DRAFT 

REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health 

COMPARISON OF SC&A’S BLIND DOSE RECONSTRUCTION 

TO NIOSH’S DOSE RECONSTRUCTION OF CASE #[REDACT] 

FROM THE DANA HEAVY WATER PLANT 

AND SAVANNAH RIVER SITE 

Contract No. 211-2014-58081

SCA-TR-DRC2015-CN[REDACT], Revision 1

Prepared by 

Kathleen Behling 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

April 2015 

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:

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Revision No.

1 (Draft)

Document No. 

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S. Cohen & Associates:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No. 

SCA-TR-DRC2015-CN[REDACT]

Effective Date: 

Draft – April 16, 2015

Comparison of SC&A’s Blind Dose 

Reconstruction to NIOSH’s Dose Reconstruction 

of Case #[Redact] from the Dana Heavy Water 

Plant and Savannah River Site

Page 2 of 23

Task Manager:

________________________ Date: ___________

Douglas Farver, CHP

Supersedes:

Rev. 0

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer:

 Douglas Farver

 John Stiver

Record of Revisions

Revision 

Number Effective Date Description of Revision

0 (Draft) 02/24/2015 Initial issued.

1 (Draft) 04/16/2015 Corrects the probability of causation values in Table 3-1.
Effective Date:

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TABLE OF CONTENTS 

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

1.0 Relevant Background Information .......................................................................................6

2.0 Comparison of Methodology/Doses used by SC&A and NIOSH for Case #[Redact] ........8

2.1 Occupational External Dose Calculations .............................................................12

2.1.1 Recorded Photon Doses .............................................................................12

2.1.2 Missed Photon Doses .................................................................................13

2.1.3 Recorded Shallow Doses ...........................................................................14

2.1.4 Missed Shallow Doses ...............................................................................15

2.1.5 Unmonitored Photon/Electron Doses ........................................................15

2.1.6 Unmonitored Neutron Doses .....................................................................15

2.1.7 Onsite Ambient Doses ...............................................................................16

2.1.8 Occupational Medical Doses .....................................................................17

2.2 Occupational Internal Doses ..................................................................................18

2.2.1 NIOSH Plutonium Intakes .........................................................................18

2.2.2 NIOSH Fission Product Intakes .................................................................18

3.0 Summary Conclusions .......................................................................................................20

4.0 References ..........................................................................................................................22

LIST OF TABLES 

Table 1-1. Comparison of SC&A’s Blind Dose Reconstruction to NIOSH’s Dose 

Reconstruction for Case #[Redact] ...............................................................................7

Table 2-1. Primary Cancers ............................................................................................................8

Table 2-2. Comparison of Data and Assumptions Used by NIOSH and SC&A ..........................10

Table 2-3. Comparison of Recorded Photon Doses ......................................................................13

Table 2-4. Comparison of Missed Photon Doses..........................................................................14

Table 2-5. Comparison of Recorded Electron Doses ....................................................................15

Table 2-6. Comparison of Onsite Ambient Doses ........................................................................17

Table 2-7. Comparison of Occupational Medical Doses ..............................................................18

Table 2-8. Comparison of NIOSH and SC&A’s ‘Method A’ Total Internal Doses .....................19

Table 3-1. Comparison of Total External and Internal Doses Estimated 

for the Five Cancers ....................................................................................................20
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ABBREVIATIONS AND ACRONYMS 

Advisory Board Advisory Board on Radiation and Worker Health 

BCC basal cell carcinoma 

CATI Computer-Assisted Telephone Interview 

CF conversion factor 

DCF dose conversion factor

DHWP Dana Heavy Water Plant 

DOE (U.S.) Department of Energy 

DOL (U.S.) Department of Labor 

dpm disintegrations per minute 

DR dose reconstruction 

EE Energy Employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

FP fission product 

GM geometric mean 

GSD geometric standard deviation

HHS Health and Human Services 

ICD International Classification of Diseases 

ICRP International Commission on Radiological Protection 

IMBA Integrated Modules of Bioassay Analysis 

IREP Interactive RadioEpidemiological Program 

keV kiloelectron volts 

LOD limit of detection

MDA minimum detectable activity

MeV million electron volts 

μCi/L microcuries per liter 

NIOSH National Institute for Occupational Safety and Health 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team 

OW open window 

PA posterior/anterior

POC probability of causation 
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rem Roentgen equivalent man 

S shielded

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

SD standard deviation 

SEC Special Exposure Cohort 

SRS Savannah River Site 

TBD technical basis document 

TIB technical information bulletin
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1.0 RELEVANT BACKGROUND INFORMATION 

Under Contract No. 200-2009-28555, SC&A was tasked by the Advisory Board on Radiation 

and Worker Health (Advisory Board) to perform six blind dose reconstructions (DRs) at the May 

21, 2013, DR Subcommittee meeting. SC&A was provided all of the Department of Energy 

(DOE) dosimetry records; the Department of Labor (DOL) correspondence, forms, and medical 

records; and the Computer-Assisted Telephone Interview (CATI) Reports that were made 

available to the National Institute for Occupational Safety and Health (NIOSH) for constructing 

doses in behalf of these cases. SC&A used two independent approaches to reconstruct 

occupational external and internal doses for the cases. Both approaches used the available 

dosimetry records and current guidance from NIOSH. The first approach, which is referred to as 

DR–Method A, used the spreadsheets and other tools developed by NIOSH to calculate the 

doses, whereas the second approach, referred to as DR–Method B, manually calculated the doses 

using a deterministic model that is based on central values and first principles. 

One of the six draft blind DR reports [SC&A’s Dose Reconstruction of Case #[Redact] from the 

Dana Heavy Water Plant and Savannah River Site (SC&A 2014), was submitted to the Advisory 

Board and NIOSH on February 26, 2014. In this report, SC&A presents a comparison between 

SC&A’s and NIOSH’s DR methodologies, doses, and resultant Probability of Causation (POC)

values for Case #[Redact]. Table 1-1 summarizes the external and internal occupational doses 

calculated by SC&A (using two independent methods) and the NIOSH-assigned doses for

cancers to the prostate, bladder and colon, and basal cell carcinomas (BCCs) of the right cheek 

and right lower eyelid diagnosed in behalf of Case #[Redact]. As a minimizing DR approach, 

SC&A’s ‘Method B’ only assigned partial doses to the non-presumptive cancers (i.e., prostate 

and BCCs). All three DR methods calculated doses that resulted in a POC >50% and would, 

therefore, be compensable. A detailed comparison of the three methodologies used to calculate

doses in behalf of this case is presented in Section 2. Section 3 of this report provides Summary 

Conclusions.

It should be noted that an explanation is provided regarding the differences in doses and why 

they occurred; however, SC&A does not make any value judgments regarding which among 

them may be the more preferred approach. It is our position that further discussions are best 

addressed by the DR Subcommittee. 
Effective Date:

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Table 1-1. Comparison of SC&A’s Blind Dose Reconstruction to NIOSH’s Dose Reconstruction for Case #[Redact]

Dose Elements

NIOSH SC&A’s DR–Method A SC&A’s DR–Method B

Prostate

Dose

(rem)

Bladder 

Dose

(rem)

Colon

Dose

(rem)

Cheek and 

Eyelid

Dose (rem)

Prostate

and Bladder

Dose (rem)

Colon

Dose

(rem)

Cheek and 

Eyelid

Dose (rem)

Prostate 

Dose

(rem)

Cheek and 

Eyelid

Dose (rem)

External Dose (Occupational):

 ▪ Recorded Photon Dose 

 30–250 keV Photons: 2.516 2.516 2.144 2.023 1.546 1.323 1.771 2.321 1.866

 >250 keV Photons: 1.786 1.786 1.707 2.023 1.617 1.548 1.771 2.321 1.866

 ▪ Missed Dose 

 30–250 keV Photons: 3.004 3.004 2.560 2.415 1.418 1.219 4.088 3.751 3.015

 >250 keV Photons: – – – 1.482 1.419 – – –

 ▪ Recorded Shallow Dose

 NIOSH, Method A (e->15 keV); Method B (e-<30 keV) 4.810 – – 4.385 – 3.196

 ▪ Missed Shallow Dose, e->15 keV: – – – – – – 0.125 – –

 ▪ Unmonitored Photon Dose (30–250 keV) – – – – – – – 0.546 0.546

 ▪ Unmonitored Shallow Dose (<30 keV) – – – – – – – – 0.332

 ▪ Unmonitored Neutron Dose (0.1–2 MeV) – – – – – – – 5.306 6.665

 ▪ Unmonitored Neutron Dose (2–20 MeV) – – – – – – – 3.424 3.099

 ▪ Occupational Medical Dose

 SRS: 0.051 0.051 0.051 0.026 0.051 0.051 0.026 0.046 0.031

 Dana: 0.375 0.375 0.375 0.096 0.375 0.375 0.096 0.375 0.090

 ▪ Occupational Environmental Dose

 Photon (30–250 keV) 0.306 0.306 0.306 0.306 0.318 0.318 0.318 1.361 1.107

Internal Dose (Occupational):

 Missed Pu (alpha) 0.323 0.537 0.710 0.863 – – – – –

 FP (e_>15 keV) 0.085 0.086 0.317 0.072 – – – – –

 Eu-154 (e_>15 keV) 0.012 0.001 0.004 0.001 – – – – –

 Unmonitored H-3 (e_>15 keV) 0.799 0.799 0.799 0.799 – – – – –

 Environmental (e_<15 keV) 0.031 0.031 0.031 0.031 1.296 1.296 1.296 – –

Total 9.288 9.492 9.004 13.465 8.103 7.549 13.876 19.451 21.813

POC 51.39% 51.00% 60.84%
Effective Date:

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2.0 COMPARISON OF METHODOLOGY/DOSES USED BY SC&A AND 

NIOSH FOR CASE #[REDACT] 

Case #[Redact] represents an energy employee (EE) who worked at the Dana Heavy Water Plant 

(DHWP) from [redact], [redact], and the Savannah River Site (SRS) from [redact], through 

[redact]. Based on DOL records and the CATI, the EE worked as a [redact]-[redact]/[redact]

during employment at the DHWP. While employed at the SRS, the EE’s job title was [redact] 

and [redact], and the EE worked primarily in the [redact] Areas. The EE was not monitored for 

external or internal exposure at DHWP; however, the EE was monitored for external radiation 

exposure and participated in the bioassay monitoring program throughout most of the 

employment at SRS. The EE was diagnosed with five cancers between [redact] and [redact], as 

shown in Table 2-1.

Table 2-1. Primary Cancers 

Diagnosis Date Description ICD-9 Code

[redact] Adenocarcinoma of Prostate 185

[redact] Papillary Transitional Cell Carcinoma of Bladder 188.8

[redact] Adenocarcinoma Sigmoid Colon 154.0

[redact] BCC of Skin of Right Cheek 173.31

[redact] BCC of Skin of Right Lower Eyelid 173.11

On February 2, 2012, the Secretary of Health and Human Services (HHS) designated the 

following class of SRS employees as an addition to the Special Exposure Cohort (SEC) under 

Petition SEC-00103: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Savannah River Site from 

January 1, 1953, through September 30, 1972, for a number of work days 

aggregating at least 250 work days, occurring either solely under this 

employment or in combination with work days within the parameters established 

for one or more other classes of employees included in the Special Exposure 

Cohort. 

With regard to non-presumptive cancers, the SEC designation stated the following (HHS 2012):

 NIOSH finds it is feasible to reconstruct the doses received from potential 

exposures to thorium (metal) and its progeny or encapsulated thorium for 

workers assigned to other areas including the 300 Area, the Savannah River Site 

R, P, K, L, C reactors (100 area), and F and H Separation Canyons (200 area). 

There was no exposure to thorium in the heavy water plant (400 area). . . . 

 NIOSH has determined that it has access to sufficient external monitoring data, 

and associated medical monitoring data, for all personnel during all time periods 

at the Savannah River Site facility. NIOSH has identified that it can bound, or 

reconstruct with sufficient accuracy, the external and occupational medical dose 

for all Savannah River Site workers. . . .
Effective Date:

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 Although NIOSH found that it is not possible to completely reconstruct radiation 

doses for the proposed class, NIOSH intends to use any internal and external 

monitoring data that may become available for an individual claim (and that can 

be interpreted using existing NIOSH dose reconstruction processes or 

procedures) to support a partial dose reconstruction for non-presumptive cancers 

and/or cases that have less than 250 work days of employment. 

Lastly, the DHWP facility produced heavy water for the nuclear weapons programs from 1943 

through 1957, and is listed as a ‘covered facility’ under the Energy Employee’s Occupational 

Illness Compensation Program Act of 2000 (EEOICPA). However, heavy water is not 

radioactive, and there is no radioactivity associated with the production of heavy water. 

Therefore, all three DR methods only estimated occupational medical doses in behalf of the EE 

for the covered periods of employment that coincide with the production of heavy water at the 

plant (i.e., 1943 through 1957). 

For calculating radiation doses from employment at SRS, all three DR methods primarily relied 

on guidance in the SRS Technical Basis Document (TBD) (ORAUT-TKBS-0003), External 

Dose Reconstruction Implementation Guideline (OCAS-IG-001), Interpretation of Dosimetry 

Data for Assignment of Shallow Dose (ORAUT-OTIB-0017), and Technical Information 

Bulletin: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures

(ORAUT-OTIB-0006) . Using the guidance provided in the relevant documents, along with the 

employee’s dosimetry records, NIOSH employed a best-estimate approach for calculating 

annual organ doses, while SC&A’s ‘Method A’ and ‘Method B’ performed a partial DR to 

calculate doses, since this was sufficient to produce a POC >50%. The SC&A DR methods were 

considered minimizing, since ‘Method A’ did not calculate any internal dose, other than 

environmental tritium doses, and ‘Method B’ only calculated doses associated with the nonpresumptive cancers and did not consider any internal doses. 

A summary of the documents, assumptions, and dose parameters used by each DR method is 

provided in Table 2-2: 
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Table 2-2. Comparison of Data and Assumptions Used by NIOSH and SC&A

Parameters NIOSH SC&A’s DR–Method A SC&A’s DR–Method B

Recorded Photon Doses

Records/Guidance 

Documents

DOE records, SRS TBD, and the 

SRS Dose Calculation 

Workbook 2.03.

DOE records, SRS TBD, and the 

SRS External Dose Calculation 

Workbook 2.10.

DOE records, SRS TBD, and

OCAS-IG-001

Work Locations [redact] Area [redact] Area [redact] Area

Energy Range 50% 30–250 keV 

50% >250 keV

50% 30–250 keV

50% >250 keV

50% 30–250 keV

50% >250 keV

Organ DCFs

Prostate/Bladder = 1.244

Colon = 0.883

Skin = 1.0

Prostate/Bladder = 0.873 

Colon = 0.747

Skin = 1.0

Prostate = 1.244 

Skin = 1.0

Dosimeter Correction

Factor 1.119 1.119 1.119

Dose Distribution Constant; no uncertainty Constant; no uncertainty Constant; no uncertainty

Missed Photon Doses

Records/Guidance 

Documents

DOE records, SRS TBD, 

ORAUT-OTIB-0017, and SRS 

Dose Calculation Workbook 

2.03.

DOE records, SRS TBD, ORAUTOTIB-0017 and 

IG-001.

DOE records, SRS TBD, OCASTIB-006, ORAUT-OTIB-0017, 

and IG-001.

No. of zeros 93 239 172

LOD Value 0.040 rem 0.040 rem 0.040 rem

Energy Range 100% 30–250 keV 50% 30–250 keV

50% >250 keV 100% 30–250 keV

Organ DCFs

Prostate/Bladder = 1.244 

Colon = 0.883

Skin = 1.0

Prostate/Bladder = 0.873 

Colon = 0.747

Skin = 1.0

Prostate = 1.244 

Skin = 1.0

Dose Distribution Lognormal with GSD = 1.52 Lognormal with GSD = 1.52 Lognormal with GSD = 1.52

Recorded Shallow Doses

Records/Guidance 

Documents

DOE records, SRS TBD, 

ORAUT-OTIB-0017 guidance, 

IG-001.

Shallow minus Deep dose.

DOE records, SRS TBD, and 

ORAUT-OTIB-0017 guidance. 

Shallow minus Deep dose. 

DOE records, OCAS-TIB-006,

and ORAUT-OTIB-0017 

guidance. Shallow minus Deep 

dose. 

Energy Range 100% E>15 keV 100% E>15 keV 100% photons <30 keV

Dosimeter Correction 

Factors None None 0.6 prior to 1971 (OTIB-0006)

1.119 (OTIB-0017)

Organ DCF DCF = 1.0 DCF = 1.0 DCF = 1.0

Dose Distribution Constant distribution Constant distribution Constant distribution

Missed Shallow Doses

Records/Guidance 

Documents

All missed shallow doses 

assigned as 100% photon 30–

250 keV, as described above 

under missed photon doses.

DOE records, SRS TBD, and 

ORAUT-OTIB-0017 guidance. 

Shallow minus Deep dose. 

All missed shallow doses 

assigned as 100% photon 30–

250 keV, as described above 

under missed photon doses.

No. of zeros 6

LOD Value 0.040 rem

Energy Range 100% E>15 keV

Dose Distribution GM of Lognormal distribution 

GSD = 1.52
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Table 2-2. Comparison of Data and Assumptions Used by NIOSH and SC&A

Parameters NIOSH SC&A’s DR–Method A SC&A’s DR–Method B

Unmonitored Photon/Electron Doses

Guidance Documents Not considered. Not considered. SRS External Coworker Model 

(ORAUT-OTIB-0032)

Coworker Percentile Not considered. Not considered. 50th percentile

Period of Time 

Assigned Not considered. Not considered. [redact]–[redact]

Energy Range Not considered. Not considered. 100% 30–250 keV

Dose Distribution Not considered. Not considered. Lognormal with GSD of 1.52

Unmonitored Neutron Doses

Guidance Documents Not considered. Not considered.

SRS Neutron Exposure (OCASTIB-007), SRS TBD, and IG001

Methodology Not considered. Not considered. neutron-to-photon ratio for the 

221-H, B-Line

Period of Time 

Assigned Not considered. Not considered. [redact]–[redact], [redact]–

[redact]

Energy Range Not considered. Not considered. 0.1–2 MeV

2–20 MeV

Organ DCF Not considered. Not considered. Prostate = 0.796

Skin = 1.0

ICRP 60 CF Not considered. Not considered. 0.1–2 MeV – CF=1.14

2–20 MeV – CF=0.53

Dose Distribution Not considered. Not considered. Lognormal with GSD of 1.52

Onsite Ambient Dose

Guidance Document ORAUT-PROC-0060, SRS TBD SRS TBD ORAUT-PROC-0060, SRS TBD

Period to Time 

Assigned [redact]–[redact] and 1977 [redact]–[redact] and 1977 [redact]–[redact]

Energy Range 30–250 keV 30–250 keV

Prostate:

 100% 30–250 keV

Skin:

 100% 30–250 (Ambient)

 30% e->15 keV (Ar-41)

 70% p >250 keV (Ar-41) 

Dose Distribution Lognormal with GSD of 1.3 Constant Lognormal with GSD of 1.3

Occupational Medical Doses

Guidance Documents DHWP = ORAUT-OTIB-0006, 

SRS = SRS TBD 

DHWP = ORAUT-OTIB-0006, 

SRS = SRS TBD 

DHWP = ORAUT-OTIB-0006, 

SRS = SRS TBD

Frequency

DHWP = annual ([redact]–

[redact])

SRS = 15 documented x-rays

DHWP = annual ([redact]–

[redact])

SRS = 16 documented x-rays

DHWP = annual ([redact]–

[redact])

SRS = 16 documented x-rays

Dose Distribution Normal; SD = 30%. Normal; SD = 30%. Normal; SD = 30%.

Internal Doses – Plutonium

Records/Guidance 

Documents

DOE records, SRS TBD, 

ORAUT-OTIB-0049, IMBA Not Considered. Not Considered.

Dose Determination 

Approach

All urinalyses results <MDA. 

Missed dose based on 1⁄2 MDA 

on last Pu urinalysis 

measurement.

Not Considered. Not Considered.

Solubility Type Type SS Not Considered. Not Considered.

Dose Distribution Mode of a triangular distribution Not Considered. Not Considered.
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Table 2-2. Comparison of Data and Assumptions Used by NIOSH and SC&A

Parameters NIOSH SC&A’s DR–Method A SC&A’s DR–Method B

Internal Dose - Fission Product

Records/Guidance 

Documents DOE records, SRS TBD, IMBA Not Considered. Not Considered.

Dose Determination 

Approach

All urinalyses results <MDA. 

Missed dose based on worst-case 

chronic intake of Ru-106. Not Considered. Not Considered.

Solubility Type Type F Not Considered. Not Considered.

Dose Distribution Constant with no uncertainty Not Considered. Not Considered.

Internal Dose - Europium

Records/Guidance 

Documents DOE records, SRS TBD, IMBA Not Considered. Not Considered.

Dose Determination 

Approach

All urinalyses results <MDA. 

Missed dose based on Eu-152 

and Eu-154 comparison, with 

Eu-154 claimant favorable.

Not Considered. Not Considered.

Solubility Type Type M Not Considered. Not Considered.

Dose Distribution Constant with no uncertainty Not Considered. Not Considered.

Internal Dose - Environmental

Guidance Documents SRS TBD, IMBA SRS External Dose Calculation 

Workbook 2.10. Not Considered.

Dose Determination 

Approach

Assumed maximum environmental annual intakes for 1966–

1977 resulting in assignment of 

plutonium and unmonitored 

tritium doses. 

Unmonitored tritium dose 

assigned 1966–1977 based on 1 

μCi/L.

Not Considered.

Dose Distribution Pu = lognormal with GSD 3.0

H-3 = constant Constant with no uncertainty Not Considered.

2.1 OCCUPATIONAL EXTERNAL DOSE CALCULATIONS 

2.1.1 Recorded Photon Doses 

The DOE records show that the EE was monitored at SRS during each year from [redact]

through [redact], except for [redact]–[redact], and the first 3 months of [redact], when no data 

were present in the records. 

All three DR methods assumed the EE worked primarily in the [redact] Area. Therefore, the 

photon energy fraction of 50% 30–250 keV and 50% >250 keV was assumed, as specified in the 

SRS TBD. All DR methods also applied a TBD-specified dosimeter correction factor (CF) of 

1.119 to the recorded doses. NIOSH and SC&A’s ‘Method B’ selected DCF that reflect 

Exposure (R) to Organ Dose (HT) values from OCAS-IG-001 for organs other than the skin. 

SC&A’s ‘Method A’ applied Deep Dose Equivalent [Hp(10)] to Organ Dose (HT) DCFs for the 

prostate, bladder and colon. All DR methods applied a DCF of 1.0 to the skin cancers, as 

specified in ORAUT-OTIB-0017.
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Using the EE’s dosimetry records and above-cited parameters, NIOSH, SC&A’s ‘Method A,’ 

and SC&A’s ‘Method B’ calculated recorded photon doses as shown in Table 2-3. The slightly 

lower doses calculated by SC&A’s ‘Method A’ reflect the use of the lower Hp(10) DCF value. 

Table 2-3. Comparison of Recorded Photon Doses 

Cancer Site NIOSH

(rem)

SC&A’s ‘Method A’

(rem)

SC&A’s ‘Method B’

(rem)

Prostate Dose 4.302 3.163 4.642

Bladder Dose 4.302 3.163 Not considered.

Colon Dose 3.851 2.871 Not considered.

BCCs [redact] 4.046 3.542 3.732

Total 16.501 12.739 8.374

All three DR methods entered doses into the Interactive RadioEpidemiological Program (IREP) 

as a constant with no uncertainty. 

2.1.2 Missed Photon Doses 

Missed photon dose was assigned by all DR methods. Determining the number of missed dose 

cycles was complicated, since not all badge cycles were recorded, and the recording method 

changed in mid-1963. This resulted in each DR method estimating a significantly different 

number of zeros or < 1⁄2 LOD values, as discussed below. 

NIOSH. As stated in their DR Report, NIOSH calculated missed photon dose as described 

below: 

. . . a zero dosimeter result was applied for each listed cycle which was blank for 

all monitored years. Dosimetry results were reported as bi-weekly from [redact]

through [redact], monthly for year [redact], [redact], and [redact], and 

quarterly from [redact] through [redact]. 

. . . In an effort to minimize the total missed dose, only the actual cycle entries 

recorded in the dose records were evaluated. [Emphasis added.] 

For missed skin dose, any badge cycle with a combination of zero results in any of the nonpenetrating and penetrating doses, a single missed dose for each cycle is assigned in accordance 

with ORAUT-OTIB-0017.

This resulted in NIOSH counting 93 missed photon doses and calculating doses assuming 1⁄2 the 

limit of detection (LOD) value of 0.040 rem for shielded (S) readings and 0.050 rem for open 

window (OW) readings. NIOSH used the same organ dose conversion factor (DCF) values as 

for recorded photon doses and entered the annual doses into IREP as geometric mean (GM) of a 

lognormal distribution, with a geometric standard deviation (GSD) of 1.52. 

SC&A’s ‘Method A’. ‘Method A’ assessed missed photon dose by using the NIOSH-supplied 

“External Dosimetry Data” file, which did not agree with the data in the DOE files, primarily 

because it did not account for recorded values <LOD/2. SC&A’s ‘Method A’ corrected these 
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data values and entered the “External Dosimetry Data” file in the “SRS Calculation Workbook 

2.10,” which calculated a total of 239 zeros, or <LOD/2, values. Annual missed photon doses 

were entered into IREP as 50% 30–250 keV and 50% >250 keV as a lognormal distribution with 

a GSD of 1.52 for the prostate, bladder, and colon. Missed skin doses were assigned as 100% 

30–250 keV. 

SC&A’s ‘Method B’. It was assumed by SC&A’s ‘Method B’ that for years [redact] through 

[redact], the EE was monitored on a monthly basis, which is consistent with Table 5.5.1-1 of 

ORAUT-TKBS-0003, even though DOE records only included quarterly results. ‘Method B’

made the claimant-favorable assumption that all reported quarterly doses were recorded during 

1 month and the remaining 2 months of the quarter were assumed to be zero doses. 

For missed skin dose, ‘Method B’ followed guidance in ORAUT-OTIB-0017 and assigned a 

single missed dose for any badge cycle with a combination of zero results in any of the nonpenetrating and penetrating doses. 

Based on these assumptions, a total of 172 monitoring cycles were assigned a missed photon 

dose. Doses were calculated assuming 1⁄2 the LOD value of 0.040 rem for S readings and 

0.050 rem for OW readings. The same organ DCF values as for recorded photon doses were 

applied, and annual doses entered into IREP as a GM of a lognormal distribution, with a GSD of 

1.52.

Table 2.4 compares the missed photon doses for the three DR methods. 

Table 2-4. Comparison of Missed Photon Doses 

Cancer Site NIOSH

(rem)

SC&A’s ‘Method A’

(rem)

SC&A’s ‘Method B’

(rem)

Prostate Dose 3.004 2.836 3.751

Bladder Dose 3.004 2.836 Not considered.

Colon Dose 2.560 2.638 Not considered.

BCCs [redact] 2.415 4.088 3.015

Total 10.983 12.398 6.766

2.1.3 Recorded Shallow Doses 

Electron dose was assigned by each of the three DR methods to only the two skin cancers. The 

electron dose was calculated by subtracting the OW reading from the S deep dose reading. All 

methods applied a DCF value of 1.0. Only SC&A’s ‘Method B’ applied a dosimeter correction 

factor of 0.6 prior to 1971, in accordance with OCAS-TIB-006, and 1.119, as specified in the 

SRS TBD and ORAUT-OTIB-0017. NIOSH and SC&A’s ‘Method A’ entered the electron 

doses into IREP as 100% >15 keV. SC&A’s ‘Method B’ entered the doses into IREP as 100% 

<30 keV. 

Table 2-5 shows a comparison of total assigned recorded electron doses. 
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Table 2-5. Comparison of Recorded Electron Doses 

Cancer Site NIOSH

(rem)

SC&A’s ‘Method A’

(rem)

SC&A’s ‘Method B’

(rem)

BCCs [redact] 4.810 4.385 3.196

All DR methods assumed a constant dose distribution with no uncertainty. 

2.1.4 Missed Shallow Doses 

Only SC&A’s ‘Method A’ assigned a missed electron dose. This dose was calculated based on 

ORAUT-OTIB-0017, page 21, which provides recommendations for the assignment of missed 

dose to the skin; if only the OW (shallow) reading was reported as zero (and the deep dose was 

positive), the missed dose assigned should be the appropriate OW LOD (divided by 2, treated as 

lognormal) and considered >15 keV electrons. Therefore, ‘Method A’ analyzed the number of 

electron dose zeros using this guidance and a best-estimate reasonable approach in estimating the 

number of potential zeros in this case, and compared them to those provided by the SRS 

Workbook 2.10, which arrived at a total of 6 zeros, or <LOD/2, values for electrons. SC&A 

used the annual zero values provided by the workbook and calculated a missed electron dose of 

0.125 rem. 

2.1.5 Unmonitored Photon/Electron Doses 

Only SC&A’s ‘Method B’ considered assigning unmonitored photon and electron doses for the 

3-year gap in external monitoring (i.e., years [redact]–[redact]). Assignment of these doses was

based on (1) the EE’s job function, which did not change throughout employment, (2) the EE’s

statement in the CATI that the EE was routinely monitored, and (3) OCAS-TIB-006, which 

states that “. . . when an entire year is missing from the SLHP3 form, this also should not be 

interpreted as meaning that an individual worker was not monitored.”

Using guidance in External Coworker Dosimetry Data for the Savannah River Site (ORAUTOTIB-0032, Table 2), gamma doses at the 50th percentile were assigned for [redact], [redact], 

and [redact]. This resulted in a total photon dose of 0.546 rem to the prostate and the two skin 

cancers. Annual doses were entered into IREP as a lognormal distribution with a GSD of 1.52. 

In addition, an unmonitored non-penetrating dose at the 50th percentile was also assigned to the 

skin cancers for years [redact]–[redact]. Values cited in Table 2 of ORAUT-OTIB-0032 

resulted in the assignment of a total unmonitored skin dose of 0.332 rem. The annual doses were 

entered into IREP as photons <30 keV and considered lognormally distributed with a GSD of 

1.52. 

2.1.6 Unmonitored Neutron Doses 

Although DOE records do not indicate that the EE was monitored for neutron doses during 

employment, SC&A’s ‘Method B’ determined that this worker did have the potential for neutron 

exposures, since the EE worked primarily in the [redact] Areas. This is supported by 

information provided in Neutron Exposures at the Savannah River Site (OCAS-TIB-007). 
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Using guidance in the SRS TBD and assuming the GM neutron-to-photon ratios for the 221-H, 

B-Line cited in Table 5.5.2-2, Method B assigned a neutron dose for all years of employment 

prior to [redact] and [redact]–[redact]. The photon doses were multiplied by the appropriate 

International Commission on Radiological Protection (ICRP) DCF and organ DCF values (ICRP 

1991). The neutron doses were assumed to be associated with energy ranges 10–100 keV and 

0.1–2.0 MeV neutrons, based on the EE’s work location in the 221-H, B-Line. This resulted in 

the assignment of 8.730 rem to the prostate and 9.764 rem to the two BCCs. 

2.1.7 Onsite Ambient Doses 

All three DR methods calculated onsite ambient doses as described below. 

NIOSH. Since the EE was not monitored for ionizing radiation in [redact], [redact], [redact], 

and [redact], NIOSH assigned onsite ambient doses for these years. It was assumed that the EE 

worked primarily worked in Area [redact]. Using guidance in Occupational On-Site Ambient 

Dose Reconstruction for DOE Sites (ORAUT-PROC-0060), and best-estimate dose values cited 

in Table C-19 of ORAUT-TKBS-0003 and assuming a 50-hour work week, NIOSH calculated a 

total onsite ambient dose of 0.306 rem for each of the cancer sites. Annual dose values were 

entered into IREP as a mean of a normal distribution with standard deviation (SD) of 1.3.

SC&A’s ‘Method A.’ ‘Method A’ also assigned onsite ambient doses for only those years when 

the EE was not monitored (i.e., [redact]–[redact], [redact]). The assignment of environmental 

external ambient photon doses during these unmonitored years was based on 2,000 hours/year 

dose values provided in Table C-19 of ORAUT-TKBS-0003, adjusting for 2,500 hours/year, and 

prorated for partial employment in [redact]. This resulted in a total dose of 0.318 rem for all 

cancer sites. Annual doses were entered into IREP as a constant value with no uncertainty. 

SC&A’s ‘Method B.’ SC&A’s ‘Method B’ assigned onsite ambient doses in accordance with 

guidance in ORAUT-PROC-0060, Attachment A. This Attachment states that monitored SRS 

employees should be assigned onsite ambient doses through 1979. Therefore, in accordance 

with best-estimate guidance in Section 3.4.1 of the SRS TBD, ‘Method B’ assigned prostate and 

skin doses using ambient radiation levels associated with Area F from Table C-19 for years 

[redact] through [redact]. Onsite ambient doses were not included for the partial years of 

employment in [redact] and [redact]. Skin doses from exposure to Ar-41 at Area F were also 

assigned, as specified in Table C-20 of the SRS TBD. 

Applying an organ DCF of 1.244 for the prostate and DCF of 1.0 for each of the two skin 

cancers resulted in a total onsite ambient dose of 1.361 rem and 1.107 rem, respectively. Annual 

onsite ambient radiation doses were entered into IREP with a photon energy range of 30–

250 keV as GM values with a GSD of 1.3, in accordance with SRS TBD best-estimate guidance. 

Skin doses associated with submersion in Ar-41 were entered into IREP as 30% electrons 

>15 keV and 70% photons >250 keV. 

Table 2-6 shows a comparison of total assigned onsite ambient doses. The NIOSH and SC&A 

‘Method A’ values are nearly identical. SC&A’s ‘Method B’ is 4 times higher due to assigning 
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doses for 17 years, while NIOSH and ‘Method A’ only assigned doses for 4 years of 

employment. 

Table 2-6. Comparison of Onsite Ambient Doses 

Cancer Site NIOSH

(rem)

SC&A’s ‘Method A’

(rem)

SC&A’s ‘Method B’

(rem)

Prostate, Bladder, Colon 0.306 0.318 1.361 (prostate only)

BCCs of cheek and eyelid 0.306 0.318 1.107

2.1.8 Occupational Medical Doses 

All three DR methods calculated an occupational medical dose from diagnostic x-ray procedures 

required as a condition of employment at both the DHWP and SRS. NIOSH and SC&A’s 

‘Method A’ assumed an annual posterior/anterior (PA) chest x-ray for each year of covered 

employment at DHWP and assigned doses based on ORAUT-OTIB-0006. This resulted in both 

DR methods calculating a total of 0.375 rem for the prostate/bladder/colon and 0.096 rem to each 

of the skin cancers. 

For calculating occupational medical doses for employment at SRS, NIOSH and SC&A’s 

‘Method A’ identified 16 documented PA x-ray exams in the EE’s records. Using values cited 

Table 3-10 of ORAUT-TKBS-0003-3, both DR methods calculated a dose of 0.051 rem to the 

prostate, bladder, and colon, and 0.026 rem to the skin cancers. 

SC&A’s DR ‘Method B’ also assigned an annual PA chest x-ray for each year of employment at 

the DHWP (i.e., [redact]–[redact]). Using ORAUT-OTIB-0006, an annual prostate dose of 

0.025 rem (based on Table A-7) and an annual skin dose of 0.0064 rem (based on Tables A-1 

and A-7 for the eye/brain) were assign for the period of [redact] through [redact].

For the EE’s employment at SRS, ‘Method B’ assigned an occupational medical dose for 15 

documented PA chest x-ray exams performed between [redact] and [redact]. DOE records 

indicate that 9 of these x-ray exams were taken with Type I equipment and the remaining 6 were 

taken with Type II equipment. Using the SRS Occupational Medical Dose guidance (ORAUTTKBS-003-3, Table 3-10), the Type I annual dose of 0.00504 rem and Type II annual dose of 

0.000141 rem were assigned to the prostate (using the bladder as the surrogate organ). An 

annual Type I dose of 0.00096 rem and Type II dose of 0.00273 rem was assigned to each of the 

two skin cancers on the face (using the eye/brain as a surrogate organ). 

Table 2-7 shows a comparison of the occupational medical doses calculated by the three DR 

methods, which resulted in identical/nearly identical dose values. 
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Table 2-7. Comparison of Occupational Medical Doses

Facility NIOSH

(rem)

SC&A-Method A 

(rem)

SC&A-Method B

(rem)

DHWP:

 Prostate/bladder/colon 0.375 0.375 0.375 (prostate only)

 BCCs 0.096 0.096 0.090

SRS:

 Prostate/bladder/colon 0.051 0.051 0.046 (prostate only)

 BCCs 0.026 0.026 0.031

All three methods entered annual doses into IREP as a normal distribution with an uncertainty of 

30%. 

2.2 OCCUPATIONAL INTERNAL DOSES 

DOE records show that the EE had in vitro (urinalysis) bioassay monitoring for plutonium, 

fission and activation products, and europium during employment at SRS. All bioassay results 

were below the minimum detectable activity (MDA) for the given radionuclides and bioassay 

method. Only NIOSH calculated missed internal doses based on the bioassay monitoring. 

Details associated with their calculation of internal doses are provided below. 

2.2.1 NIOSH Plutonium Intakes 

The EE submitted 6 samples for plutonium urinalysis between [redact] and [redact]. All results 

were reported below the MDA level. Therefore, to assessed potential internal dose from 

exposure to plutonium, NIOSH assumed exposure to 1⁄2 the MDA level of 0.1 dpm/sample of the 

last urinalysis measurement. They also assumed a 10-year aged, 12% fuel-grade Pu-240 material 

was chronically inhaled from the beginning of employment until August [redact]. Solubility 

Types M, S, and SS were compared, with SS producing the highest dose.

2.2.2 NIOSH Fission Product Intakes 

The EE submitted nine urinalysis samples for fission/activation products between [redact] and 

[redact]. To assess potential fission/activation product doses, NIOSH assumed a worst-case, 

chronic intake based on ruthenium-106, Type F absorption at 1⁄2 the MDA value from the 

beginning of employment until the last fission product bioassay on [redact].

2.2.3 NIOSH Europium Intakes 

The EE submitted five samples between [redact] and [redact] for europium urinalysis. All 

results were reported at below the MDA. NIOSH assessed dose from potential exposure to 

europium by comparing europium-152 and europium-154 at levels below the detection limits. A 

chronic intake from inhalation for the period [redact] (beginning of employment), through 

[redact] (last europium bioassay sample), was assessed. It was determined that europium-154, 

Type M, resulted in the most claimant-favorable dose.
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2.2.4 NIOSH Internal Environmental Dose 

For years [redact] through [redact], when the EE has no records for bioassay monitoring, 

NIOSH assigned internal dose based on maximum annual intakes of environmental airborne 

radionuclides cited in the SRS TBD. This assessment assumed a constant exposure to iodine and 

uranium.

2.2.5 NIOSH Unmonitored Tritium Dose 

NIOSH also calculated an unmonitored tritium dose for the years [redact] through [redact]. 

This dose was calculated using the minimum tritium urine concentration of 1 μCi/L. This 

resulted in an annual assignment of 0.071 rem.

2.2.6 SC&A’s ‘Method A’ Environmental Tritium Dose 

SC&A’s ‘Method A’ calculated the intake of environmental tritium for the entire employment 

period, since this calculation is incorporated in the SRS Dose Calculation Workbook 2.10, and 

included when deriving the external dose assignments. The workbook also uses the minimum

tritium urine concentration of 1 μCi/L, which resulted in the assignment of 0.071 rem per year. 

A summary of the total internal dose assigned by NIOSH and SC&A’s ‘Method A’ is shown in 

Table 2-8. SC&A’s ‘Method B’ partial DR did not consider any dose from potential internal 

exposures. 

Table 2-8. Comparison of NIOSH and SC&A’s ‘Method A’ Total Internal Doses 

Cancer Site

NIOSH

(rem)

SC&A

Method A

(rem)

Plutonium Fission 

Products Europium Environmental Tritium Total Tritium

Prostate 0.323 0.085 0.012 0.031 0.799 9.288 1.296

Bladder 0.537 0.086 0.001 0.031 0.799 9.492 1.296

Colon 0.710 0.317 0.004 0.031 0.799 9.004 1.296

BCC, [redact] 0.863 0.074 0.001 0.031 0.799 13.465 1.296

BC, [redact] 0.863 0.074 0.001 0.031 0.799 13.465 1.296
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3.0 SUMMARY CONCLUSIONS 

Total external and internal doses and resultant POCs calculated by NIOSH, SC&A ‘Method A,’ 

SC&A ‘Method B’ in behalf of Case #037013 are presented in Table 3-1 for comparison.

Table 3-1. Comparison of Total External and Internal Doses Estimated 

for the Five Cancers 

Total Doses NIOSH

(rem)

SC&A-Method A

(rem)

SC&A-Method B

(rem)

External Doses:

 - Prostate

 - Bladder

 - Colon

 - BCC, [redact]

 - SCC, [redact]

8.038

8.038

7.143

11.699

11.699

6.807

6.807

6.253

12.580

12.580

19.451

–

–

21.813

21.813

Internal Skin Doses:

- Prostate

 - Bladder

 - Colon

 - BCC, [redact]

 - SCC, [redact]

1.250

1.454

1.861

1.766

1.766

1.296

1296

1.296

1.296

1.296

–

–

–

–

–

Total Skin Dose

- Prostate

 - Bladder

 - Colon

 - BCC, [redact]

 - SCC, [redact]

9.288

9.492

9.004

13.465

13.465

8.103

8.103

7.549

13.876

13.876

19.451

–

–

21.813

21.813

POC 38.12% 39.33% 48.27%

As shown in Table 3-1, even though NIOSH performed a best-estimate DR and SC&A’s 

‘Method A’ performed a partial DR, the doses are in very close agreement. The higher doses 

estimated by SC&A’s ‘Method B’ were the result of calculating an unmonitored photon dose for 

a 3-year period and a 15-year unmonitored neutron dose for the three non-presumptive cancers 

(i.e., prostate, two BCCs). A more detailed discussion of variables that contributed to key 

differences in dose assignments is presented below. 

 Dose Reconstruction Methodology 

 – NIOSH employed a best-estimate approach to dose reconstruction. 

 – SC&A’s ‘Method A’ and SC&A’s ‘Method B’ employed a minimizing (partial) 

approach to reconstructing doses. 

 Assignment of Unmonitored Dose 

 – Only SC&A’s ‘Method B’ calculated unmonitored photon dose based on the 

50th percentile coworker data for years [redact], [redact], and [redact].

 – Only SC&A’s ‘Method B’ calculated unmonitored neutron dose based on a GM 

neutron-to-photon ratio for years [redact]–[redact] and [redact]–[redact].
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 Assignment of Onsite Ambient Dose 

 – NIOSH and SC&A’s ‘Method A’ assigned onsite ambient doses for years [redact]–

[redact] and [redact], when the EE was not monitored.

 –SC&A’s ‘Method B’ assigned onsite ambient doses for years [redact]–[redact] and 

assigned a skin dose from exposure to Ar-41 for the same period.

 Assignment of Internal Doses 

 – NIOSH assigned internal doses from monitored bioassays, which were all <MDA, 

based on missed dose approach (i.e., 1⁄2 MDA value of urinalysis data for plutonium, 

fission/activation products, europium, environmental, and unmonitored tritium. 

Internal environmental doses and unmonitored tritium were only assigned for years 

[redact]–[redact].

 – SC&A’s ‘Method A’ assigned an environmental tritium dose using the SRS Dose 

Calculation Workbook for the EE’s entire employment period ([redact]–[redact]).
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4.0 REFERENCES

HHS 2012. HHS Letters to Congress Regarding the SEC Petition (Petition 00103 concerning 

workers at the Savannah River Site in Aiken, South Carolina). Kathleen Sebelius, Secretary of 

Health and Human Services. February 2, 2012. Available on the NIOSH website: 

http://www.cdc.gov/niosh/ocas/srs.html.

ICRP (International Commission on Radiological Protection) 1991. Recommendations of the 

International Commission on Radiological Protection, ICRP Publication 60, Pergamon Press, 

Oxford, England.

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

National Institute for Occupational Safety and Health, Office of Compensation Analysis and 

Support, Cincinnati, Ohio. November 21, 2007.

OCAS-TIB-006. 2007. Interpretation of External Dosimetry Records at the Savannah River 

Site (SRS), Rev. 2, National Institute for Occupational Safety and Health (NIOSH), Office of 

Compensation Analysis and Support: Cincinnati, Ohio. October 4, 2007.

OCAS-TIB-007. 2007. Neutron Exposures at the Savannah River Site, Rev. 1, National 

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

Support: Cincinnati, Ohio. October 15, 2007.

ORAUT-OTIB-0006. 2011. Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures, Rev. 04, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. June 20, 2011.

ORAUT-OTIB-0017. 2005. Technical Information Bulletin: Interpretation of Dosimetry Data 

for Assignment of Shallow Dose, Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. October 11, 2005.

ORAUT-OTIB-0032. 2006. External Coworker Dosimetry Data for the Savannah River Site, 

Rev. 00 PC-1, Oak Ridge Associated Universities, Cincinnati, Ohio. November 7, 2006.

ORAUT-OTIB-0049. 2010. Technical Information Bulletin: Estimating Doses for Plutonium 

Strongly Retained in the Lung, Rev. 01 PC-2, Oak Ridge Associated Universities, Cincinnati, 

Ohio. November 29, 2010.

ORAUT-PROC-0060. 2006. Occupational On-Site Ambient Dose Reconstruction for DOE Site, 

Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 28, 2006.

ORAUT-TKBS-0003. 2005. Technical Basis Document for the Savannah River Site, Rev. 03, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 5, 2005.
Effective Date:

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

ORAUT-TKBS-0003-3. 2009. Savannah River Site- Occupational Medical Dose, Revision of 

Section 3 of ORAUT-TKBS-0003, Rev. 04. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. November 30, 2009.

SC&A 2014. SC&A’s Blind Dose Reconstruction of Case #[redact] from the Dana Heavy 

Water Plant and Savannah River Site, SCA-TR-BDR2014-CN[redact], Rev. 0, SC&A, Inc., 

Vienna, Virginia. February 26, 2014.