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MEMO 

TO: Dose Reconstruction Review Methods Work Group, 

the Subcommittee on Dose Reconstruction, and the ABRWH 

FROM: Kathleen Behling, SC&A 

DATE: July 15, 2015 

SUBJECT: Approach to Expediting DRSC Findings Backlog 

At the first Dose Reconstruction Review Methods (DRRM) Work Group meeting on June 22, 

2015, an agenda item included a discussion of possible approaches to resolving findings from the 

dose reconstruction (DR) case audits identified in Sets 14 through 21. SC&A, therefore, took the 

opportunity to briefly present a potential method for expediting the findings backlog. As a result 

of this discussion, Dr. Melius, the Chairperson, asked SC&A to provide the Work Group and the 

Dose Reconstruction Subcommittee (DRSC or Subcommittee) with a memo detailing our new 

approach. This memo satisfies that request. 

In an effort to increase the efficiency and timeliness of the issues resolution process, the DRSC 

previously adopted the approach of categorizing findings for a specific group of sets by site. 

SC&A is recommending a further grouping of site-specific findings and observations into two 

groups. The first group, Type 1, includes those that appear as though they could be resolved 

with minimal to no discussion. Type 1 issues have been resolved to SC&A’s satisfaction, but 

have not been formally discussed with the DRSC. These findings and observations include 

issues such as QA/QC problems, technical clarifications, and previously resolved issues. The 

second group, Type 2, includes the remaining findings and observations. Type 2 findings and 

observations will likely need additional attention and should be brought up for more detailed 

discussions in the DRSC forum. 

SC&A proposes creating a table prior to each meeting that summarizes our recommendations for 

Type 1 findings/observations. SC&A believes that providing the Subcommittee members with 

an additional grouping of findings/observations and sufficient time to review our suggestions 

should accelerate the finding closeout process during DRSC meetings. This summary table 

would be submitted to the DRSC members and NIOSH staff at least 1 week prior to the meeting 

(or the timeframe determined by the DRSC), in order to give Subcommittee members an 

opportunity to carefully review our recommendations prior to the meeting. This table would 

contain the site, finding rank, POC, a description of the finding, and a summary of the 

resolutions for all Type 1 findings and observations. The summary table will highlight for the 

DRSC members the findings/observations that NIOSH and SC&A are in agreement on and that 

SC&A recommends closing. DRSC members can then review these recommendations and 

determine if they agree that the finding can be closed or believe additional discussion is 

warranted despite SC&A’s recommendation. At the discretion of the DRSC, many of the 

findings/observations that SC&A identified within Type 1 can then be closed quickly without the 

need for lengthy discussions. This will allow the DRSC’s time and resources to be better 
Memo: Expediting DRSC Finding 2 SC&A – July 15, 2015 

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. 

directed toward issues that are more pressing, such as those that have broad DR implications. 

Additionally, with this information, NIOSH will be aware of the findings/observations that 

SC&A believes require additional discussion and can be better prepared to discuss the issues in 

question at the meeting. In order to effectively implement this process, however, SC&A will 

need NIOSH’s cooperation in responding to findings in a timely manner. 

To provide an example of this grouping system, SC&A has evaluated and sorted the 14th–18th set 

findings/observations associated with four sites [i.e., Oak Ridge Sites ( X-10, Y-12, and K-25), 

Paducah, Portsmouth, and SRS]. SC&A’s recommendations for the grouping of findings and 

observations from these sites are contained in a summary table in Attachment 1. The grouping 

of these findings as they relate to the subset of cases of this evaluation is summarized in Table 1. 

Based on this evaluation, SC&A estimates that 79% of the total number of findings in this subset 

and 94% of the total number of observations in this subset could be closed with minimal 

discussion. 

th Table 1. Summary of Finding Grouping for 5 Sites in the 14-18 Sets 

Site

Findings Observations

Total Open

Type 1: 

Minimal 

Discussion

Type 2: More 

Detailed 

Discussion

Total Open

Type 1: 

Minimal 

Discussion

Type 2: More 

Detailed 

Discussion

Oak Ridge Sites 30 2 1 1 7 1 1 –

Paducah GDP 3 3 2 1 2 2 2 –

Portsmouth GDP 2 2 2 – 1 1 1 –

SRS 31 31 25 6 12 12 11 1

Total 66 38 30 8 22 16 15 1
Memo: Expediting DRSC Finding 3 SC&A – July 15, 2015 

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. 

Attachment 1. Type 1 Recommendations

Finding/Observation 

No. Rank POC% Finding/Observation Description Finding/Observation Resolution

Oak Ridge 

391.1-C.1.1

L 46.63 Inconsistency in Unmonitored 

Dose

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

DR; additionally, NIOSH provided 

information to fill in data gaps to SC&A's 

satisfaction.

Oak Ridge 

394.1-C.2.3

M 44.09 Incorrect Dose Values Used and 

no PFG Exam for X-10

NIOSH correctly followed guidance of 

ORAUT-OTIB-0006. Additionally, 

NIOSH committed to revise PROC-0061 

to be consistent with OTIB-006.

Oak Ridge 

438 Observation 1

NA 43.71 SC&A is concerned with 

radionuclides other than the

predominate ones (such as Pu-239 

and uranium), which may be 

applicable to this case when 

resolved.

NIOSH committed to review the claim 

under PER if site profile changes result in 

potential increases in dose.

Paducah 

355.1-C.2.1

L 30.42 NIOSH did Not Include the 

Recorded Dose for 1980

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

DR.

Paducah 

395.1-G.3

L 34.03 Uranium Chronic Intake 

Significantly Underestimated by 

CADW

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

DR.

Paducah 

396 Observation 1

NA 50.16 Claimant-favorable use of 

surrogate organ

NIOSH appropriately implemented the 

procedure in place at the time of the DR.

Paducah 

397 Observation 1

NA 50.51 NIOSH did not start using the 

new procedure revision when it 

was released mid-DR

SC&A referenced an interim document 

that had not undergone review and thus 

could not be used in a DR. NIOSH 

appropriately implemented the procedure 

in place at the time of the DR.

Portsmouth

351.1-C.2.2

UR 44.24 Incorrect Photon Missed Dose 

Correction Factor

SC&A did not understand the methods 

used by NIOSH. NIOSH provided 

additional information that clarified the 

issue; will include clarifications in the 

next revision of the site TBD.

Portsmouth

352 Observation 1

NA 50.06 Inappropriate Procedure used for 

Calculation of Missed Dose.

NIOSH agreed that DCF should not be 

applied to missed dose and committed to 

revise the site TBD.

Portsmouth

352.1-E.1.1

L 50.06 Lack of Neutron Dose 

Assignment

NIOSH agreed that neutron doses could 

be included, but including them does not 

have an impact on the claim 

determination, because the case was 

already compensable.

SRS 

400.2-G.3

L 47.37 Missed 1959 Tritium Dose 

Assigned Twice

NIOSH agrees a cut-and-paste error 

occurred. The workbook has since been

updated to prevent this type of error from 

occurring again.
Memo: Expediting DRSC Finding 4 SC&A – July 15, 2015 

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. 

Attachment 1. Type 1 Recommendations

Finding/Observation 

No. Rank POC% Finding/Observation Description Finding/Observation Resolution

SRS 

356 Observation 1

NA 44.35 OCAS-IG-001 (2007) contains 

two separate tables labeled “Table 

4-1a,” one on page 38 and one on 

page 39; this is confusing and 

needs to be corrected. 

Additionally, there are no lists of 

tables in the Table of Contents.

NIOSH agrees that there is an error and 

committed to revise OCAS-IG-001.

SRS 

356.1-C.1.1

L 44.35 Inappropriate Method Used for 

Determining Recorded Dose

SC&A did not understand the methods 

used by NIOSH. NIOSH provided 

additional information that clarified the 

issue.

SRS 

356.2-C.1.2

L 44.35 Inappropriate Method Used for 

Determining Number of Zeros

SC&A did not understand the methods 

used by NIOSH. NIOSH provided 

additional information that clarified the 

issue.

SRS 

356.3-C.1.1

L 44.35 Inappropriate Method Used for 

Assigning Dose for 1981 and 

1982

SC&A and NIOSH agreed that the 

approach required a certain degree of 

subjective judgment and more than one 

strategy was reasonable.

SRS 

356.6-G.4

L 44.35 Inconsistent Assignment of 

Unmonitored/Environmental 

Tritium Dose

This case is eligible for inclusion in the 

SRS SEC; additional dose would not 

impact the outcome of this case.

SRS 

356.7–G.3

L 44.35 Incorrect Assignment of FP Dose 

for 1965–1966

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

case.

SRS 

400 Observation 1

NA 47.37 SC&A noted that roughly half of 

the dosimetry records have a dark 

line drawn through the EE’s name 

and corresponding dose record. 

This line effectively makes many 

records illegible to SC&A and 

NIOSH. Due to this line, NIOSH 

could not use many records to 

assign dose and SC&A cannot 

verify that the correct dosimetry 

values were used.

NIOSH clarified confusion due to 

interpretation of illegible DOE records.
Memo: Expediting DRSC Finding 5 SC&A – July 15, 2015 

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. 

Finding/Observation 

No. Rank POC

Attachment 1. Type 1 Recommendations 

%

Finding/Observation 

Description Finding/Observation Resolution

SRS 

400 Observation 2

NA 47.37 Although NIOSH correctly 

assigned medical dose based on 

guidance available at the time of 

the DR, less than 1 month 

following the issuance of the 

current revision of the DR, 

ORAUT-TKBS-0003-3 Rev. 4 

was issued. This revision reduces 

the dose contribution to each 

organ from a PA x-ray 

examination. As a result, if the 

DR is revised, there will be a 

>50% reduction in assigned 

occupationally required medical 

dose.

This observation was made for the benefit 

of the DRSC. The assigned occupational 

medical dose was consistent with the site 

profile at the time it was written.

SRS 

401 Observation 1

NA 48.24 Possible incomplete bioassay 

records for the EE.

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

case, because the EE should be 

compensated under the SRS SEC.

SRS 

401.1-E.1.2

L 48.24 Unable to Reproduce Assigned 

Neutron Dose 1961–1963

There were gaps in the exposure data that 

NIOSH filled in to SC&A’s satisfaction.

SRS 

401.2-E.1.3

L 48.24 Unable to Reproduce Missed 

Neutron Dose 1961–1963

There were gaps in the exposure data that 

NIOSH filled in to SC&A’s satisfaction.

SRS 

401.3-B.4

L 48.24 NIOSH did Not Adjust Ambient 

Doses for 46-hour Work Weeks

A workbook revision subsequent to the 

DR review clarified and resolved the 

issue.

SRS 

401.5-G.3

L 48.24 Incomplete Fitted Uranium Dose 

Assigned

NIOSH agrees that there could have been 

a better explanation in the DRR; 

however, including the result does not 

have an impact on the case.

SRS 

402 Observation 1

NA 47.57 From the site TBD, it is not clear 

what work locations had a risk of 

RU exposure. 

NIOSH committed to revising the SRS 

TBD and addressing RU contaminants in 

the next revision.

SRS 

402 Observation 2

NA 47.57 NIOSH used ORAUT-OTIB0018 to assign RU dose, which is 

not applicable for respiratory 

cancers

NIOSH committed to revising the SRS 

TBD and addressing RU contaminants in 

the next revision.

SRS 

402.1-C.2.1

L 47.57 No Photon Dose Assigned 1952–

1964

NIOSH and SC&A agree that this is an 

instance where professional judgment 

was made by the dose reconstructor.

Additionally, this case should qualify for 

inclusion in the SRS SEC and the 

additional dose would not impact the 

outcome of the case.

SRS 

402.2-G.3

L 47.57 Environmental Dose Not 

Assigned after 1983

NIOSH agrees an error was made, but 

fixing it does not have a significant 

impact on the POC of the case.

SRS 

403.1-C.2.1

L 49.10 Incorrect Facility and Energy 

Distribution used to Calculate 

Photon Doses

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

DR.
Memo: Expediting DRSC Finding 6 SC&A – July 15, 2015 

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. 

Attachment 1. Type 1 Recommendations

Finding/Observation 

No. Rank POC% Finding/Observation Description Finding/Observation Resolution

SRS 

403.2-D.3.1

L 49.10 Incorrect Dose CF Applied to 

Shallow Dose of Lip

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

DR.

SRS 

403.3-G.2

L 49.10 Missed and Environmental Dose 

Not Carried Through the Year of 

Cancer Diagnosis

NIOSH and SC&A agree that this is an 

instance where inconsistent doses less 

than 0.001 rem were applied to the cancer 

location.

SRS 

403.4-G.3

L 49.10 Failure to Assign Unmonitored 

Tritium Dose to 1994

NIOSH and SC&A agree that this is an 

instance where professional judgment 

was made by the dose reconstructor and 

the difference in calculated dose would 

not impact the outcome of the case.

SRS 

404 Observation 2

NA 49.07 SC&A was unable to locate any 

procedural guidance advising how 

dose should be modeled 

following a chelation 

NIOSH indicated the intent to include 

additional guidance in a future procedure 

revision.

SRS 

404.1-C.2.1

M 49.07 Failure to Consider Finger Ring 

Monitoring

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

final decision of the case.

SRS 

404.2-E.2.3

M 49.07 Failure to Apply Wrist Correction 

Factor to Missed Neutron Dose

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

final decision of the case.

SRS 

404.3-D.1.1

L 49.07 Failure to Apply Attenuation 

Factors

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

final decision of the case.

SRS 

404.5-C.2.3

L 49.07 Failure to Assign Preemployment Medical DoseNIOSH agrees an error was made, but 

fixing it does not have an impact on the 

final decision of the case.

SRS 

405.1-C.2.1

M 46.99 Failure to Assign Coworker Dose NIOSH and SC&A agree that this is an 

instance where professional judgment 

was made by the dose reconstructor. 

Additionally, this case now qualifies for 

inclusion in the SRS SEC.

SRS 

405.2-C.2.3

L 46.99 Failure to Assign Preemployment Medical DoseNIOSH agrees an error was made, but 

fixing it does not have an impact on the 

final decision of the case. This case 

qualifies for inclusion in the SRS SEC.

SRS 

416 Observation 1

NA 44.31 Case is eligible to be included in 

the SRS SEC; however, this case 

has not yet been flagged as such.

NIOSH agrees with SC&A. The SEC 

was granted after the DR and inclusion in 

the SEC is under DOL purview.

SRS 

416 Observation 2

NA 44.31 Incorrect Organ DCFs Stated in 

DR Report

NIOSH agrees a QA error was made; 

however, the error is in the DR report 

only and fixing it does not have an impact 

on the DR.

SRS 

416 Observation 3

NA 44.31 NIOSH did not consider all x-ray 

examination records found in the 

DOE files

NIOSH and SC&A agree these scans are 

not eligible to be included; however,

SC&A believes they should have been 

mentioned in the DR Report.
Memo: Expediting DRSC Finding 7 SC&A – July 15, 2015 

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. 

Attachment 1. Type 1 Recommendations

Finding/Observation 

No. Rank POC% Finding/Observation Description Finding/Observation Resolution

SRS 

416.1-E.2.1

L 44.31 Incomplete Accounting of Fitted 

Neutron Dose 

NIOSH agrees a QA error was made; 

however, inclusion of additional neutron 

dose does not impact the outcome of the 

case.

SRS 

416.2-E.2.3

L 44.31 Incomplete Accounting of Missed 

Neutron Dose

NIOSH agrees a QA error was made; 

however, inclusion of additional neutron 

dose does not impact the outcome of the 

case.

SRS 

416.4-F.2

L 44.31 Inconsistent Method used to 

Assign Unmonitored FP Dose

NIOSH agrees an error was made, but 

fixing it does not have an impact on the 

POC. The claim now qualifies for 

inclusion in the SRS SEC.

SRS 

440 Observation 1

NA 51.21 SC&A questions if NIOSH 

selected the correct IREP risk 

model that corresponds with

Myelodysplastic Syndrome 

(MDS)

NIOSH and SC&A agree that DOL could 

have assigned a different ICD-9 code; 

however, application of the other code 

would not change the final POC/outcome.