Secretary on a petition?

 83.16: How will the Secretary decide the outcome(s) of a petition?
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

13 of 49

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

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

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

 83.17: How will the Secretary report a final decision to add a class of employees to the 

Cohort and any actions of Congress concerning the effect of the final decision?

 83.18: How can petitioners obtain an administrative review of a final decision by the 

Secretary?

DCAS-PR-004 includes the following sections, which are related to the aforementioned Part 83 

sections:

 6.8: Schedule a presentation to the Board

 6.9: Establish a proposed decision on the outcome of the petition(s)

 6.10: Transmit proposed decisions to the Board and the Secretary

 6.11: Basis for the Secretary’s (or designee’s) making and reporting a final decision

 6.12: If a class which the Board has recommended be designated is found not to meet the 

statutory criteria for adding a class, prepare for the Secretary a determination to be 

submitted to Congress within 30 calendar days following receipt of the Board’s 

recommendation

 6.13: Transmit and publicize final decisions

 6.14: Transmit and publicize the outcome of congressional review

 6.15: Conduct an HHS administrative review of final decisions, as necessary

 6.16: Review the utility of newly obtained records and information for classes of 

employees added to the Cohort

Finding 3: ORAUT-PROC-0044 ends with Section 6.2.10 and does not address any of the 

Part 83 requirements or DCAS-PR-004 guidelines contained in 43 CFR 83.15–18, and 

DCAS-PR-004 Sections 6.8–6.16. While it is recognized that DCAS, HHS, etc., may 

conduct many of the activities without ORAUT involvement, DCAS can and does call on 

ORAUT for support (i.e., preparing draft responses, recommendations, or other 

documents) in several of the areas. This should be reflected in the ORAUT procedure.

General Comments

SC&A’s review of the ORAUT procedure resulted in the following three general comments/ 

findings that are not aligned with any particular sections of 42 CFR Part 83 and DCAS-PR-004.

Finding 4: It should be noted that ORAUT-PROC-0044 (ORAUT 2005) antedates the 

current version of DCAS-PR-004 (2011), so that the references in the former procedure to 

sections in the latter procedure are often incorrect and should be appropriately corrected 

in a future revision.

Finding 5: ORAUT-PROC-0044 does not adequately reflect the role of the Advisory Board 

and the Board’s Technical Support Contractor (currently SC&A) in the SEC process. For 

example, Advisory Board Work Groups for specific sites often become very involved 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

14 of 49

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

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

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

reviewing, commenting on, and requiring additional analyses for PERs. The Technical 

Support Contractor reviews and comments on PERs and frequently performs its own 

independent evaluations and calculations, which are themselves evaluated by the Work 

Groups, DCAS, and ORAUT; and DCAS and ORAUT often respond with their own, new,

or revised analyses and reports. This cycle may be repeated several times before 

convergence is reached and the Work Group is satisfied. In addition, all four organizations 

frequently speak to and gather information from claimants and their representatives.

Finding 6: ORAUT-PROC-0044 does not discuss the issue of separating SEC from Site 

Profile [Technical Basis Document (TBD)] issues that frequently arises when the Advisory 

Board, Work Groups, and the Board’s Technical Contractor review PERs. When this 

issue arises, ORAUT is often charged with performing supporting work.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

15 of 49

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

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

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

3.0 TECHNICAL EVALUATION OF QUALIFIED SEC PETITIONS

3.1 GENERAL CONSIDERATIONS

Section 6.2 of PROC-0044, “Evaluating Qualified Petitions,” begins with the statement, “Note 

that in the SEC process, actual dose reconstruction is not required, only that the feasibility of 

dose reconstruction can be shown...,” and refers to several guidelines developed by DCAS that 

can be used to help make judgments regarding the feasibility of performing dose reconstructions. 

SC&A reviewed Part 83 and concurs with this qualifying statement.

Section 6.2 of PROC-0044 states that the SEC petition evaluation process should explicitly 

evaluate the degree to which “...exposures could have endangered the health of members of the 

petition class-the maximum exposures.” General criteria for judging health endangerment are 

provided in Section 6.3.11 of DCAS-PR-004. However, because of the very general nature of 

these criteria, one of the recurring challenges to the SEC petition evaluation process has been the 

lack of quantitative criteria/guidance that can help in determining exposures or conditions that

represent health endangerment. On many occasions, an SEC PER published by NIOSH states

that NIOSH was unable to reconstruct exposures with sufficient accuracy. However, in SC&A’s 

opinion, many of these reports are unable to clearly establish, within a regulatory framework 

established by rule or precedent, that health was endangered. A review of the record of SEC 

decisions reveals that, once it has been determined that there was, in fact, the potential for at least 

some radiation exposures associated with weapons complex activities, and that doses could not 

be reconstructed with sufficient accuracy, health endangerment is presumed. To the extent 

possible, the program would benefit if additional criteria and/or guidance could be developed 

that help to define the level of radiation exposure that constitutes health endangerment. SC&A 

recognizes that efforts have been made by the Advisory Board in the past to establish 

quantitative criteria defining health endangerment, and that these efforts encountered many 

challenges. Nevertheless, SC&A believes that these efforts need to continue.

Section 6.2 of PROC-0044 reiterates the “tension” that exists between the need to thoroughly 

evaluate the issues raised in SEC petitions and timeliness. Timeliness is explicitly addressed in 

the statute and its implementing regulations and guidelines. In addition, timeliness is clearly of 

great concern to petitioners, as expressed by petitioners on numerous occasions at Advisory 

Board meetings. However, issues related to timeliness appear to arise primarily after an SEC 

PER is submitted to the Advisory Board, wherein NIOSH recommends denial of the petition. 

Such a recommendation often results in the initiation of a protracted review process by the Board

that involves the cognizant Work Group, NIOSH, and SC&A trading reports and assessments, 

and meeting both in-person and by conference call. However, timeliness does not appear to be 

an issue with respect to PROC-0044, in that considerable attention is given to protocols that help 

to ensure that SEC PERs meet the 180-day schedule for delivery to the Advisory Board, and that 

this schedule is generally met.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

16 of 49

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

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

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

3.2 EXAMINE SITE PROFILES, USER GUIDES, AND PREVIOUS DOSE 

RECONSTRUCTIONS

Sections 6.2.1 and 6.2.2 provide specific guidance to the team reviewing SEC petitions with 

respect to judging whether doses can be reconstructed with sufficient accuracy through the 

examination of site profiles, user’s guides, and previous dose reconstructions. We understand 

why these steps in the review process could be useful, but it seems to miss the fundamental 

issues, which include the adequacy, accuracy, and completeness of the data needed to reconstruct

exposures. The fact that there is a site profile, user’s guide, and previous dose reconstructions

for a given site does not necessarily mean that doses can be reconstructed with sufficient

accuracy. SC&A believes that the starting point for an SEC petition evaluation should be an indepth review of source documents that characterize the operations that took place at the facility,

and the nature and extent of the external and internal dosimetry data and other data that might 

help in determining data accuracy, adequacy, and completeness.

One of the recurring findings SC&A has identified in the past is that site profiles, user’s guides, 

and dose reconstructions are often deficient with respect to these issues. Specifically, site 

profiles are considered working documents that are a convenient tool to help dose reconstructors 

complete as many dose reconstructions as possible in a scientifically sound, consistent, and 

claimant-favorable manner. However, they were not conceived as a tool to assess data accuracy, 

completeness, and adequacy from the perspective of an SEC petition evaluation, though they can 

be useful for that purpose. For example, Section 1.2 of the Advisory Board’s SEC petition 

review procedures states the following:

Site profile and workbook reviews can play a significant role in ensuring 

consideration of all the issues that may be part of the “full evaluation” of each 

petition required by 42 CFR 83. While they are helpful, such reviews are not 

essential to the process of review of SEC petitions and their evaluation reports 

(see Section 4).

Finding 7: ORAUT-PROC-0044 should de-emphasize its dependence on site profiles, 

user’s guides, and previous dose reconstructions for evaluating SEC petitions, and 

emphasize the need to review source documents that will help to achieve a complete 

understanding of the operations, radionuclides of concern, exposure scenarios, health 

physics oversight programs, and the accuracy, adequacy, and completeness of the data 

needed to reconstruct the doses to all workers over all time periods of interest to the 

petition. Reviews of site profiles, user’s guides, and previous dose reconstructions can be 

helpful in accomplishing these types of reviews, but should not be assumed to be the 

authoritative documents with respect to SEC petition evaluations.

Continuing with this theme, Section 6.2.1.4 of PROC-0044 provides important direction, as 

follows: “determine whether a maximum potential exposure scenario can be developed for the 

defined class in the petition.” Section 6.2.3 of PROC-0044 states that, “if reliable monitoring 

data exists for personnel meeting the class definition in the petition, dose reconstructions can be 

performed for individuals within the class.” Other sections of PROC-0044 refer to judging data 

adequacy, etc. SC&A believes that the guidance should focus on how the evaluator should go 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

17 of 49

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

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

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

about identifying a maximum exposure scenario and compiling and evaluating data so that 

judgments can be made with respect to whether doses associated with a maximum exposure 

scenario can be reconstructed with sufficient accuracy. The guidance is limited with respect to 

these matters. SC&A’s reviews of many SEC PERs include a suite of strategies designed to 

accomplish these very tasks. SC&A recommends that NIOSH and ORAUT take advantage of 

this collective experience and codify these strategies into its protocols for evaluating SEC 

petitions.

3.3 EXAMINE PERSONNEL AND AREA/FACILITY MONITORING DATA

Sections 6.2.3 and 6.2.4 of PROC-0044 provide guidance on using and researching personnel 

and area/facility monitoring data for evaluating SEC petitions. The guidance is structured in a 

manner that follows the hierarchy of data, where primacy is given to personnel monitoring data, 

such as film badge and bioassay data, followed by facility monitoring data, such as air sampling 

data, and concluding with source terms and process knowledge.

Section 6.2.3 begins to address SEC petition evaluations in a manner that is more consistent with 

the fundamental strategies we believe should be employed. For example, Section 6.2.3 of 

PROC-0044 states the following:

If only a portion of the group has monitoring records, reasonable assumptions 

can be made for the remainder of the group based on job title, work location, and 

the monitoring records that are available. This approach is identified in OCASPR-003, Performing and Reporting Dose Reconstructions. This process requires 

the ORAU Team to determine if personal monitoring records exist for the group, 

portions of the group, or individuals within the class identified in the petition for 

the identified period. This can be done by evaluating existing NIOSH data, 

including NOCTS, or by evaluating information requested from DOE or an AWE.

This is the type of guidance that we believe should be emphasized in the procedure and 

developed to the fullest extent possible. However, a lot more can be done with respect to 

offering more detailed guidance on how one goes about collecting and analyzing data in the 

NIOSH OCAS Claims Tracking System (NOCTS). 

Appendix A provides four examples of data completeness evaluations that have been completed 

in the past and describes the different strategies that have been employed to evaluate the use of 

surrogate or coworker approaches in an SEC context. The examples were chosen to cover 

different situations and challenges experienced based on the state of available records at 

individual sites (i.e., electronic databases, site-wide hardcopy records, claimant sampling, and 

workplace monitoring). In addition, Appendix B provides two examples of strategies that can be 

used to evaluate the possibility of data falsification, a concern that has been raised in the past by 

petitioners.

Finding 8: The guidance should be more specific with respect to the evaluation of NOCTS 

data that will help to determine data adequacy and completeness.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

18 of 49

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

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

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

Continuing in this vein, Sections 6.2.3.7 and 6.2.4.2 of PROC-0044 refer to reviewing personnel 

monitoring data and area/facility monitoring data with respect to flaws. However, no guidance is 

provided with respect to what types of flaws to look for. Examples of possible flaws include

evidence of data falsification, deliberately not wearing film badges, lack of responsiveness of 

NTA film to neutrons below 0.5 to 1 MeV, need to correct for photon and neutron angle of 

incidence, unreliable chest count data (such as the challenges experienced with Th-232 chest 

count data at Fernald), availability of both breathing zone and general air sampling data, and 

other such examples.

Finding 9: The guidance would benefit from identifying specific types of flaws in personnel 

and area/facility monitoring data that should be investigated, and examples of how those 

investigations can be performed.

Section 6.2.3 of PROC-0044 also makes reference to using surrogate data from another site to 

help fill in gaps that might exist in the data for the facility under consideration. However, the 

guidance does not mention the surrogate data criteria adopted by the Advisory Board. 

Finding 10: The procedure would benefit by referencing the Advisory Board’s surrogate 

data criteria.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

19 of 49

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

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

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

4.0 CHECKLIST

The following presents a checklist of findings in accordance with SC&A’s requirements for 

reviewing procedures. Because PROC-0044 focuses on SEC petition reviews rather than dose 

reconstruction reviews, the checklist is not entirely applicable to this procedure. For this reason, 

rather than scoring each item as 1 through 5, we simply indicate yes, no, or NA. 

Document No.: OCAS-PR-0044 Effective Date: 10/07/2005

Document Title: Special Exposure Cohort (SEC)

Reviewer: John Mauro, Steve Ostrow, and Bob Barton

No. Description of Objective Rating 

1-5

Comments 

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

timely for dose reconstruction.

1.1 Is the procedure written in a style that is clear 

and unambiguous?

Yes

1.2 Is the procedure written in a manner that 

presents the data in a logical sequence?

Yes

1.3 Is the procedure complete in terms of required 

data?

No An overarching concern is that 

specific technical guidance is not 

provided regarding how to go 

about making the judgments 

required in the flow diagrams

1.4 Is the procedure consistent with all other 

procedures that are part of the hierarchy of 

procedures employed by NIOSH for dose

reconstruction?

Yes

1.5 Is the procedure sufficiently prescriptive in 

order to minimize the need for subjective 

decisions and data interpretation?

No See 1.3

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

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

outcome.

2.1 Does the procedure provide adequate guidance 

for identifying a potentially high probability of 

causation as part of an initial dose evaluation 

of a claim?

NA

2.2 Conversely, for claims with suspected 

cumulative low doses, does the procedure 

provide clear guidance in defining worst-case 

assumptions?

NA
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

20 of 49

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

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

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

Document No.: OCAS-PR-0044 Effective Date: 10/07/2005

Document Title: Special Exposure Cohort (SEC)

Reviewer: John Mauro, Steve Ostrow, and Bob Barton

No. Description of Objective Rating 

1-5

Comments 

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

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

the POC is not evidently clear.

3.1 Assess quality of data sought via interview:

3.1.1 Is scope of information sufficiently 

comprehensive?

No It appears that no steps are 

included in the process for 

feedback from the Board or for 

additional interviews and data 

capture activities.

3.1.2 Is the interview process sufficiently 

flexible to permit unforeseen lines of

inquiry?

 No Se 3.1.1

3.1.3 Does the interview process demonstrate 

objectivity and is it free of bias?

Yes

3.1.4 Is the interview process sensitive to the 

claimant?

No See 3.1.1

3.1.5 Does the interview process protect 

information as required under the Privacy 

Act?

NA

3.2 Assess whether the procedure adequately addresses generic as well as site-specific data

pertaining to: 

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

PICs) 

No See 1.3

3.2.2 In vivo/In vitro bioassays No See 1.3

3.2.3 Missing dosimetry data No See 1.3

3.2.4 Unmonitored periods of exposure No See 1.3

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

of claimants’ exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive 

approach to dose reconstruction? 

NA

4.2 Does the procedure adhere to the hierarchical 

process as defined in 42 CFR 82.2? 

Yes

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

claimant. 

5.1 Is the procedure claimant favorable in 

instances of missing data? 

NA

5.2 Is the procedure claimant favorable in 

instances of unknown parameters effecting 

dose estimates? 

NA

5.3 Is the procedure claimant favorable in 

instances where claimant was not monitored? 

NA
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

21 of 49

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

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

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

Document No.: OCAS-PR-0044 Effective Date: 10/07/2005

Document Title: Special Exposure Cohort (SEC)

Reviewer: John Mauro, Steve Ostrow, and Bob Barton

No. Description of Objective Rating 

1-5

Comments 

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

estimates. 

6.1 Does the procedure provide adequate guidance 

for selecting the types of probability 

distributions (i.e., normal, lognormal)? 

NA

6.2 Does the procedure give appropriate guidance 

in the use of random sampling in developing a 

final distribution?

NA

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

process efficiency.

7.1 Does the procedure require levels of detail that 

can reasonably be accounted for by the dose 

reconstructor?

NA

7.2 Does the procedure avoid levels of detail that 

have only limited significance to the final dose 

estimate and its POC?

NA

7.3 Does the procedure employ scientifically valid 

protocols for reconstructing doses?

NA
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

22 of 49

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

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

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

5.0 REFERENCES

42 CFR Part 82 2002. Methods for radiation dose reconstruction under the Energy Employees 

Occupational Illness Compensation Program Act of 2000, final rule. U.S. Department of Health 

and Human Services.

42 CFR Part 83 2004. Procedures for designating classes of employees as members of the 

special exposure cohort under the Energy Employees Occupational Illness Compensation 

Program Act of 2000; final rule. U.S. Department of Health and Human Services.

DCAS-PR-004 2011. Internal Procedures for the Processing of Special Exposure Cohort 

Petitions, National Institute for Occupational Safety and Health (NIOSH), Division of 

Compensation Analysis and Support.

NIOSH 2007. SEC Petition Evaluation Report – Petition SEC-00084 – Nevada Test Site,

Rev. 00. Coblentz, R., Harrison-Maples, M., Mahathy, M., National Institute for Occupational 

Safety and Health. September 25, 2007.

NIOSH 2012a. Potential Stable Metal Tritide Exposures at the Mound Laboratory, Rev. 00. 

National Institute for Occupational Safety and Health. March 30, 2012

NIOSH 2012b. Responses to Action Items Introduced During the Mound Work Group Meeting 

of June 5, 2012. Chew, M., Smith, B., Rich, B. National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. August 22, 2012.

OCAS-IG-001 2007. External Dose Reconstruction Implementation Guidelines, Rev. 3, 

National Institute for Occupational Safety and Health (NIOSH), Office of Compensation 

Analysis and Support (OCAS), Cincinnati, Ohio. 

OCAS-IG-002 2002, Internal Dose Guidelines, Rev. 0, National Institute for Occupational 

Safety and Health (NIOSH), Office of Compensation Analysis and Support (OCAS) , Cincinnati, 

Ohio.

ORAUT 2005. Special Exposure Cohort, ORAUT-PROC-0044, Rev. 0. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. October 7, 2005.

ORAUT 2008. Thorium In Vivo Coworker Study for FEMP – A Proposed Attachment for 

ORAUT-TKBS-0017-5, Revision 1. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

January 8, 2008.

ORAUT 2010a. Hanford Site – Introduction, ORAUT-TKBS-0006-1, Rev. 04, Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. March 2010.

ORAUT 2010b. Hanford Site – Site Description, ORAUT-TKBS-0006-2, Rev. 02, Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. February 2010.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

23 of 49

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

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

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

ORAUT 2010c. Hanford Site – Occupational Medical Dose, ORAUT-TKBS-0006-3, Rev. 02, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. January 2010.

ORAUT 2010d. Hanford Site – Occupational Environmental Dose, ORAUT-TKBS-0006-4, 

Rev. 03, Oak Ridge Associated Universities Team, Cincinnati, Ohio. January 2010

ORAUT 2010e. Hanford Site – Occupational Internal Dose, ORAUT-TKBS-0006-5, Rev. 03, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. January 2010

ORAUT 2010f. Hanford Site – Occupational External Dose, ORAUT-TKBS-0006-6, Rev. 04, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. January 2010

SC&A 2004. A Protocol for the Review of Procedures and Methods Employed by NIOSH for 

Dose Reconstruction, Rev. 2. SC&A, Inc., McLean, Virginia.

SC&A 2006. Board Procedures for Review of Special Exposure Cohort Petitions and Petition 

Evaluation Reports, Rev. 1. SC&A, Inc., Vienna, Virginia.

SC&A 2010. Feasibility of Internal Dose Reconstruction with Sufficient Accuracy at the Nevada 

Test Site During the Underground testing Period: A Review of the NIOSH Position Paper 

“NIOSH Review of the SEC-00084 Nevada Test Site Evaluation Report: Internal Dosimetry 

Issues Analysis.” SC&A, Inc., Vienna, Virginia. January 2010.

SC&A 2011. Draft – Review of Special Exposure Cohort Issues for the Hanford Site for the 

Period July 1, 1972, to December 31, 1990. Volume II – Appendices – Appendix A. Prepared 

by Makhijani, A., Barton, B., Lipsztein, J., Sanford Cohen and Associates, Vienna, Virginia. 

July 2011.

SC&A 2012. Mound Laboratory Site Potential Exposures to Stable Metal Tritides. Fitzgerald, 

J., Mauro, J., Barton, B., Buchanan, R., Stiver, J., SC&A, Inc., Vienna, Virginia. May 2012.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

24 of 49

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

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

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

APPENDIX A: EXAMPLES OF STRATEGIES USED BY SC&A IN 

REVIEWING THE COMPLETENESS OF AVAILABLE SITE-SPECIFIC 

RECORDS IN AN SEC CONTEXT

As stated previously in this document, two of the most important aspects in making an SEC 

determination are the “adequacy” and the “completeness” of available data sources. In this 

context, “adequacy” refers to the ability to use available data to accurately reflect real and 

meaningful exposures incurred by the worker population with sufficient accuracy. For example, 

during its review of thorium in-vivo (chest count) data for use in reconstructing internal 

exposures to Th-232 and associated daughter products, the Advisory Board determined that 

measurements given in units of “milligrams of thorium” were not “adequate” for the purposes of 

dose reconstruction. The basis of this determination was the lack of raw data and defined 

analytical methods that were used in arriving at the values of mg of thorium.

2

In this way, the 

dataset was not “adequate” to establish real and meaningful exposures for the exposed worker 

population. 

“Completeness” of available datasets does not address the technical accuracy of the data, but 

rather how well the available records are representative of the potentially exposed worker 

population. The issue of data completeness is the subject of this appendix. The three most 

important facets of data completeness can be summarized by the following:

 Temporal coverage: Do the records cover the necessary time periods evaluated by the 

SEC?

 Job type coverage: Are the highest exposed job types covered by the available records?

 Work area coverage: Are the work areas of highest exposure potential represented by the 

available monitoring data?

Obviously, these facets are not mutually exclusive and are usually interdependent. For example, 

a particular dataset may have “complete” data as regards the chronology of the site, but is 

missing data for the highest job types and/or plant areas during some of those years. It must be

noted that decisions regarding the “completeness” of a particular dataset in an SEC context are

ultimately a judgment call. As such, there is no quantitative way to definitely determine whether 

particular monitoring records are complete. However, analytical methods have been used by 

SC&A in the past, which build a “weight of evidence” argument to assist the Advisory Board in 

making such determinations.

This appendix provides examples of some of the analytical approaches that have been used for 

SEC deliberations previously for four different sites (Hanford, Fernald, Nevada Test Site (NTS),

and Mound). The examples were chosen to reflect many of the different scenarios and potential 

problems encountered by the Advisory Board in making SEC recommendations. The four 

chosen examples include analysis of an extensive electronic database (Example 1), compilation 

 

2 Th-232 cannot be measured directly in the lung and so must be inferred from the relative measurements of 

associated daughter products. The original daughter product measurements were not available, nor was the exact 

procedure used in calculating the lung burden of thorium.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

25 of 49

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

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

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

of site-wide data from hardcopy records (Example 2), sampling of claimant dosimetry records 

(Example 3), and use of workplace monitoring in the absence of adequate bioassay records 

(Example 4). 

Example 1: Electronic Internal Dosimetry Database for the Hanford Site

Background Summary:

In 2011, SC&A was tasked with performing a review of the most recent Hanford Site Profile 

(ORAUT 2010a–2010f) with a focus on remaining SEC issues for the period of July 1, 1972,

3

through December 31, 1990. One aspect of this site profile review was to assess the data 

completeness of internal monitoring records during this period. Hanford is somewhat unique, in 

that it has a very extensive electronic database (known as the Radiological Exposure or “REX” 

Database) of worker records, which are available for analysis. As described below, SC&A used 

the REX database to assess the extent of worker monitoring for individual radionuclides as it 

relates to temporal considerations, job title, and work location. The basic methodology and 

information available are described below. For the full results of the completeness analysis, the 

reader is referred to SC&A 2011, Appendix A.

Analytical Approach Taken:

SC&A 2011 states the purpose of the completeness analysis as follows:

The purpose of this report is to examine the internal monitoring records 

contained in the Radiological Exposure Database (REX) for adequacy and 

suitability in constructing the coworker model presented in Appendix C of the 

Hanford Site internal dose TBD (ORAUT 2010e). Specifically, this report will 

seek to identify monitoring practices, exposure potential, and potential gaps as 

they pertain to worker job categories, as well as periods of production and 

exposure potential during the SEC period. (SC&A 2011)

As specified previously, a rather extensive database (REX) contains worker monitoring records 

for the Hanford Site. The REX database itself is made up of nearly 70 individual files; some of 

these files contain monitoring data, while most others represent reference tables that can be used 

to interpret the dosimetry files. As an example, the reference files 

“REX_DOE_OCCUPATION” and “REX_HAN_FACILITY” provide individual codes for job 

title and some individual work areas to be used in other database files. These reference files are 

necessary in order to be able to decode and associate the appropriate job titles and work locations 

with specific workers and monitoring results.

Inspection of the available REX Database files identified five main database files to be used in 

the internal completeness analysis. These files are described in Table A-1. The first file listed, 

REX_WORK_HIST, does not actually contain any monitoring data; however, it enables the 

tracking of individual workers (via an individual ID number) and their respective employment 

 

3 On October 20, 2009, the Advisory Board accepted the NIOSH recommendation to extend the Hanford 

SEC to cover all workers who meet the eligibility criteria up to June 30, 1972.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

26 of 49

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

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

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

periods across the three internal dosimetry files of interest: ‘INV_RESULT,’ 

‘INV_ISO_RESULT,’ and ‘EXC_RESULT.’ The last file in Table A-1, 

‘DOS_SUM_RESULTS,’ is related to external dosimetry; however, it also contains individual 

worker job title information, which can be used to supplement job title information contained in

the internal dosimetry files.

Table A-1: Description of REX Database Files Used in Completeness Study

DATABASE NAME DESCRIPTION

REX_WORK_HIST Identifies workers by a ‘REX ID,’ which allows for the tracking of individual workers 

across the different database files. Also contains employment start and end dates.

INV_RESULT

Lists in-vivo counting samples by REX ID and date, and assigns a tracking number to 

each in-vivo sample, which can be used to obtain the results of the count in 

‘INV_ISO_RESULT’ described in the next row.

INV_ISO_RESULT Uses the tracking number from ‘INV_RESULT’ and provides the radionuclides and 

result of the in-vivo sample.

EXC_RESULT Contains the urinalysis data for workers listed by REX ID.

DOS_SUM_RESULTS

Contains external monitoring results, which are not part of this analysis; however, the 

database also contains job title information, which can be linked to the internal 

database files by REX ID

In many instances in the database, work location and/or job title are not specified for each 

individual internal monitoring result. For example, a worker might have dozens of urinalysis 

data points available, but only one of those results specifies the job title and work area. SC&A 

2011 states the following on this issue:

Because taking this information at face value (i.e., only considering worker 

employment periods with a job title specified or only internal monitoring results 

that specify a work area) would severely limit the amount of data available for 

analysis, an approximate approach was developed, so that as much data as 

possible could be included. To this end, it has been assumed that, if a worker is 

identified with a specific job title, they held that job title throughout their SEC 

employment. Similarly, if a worker is identified with a specific area of work, it is 

assumed they spent their entire employment at that location. (SC&A 2011)

Clearly this type of approach would result in some “double counting” for cases in which a 

worker may have held more than one job title or worked in more than one area of the site. 

SC&A 2011 explored the potential issue of double counting in its completeness study. For 

example, it was found that over 93% of the surveyed workers were associated with only one job 

title in the REX_Database. Less than 1% had more than two job titles, and no worker had more 

than 4 job titles. The effect on work location analyses was less easily quantified; however, it was 

deemed that the assumption of grouping workers into specific areas for the length of their 

employment was more beneficial than any potential loss in accuracy.

Using this assumption and available information on job title and work location scattered 

throughout the database, SC&A was able to modify the information in REX so that the majority 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

27 of 49

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

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

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

of internal monitoring results could be used in the completeness study. The subsequent analysis 

was able to draw some of the following conclusion/findings:

4

(1) For the main radionuclides analyzed (Am, Cs, MFP, Pu, and U), workers associated with 

the 200 Tank Farms were most likely to be monitored during their employment.

(2) ‘Radiation monitors,’ ‘electricians,’ ‘operators,’ ‘pipefitters,’ and ‘science technicians’

were consistently among the five job titles most likely to be monitored during their SEC 

employment.

(3) In general, the most commonly monitored job titles by area and year were ‘managers and 

administrators’ (for the 100, 100-N, 200, and 300 Areas), ‘operators’ (for the 200, 200 

Tank Farms, and 300 Area), and ‘scientists’ (for the 300 Area).

(4) In-vivo records analysis for americium, cesium, mixed fission products, and uranium 

monitoring showed a significant decrease in worker sampling in 1975 (generally less than 

1% of the worker population was monitored). Other significant decreases in worker 

monitoring include 1974 (iodine), 1976–1977 (mixed fission products), and 1985 

(cesium). Thorium-232 was sparsely monitored throughout the period, and there are very 

few data points overall. No significant decreases in worker monitoring were identified 

for plutonium.

(5) Exotic radionuclides with sparsely available records include thorium, iodine, polonium, 

neptunium, radium, curium, californium/berkelium, and ‘total actinides.’ Polonium, 

curium, and ‘total actinides’ were mostly periodic sampling, while radium and neptunium

appear to be incident related.

Finding 1 demonstrates that one of the known areas of highest exposure potential, the 200 Tank 

Farms, had a higher percentage of workers monitored compared to the other areas. Finding 2 

shows that high exposure potential jobs, such as ‘operators’ and ‘technicians,’ were often 

monitored more frequently than many of the other job types. However, Finding 3 also notes that 

‘managers and administrators’ were the most commonly monitored job title for the 100 Area,

and it is not likely that they would be among the highest potentially exposed job types.

Finding 4 notes where there are significant temporal gaps by radionuclide. It is important in the 

context of completeness to establish whether a greater risk for potential exposure might have 

occurred in those years. As part of its completeness review, SC&A also established what years 

and areas particular radionuclides are known to have been handled, so parallels can be drawn 

between any data gaps and any “off-normal” operations. Finally, Finding 5 notes that the 

available records for some of the more exotic radionuclides are sparse and likely not suitable for 

the development of a coworker model from a completeness standpoint.

Example 1 Discussion:

One of the major advantages to this type of approach of a completeness evaluation is the sheer 

amount of information and data contained in the REX database. Though certain assumptions had 

 

4

It must be noted that findings are meant to be summary conclusions and that much more quantitative 

information is contained in SC&A 2011 than is appropriate to include here.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

28 of 49

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

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

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

to be made when applying the information (such as presumed job title and work location), this 

allowed for the inclusion of the vast majority of data available and provided a very good 

overview of the monitoring practices of the site as applied to nearly all workers (nearly 50,000 

workers and their associated bioassay records were included in the completeness study). 

However, the advantages of this type of “site-wide” approach can also be viewed as a drawback,

since issues such as the inconsistency of reporting the work location and job type require that 

workers be “grouped” based on the available information. This results in some “double 

counting,” which can potentially cause the accuracy of conclusions regarding monitoring 

practices to suffer (for example, if one particular job title was ‘reported’ more often in the REX 

database).

One potential solution to this difficulty would be to perform both types of analyses: 

 One analysis that only considers job and area information directly related to an individual 

monitoring result and ignores all other results for that worker

 A second analysis that associates job and area information with a particular worker for 

their entire employment (as was done in SC&A 2011)

The combined findings and observations from both analyses would likely provide a sufficiently 

solid analytical base from which to draw conclusions about the completeness of the available 

records. It should be noted that on May 31, 2012, NIOSH recommended that the SEC class be 

expanded to also cover the period from July 1, 1972, to December 31, 1983, on the basis of 

insufficient information to reconstruct doses to enriched uranium, U-233, neptunium or thorium. 

The Advisory Board agreed with this recommendation during its July 2012 meeting. 

Example 2: Fernald In-Vivo Lung Count for Thorium

Background Summary:

While the majority of processing at Fernald concerned uranium compounds, thorium compounds 

were also processed at the site, at least up until 1979 and perhaps afterwards in a minimal 

capacity. Fernald also became the Department of Energy’s (DOE’s) national repository for 

thorium compounds beginning in 1972. Therefore, even after the end of most processing in 

1979, exposure potential would have existed through stewardship and repackaging operations up 

through the end of the SEC period in 1989.

From 1953 up through 1967, Fernald utilized Daily Weighted Exposure (DWE) studies to 

characterize the alpha contamination present in the worker’s breathing zone as a way of 

controlling radiation intakes. Starting in 1968, Fernald began receiving periodic visits from the 

Mobile In-Vivo Radiation Monitoring Laboratory (MIVRML), which was a mobile lung counter 

developed at Y-12. Once the MIVRML arrived on site, the practice of performing DWE studies 

ceased and monitoring for thorium deposition, along with uranium, was assigned to the mobile 

counter. The MIVRML went through two different periods of reporting conventions for 

thorium; from 1968–1978, thorium measurements were reported in “milligrams of thorium,” 

while post-1978 thorium measurements were reported as the daughter products of Ac-228 and 

Pb-212.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

29 of 49

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

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

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

In March 2008, NIOSH released its coworker model for thorium exposure entitled, Thorium In 

Vivo Coworker Study for FEMP – A Proposed Attachment for ORAUT-TKBS-0017-5, Revision 1

(ORAUT 2008). On April 26, 2012, the Advisory Board determined that Th-232 internal doses 

cannot be reconstructed with sufficient accuracy for the 1968 to 1978 period (when thorium lung 

burdens were reported in mg of Th). Therefore, the following completeness study example will 

focus on the later period of thorium in-vivo monitoring (1979–1988).

Analytical Approach Taken:

No electronic database previously existed to characterize in-vivo monitoring at Fernald. 

Therefore, ORAUT 2008 developed its coworker model using site-specific hardcopy logbooks,

which would document the in-vivo results for individual workers. These logbooks contained the 

worker’s name, a badge number, date of the measurement, number of days off, measurement 

result, and in most cases the work location (by plant) and job title. An example of a typical 

logbook is shown in Figure A-1. One vital piece of evidence that the logbooks do not contain is 

which workers might have handled thorium, and how the in-vivo measurements might reflect 

these potential exposures. The available hardcopy logbooks contained both claimants and nonclaimants, and were compiled into an electronic database by NIOSH/ORAUT. 

Figure A-1. Example of Thorium Logbooks used in ORAUT 2008

Because the practice of reporting the job title and work area was so prevalent, the approach and 

assumptions utilized in Example 15 were not deemed necessary. The first step in the 

completeness evaluation involved looking at an overview of records by year to determine the 

number and relative magnitude of the results. The purpose of this is to determine if there are 

years with significantly less monitoring, but which might have shown greater exposure potential 

via the magnitude of available sampling. An example of this analysis is shown in Table A-2,

which displays the relative magnitude of results by counting the number of results above the 

minimum detectable activity (MDA). As seen in the table, the number of total samples generally 

increased from 1979 onward, with a significant jump in 1984. Meanwhile, the number of 

“positive” samples decreased from 1979 onward, although they still only constituted a small 

 

5 The approach taken in Example 1 assumed that if a worker was associated with a specific job title/work 

area that they held that title and location for their entire employment.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

30 of 49

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

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

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

percentage of the overall monitored population. There do not appear to be significant gaps in the 

number of samples on an annual basis. Based on historical records for Fernald, the large 

increase in frequency of sampling in the mid-1980s is likely due to the increased focus on 

radiological protection, which generally coincided with the change in management from National 

Lead of Ohio to Westinghouse.

Table A-2: Overview of Available In-Vivo Data 1979–1988

Year # Samples

# Samples with 

both Ac and Pb 

Results above the 

MDA

# Samples with 

Only the Ac 

Result above the 

MDA

# Samples with 

Only the Pb 

Result above the 

MDA

# Samples with 

no Results 

above the MDA

1979 177 26 (14.7%) 4 (2.3%) 2 (1.1%) 145 (81.9%)

1980 188 13 (6.9%) 14 (7.4%) 1 (0.5%) 160 (85.1%)

1981 141 8 (5.7%) 3 (2.1%) 1 (0.7%) 129 (91.5%)

1982 180 8 (4.4%) 1 (0.6%) 5 (2.8%) 166 (92.2%)

1983 169 4 (2.4%) 1 (0.6%) 1 (0.6%) 163 (96.4%)

1984 371 9 (2.4%) 3 (0.8%) 0 (0.0%) 359 (96.8%)

1985 382 2 (0.5%) 3 (0.8%) 4 (1.0%) 373 (97.6%)

1986 463 4 (0.9%) 2 (0.4%) 5 (1.1%) 452 (97.6%)

1987 562 4 (0.7%) 1 (0.2%) 5 (0.9%) 552 (98.2%)

1988 108 1 (0.9%) 1 (0.9%) 0 (0.0%) 106 (98.1%)

All In-Vivo Data 

(1979–1988) 2741 79 (2.9%) 34 (1.2%) 24 (0.9%) 2604 (95.0%)

The next step in the completeness study was to break down the in-vivo records by job title to see 

which jobs were sampled the most frequently and how their results compare to other lessmonitored job types. The results are shown in Table A-3, which demonstrate that the most 

commonly monitored job title (Chemical Operator) also had the highest results among any other 

job title. This demonstrates that monitoring was generally focused on the job types with higher 

exposure potential. However, as mentioned previously, the inability to actually identify which 

workers handled thorium and to what extent they are reflected in the monitoring records is still 

somewhat of a concern.

A similar analysis was performed based on plant area; however, the results were less conclusive. 

It is worth noting that a large portion of the results were associated with “other areas” of the site 

(not Plants 1–9). Repackaging and redrumming operations at Fernald were not generally carried 

out inside any of the main plants, so these “other areas” likely cover some of the places where 

these stewardship activities occurred.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

31 of 49

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

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

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

Table A-3: Comparison of In-Vivo Results by Job Title (1979–1988)

Job Title # of Samples (%of Total)

Magnitude of Results

95th Percentile*

(Ac-228)

95th Percentile*

(Pb-212)

Chemical Operator 1207 (55.0%) 0.387 0.330

Unknown 549 (25.0%) 0.150 0.160

Construction Trades 248 (11.3%) 0.096 0.056

Other Operator 156 (7.1%) 0.278 0.194

Millworker 141 (6.4%) 0.100 0.020

Engineer/Technician 81 (3.7%) 0.100 0.030

Supervisor 73 (3.3%) 0.186 0.200

ITO 68 (3.1%) 0.120 0.113

Laborer 59 (2.7%) 0.104 0.071

Inspection/QA 53 (2.4%) 0.084 0.050

Oiler/Degreaser 28 (1.3%) 0.097 0.070

Health and Safety 21 (1.0%) 0.090 0.260

Administrative 20 (0.9%) 0.061 0.057

Mechanic 16 (0.7%) 0.073 0.040

Security 12 (0.5%) 0.183 0.282

Laundry 10 (0.5%) 0.081 0.000

*95th percentile evaluated using Microsoft Excel’s Percentile Function

The last analysis performed for this completeness evaluation involved gaining insight into how 

workers were selected for counting regardless of job type or work area. Specifically, the analysis 

sought to determine if workers who displayed “positive” lung counts were scheduled to be 

monitored more frequently than workers whose results were less than the detection limit. It was 

found that geometric mean number of days that passed between counts for workers with results 

below the detection limit was nearly a year (364 days), while the number of days for workers 

with positive results was only 36, nearly 1/10th the time elapsed when compared to results less 

than the MDA. 

In summary, the completeness analysis was able to determine that (1) there were no significant 

gaps in the monitoring data on an annual basis, (2) higher potential job types (such as chemical 

operator) were sampled more frequently, and (3) the time elapsed between samples for workers 

with positive results was approximately 1/10th the elapsed time of those with no positive result. 

While the work area analysis was generally inconclusive, it also did not demonstrate a bias

towards sampling areas with lower exposure potential. SC&A concluded that the dataset was 

suitably complete for the purposes of dose reconstruction, though cautioned that the 

implementation of any coworker model should account for the inability to identify the specific 

workers who handled thorium.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

32 of 49

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

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

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

Example 2 Discussion:

This approach used a large cross section of workers (not just claimants, as shown in the next 

example) and had reasonably extensive work location and job type information included in the

hardcopy records. Given these characteristics of the dataset, it is reasonable to conclude that any 

quantitative analysis including the job and work area was accurate for the group of monitored 

workers. However, it is not clear to what extent these records reflect the entire affected worker 

population. As stated previously, the lack of information identifying which workers actually 

handled thorium and to what extent they were monitored is not currently available. However, 

reasonable claimant-favorable assumptions regarding the implementation and assignment of 

thorium intakes using this dataset likely obviates this uncertainty from an SEC perspective.

Example 3: Internal Dose to Workers at Nevada Test Site during the Underground Testing 

Period (1963–1990)

Background Summary:

The NTS operated from 1951 until 1992 and was one of the primary sites for testing nuclear 

explosive devices during that time. From the beginning of site operations until 1963, the United 

States conducted more than 100 aboveground nuclear tests, at which point all further nuclear 

testing was conducted underground until radiological operations ceased in 1992. In April of 

2006, NIOSH evaluated the period of atmospheric testing (1951–1962) and determined that it 

could not reconstruct doses with sufficient accuracy. The Advisory Board accepted NIOSH’s 

findings and the SEC was granted in May of 2006.

Subsequent to this Advisory Board recommendation, NIOSH produced a new evaluation report 

covering the period of 1963 through 1992 (NIOSH 2007). In this evaluation report, NIOSH 

proposed an internal dose coworker model based on the bioassay data from a group of 100 

claimants with evidence of radiological exposure at NTS. Specifically, NIOSH 2007 states:

NIOSH examined the records supplied by DOE for 100 NS claimants with 

significant total external whole-body photon exposures (cumulative above 

1.0 rem). The nature of the potential exposure scenarios at NTS makes it most 

likely that significant internal exposure would be associated with significant 

external exposure. (NIOSH 2007)

At the time, DOE had supplied records for 1,287 total claims for NTS, and over 400 of those 

claims contained some internal dosimetry data.

Analytical Approach Taken:

In this example, the proposed coworker model is based on a sample of 100 claimants, which 

differs from the first two examples that contained an expansive electronic radiological database 

(Example 1) or site-wide hardcopy records that represent both claimants and non-claimants 

(Example 2). It must be noted that at the time of the initial evaluation report (NIOSH 2007), no 

electronic database was known to be available that would encompass a larger portion of the 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

33 of 49

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

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

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

workers at NTS. It is the absence of a radiological database that necessitated the approach of 

using claimant records to attempt to characterize the potential dose at NTS.

Since the group of claimants chosen for the basis of the coworker model (henceforth referred to 

as the “NIOSH 100”) only comprise 25% of the NTS claimants with internal dosimetry 

information, the first step taken in evaluating this approach was to construct an alternate group of 

claimants for comparison. In order to get a sense for the exposure potential for different job 

categories, SC&A randomly selected 20 claimants each from 6 job classifications (radiological 

safety, laborers, welders, wiremen, miners, and security guards). This semi-randomly selected 

group is comprised of 120 claimants and can be referred to as the “SC&A 120.” It should be 

noted that since the claimants were randomly selected, some of the claimants were included in 

both the NIOSH 100 and SC&A 120 sampling groups.

SC&A then compiled radiological information provided in the claimant records for both the 

NIOSH 100 and SC&A 120. From this compilation and analysis, it became clear that the 

internal monitoring program at NTS was biased, from a frequency standpoint, towards the job 

titles of radiological safety and security guard. However, there was no evidence from this 

analysis that those job types exhibited a higher exposure potential than other job types at NTS. 

Also apparent was the fact that many claimants in the remaining trades analyzed (laborer, 

welder, wireman, and miner) did not have any available bioassay data.

Subsequent to this comparison, a large electronic database was discovered that contained a 

significant amount of bioassay data (over 122,000 samples in the evaluated SEC period) which 

were not previously available to ORAUT. This database did not specify job title; however,

SC&A was able to identify the claimants in the database by their social security number and 

assign them their job titles based on information in the individual claim files. By doing this, 

SC&A was able to expand on the number of sampled workers in the six job categories of 

interest. SC&A then analyzed the database by the four major types of internal monitoring at 

NTS: beta/gross fission products, gamma, plutonium, and tritium. Similar trends to the previous 

analysis were apparent, in that radiological safety and security guards were sampled much more 

frequently than the other job types. 

An example of the analysis results is shown for tritium in Table A-4, which presents an overview 

of the frequency that the particular job titles were monitored, as well as providing some 

indication of the magnitude of the actual results. As shown, though radiological safety workers 

only compromised 13 of the 134 claimants identified with 1 of the 6 job titles, they accounted for 

over 50% of the samples taken. Figure A-2 shows a rank order plot of the magnitude of tritium 

results (MI/cc) for the job categories surveyed. As can be seen, the job categories that had the 

highest results for tritium were actually the miners, wiremen, and laborers, even though they had 

significantly less samples present in the dataset. In fact, the magnitude of tritium bioassay for 

radiological safety was slightly lower than the “all claimant average” at most percentiles and 

lower than the “all worker average” at the upper percentiles. Similar findings were observed for 

the other major bioassay categories (beta/gross fission products, gamma, and plutonium); the 

reader is referred to SC&A 2010 for the full analysis.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

34 of 49

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

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

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

Based on this review of job-specific bioassay results, it can reasonably be concluded that the 

monitoring program was not focused on the most highly exposed workers, and often times did 

not include those job designations in the sampling program. On January 25, 2010, NIOSH 

recommended to the Advisory Board that the class of employees at NTS from 1963 through 

1992 be included in the SEC. In May of 2010, the Advisory Board accepted NIOSH’s 

recommendation.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

35 of 49

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

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

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

Table A-4: Analysis of Electronic Database for Tritium Data Including Data Overview and Characteristics

Tritium Data

Claims

All Workers RadSafe Laborers Welders Wireman Miners Security All Claimant 

Pu

Data Overview 

Total Samples 1985 221 39 37 817 826 4977 42748

# Individuals 13 17 9 13 48 34 244 4724

Urine Samples 1900 (95.72%) 207 (93.67%) 35 (89.74%) 31 (83.78%) 757 (92.66%) 764 (92.49%) 4673 (93.89%) 40253 (94.16%)

Whole Body Counts 85 (4.28%) 14 (6.33%) 4 (10.26%) 6 (16.22%) 60 (7.34%) 62 (7.51%) 304 (6.11%) 2495 (5.84%)

Data Characteristics

Number of Positive 

Results 1718 (86.55%) 202 (91.40%) 29 (74.36%) 28 (75.68%) 717 (87.76%) 755 (91.40%) 4320 (86.80%) 36805 (86.10%)

Number of Results 

Listed as 

‘Less than’

148 (7.46%) 3 (1.36%) 2 (5.13%) 2 (5.41%) 23 (2.82%) 3 (0.36%) 276 (5.55%) 2447 (5.72%)

Number of Negative 

Results 21 (1.06%) 1 (0.45%) 4 (10.26%) - 1 (0.12%) 6 (0.73%) 41 (0.82%) -

Number of Zero 

Results 13 (0.65%) - - - 2 (0.24%) - 19 (0.38%) 135 (0.32%)

Number of Results 

listed as 

‘No Detectable’

- - - - - - - -

Number of Blank 

Results 85 (4.28%) 15 (6.79%) 4 (10.26%) 7 (18.92%) 74 (9.06%) 62 (7.51%) 321 (6.45%) 3361 (7.86%)
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

36 of 49

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

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

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

Rank Ordered Tritium Concentration in Urine

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

1.1

1.00E-08 1.00E-07 1.00E-06 1.00E-05 1.00E-04 1.00E-03 1.00E-02 1.00E-01

Concentration (MI/cc) Rank Order

All Claimants

Radsafe

Laborers

Welders

Wireman

Miners

Security

All Workers

Figure A-2. Rank Ordered Tritium Concentration in Urine (MI/cc) for Surveyed Job Titles
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

37 of 49

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

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

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

Example 3 Discussion:

The approach described above was clearly an iterative process due to the unavailability of an 

electronic database in the beginning stages of the completeness evaluation process. 

Nevertheless, the methodology of using claimant samples can be an effective instrument in 

gathering information and insight into the monitoring practices of a particular site. This is 

illustrated by the corroborating analysis of the electronic database later uncovered, though care 

must be taken to put such claimant sample-based analyses in their proper frame of reference. 

Though it is always preferable to analyze data that are representative of the workforce as a 

whole, absent the availability of such information, claimant sampling is a useful tool to gain 

insight into the completeness of available data in an SEC context.

Example 4: Bounding Internal Exposures to Stable Metal Tritides at the Mound Plant

Background Summary:

Stable metal tritides (SMTs) are a form of insoluble tritium that do not metabolize from the lung 

like normal tritiated compounds, and, as a result, it is not possible for traditional bioassay 

methods, such as urinalysis, to accurately reflect the actual exposure to SMTs. It has been 

established that SMTs were handled in specific known areas of the Mound Plant, and it is also 

known who the primary workers are who handled the material. Air monitoring data are

available; however, it is equally problematic, because this material would have been caught in 

the air filters prior to being counted by the detector.

Since it is known who the primary handlers of the material were, maximizing assumptions can be 

made to adjust those individual urinalysis results to effectively bound the potential exposure to 

these workers. However, this type of bounding model would be inappropriate to use on ancillary 

or support workers whose exposure to the material would likely have been infrequent and the 

potential for intake minimal. Therefore, an alternate method was constructed, which used area 

swipe samples to model the resuspension and intake of the tritiated material. This method was 

finalized in the NIOSH report: Potential Stable Metal Tritide Exposures at the Mound 

Laboratory (NIOSH 2012a).

Analytical Approach Taken:

As stated in the previous section, the proposed model is not based on actual bioassay or in-vivo 

monitoring of workers, but rather workplace sampling in the form of swipe data. Though the 

specific areas/rooms where the work was performed are known, there is still the potential that 

particular areas of the room may not have been sufficiently monitored via swipe samples. 

Fortunately, the original swipe sample reports are available and inspection of these reports shows

that swipes were taken all over the rooms of interest (an example of one such report is shown in 

Figure A-3). Therefore, it is not likely that an area within the room had significantly higher 

contamination and was routinely missed by the swipe sampling program.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

38 of 49

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

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

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

Figure A-3. Example of a Swipe Sample Report Showing the Layout of the Room 

and Areas that were Sampled

The primary handlers of the SMT material have been identified and a bounding approach has 

already been developed; therefore, the proposed resuspension model only applies to ancillary or 

support workers. Since it is not possible to identify which of these workers might have been 

exposed, the model applies to all workers who entered radiological areas. At Mound, if a worker 

entered a radiological area, then a tritium urinalysis sample was mandatory. As a result, anyone 

with tritium bioassay is considered to have been potentially exposed to SMTs. Therefore, any 

evaluation of the completeness of the proposed approach need only consider the temporal 

coverage of the available swipe results and not the job types and areas of interest (which are both 

known).

SC&A presented its completeness study in SC&A 2012 and found that there were significant 

temporal gaps in the available swipe data. One example is shown in Figure A-4, which plots the 

number of available swipe samples for Room R-108 during the period of interest. As seen in the 

figure, there is a gap in the swipe data that extends over 2 years, as well as a few other smaller 

data gaps. It is important to determine whether a surrogate data approach is appropriate to use 

during these gaps in data coverage, and that no off-normal operations involving SMTs occurred. 

Any off-normal operations or conditions might have posed a higher exposure potential, which 

would make using surrogate data from surrounding periods problematic. 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

39 of 49

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

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

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

Source: SC&A 2012

Figure A-4. Number of Samples by Year for Room R-108 during the Period of Interest

NIOSH 2012b addressed these gaps in the data using two different approaches. First, NIOSH 

conducted further interviews with former workers who had direct knowledge of the SMT 

operations. These workers were shown the gaps in the available data and were asked if there was 

any reason to believe that operations would differ from the periods when swipe data were

available. NIOSH 2012b states:

Interviews with the research chemists and radiological health personnel that have 

firsthand knowledge of the operations were specifically asked if any working 

situations occurred or they were made aware of that would have caused the 

missing swipe data to be different than the data on either side of the gap. The 

overall agreement was the data from both sides of the gaps should be adequate to 

extrapolate the data within the gaps.

In the second approach, NIOSH analyzed the tritium urinalysis data during the entire period of 

interest, which included the periods with swipe data gaps. Though tritium urinalysis data are not 

indicative of exposure to SMTs, they do indicate whether site-wide tritium operations might have 

increased during the periods with no swipe data. This type of indirect test helps build a weight 

of evidence argument, since it is not unreasonable to assume that operations involving SMTs 

would generally parallel the other tritium operations at the site from a production and exposure 

standpoint. An example of this is shown in Figure A-5 for Room R-108, which essentially takes 

the plot shown in Figure A-4 and overlays the average tritium doses during the period. As seen 

in the figure, overall tritium doses at the site during periods with swipe data gaps were not 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

40 of 49

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

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

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

significantly different than the periods with swipe data. In fact, the period with the highest 

tritium doses (late 1985) is covered by the swipe data. Therefore, reasonable application of 

surrogate data is likely appropriate to bound SMT exposures during the periods with no data. 

Similar results were found for the other room of interest (SW-8) that had identified data gaps.

Source: NIOSH 2012b

Figure A-5. Number of Swipe Samples Plotted against the Average Dose 

Based on Tritium Urinalysis

Example 4 Discussion:

While it is always preferable to use worker bioassay data to reconstruct doses and develop 

coworker models, in some situations, the bioassay information is unavailable or is not adequate 

for the task. In the case of Mound, urinalysis data are available, but are inappropriate for the 

purpose of reconstructing doses to the support workers. Therefore, the alternate approach of 

using workplace monitoring was adopted to bound doses to this group of workers.

This type of approach still requires the ability to identify the specific areas and workers that were 

involved in the operation of interest. Fortunately in this case, the pertinent information was 

available. Therefore, the main concern from a completeness perspective is the temporal 

considerations. Although there were significant data gaps identified, worker interviews and 

characterization of the overall site production during the gap mitigate any potential issues arising 

from the unavailability of swipe data.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

41 of 49

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

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

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

APPENDIX B: EXAMPLES OF STRATEGIES USED BY SC&A 

IN ANALYZING ALLEGATIONS OF DATA FALSIFICATION 

IN AN SEC CONTEXT

Example 1: Internal Monitoring Record Falsification at Fernald

Background Summary:

During the Work Group meeting on January 29, 2010, the concern was raised by petitioner and 

others as to the integrity of the Feed Materials Production Center (FMPC or Fernald) bioassay 

program. Specifically, the integrity of the uranium urinalysis data entered onto logsheets and 

other hardcopy records was questioned. It was felt that the available data did not reflect the 

actual uranium exposures and was systematically manipulated to avoid recording high internal 

exposures. During that Work Group meeting, SC&A was tasked with developing potential 

strategies to evaluate this issue. The subsequent effort was documented in SC&A 2010.

Analytical Approach Taken:

SC&A investigated the feasibility of three different approaches for evaluating the potential for 

data falsification:

(1) Comparison of uranium urinalysis and in-vivo lung counting records for individual 

workers to assess the consistency between the two forms of internal monitoring.

(2) Perform a biokinetic analysis on available urinalysis sampling for a group of workers to 

determine if the observed fluctuations in uranium concentration are biologically feasible.

(3) Review available daily weighted exposure (DWE) reports to identify the job titles and 

areas of the site with the highest exposure potential; then compare the DWE reports to the 

dosimetry records of claimants who can be identified with those jobs and areas. 

While data falsification is a difficult thing to prove quantitatively, SC&A explored these 

analytical approaches to determine if there was an appropriate “test” that might indicate the 

possibility of widespread record fabrication. For each of the three analytical methods, SC&A 

2010 provides a description of the theory behind the proposed approaches, evaluated their 

feasibility, provided an example (or “proof of concept”), and discussed the advantages and 

disadvantages of each method.

As stated above, the first strategy involves comparing two different types of internal monitoring 

for a group of workers. The theory behind the method is that the relative magnitude of in-vivo 

uranium measurements for exposed workers would closely mirror their urinalysis results at the 

time. For example, if a worker consistently had a significantly elevated uranium lung burden, 

but the associated urinalysis results were all “zeros,” this might indicate that the bioassay 

program was corrupt.

The first step in addressing the feasibility of this approach was to determine how many workers 

can be identified that have a sufficient number of both urinalysis and in-vivo results. Based on 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

42 of 49

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

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

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

an analysis of the electronic dosimetry database for Fernald (also known as the “HIS_20”), 

SC&A was able to determine that there were 53 workers who had at least 10 results for both 

forms of internal monitoring. SC&A also presented two figures that provided examples of the 

comparison between in-vivo and urinalysis results for individual workers. One such example is 

shown in Figure B-1 below. As seen in the figure, the worker had one instance where the in-vivo 

uranium result spiked significantly compared to neighboring measurements; however, no change 

was witnessed in the urinalysis data, and there was also an instance where the urinalysis result 

spiked significantly with no associated change in measured lung burden.

-20

-10

0

10

20

30

40

50

60

70

80

1967 1969 1971 1973 1975 1977 1979 1981 1983

Year Monitoring Result

In Vivo Result (mg)

Bioassay Result (ug/l)

Figure B-1. Comparison of In Vivo (mg U Total) and Bioassay Results (μg/l U Total) 

for a Select Worker

Some of the benefits identified for this approach include the fact that it is a direct comparison of 

individual worker dosimetry records. Also, the workers who would be included in the analysis 

are likely to have had the highest exposure potential, since they were targeted for both the 

urinalysis and in-vivo program. However, there were also many deficiencies identified 

including:

 The individual in-vivo and urinalysis results were not often in close proximity 

chronologically, which could make it difficult to compare and interpret the two 

monitoring techniques. 

 In-vivo monitoring at Fernald was not available prior to 1968.

 The analysis would be restricted to only about 50 workers.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

43 of 49

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

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

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

 Without specific information regarding uranium solubility type and the exact sampling 

methods employed, accurate interpretation of the available data would be problematic.

The second proposed approach involved analyzing individual worker urinalysis results to see if 

there were instances of biokinetically infeasible declines in uranium concentration in urine as a 

function of time. If part of a worker’s uranium urinalysis record was being purposely underreported, then these unrealistic drops in urine concentration might be evident. 

Similar to the first strategy, this method requires that a worker have a significant number of 

urinalysis results available for analysis. To address the feasibility of such an approach, SC&A 

analyzed the HIS_20 database to determine the frequency of uranium monitoring by decade at 

Fernald. The results are recreated in Table B-1.

Table B-1: Frequency of Worker Sampling by Decade

Number of 

Records in 

Period

Number of Workers with Listed Number 

of Records by Period

1950s 1960s 1970s 1980s

1–10 2442 1342 933 3317

11–20 741 516 263 428

21–30 371 392 64 246

31–40 242 472 40 122

41–50 149 253 88 91

>50 293 369 90 337

Based on Table B-1, it is apparent that there are a significant number of workers who could be 

selected for analysis. As an example, SC&A selected a worker who had multiple urinalysis 

results and also at least one significantly high concentration reported. This high urinalysis result 

was analyzed using the IMBA program (Integrated Modules for Bioassay Analysis) to predict 

what subsequent urinalysis concentrations should be. These predicted concentrations can then be 

compared to the worker’s actual bioassay record. One such example is presented in Figure B-2, 

which shows that subsequent urinalysis results were not unrealistic compared to the high result.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

44 of 49

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

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

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

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

Oct-55 Nov-55 Jan-56 Mar-56 Apr-56 Jun-56 Aug-56 Sep-56 Nov-56 Jan-57

Date

Bioassay Result (mg/l)

Sample Worker Bioassay

Calculated Bioassay Type M

Calculated Bioassay Type F

Figure B-2. IMBA Predicted Bioassay Results Based on First High Sample for Select 

Worker Compared to Actual Bioassay Results

One of the main benefits of this second strategy is that it would cover the entire SEC period at 

Fernald and utilizes individual bioassay records. Also, this method allows for a larger pool of 

workers that could be analyzed than the first approach. However, some of the drawbacks are that 

the strategy still is only applicable to workers with a significant number of urinalysis results. In 

addition, implausibly large drops in uranium concentration may not be evidence of data 

falsification, but rather an error in the original sample analysis. Similarly to the first approach, 

uranium solubility has a major effect on observed urine concentrations, and accurately 

interpreting the available data would be problematic.

The third and final approach involves identifying the work areas and job titles with the highest 

exposure potential based on the DWE reports. These higher-risk jobs can then be matched to 

available claimant records and analyzed to determine if these claimants have unusually low 

urinalysis results. Logically, if data falsification was prevalent at Fernald, then these higher-risk 

workers would likely be targeted, and their results falsified.

The first step in determining the feasibility of this strategy was to evaluate the number of 

claimants who could be matched to facilities and years with available DWE data. The analysis is 

restricted to claimants, because there are no job title designations available in the HIS_20 

database. Also, the pool of workers available for the proposed analysis is further restricted by 

the limited amount of work area information available. The number of workers available for 

analysis is in Table B-2.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

45 of 49

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

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

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

Table B-2: Plants and Years in Which Claimant Urinalysis Can be Matched 

and DWE Data Exist

FEMP 

Location

# of Claimants (# of Samples)*

1953 1954 1955 1956 1957 1958 1959 1960 1961

Pilot Plant - - - 20 (184) 11 (53) - - - -

Plant 1 - - 14 (42) 39 (140) 22 (49) - - - -

Plant 2 - - 21 (85) 42 (127) 32 (67) 1 (1) - - -

Plant 2-3 - - - - - - - - -

Plant 3 - - 31 (93) 23 (43) 27 (64) 1 (1) - - 18 (18)

Plant 4 - 5 (13) 16 (30) 26 (112) 27 (148) 4 (4) - - -

Plant 5 8 (11) 5 (11) 48 (343) 61 (135) 69 (257) 9 (9) - - 1 (1)

Plant 6 6 (6) 7 (21) 48 (167) 73 (444) 121 

(822) 7 (7) - - -

Plant 7 - - 42 (629) 25 (154) - - - - -

Plant 8 - - 15 (66) 35 (197) 42 (387) 2 (2) - - -

Plant 9 - - 5 (8) - 21 (58) - - - -

*Dashes indicate that either no claimant samples could be identified or no DWE report is available for that plant and 

year.

Additionally, it was noted that many of the DWE reports contained an appendix with urinalysis 

samples taken for the workers involved in the DWE study. These appendices would allow for a 

more direct comparison of the working conditions and available bioassay data. Another benefit 

of the approach, as noted before, is that it targets the workers with the greatest exposure 

potential, and therefore the most likely target for any falsified monitoring.

However, one of the major limitations of the strategy is its restriction to plants and years with 

available DWE reports. The approach is also limited by the number claimants that can be 

identified with the specific job type, area, and year. The method is further complicated by a lack 

of information on whether sampled workers might have worn respiratory protection. Similar to 

the first two proposed strategies, a lack of information on the solubility type of the uranium 

exposure makes appropriate interpretation of the urinalysis results problematic. 

Discussion:

The strategies presented in the previous section were discussed at the Fernald Work Group 

meeting on November 9, 2010. The consensus of that discussion was that the limitations of each 

of the three strategies were too great and the results of pursuing any of the approaches would 

likely be inconclusive. As such, it was determined that it was not feasible to construct an 

appropriate analytical approach to investigate the potential for records falsification at Fernald. 

However, by crafting these three approaches and evaluating their feasibility, the Work Group, 

SC&A, and NIOSH performed the required due diligence in examining this SEC issue.
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

46 of 49

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

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

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

Example 2: External Badging Practices at the Nevada Test Site

Background Summary:

One major facet of the Nevada Test Site (NTS) SEC petition (HHS 2007) called into question the 

representativeness of external film badging records due to the stated practice of “hiding” film 

badges to avoid reaching the regulated external dose limits. The petition covered the period of 

September 1, 1963, through September 30, 1992, and specifically stated:

It was common practice that workers, apparently at the direction of management, 

did not wear and/or hid dosimeter badges to prevent registering doses that would 

cause them to exceed project, monthly, or cumulative doses. Consequently, film 

badge data will underestimate the exposure of individuals and groups of workers.

(HHS 2007)

NIOSH reviewed the petition and released its evaluation report (NIOSH 2007), which addressed 

the potential issue of whether film badge records accurately reflect the external exposure 

potential for workers at NTS. In the report, NIOSH utilized the available Computer Assisted 

Telephone Interviews (CATIs) to show that only about 1% of the NTS claimants confirmed the 

practice of hiding film badges to keep reported external doses at an allowable level. The results 

of this analysis were shown in Table 7-16 of NIOSH 2007 and are recreated below in Table B-3.

Table B-3: Results of Interviews regarding Defeat of the Universal Badging Policy

(Source: NIOSH 2007, Table 7-16)

Job Title

Number of 

CATI Results 

Reviewed

Number of 

Additional 

Interviews

Number of 

Interviews by 

Job Category

Number of 

Interviewees 

Indicating Monitoring 

Defeat

Administrative 9 1 10 1

Drill Worker/Engineer 32 1 33 3

Tunnel Worker/Miner 66 1 67 1

Plumber/Pipefitter 48 1 49 0

Carpenter/Welder 36 0 36 1

Surveyor/Civil 

Engineer 

7 0 7 2

Laborer 71 0 71 2

Other 932 10 942 3

Total 1,201 14 1,215 13 (1.1% of total )

During SC&A’s review of NIOSH 2007, the concern was raised that CATI reports do not 

specifically ask whether workers might have hidden their badges or misrepresented their accrued 

external exposure. Therefore, the use of these interviews was not a strong basis to conclude that 

the practice was not widespread. As a result, the NTS Work Group directed SC&A to perform 

an additional investigation to gain more information on the potential that external monitoring 

policies had been compromised. 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

47 of 49

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

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

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

Analytical Approach Taken:

SC&A’s investigation into the allegations of external badge tampering was two-phased:

(1) Perform additional interviews with former workers and specifically address the practice 

of hiding film badges in order to keep external exposures low.

(2) Review a sample of claimant dosimetry records to determine if film badge records are 

consistent with other forms of external monitoring, such as pencil dosimeters or pocket 

ionization chambers (PICs).

It is this second facet of the investigation that is the subject of this example and was documented 

in SC&A 2008. That report described the sampling and review of dosimetry records for 10 NTS 

claimants to assess the consistency between the official film badge records and other forms of 

external monitoring, such as the pencil dosimeters or PICs. Specifically, SC&A 2008 states:

SC&A investigated the issue of the “hidden badges” by carefully reviewing the 

records of 10 workers (referred to as case studies). For each of these cases, 

SC&A compared area access register data to the yearly and monthly film badge 

doses reported in the DOE records. Since SC&A had already gathered much of 

the dosimetry data from 120 randomly selected NTS cases for another petition 

issue investigation, the 10 cases for this analysis were chosen from that group. 

SC&A chose cases based on three criteria: (1) job category, (2) availability of 

area access register data, and (3) employment during the 1963–1967 time period.

(SC&A 2008)

The job categories selected include three Miners, two Radiation Safety workers, two Welders, 

one Laborer, one Security Guard, and one Wireman. The emphasis on the “miners” in the 

selected sample was due to their generally higher exposure potential and, therefore, increased 

motivation to tamper with the external dosimetry results. The 1963–1967 timeframe was chosen 

because during this time, a worker’s film badge and security/ID badge were separate items. At 

some point in 1966, the film and security badges were integrated. After this time, it would have 

been much more difficult to gain access to radiological areas without also wearing the film 

badge. However, SC&A extended the investigation into 1967 to gain insight into the period after 

the badges were integrated.

The review of each individual case is described in SC&A 2008 to include the following:

For each case, SC&A reviewed the area access register information and created 

spreadsheet tables which included the register date, the shift, the PIC reading, 

and whether the film badge had been pulled for analysis. We also included any 

film badge readings that were reported during the dates of the area access 

registers. In addition, SC&A closely reviewed the area access registers for any 

inconsistencies or missing information. (SC&A 2008)
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

48 of 49

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

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

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

It was found that each case generally fit into one of three categories.

(1) The worker had PIC readings that were all zero or nearly zero (3 cases). For these 

claimants, no further investigation was warranted.

(2) The worker had positive PIC readings that were less than 100 mrem (2 cases). In these 

cases, the worker’s film badge would not have been pulled for immediate analysis, so the 

monthly totals for the PIC readings could be directly compared to the film badge result 

for that month.

(3) The worker had positive PIC readings that were greater than 100 mrem and/or that 

worker’s film badge was pulled for immediate analysis prior to the 1-month interval 

typical at NTS (5 cases). In these cases, dosimetry records were specifically reviewed to 

ensure that pulled badges were, in fact, analyzed on the day in question. If so, then the 

film badge reading was compared to the PIC readings taken up until the date the badge 

was pulled.

SC&A found no significant inconsistencies for 9 out of the 10 claimant dosimetry files reviewed. 

However, for the remaining case, it was found that there were multiple incidents where PIC 

readings were not entered into the area access registers. Also, one of the years showed a 

discrepancy of approximately 750 mrem between the reported film badge and PIC annual doses. 

The results for this worker are shown in Table B-4. For the complete analysis of the 10 

claimants, please refer to SC&A 2008. 

Table B-4: Comparison of PIC and Film Badge Annual Totals for an NTS Claimant

Year PIC total

(mrem)

Film badge total

(mrem)

1965 355 4415

1966 935 2365

1967 2701 1945

Discussion:

Similar to Example 4 in Appendix A, an approach utilizing the sampling of claimant documents 

was necessitated due to the unavailability of a site-wide database (electronic or hardcopy) of 

worker dosimetry records. This investigation also demonstrated a numerical approach to the 

issue that can be used to supplement the valuable information gathered from worker interviews. 

Ultimately, the issue concerning the validity of available film badge records was rendered moot 

in an SEC context. On January 25, 2010, NIOSH recommended to the Advisory Board that the 

class of employees at NTS from 1963 through 1992 be included in the SEC on the basis of an 

inability to reconstruct internal doses during that period (NIOSH 2010). This recommendation 

was accepted by the Advisory Board in May of 2010. 
Effective Date:

October 15, 2012

Revision No.

0 - Draft

Document No.

SCA-TR-PR2012-0011

Page No.

49 of 49

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

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

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

REFERENCES:

NIOSH 2010. SEC Petition Evaluation Report – Petition SEC-00084, Nevada Test Site (NTS) 

Rev. 1. National Institute for Occupational Safety and Health. September 25, 2007.

SC&A 2008. SC&A Review of NTS Petition SEC-00084: Defeat of the Universal Badging 

Policy. Sanford Cohen and Associates. Vienna, Virginia. September 25, 2008. 

SC&A 2010. Strategies to Investigate Allegations of Corrupt Bioassay Monitoring at Fernald. 

Sanford Cohen and Associates. Vienna, Virginia. June 2010.

HHS 2007. Nevada Test Site Special Exposure Cohort Petition. U.S. Department of Health and 

Human Services – Special Exposure Cohort Form B. OMB Number: 0920-0639. February 5, 

2007.