SCA-TR-TASK3-0001, Supplement 1, Rev. 1, Draft, August 2007 

Draft Report 

NATIONAL INSTITUTE OF 

OCCUPATIONAL SAFETY AND HEALTH 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

TASK 3 

REVIEW OF NIOSH/ORAUT PROCEDURES AND METHODS 

USED FOR DOSE RECONSTRUCTION

(Supplement 1) 

Contract No. 200-2004-03805

SCA-TR-TASK3-0001, Revision 1 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

August 2007 

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 pre-decisional 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.
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S. Cohen & Associates: Technical Support for the 

Advisory Board on Radiation and Worker Health 

Review of NIOSH Dose Reconstruction Program

Document No. 

SCA-TR-TASK3-0001

(Supplement 1)

Effective Date:

August 3, 2007 – Revised Draft

Revision No.

1

REVIEW OF NIOSH/ORAUT PROCEDURES AND 

METHODS USED FOR DOSE RECONSTRUCTION

Page 2 of 199

Task Manager:

______________________ Date: ____________ 

U. Hans Behling, PhD, MPH

Project Manager:

______________________ Date: ____________

John Mauro, PhD, CHP

Supersedes:

SCA-TR-Task3 Supplement 1

Revision 0 – June 8, 2006
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TABLE OF CONTENTS

Executive Summary.......................................................................................................................10

Summary Findings.............................................................................................................11

1.0 Introduction........................................................................................................................19

1.1 Statement of Purpose .............................................................................................19

1.2 Identification of Procedures Subject to Review.....................................................19

1.2.1 OCAS Procedures......................................................................................34

1.2.2 ORAU Team Technical Information Bulletins..........................................35

1.2.3 ORAU Team Procedures ...........................................................................38

1.3 SC&A’s Approach for Task 3................................................................................40

1.4 Structure and Organization of the Report ..............................................................42

2.0 External Dosimetry Procedures/Documents......................................................................47

2.1 OCAS-TIB-0010: Best Estimate External Dose Reconstruction for 

Glovebox Workers.................................................................................................47

2.1.1 Purpose of Procedure .................................................................................47

2.1.2 Review Protocol.........................................................................................47

2.1.3 General Comments.....................................................................................49

2.1.4 Review Comments.....................................................................................50

2.2 ORAUT-PROC-0061: Occupational X-ray Dose Reconstruction for DOE 

Sites........................................................................................................................54

2.2.1 Purpose of Procedure .................................................................................55

2.2.2 Review Protocol.........................................................................................55

2.2.3 General Comments.....................................................................................57

2.2.4 Review Comments.....................................................................................59

2.3 ORAUT-OTIB-0020: Use of Coworker Dosimetry Data For External Dose 

Assignment ............................................................................................................59

2.3.1 Purpose of Procedure .................................................................................59

2.3.2 Review Protocol.........................................................................................59

2.3.3 General Comments.....................................................................................61

2.3.4 Review Comments.....................................................................................64

2.4 ORAUT-OTIB-0023: Assignment of Missed Neutron Doses Based on 

Dosimeter Records.................................................................................................65

2.4.1 Purpose of Procedure .................................................................................65

2.4.2 Review Protocol.........................................................................................65

2.4.3 Review Comments.....................................................................................68

2.5 ORAUT-OTIB-0017: Interpretation of Dosimetry Data for Assignment of 

Shallow Dose .........................................................................................................71

2.5.1 Purpose of Procedure .................................................................................71

2.5.2 Review Protocol.........................................................................................71

2.5.3 General Comments.....................................................................................73
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2.5.4 Review Comments.....................................................................................78

2.6 ORAUT-OTIB-0024: Estimation of Neutron Dose Rates from AlphaNeutron Reactions in Uranium and Thorium Compounds....................................79

2.6.1 Purpose of Procedure .................................................................................79

2.6.2 Review Protocol.........................................................................................79

2.6.3 General Comments.....................................................................................81

2.6.4 Review Comments.....................................................................................84

2.6.5 Review of Workbook.................................................................................87

3.0 Internal Dosimetry Procedures/Documents.......................................................................90

3.1 OCAS-TIB-009 (Revision No. 0, 4/13/2004): Estimation of Ingestion 

Intakes....................................................................................................................90

3.1.1 Purpose of Procedure .................................................................................90

3.1.2 Review Protocol.........................................................................................90

3.1.3 Review Comments.....................................................................................93

3.2 OCAS-TIB-011: Lung Dose Conversion Factors for Thoron, WLM...................94

3.2.1 Purpose of Procedure .................................................................................95

3.2.2 Review Protocol.........................................................................................95

3.2.3 General Comments.....................................................................................95

3.2.4 Review Comments.....................................................................................98

3.3 ORAUT-OTIB-0028: Validation of Thorium Annual Dose Conversion 

Factors....................................................................................................................98

3.3.1 Purpose of Procedure .................................................................................98

3.3.2 Review Protocol.........................................................................................98

3.3.3 General Comments...................................................................................100

3.3.4 Review Comments...................................................................................101

3.4 ORAUT-OTIB-0022: Guidance on Wound Modeling for Internal Dose 

Reconstruction .....................................................................................................101

3.4.1 Purpose of Procedure ...............................................................................101

3.4.2 Review Protocol.......................................................................................102

3.4.3 General Comments...................................................................................104

3.4.4 Review Comments...................................................................................104

3.5 ORAUT-OTIB-0011: Tritium Calculated and Missed Dose Estimates.............104

3.5.1 Purpose of Procedure ...............................................................................104

3.5.2 Review Protocol.......................................................................................104

3.5.3 General Comments...................................................................................107

3.5.4 Review Comments...................................................................................108

3.6 ORAUT-OTIB-0019: Analysis of Coworker Bioassay Data for Internal 

Dose Assignment .................................................................................................109

3.6.1 Purpose of Procedure ...............................................................................109

3.6.2 Review Protocol.......................................................................................109

3.6.3 General Comments...................................................................................111

3.6.4 Review Comments...................................................................................112
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3.7 ORAUT-OTIB-0012: Monte Carlo Methods for Dose Uncertainty 

Calculations..........................................................................................................113

3.7.1 Purpose of Procedure ...............................................................................114

3.7.2 Review Protocol.......................................................................................114

3.7.3 General Comments...................................................................................114

3.7.4 Review Comments...................................................................................116

3.8 ORAUT-OTIB-0033: Application of Internal Doses Based on ClaimantFavorable Assumptions for Processing Best Estimates.......................................122

3.8.1 Purpose of Procedure ...............................................................................122

3.8.2 Review Protocol.......................................................................................123

3.8.3 General Comments...................................................................................123

3.8.4 Review Comments...................................................................................129

3.9 ORAUT-OTIB-0004, Revision 3: Estimating the Maximum Plausible Dose 

to Workers at Atomic Weapons Employer Facilities ..........................................130

3.9.1 Purpose of Procedure ...............................................................................130

3.9.2 Review Protocol.......................................................................................130

3.9.3 General Comments...................................................................................133

3.9.4 Review Comments...................................................................................142

3.10 ORAUT-OTIB-0018: Internal Dose Overestimates for Facilities with Air 

Sampling Programs..............................................................................................145

3.10.1 Purpose of Procedure ...............................................................................145

3.10.2 Review Protocol.......................................................................................146

3.10.3 General Comments...................................................................................148

3.10.4 Review Comments...................................................................................150

3.10.5 Review of OTIB-0018 Workbook ...........................................................152

3.11 ORAUT-PROC-0060, Revision 00: External Onsite Ambient Dose 

Reconstruction .....................................................................................................152

3.11.1 Purpose of Procedure ...............................................................................152

3.11.2 Review Protocol.......................................................................................152

3.11.3 General Comments...................................................................................155

3.11.4 Review Comments...................................................................................155

3.12 ORAUT-OTIB-0014, Revision 00: Assignment of Environmental Internal 

Doses for Employees Not Exposed to Airborne Radionucldes in the 

Workplace ............................................................................................................155

3.12.1 Purpose of Procedure ...............................................................................155

3.12.2 Review Protocol.......................................................................................155

3.12.3 General Comments...................................................................................157

3.13 ORAUT-OTIB-0025, Revision 00: Estimation of Radium-226 Activity in 

the Body from Breath Radon Measurements.......................................................158

3.13.1 Purpose of Procedure ...............................................................................158

3.13.2 Review Protocol.......................................................................................158

3.13.3 General Comments...................................................................................160

4.0 Quality Assurance Plans..................................................................................................163
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4.1 OCAS-PR-005: Conduct of Assessments...........................................................163

4.1.1 Purpose of Procedure ...............................................................................163

4.1.2 Review Protocol.......................................................................................163

4.1.3 General Comments...................................................................................163

4.1.4 Review Comments...................................................................................165

4.2 OCAS-PR-007: Dose Reconstruction Review....................................................166

4.2.1 Purpose of Procedure ...............................................................................167

4.2.2 Review Protocol.......................................................................................167

4.2.3 General Comments...................................................................................167

4.2.4 Review Comments...................................................................................169

4.3 ORAUT-PROC-0022: Additional Requests for DOE Information ....................171

4.3.1 Purpose of Procedure ...............................................................................171

4.3.2 Review Protocol.......................................................................................171

4.3.3 General Comments...................................................................................173

4.3.4 Review Comments...................................................................................173

4.4 ORAUT-PROC-0031: DOE Technical Basis Document Development, 

Review, and Approval Processs...........................................................................174

4.4.1 Purpose of Procedure ...............................................................................174

4.4.2 Review Protocol.......................................................................................174

4.4.3 General Comments...................................................................................176

4.4.4 Review Comments...................................................................................177

4.5 ORAUT-PROC-0065: Internal Finding and Corrective Action to Prevent 

Recurrence ...........................................................................................................177

4.5.1 Purpose of Procedure ...............................................................................177

4.5.2 Review Protocol.......................................................................................177

4.5.3 General Comments...................................................................................179

4.5.4 Review Comments...................................................................................180

4.6 ORAUT-PROC-0066: Quality Assurance Records Management......................180

4.6.1 Purpose of Procedure ...............................................................................180

4.6.2 Review Protocol.......................................................................................180

4.6.3 General Comments...................................................................................182

4.6.4 Review Comments...................................................................................183

4.7 ORAUT-PROC-0067: Conduct of Quality Assurance Surveillances ................183

4.7.1 Purpose of Procedure ...............................................................................183

4.7.2 Review Protocol.......................................................................................183

4.7.3 General Comments...................................................................................185

4.7.4 Review Comments...................................................................................186

4.8 ORAUT-PROC-0069: External Nonconformance and Corrective Action to 

Prevent Recurrence ..............................................................................................186

4.8.1 Purpose of Procedure ...............................................................................187

4.8.2 Review Protocol.......................................................................................187

4.8.3 General Comments...................................................................................189

4.8.4 Review Comments...................................................................................189
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4.9 ORAUT-PROC-0077: Dose Reconstruction Error Tracking and Reporting .....189

4.9.1 Purpose of Procedure ...............................................................................190

4.9.2 Review Protocol.......................................................................................190

4.9.3 General Comments...................................................................................190

4.9.4 Review Comments...................................................................................192

4.10 ORAUT-PROC-0080: Conduct of Quality Assurance Audits ...........................193

4.10.1 Purpose of Procedure ...............................................................................193

4.10.2 Review Protocol.......................................................................................193

4.10.3 General Comments...................................................................................195

4.10.4 Review Comments...................................................................................196

4.11 ORAUT-PROC-0091: Dose Reconstruction Submittal......................................196

4.11.1 Purpose of Procedure ...............................................................................196

4.11.2 Review Protocol.......................................................................................196

4.11.3 General Comments...................................................................................198

4.11.4 Review Comments...................................................................................198
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LIST OF TABLES

Table ES-1. Roll-up of Findings of the Review of the 6 External and 

13 Internal Dosimetry Procedures.....................................................................15

Table ES-2. Roll-up of the Findings of the Review of the 11 Quality Assurance Procedures..17

Table 1.2-1 Listing of Documents.............................................................................................21

Table 1.4-1. Procedure Review Outline/Checklist.....................................................................44

Table 2.1-1. Procedure Review Outline/Checklist.....................................................................48

Table 2.2-1. Procedure Review Outline/Checklist.....................................................................56

Table 2.3-1. Procedure Review Outline/Checklist.....................................................................60

Table 2.4-1. Procedure Review Outline/Checklist.....................................................................66

Table 2.5-1. Procedure Review Outline/Checklist.....................................................................72

Table 2.6-1. Procedure Review Outline/Checklist.....................................................................80

Table 2.6-2. Dose Rates from Neutrons at 1 Foot from Point Sources of 

Various Uranium Compounds ...............................................................................84

Table 2.6-3. User Input Field in ORAU Workbook...................................................................88

Table 3.1-1. Procedure Review Outline/Checklist.....................................................................91

Table 3.2-1. Procedure Review Outline/Checklist.....................................................................96

Table 3.3-1. Procedure Review Outline/Checklist.....................................................................99

Table 3.4-1. Procedure Review Outline/Checklist...................................................................102

Table 3.5-1. Evaluation of Findings Identified in the Review of ORAUT-OTIB-0003, 

Rev. 0 ...................................................................................................................105

Table 3.5-2. Procedure Review Outline/Checklist...................................................................106

Table 3.6-1. Procedure Review Outline/Checklist...................................................................110

Table 3.7-1. Procedure Review Outline/Checklist...................................................................115

Table 3.8-1. Procedure Review Outline/Checklist...................................................................124

Table 3.9-1. Evaluation of Findings Identified in the Review of ORAUT-OTIB-0003, 

Rev. 0 ...................................................................................................................131

Table 3.9-2. Procedure Review Outline/Checklist...................................................................132

Table 3.9-3. Distribution of Employees by Length of Employment and Level of Dust 

Exposure at Harshaw Chemical Company ..........................................................135

Table 3.9-4. Summary of Weighted Daily Exposures at Simonds Saw & Steel......................136

Table 3.9-5. Summary of Average Daily Exposures to Alpha-Emitting Dust at 

Seven Uranium Plants..........................................................................................137

Table 3.9-6. Alpha Radiation Measurements Taken at Simonds Saw (dpm/100 cm

2

)............144

Table 3.10-1. Procedure Review Outline/Checklist...................................................................147

Table 3.11-1. Procedure Review Outline/Checklist...................................................................153

Table 3.12-1. Procedure Review Outline/Checklist...................................................................156

Table 3.13-1. Procedure Review Outline/Checklist...................................................................159

Table 4.1-1: QA-related Document Compliance Checklist .....................................................164

Table 4.2-1: QA-related Document Compliance Checklist .....................................................168

Table 4.3-1: QA-related Document Compliance Checklist .....................................................172

Table 4.4-1: QA-related Document Compliance Checklist .....................................................175

Table 4.5-1: QA-related Document Compliance Checklist .....................................................178

Table 4.6-1: QA-related Document Compliance Checklist .....................................................181

Table 4.7-1: QA-related Document Compliance Checklist .....................................................184
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Table 4.8-1: QA-related Document Compliance Checklist .....................................................187

Table 4.9-1: QA-related Document Compliance Checklist .....................................................191

Table 4.10-1: QA-related Document Compliance Checklist .....................................................194

Table 4.11-1: QA-related Document Compliance Checklist .....................................................197

LIST OF FIGURES

Figure 3.7-1. K-S and A-D Statistics for All Distributions Fitted to a Sample of 10,000 

Products using Crystal Ball 2000 Batch Fit Procedure........................................118

Figure 3.7-2. The Best-Fitting Beta Distribution, Fitted to the Sample of 10,000 Products.....119

Figure 3.7-3. The Best-Fitting Normal Distribution, Fitted to the Sample of 10,000 

Products................................................................................................................120

Figure 3.7-4. Comparison of Statistics Obtained from Samples of Size 10,000 from the 

Best-Fitting Beta Distribution and the Best-Fitting Normal Distribution ...........121

Figure 3.10-1. Comparison of Lapel to Fixed Station Air Sampling ..........................................151
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EXECUTIVE SUMMARY

Under the Energy Employees Occupational Illness Compensation Program Act (EEOICPA) and 

Title 42, Part 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000, of the Code of Federal Regulations

(42 CFR Part 82), the Advisory Board on Radiation and Worker Health is mandated to conduct 

an independent review of the methods and procedures used by the National Institute of 

Occupational Safety and Health (NIOSH) and its contractors for dose reconstruction.

As contractor to the Advisory Board on Radiation and Worker Health (Advisory Board or 

Board), S. Cohen & Associates (SC&A) has been charged under Task 3 to support the Advisory 

Board in this effort by completing the following three work products:

(1) Develop a Formal Review Protocol for the Evaluation of Procedures Used in Dose 

Reconstruction: The purpose of a review protocol is to ensure a structured and 

systematic review process that determines whether procedures are consistent with the 

philosophy, intent, and/or statutory directives cited in EEOICPA, and comply with the 

general requirements, methods, and guidance provided in 42 CFR Part 82.

In behalf of the first work product, SC&A submitted a report entitled, 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. 

(2) Conduct a Critical Review of Methods and Procedures Used by NIOSH for Dose 

Reconstruction: Under Modifications Nos. 2 through 5 (initially authorized on June 24,

2004), the Advisory Board approved SC&A’s proposal of work to perform a review of a 

total of 33 procedural documents that included implementation guidelines, procedures, 

technical information bulletins (TIBs), and plans. This review was completed and a draft 

report delivered to NIOSH and the Advisory Board on January 17, 2005, entitled Task 3: 

The review of NIOSH/ORAUT Procedures and Methods Used for Dose Reconstruction, 

SCA-TR-Task3, Rev 0, Final Draft, January 17, 2005. This document and its findings 

are the subject of an issues resolution process that is currently underway under the 

direction of an Advisory Board working group.

(3) Conduct a Supplemental Critical Review of Methods and Procedures Used by 

NIOSH for Dose Reconstruction: Under Modification No. 6 (authorized on August 30, 

2005), NIOSH and the Advisory Board authorized SC&A to proceed with the scope of 

work delineated in SC&A’s proposal of work entitled Task Order 3 Proposal for FY 

2006, Review Dose Reconstruction Procedures and Methods, dated August 16, 2005. 

Modification No. 6 adds an additional set of 32 OCAS and ORAU procedures and 

13 generic workbooks to the review process, and provides the resources and mandate to 

continue with the issues resolution process that was initiated in FY 2005 to address the 

findings provided in our January 17, 2005, report cited above. The draft work product 

presented herein is provided in partial fulfillment of Modification No. 6 to this work 
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assignment, in that it is limited to the review of the supplemental set of 321procedures 

listed in SC&A’s August 16, 2005, proposal of work.

SUMMARY FINDINGS

The 32 documents identified to SC&A for review represent a sizeable body of written text that 

embraces a wide array of complex topics and clearly reflects an intense effort by many 

individuals who are regarded as scientific experts in their fields. These documents were created 

in 2004 and 2005 by the Office of Compensation Analysis and Support (OCAS) and the Oak 

Ridge Associated Universities Team (ORAUT), and reflect a maturation of the dose 

reconstruction program that began in 2000, and the first set of guidelines issued in 2002. Unlike 

our previous Task 3 procedures review report issued in January 2005, this report reveals an 

integration of the generic OCAS and ORAUT guidelines with the site profiles to the extent 

feasible. We believe this aspect of the guidelines will help to avoid inconsistencies between the 

procedures and the site profiles. 

It is equally important to note that some of the 32 documents have been revised and are likely to 

be revised in the future, due to the fact that these documents are regarded as “living documents.” 

The need for living documents, as explained to SC&A by NIOSH, reflects the urgent demand for 

NIOSH to begin the adjudication of claims by a progressive selection process that started with 

claims requiring the least amount of procedural guidance and data. Future, more complex dose 

reconstructions may, therefore, require further procedural revisions and/or the development of 

additional procedures.

In brief, SC&A’s review of the methods and procedures used for dose reconstruction must be 

viewed with some caution, since these findings are not only limited to generic procedures as they 

exist currently, but more importantly do not include the role of site profiles in dose 

reconstruction. However, the latter issue is less of a concern for the procedures reviewed in this 

supplement because of the concerted effort made by NIOSH to cross-reference site profiles.

An overview of SC&A’s findings is given below in behalf of the seven general review objectives 

identified by SC&A in its review protocol. Due to the large number of documents and their 

heterogeneous contents, some comments may not apply to all documents and, in select instances,

may only apply to one or a few procedures.

Objective 1: Determine the Degree to Which Procedures Support a Process that is 

Expeditious and Timely for Dose Reconstruction

A well-written procedure presents all required data in a logical, concise, unambiguous, and 

prescriptive manner. Our review of this set of procedures revealed that most were concise, well 

organized, and provided generally complete and unambiguous guidance. Unlike many of the 

procedures we reviewed in our January 2005 report, the procedures reviewed in this report do not 

 

1 As described in subsequent sections of this report, the specific procedures reviewed herein changed over 

time as it became apparent that some of the procedures originally identified for review did not require a review, 

while other procedures not identified in our original proposal were identified for review or were reviewed at the 

request of the Board.
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require the dose reconstructor to read through voluminous and frequently irrelevant background 

information. 

Objective 2: Determine Whether Procedures Provide Adequate Guidance to be Efficient in 

Select Instances Where a More Detailed Approach to Dose Reconstruction Would Not 

Affect the Outcome

SC&A understands the benefit of and endorses the need for an efficient dose reconstruction 

process that, in appropriate instances, either avoids a full-blown dose reconstruction (i.e., when a 

partial dose reconstruction yields a probability of causation (POC) > 50%) or simplifies a dose 

reconstruction by means of worst-case assumptions/dose assignments for claims with a low 

POC. As in our January 2005 report, we found that a sizeable number of procedures, while 

making reference to the likely or unlikely compensability of a claim, provide little or no 

guidance to the dose reconstructor for prejudging a claim. However, we have come to believe 

that it is not always possible to provide explicit guidance on making these judgments, and that it 

is best to leave these judgments to the dose reconstructor working within a QA/QC framework 

that ensures consistency in these judgments. However, we have also found that, when it was 

possible to assist the dose reconstructor in making these judgments, such guidance was provided. 

For example, many of the guides are highly explicit regarding the assumptions that should be 

employed for reconstructing doses at specific facilities and for specific time frames. A good 

example is ORAUT-OTIB-0033. However, for some guidelines, such as ORAUT-OTIB-0020, 

Use of Coworker Dosimetry for External Dose Assignment, a great deal of judgment is left to the 

dose reconstructor. 

Objective 3: Assess the Extent to Which Procedures Account for all Potential Exposures, 

and Ensure that Resultant Doses are Complete and Based on Adequate Data in Instances 

Where the POC is not Evident

This objective focused on claims for which assignment of external and internal doses must be 

scientifically defensible and invariably requires site-specific information relating to timedependent health physics practices, personnel monitoring, dosimeter and bioassay performance 

criteria, etc. We found that, to a large extent, a concerted effort was made in these procedures to 

take into consideration site-specific and time-dependent factors, with appropriate crossreferences to site profiles.

Objective 4: Assess Procedures for Providing a Consistent Approach to Dose 

Reconstruction Regardless of Claimants’ Exposures by Time and Employment Locations

In order for the adjudication process to be fair to claimants, the process of dose reconstruction 

must attempt to remain consistent over time and space. Consistency implies that the same 

procedures are applied to claims that share a high degree of commonality. SC&A’s review of 

procedures shows that, though some of the procedures tend to overlap, which presents the dose 

reconstructor with multiple options, an effort was made to help the dose reconstructor navigate 

his way through multiple overlapping guides. For example, ORAUT-OTIB-0033 attempts to 

guide the dose reconstructor through the appropriate selection and use of ORAUT-OTIB-0002, 
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-0014, and -0018. However, we uncovered some inconsistencies between the guidance provided 

in ORAUT-OTIB-0023 regarding missed neutron dose and that provided in OCAS-IG-001.

Objective 5: Evaluate Procedures with Regard to Fairness and the Extent to which the 

Claimant is given the Benefit of Doubt when there are Unknowns and Uncertainties 

Concerning Radiation Exposures

The statutory requirement of a claimant-favorable dose reconstruction process is achieved by 

(1) giving the benefit of the doubt when there are unknowns, and (2) defining uncertainties for 

measured data and selecting the 99th percentile value of a Monte Carlo distribution when 

determine the POC.

With few exceptions, the guidelines reviewed in this report give the benefit of the doubt to the 

claimant. Some exceptions include the procedure for reconstructing occupational medical doses 

where the full range of potential uncertainties are not addressed (ORAUT-PROC-61), and the 

procedures for reconstructing ingestions doses (OCAS-TIB-009) where, under some 

circumstances, the procedures could underestimate the dose. 

Objective 6: Evaluate Procedure for its Ability to Adequately Account for the Uncertainty 

of Dose Estimates

With few exceptions, the procedures reviewed in this report adequately address uncertainties, 

with the possible exception of ORAUT-PROC-61 dealing with medical x-ray exposures. 

Objective 7: Assess the Scientific and Technical Quality of Methods and Guidance 

Contained in Procedures to ensure that they reflect the Proper Balance Between Current/ 

Consensus Scientific Methods and Dose Reconstruction Efficiency

The seventh and final review objective not only assessed the scientific credibility of procedural 

methods, but also the EEOICPA directive that the methods and procedures must achieve a 

balance between technical precision and dose reconstruction efficiency. Some of the areas where 

we identified technical inadequacies include the methods used to (1) derive ingestion doses, 

(2) quantify uncertainty in deriving medical x-ray exposure, (3) address exposure to nonpenetrating radiation, (4) adjust film badge readings for glovebox workers, and (5) derive 

neutron doses associated with alpha,n reactions. These deficiencies were found to be minor, 

however, and most of our independent technical evaluations found the methodologies to be 

scientifically correct.

Tables ES-1 and ES-2 present a roll-up of the findings of the results of SC&A’s review of the 19 

procedures dealing with internal and external dosimetry and the 11 procedures dealing with 

quality assurance issues. For the internal/external procedures, findings summarized in ES-1 are 

rated using a scaling system of 1 through 5, with 5 representing the best rating. As indicated by 

the number of “fives” that were assigned to individual criteria, it is evident that most procedures 

received very high scores. However, there are a few procedures that were assigned a “one” for 

some of the criteria that should be mentioned, as follows:
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 In the review of ORAUT-OTIB-0020 (Use of Coworker Dosimetry Data for External 

Dose Assignment, Table 2.3.1), item No. 4.1 was assigned a score of 1, indicating that 

the procedure does not support a prescriptive approach to dose reconstruction. The 

reason for the low score for this item is that the procedure directs the dose reconstructor 

to make a quantitative determination of what corresponds to “reasonable” upper 

exposures that the unmonitored person may have received. Such an approach requires 

considerable judgment and is not considered prescriptive.

 In the review of ORAUT-OTIB-0017 (Interpretation of Dosimetry Data for Assignment 

of Shallow Dose, Table 2.5.1), item No. 2.1 does not provide adequate guidance for 

identifying a potentially high probability of causation as part of an initial dose evaluation 

of a claim. The concern is that in many circumstances, a negative reading on a film badge 

is not a reliable indicator that a person has not experienced localized skin exposures due 

to either localized contamination of the skin or exposure to a beta source located at some 

distance from the location of the dosimeter. Beta dosimetry is useful when it reveals a 

positive result, but a negative result does not necessarily mean that the individual 

experienced no localized beta exposure.

 In the review of ORAUT-OTIB-0024 (Estimation of Neutron Dose Rates from AlphaNeutron Reactions in Uranium and Thorium Compounds, Table 2.6-1), items No. 2.1, 

5.1, 5.2 and 5.3 (all dealing with claimant favorability) were assigned a score of 1 

because the procedure neglects the neutron contribution to dose due to fissioning. In 

addition, item 7.3 was assigned a score of 1 because the fundamental methodologies used 

to derive the neutron flux associated with alpha,n reactions are technically deficient. 

With regard to the quality assurance procedures reviewed in this report, Table ES-2 indicates that 

a few items were assigned a score of “no.” In these circumstances, the procedures could have 

done a better job in establishing the overall quality assurance framework within which the given 

procedure applies. In addition, there were a number of places where the procedures were not 

properly labeled with regard to document number, revision number, etc.
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Table ES-1. Roll-up of Findings of the Review of the 6 External and 

13 Internal Dosimetry Procedures

No. Description of Objective 5 4 3 2 1 N/A

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? 16 3

1.2 Is the procedure written in a manner that presents the 

data in a logical sequence? 16 1 2

1.3 Is the procedure complete in terms of required data 

(i.e., does not reference other sources that are needed 

for additional data)?

14 1 2 1 1

1.4 Is the procedure consistent with all other procedures 

that are part of the hierarchy of procedures employed 

by NIOSH for dose reconstruction?

16 1 1 1

1.5 Is the procedure sufficiently prescriptive in order to 

minimize the need for subjective decisions and data 

interpretation?

11 5 2 1

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?

11 2 2 1 3

2.2 Conversely, for claims with suspected cumulative low 

doses, does the procedure provide clear guidance in 

defining worst-case assumptions?

11 2 6

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? 19

3.1.2 Is the interview process sufficiently flexible to permit 

 unforeseen lines of inquiry? 19

3.1.3 Does the interview process demonstrate objectivity, 

and is it free of bias? 19

3.1.4 Is the interview process sensitive to the claimant? 19

3.1.5 Does the interview process protect information as 

required under the Privacy Act? 19

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) 4 15

3.2.2 In vivo/In vitro bioassays 8 11

3.2.3 Missing dosimetry data 8 1 10

3.2.4 Unmonitored periods of exposure 8 1 1 9
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No. Description of Objective 5 4 3 2 1 N/A

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? 16 1 1 1

4.2 Does the procedure adhere to the hierarchical process 

as defined in 42 CFR 82.2? 14 2 2 1

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? 10 1 3 1 4

5.2 Is the procedure claimant favorable in instances of 

unknown parameters effecting dose estimates? 10 1 4 1 1 2

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 9 1 3 1 5

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)?

12 1 6

6.2 Does the procedure give appropriate guidance in the 

use of random sampling in developing a final 

distribution?

7 12

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? 17 2

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its 

POC? 

16 2 1

7.3 Does the procedure employ scientifically valid 

protocols for reconstructing doses? 9 3 4 2 1
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Table ES-2. Roll-up of the Findings of the Review of the 11 Quality Assurance Procedures 

No. Question Yes No N/A

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

11

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

11

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

11

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

11

1.4 Are there adequate procedures for training of project personnel? 11

1.4.1 Have staff training requirements been identified? 11

1.4.2 Has staff received general orientation training? 11

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act? 11

1.4.4 Has staff received training in the provisions of the QAPP? 11

1.4.5 Is a master record of staff training maintained in project files? 11

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

11

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

11

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition? 11

1.8 Are there procedures covering all work activities of the project? 1 10
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No. Question Yes No N/A

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date? 11

2.2 Do the title, document number, revision number, page number, 

and date appear on each page? 11

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter? 11

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description? 11

2.5 Are revisions clearly indicated on affected pages? 12 8

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

11

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

11
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1.0 INTRODUCTION

1.1 STATEMENT OF PURPOSE

The purpose of this draft report is to assist the Advisory Board on Radiation and Worker Health 

(Advisory Board or Board) in fulfilling its mandate to review the methods and procedures used 

by the National Institute of Occupational Safety and Health (NIOSH) and its contractors in the 

performance of dose reconstruction, as directed by the Energy Employees Occupational Illness 

Compensation Program Act (EEOICPA) and Title 42, Part 82, Methods for Radiation Dose 

Reconstruction Under the Energy Employees Occupational Illness Compensation Program Act 

of 2000 of the Code of Federal Regulations (42 CFR Part 82).

Specifically, Section B of the Preamble to 42 CFR Part 82 identifies the following statutory 

requirement:

. . . The Advisory Board on Radiation and Worker Health to independently review 

the methods established by this rule and to verify a reasonable sample of dose 

reconstructions established under these methods. [Emphasis added.]

Section P of the Preamble to 42 CFR Part 82 restates this requirement, as well as discussing that 

the Advisory Board should identify those procedures that are to be reviewed by the Advisory 

Board, as stated in the following:

As described above under the discussion of statutory provisions related to the 

rule, EEOICPA requires the Advisory Board to conduct an independent review of 

a sample of NIOSH dose reconstructions. 42 U.S.C. 7348 n(d). Since this review 

is specified to be independent, the Advisory Board, rather than HHS, must 

determine the procedures for the Advisory Board’s review of NIOSH dose 

reconstructions. Moreover, this level of autonomy is important for the credibility 

of the review. [Emphasis added.]

1.2 IDENTIFICATION OF PROCEDURES SUBJECT TO REVIEW

In its proposal of work dated August 16, 2005, which was approved by NIOSH and the Advisory 

Board in Modification No. 6, dated August 30, 2005, SC&A identified a list of OCAS/ORAUT 

dose reconstruction-related procedures, technical information bulletins (TIBs), and workbooks 

for review. That list included 7 OCAS documents, 13 ORAU Team procedures, 12 ORAU Team 

TIBs, and 13 complex-wide workbooks. This list was obtained from ORAU’s Controlled 

Document list that was on the web as of August 3, 2005. As acknowledged in our August 16, 

2005, proposal of work, these lists of documents and workbooks are continually being revised 

and expanded. In appreciation of the fluid nature of the various procedures and other tools in use 

by OCAS and ORAU, such as workbooks, Table 1 presents a complete list of all documents and 

workbooks that were on ORAU’s Controlled Document list as of December 7, 2005. The 

documents designated as “authorized for review” are within SC&A’s scope of work for this 

assignment. Some of the documents are designated as “authorized for review under Task 1.” 

These documents are currently authorized for review in FY 2006, but are being reviewed under 
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Task Order 1. Some documents are designated as “previously reviewed.” These documents 

have already been reviewed, and the review reports have already been delivered to NIOSH and 

the Advisory Board under this work assignment or other work assignments in FY 2005. Some 

documents are designated as “out of scope.” This means that SC&A has not yet been requested 

to perform a review of those documents. In addition, documents highlighted in yellow identify 

procedures that (1) SC&A recommends for review as replacements for other procedures that, on 

close inspection, require no reviews, or (2) are included in the list requiring review as a result of 

direction provided by the Advisory Board at the meeting held in Oak Ridge, Tennessee, on 

January 24–26, 2006. These include the latest revisions of ORAUT-OTIB-0004 and ORAUTPROC-0092.
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Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

APPROVED OCAS CONTROLLED DOCUMENTS

DCN-OCAS-IG-001-002 0

Appendix A – ICD Codes and 

Corresponding Organs for External 

Dose Reconstruction

10/31/2005 Out of Scope No

OCAS-COT-0007 0

OCAS Assessment Report: Efficiency 

of the Dose Reconstruction Process 7/20/2004 Authorized for Review

No

OCAS-COT-0011 0

OCAS Assessment Report: Verification 

of OCAS-COT-0007 Corrective Actions 5/3/2005 Out of Scope No

OCAS-COT-0012 0

OCAS Assessment Report: Task 3 

Production 4/1/2005 Out of Scope No

OCAS-IG-001 1

External Dose Reconstruction 

Implementation Guideline 8/1/2002 Previously Reviewed No

OCAS-IG-002 0

Internal Dose Reconstruction 

Implementation Guideline 8/1/2002 Previously Reviewed No

OCAS-PER-001 0

SRS Underestimate Miss Dose due to 

Misinterpret Dose Reconstruction 9/8/2003 Previously Reviewed No

OCAS-PER-002 0

Error in Surrogate Organ Assignment 

Resulting in an Underestimate of X-Ray 

Dose in SRS Dose Reconstruction

12/15/2003 Previously 

Reviewed No

OCAS-PER-003 0

Evaluation of the Effect of Adding 

Ingestion Intakes to Bethlehem Steel

Cases

1/28/2005 Out of Scope No

OCAS-PER-004 0

Application of Photofluorography at the 

Pinellas Plant 2/15/2005 Out of Scope No

OCAS-PR-003 0

Performing and Reporting Dose 

Reconstructions 9/24/2002 Previously Reviewed No

OCAS-PR-004 0

Internal Procedures for the Evaluation of 

Special Exposure Cohort Petitions 9/23/2004 Previously Reviewed No

OCAS-PR-005 0 Conduct of Assessments 12/3/2004 Authorized for 

Review No

OCAS-PR-006 3 CIC Processing Compensation Cases 11/7/2005 Out of Scope No

OCAS-PR-007 1 Dose Reconstruction Review 4/18/2005 Authorized for 

Review No

OCAS-TIB-001 0 IREP Issues 3/4/2003 Previously 

Reviewed No

OCAS-TIB-002 0 Tritium Calculations with IMBA 4/22/2003 Previously 

Reviewed No

OCAS-TIB-003 0

IREP Requirements for Multiple 

Cancers 4/30/2003 Previously Reviewed No

OCAS-TIB-004 1 Naming Conventions 10/3/2003 Previously 

Reviewed No

OCAS-TIB-005 0

Dose Reconstruction Cancer Data 

Requirements 9/5/2003 Previously Reviewed No
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Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

APPROVED OCAS CONTROLLED DOCUMENTS (Continued)

OCAS-TIB-006 1

Interpretation of External Dosimetry 

Records at the Savannah River Site 2/20/2004 Previously Reviewed No

OCAS-TIB-007 0

Neutron Exposures at the Savannah 

River Site 9/17/2003 Previously Reviewed No

OCAS-TIB-008 0

Use of ICRP 66 to Calculate Respiratory

Tract Doses 9/29/2003 Previously Reviewed No

OCAS-TIB-009 0 Estimation of Ingestion Intakes 4/13/2004 Authorized for 

Review No

OCAS-TIB-0010 1

Special External Dose Reconstruction 

Considerations for Glovebox Workers 5/18/2005 Authorized for Review No

OCAS-TIB-0011 1

Lung Dose Conversion Factor for 

Thoron WLM 4/15/2005 Authorized for Review No

OCAS-TIB-0013 0

Special External Dose Reconstruction 

Considerations for Mallinckrodt 

Workers

10/26/2005 Out of Scope No

ORAU TEAM TECHNICAL INFORMATION BULLITENS (TIBs)

ORAUT-OTIB-0001 0

Maximum Internal Dose Estimates for 

Savannah River Site (SRS) Claims 7/15/2003 Previously Reviewed No

ORAUT-OTIB-0002 00 Maximum Internal Dose Estimates for 

Certain DOE Complex Claims 4/22/2003 Previously Reviewed Yes

ORAUT-OTIB-0002 01 PC-2

Maximum Internal Dose Estimates for 

Certain DOE Complex Claims 5/7/2004 Out of Scope Yes

ORAUT-OTIB-0004 2

Estimating the Maximum Plausible 

Dose to Workers at Atomic Weapons 

Employer Facilities

12/4/2003 Previously 

Reviewed Yes

ORAUT-OTIB-0004 03 PC-1

Estimating the Maximum Plausible 

Dose to Workers at Atomic Weapons 

Employer Facilities

11/18/2005

Authorized for 

Review

(At Jan. 2006 

Board Meeting

Yes

ORAUT-OTIB-0005 0

IMBA Organ, External Dosimetry 

Organ and IREP Selection by ICD-9 

Code

9/5/2003 Previously 

Reviewed No

ORAUT-OTIB-0005 2

IMBA Organ, External Dosimetry 

Organ and IREP Selection by ICD-9 

Code

12/2/2005 Out of Scope No

ORAUT-OTIB-0006 2

Dose Reconstruction from 

Occupationally Related Diagnostic 

X-ray Procedures

12/29/2003 Previously 

Reviewed No

ORAUT-OTIB-0006 3 PC-1

Dose Reconstruction from 

Occupationally Related Diagnostic 

X-ray Procedures

12/21/2005 Out of Scope No

ORAUT-OTIB-0007 0

Occupational Dose from Elevated 

Ambient Levels of External Radiation 11/12/2003 Previously Reviewed No
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Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL INFORMATION BULLITENS (TIBs) (Continued)

ORAUT-OTIB-0008 0

A Standard Complex-Wide 

Conversion/Correction Factor for 

Overestimating External Doses 

Measured with TLD

11/7/2003 Previously 

Reviewed No

ORAUT-OTIB-0009 0

Reanalysis of Hankins MTR Bonner ball 

Surveys 3/17/2004 Out of Scope No

ORAUT-OTIB-0010 0

A Standard Complex-Wide Conversion/Correction Factor for Overestimating External Doses Measured 

with Film Badge Dosimeters

1/12/2004 Previously 

Reviewed No

ORAUT-OTIB-0011 0

Tritium Calculated and Missed Dose 

Estimates 6/29/2004 Authorized for Review Yes

ORAUT-OTIB-0012 0

Monte Carlo Methods for Dose 

Uncertainty Calculations 2/14/2005 Authorized for Review Yes

ORAUT-OTIB-0013 0

Individual Dose Adjustment Procedure 

for Y-12 Dose Reconstruction 9/9/2004 Out of Scope Yes

ORAUT-OTIB-0014 0

Assignment of Environmental Internal 

Doses for Employees Not Exposed to 

Airborne Radionuclides

6/22/2004 Authorized for 

Review No

ORAUT-OTIB-0015 0

Bayesian Methods for Estimation of 

Unmonitored Y-12 External Penetrating 

Doses with a Time-Dependent 

Lognormal Model

9/9/2004 Out of Scope Yes

ORAUT-OTIB-0017 1

Interpretation of Dosimetry Data for 

Assignment of Shallow Dose 10/11/2005 Authorized for Review Yes

ORAUT-OTIB-0018 1

Internal Dose Overestimates for 

Facilities with Air Sampling Programs 8/9/2005 Authorized for Review Yes

ORAUT-OTIB-0019 1

Analysis of Coworker Bioassay Data for 

Internal Dose Assignment 10/7/2005 Authorized for Review No

ORAUT-OTIB-0020 1

Use of Coworker Dosimetry Data for 

External Dose Assignment 10/7/2005 Authorized for Review No

ORAUT-OTIB-0021 0

External Coworker Dosimetry Data for 

the X-10 Site 12/29/2004

Authorized for 

Review

(Recommend 

Deleting Since 

Site Profile is 

Not Being 

Reviewed)

Yes

ORAUT-OTIB-0022 0

Guidance on Wound Modeling for 

Internal Dose Reconstruction 11/18/2005

Out of Scope –

(Recommend 

as a 

replacement)

No

ORAUT-OTIB-0023 0

Assignment of Missed Neutron Doses 

Based on Dosimeter Records 3/7/2005 Authorized for Review No
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Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL INFORMATION BULLITENS (TIBs) (Continued)

ORAUT-OTIB-0024 0

Estimation of Neutron Dose Rates from 

Alpha-Neutron Reactions in Uranium 

and Thorium Compounds

4/7/2005 Authorized for 

Review No

ORAUT-OTIB-0025 0

Estimation of Radium-226 Activity in 

the Body from Breath Radon-222 

Measurements

4/5/2005 Authorized for 

Review No

ORAUT-OTIB-0026 00 PC-1

External Coworker Dosimetry Data for 

the K-25 Site 7/29/2005

Authorized for 

Review

(Recommend 

Deleting Since 

Site Profile is 

Not Being 

Reviewed)

Yes

ORAUT-OTIB-0027 0

Supplementary External Dose 

Information for Rocky Flats Plant 5/19/2005

Authorized for 

Review under 

Task 1

No

ORAUT-OTIB-0028 1

Validation of Thorium Annual Dose 

Conversion Factors 3/7/2005 Authorized for Review Yes

ORAUT-OTIB-0029 0

Internal Dosimetry Coworker Data for 

Y-12 4/5/2005

Authorized for 

Review under 

Task 1

No

ORAUT-OTIB-0030 0

External Coworker Dosimetry Data for 

the Hanford Site 3/23/2005

Authorized for 

Review under 

Task 1

Yes

ORAUT-OTIB-0031 00 PC-1

External Coworker Dosimetry Data for 

the Paducah Gaseous Diffusion Plant 8/15/2005

Authorized for 

Review under 

Task 5

Yes

ORAUT-OTIB-0032 0

External Coworker Dosimetry Data for 

the Savannah River Site 5/31/2005

Authorized for 

Review under 

Task 1

Yes

ORAUT-OTIB-0033 0

Application of Internal Doses Based on 

Claimant-Favorable Assumptions for 

Processing as Best Estimates

4/20/2005 Authorized for 

Review Yes

ORAUT-OTIB-0034 0

Internal Dosimetry Coworker Data for 

X-10 12/13/2005 Out of Scope No

ORAUT-OTIB-0035 0

Internal Dosimetry Coworker Data for 

K-25 8/9/2005 Out of Scope No

ORAUT-OTIB-0036 0

Internal Dosimetry Coworker Data for 

Portsmouth Gaseous Diffusion Plant 7/29/2005 Out of Scope No

ORAUT-OTIB-0037 0

Internal Dosimetry Coworker Data for 

Paducah Gaseous Diffusion Plant 9/20/2005 Out of Scope No

ORAUT-OTIB-0039 0

Internal Dosimetry Coworker Data for 

the Hanford Site 10/28/2005

Out of Scope –

(Recommend 

as a 

replacement)

No
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Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL INFORMATION BULLITENS (TIBs) (Continued)

ORAUT-OTIB-0040 0

External Coworker Dosimetry Data for 

Portsmouth Gaseous Diffusion Plant 7/29/2005 Out of Scope Yes

ORAUT-OTIB-0047 0

External Radiation Monitoring at the Y12 Facility During the 1948-1949 Period 9/20/2005

Out of Scope –

(Recommend 

as a 

replacement)

No

ORAU TEAM PROCEDURES

ORAUT-PROC-0001 1 Document Control 8/17/2005 Previously 

Reviewed No

ORAUT-PROC-0002 1

Use of Integrated Modules for Bioassay 

Analysis (IMBA) 8/14/2003 Previously Reviewed No

ORAUT-PROC-0003 0 Internal Dose Reconstruction 5/1/2003 Previously 

Reviewed No

ORAUT-PROC-0006 0 External Dose Reconstruction 6/28/2003 Previously 

Reviewed No

ORAUT-PROC-0006 00 PC-2 External Dose Reconstruction 12/11/2003 Out of Scope No

ORAUT-PROC-0007 0

Routine Quality Control Check of the 

IMBA Software 9/20/2005 Out of Scope No

ORAUT-PROC-0008 0 Claims Status Tracking 7/29/2005 Out of Scope No

ORAUT-PROC-0022 0

Additional Requests for DOE 

Information 3/15/2005 Authorized for Review No

ORAUT-PROC-0023 0 Records Indexing and Review of Data 3/5/2004 Out of Scope No

ORAUT-PROC-0025 1 Data Reconnaissance and Data Capture 10/3/2005 Out of Scope No

ORAUT-PROC-0030 0

NOCTS SQL Server Transactional 

Database Replication 7/20/2004 Out of Scope No

ORAUT-PROC-0031 1

DOE Technical Basis Document 

Development, Review, and Approval 

Process

12/15/2005 Authorized for 

Review No

ORAUT-PROC-0032 01 PC-1

New Hire Notification and Change 

Request 9/2/2005 Out of Scope No

ORAUT-PROC-0033 00 PC-2

Implementing and Maintaining the 

Training Program 9/7/2005 Out of Scope No

ORAUT-PROC-0035 0 Library Operations 11/1/2004 Out of Scope No

ORAUT-PROC-0036 0 Notification of Employee Termination 12/9/2004 Out of Scope No

ORAUT-PROC-0042 0

Accounting for Incomplete Personal 

Monitoring Data on Penetrating 

Gamma-Ray Doses to Workers in 

Radiation Areas at the Oak Ridge Y-12

Plant Prior to 1961

9/9/2004

Authorized for 

Review under 

Task 1

Yes

ORAUT-PROC-0044 0 Special Exposure Cohort (SEC) 10/7/2005

Authorized for 

Review under 

Task 5

No
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

26 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM PROCEDURES (Continued)

ORAUT-PROC-0057 0

Scanning Documents from Data Capture 

Activities and Other Project Records 11/15/2005 Out of Scope No

ORAUT-PROC-0058 0 Correspondence Control 9/13/2004 Out of Scope No

ORAUT-PROC-0059 0 Peer Review of Dose Reconstructions 9/6/2005 Out of Scope No

ORAUT-PROC-0060 0

External On-Site Ambient Dose 

Reconstruction 3/7/2005

Out of Scope –

(Recommend 

as a 

replacement)

Yes

ORAUT-PROC-0061 0

Occupational X-Ray Dose 

Reconstruction for DOE Sites 12/1/2004 Authorized for Review No

ORAUT-PROC-0065 00 PC-1

Internal Finding and Corrective Action 

to Prevent Recurrence 11/3/2005 Authorized for Review No

ORAUT-PROC-0066 0

Quality Assurance Records 

Management 9/3/2004 Authorized for Review No

ORAUT-PROC-0067 0

Conduct of Quality Assurance 

Surveillances 9/14/2004 Authorized for Review No

ORAUT-PROC-0069 0

External Nonconformance and 

Corrective Action to Prevent Recurrence 9/9/2004 Authorized for Review No

ORAUT-PROC-0072 0 Stop Work 9/14/2004 Out of Scope No

ORAUT-PROC-0074 0 Commitment Control 1/13/2005 Out of Scope No

ORAUT-PROC-0076 1 Change Management 10/18/2005 Out of Scope No

ORAUT-PROC-0077 0

Dose Reconstruction Error Tracking and 

Reporting 3/28/2005 Authorized for Review No

ORAUT-PROC-0078 0 Records Center Operations 4/13/2005 Out of Scope No

ORAUT-PROC-0079 0 Protecting Privacy Act Data 7/6/2004 Out of Scope No

ORAUT-PROC-0080 0 Conduct of Quality Assurance Audits 9/9/2004 Authorized for 

Review No

ORAUT-PROC-0081 0 Information Technology (IT) Support 1/3/2005 Out of Scope No

ORAUT-PROC-0086 0

Case Preparation – Complex Internal 

Dosimetry Claims

12/7/2005 Out of Scope No

ORAUT-PROC-0088 00 PC-1

Review Process for Documents in the 

Site Research Database 2/4/2005 Out of Scope No

ORAUT-PROC-0090 0

Computer Assisted Telephone Interview 

(CATI) Process 6/21/2005 Authorized for Review No

ORAUT-PROC-0091 0 Dose Reconstruction Submittal 6/29/2005 Authorized for 

Review No

ORAUT-PROC-0092 0 Close-Out Interview Process 8/17/2005 Out of Scope No
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

27 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS

ORAUT-TKBS-0001 1 & 2

Exposure Matrix for Bethlehem Steel 

Corporation, Lackawanna, NY; Period 

of Operation: 1949-1952

6/29/2004 Previously 

Reviewed No

ORAUT-TKBS-0002 1

Exposure Matrix for Blockson Chemical 

Company, Joilet, Illinois; Period of 

Operation: March 1, 1951 through 

March 31, 1962

6/29/2004 Out of Scope No

ORAUT-TKBS-0003 2 Savannah River Site 10/29/2004 Previously 

Reviewed Yes

ORAUT-TKBS-0003 3 Savannah River Site 4/5/2005 Out of Scope Yes

ORAUT-TKBS-0004 1

Exposure Matrix for Huntington Pilot 

Plant 1/16/2004 Out of Scope No

ORAUT-TKBS-0005 1 Mallinckrodt 3/10/2005 Previously 

Reviewed No

ORAUT-TKBS-0006-1 1 Hanford Site – Introduction 1/9/2004 Previously 

Reviewed No

ORAUT-TKBS-0006-2 00 PC-1 Hanford Site – Site Description 12/29/2004 Previously 

Reviewed No

ORAUT-TKBS-0006-3 0

Hanford Site – Occupational Medical 

Dose 9/16/2003 Previously Reviewed Yes

ORAUT-TKBS-0006-3 1

Hanford Site – Occupational Medical 

Dose 4/11/2005 Out of Scope Yes

ORAUT-TKBS-0006-4 0

Hanford Site – Occupational 

Environmental Dose 10/15/2003 Previously Reviewed Yes

ORAUT-TKBS-0006-4 0

Hanford Site Attachment A –

Occupational Environmental Dose 10/15/2003 Previously Reviewed Yes

ORAUT-TKBS-0006-5 1

Hanford Site Attachment D –

Occupational Internal Dose for 

Monitored Workers

11/24/2004 Previously 

Reviewed No

ORAUT-TKBS-0006-5 1

Hanford Site – Occupational Internal 

Dose 11/24/2004 Previously Reviewed No

ORAUT-TKBS-0006-6 1

Hanford Site – Occupational External 

Dose 1/9/2004 Previously Reviewed Yes

ORAUT-TKBS-0007-1 0 INEEL – Introduction 5/7/2004 Previously 

Reviewed No

ORAUT-TKBS-0007-2 2 INEEL – Site Description 7/29/2005 Previously 

Reviewed No

ORAUT-TKBS-0007-3 00 Pc-1 INEEL – Occupational Medical Dose 5/28/2004 Previously 

Reviewed Yes

ORAUT-TKBS-0007-4 0

INEEL – Occupational Environmental 

Dose 3/30/2004 Previously Reviewed Yes

ORAUT-TKBS-0007-5 00 PC-1 INEEL – Occupational Internal Dose 10/12/2004 Previously 

Reviewed Yes

ORAUT-TKBS-0007-6 0

INEEL – Occupational External 

Dosimetry 4/6/2004 Previously Reviewed Yes
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

28 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS (Continued)

ORAUT-TKBS-0008-1 0 Nevada Test Site – Introduction 2/4/2004 Previously 

Reviewed No

ORAUT-TKBS-0008-2 0 Nevada Test Site – Site Description 2/2/2004 Previously 

Reviewed No

ORAUT-TKBS-0008-3 0

Nevada Test Site – Occupational 

Medical Dose 6/9/2004 Previously Reviewed No

ORAUT-TKBS-0008-4 0

Nevada Test Site – Occupational 

Environmental Dose 4/20/2004 Previously Reviewed Yes

ORAUT-TKBS-0008-5 0

Nevada Test Site – Occupational 

Internal Dose 9/30/2004 Previously Reviewed Yes

ORAUT-TKBS-0008-6 0

Nevada Test Site – Occupational

External Dose 9/21/2004 Previously Reviewed No

ORAUT-TKBS-0009-1 0 K-25 Site – Introduction 1/6/2004 Out of Scope No

ORAUT-TKBS-0009-2 0 K-25 – Site Description 1/12/2004 Out of Scope No

ORAUT-TKBS-0009-3 0 K-25 – Occupational Medical Dose 6/29/2004 Out of Scope Yes

ORAUT-TKBS-0009-4 0

K-25 Site – Occupational 

Environmental Dose 12/29/2004 Out of Scope Yes

ORAUT-TKBS-0009-5 0

K-25 Gaseous Diffusion Plant –

Occupational Internal Dose 12/21/2004 Out of Scope Yes

ORAUT-TKBS-0009-6 0 K-25 Site – Occupational External Dose 11/24/2004 Out of Scope Yes

ORAUT-TKBS-0010-1 0

Los Alamos National Laboratory –

Introduction 1/25/2005 Authorized for Review No

ORAUT-TKBS-0010-2 0

Los Alamos National Laboratory – Site 

Description 5/7/2004 Authorized for Review No

ORAUT-TKBS-0010-3 0

Los Alamos National Laboratory –

Occupational Medical Dose 12/29/2004 Authorized for Review Yes

ORAUT-TKBS-0010-4 0

Los Alamos National Laboratory –

Occupational Environmental Dose 10/8/2004 Authorized for Review Yes

ORAUT-TKBS-0010-5 0

Los Alamos National Laboratory –

Occupational Internal Dose 12/21/2004 Authorized for Review Yes

ORAUT-TKBS-0010-6 0

Los Alamos National Laboratory –

Occupational External Dose 5/10/2005 Authorized for Review No

ORAUT-TKBS-0011-1 0 Rocky Flats Plant – Introduction 4/20/2004 Previously 

Reviewed No

ORAUT-TKBS-0011-2 0 Rocky Flats Plant – Site Description 1/10/2004 Previously 

Reviewed No

ORAUT-TKBS-0011-3 0

Rocky Flats Plant – Occupational 

Medical Dose 2/9/2004 Previously Reviewed Yes

ORAUT-TKBS-0011-4 1

Rocky Flats Plant – Occupational 

Environmental Dose 6/29/2004 Previously Reviewed Yes

ORAUT-TKBS-0011-5 0

Rocky Flats Plant – Occupational 

Internal Dose 1/12/2004 Previously Reviewed Yes
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

29 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS (Continued)

ORAUT-TKBS-0011-6 0

Rocky Flats Plant – Occupational 

External Dose 1/20/2004 Previously Reviewed Yes

ORAUT-TKBS-0012-1 0 ORNL (X-10) Site – Introduction 8/11/2004 Authorized for 

Review No

ORAUT-TKBS-0012-2 0 ORNL (X-10) Site – Site Description 11/14/2003 Authorized for 

Review No

ORAUT-TKBS-0012-3 1

Oak Ridge National Laboratory (X-10) 

– Occupational Medical Dose 10/29/2004 Authorized for Review Yes

ORAUT-TKBS-0012-4 0

ORNL (X-10) Site – Occupational 

Environmental Dose 5/7/2004 Authorized for Review Yes

ORAUT-TKBS-0012-5 0

ORNL (X-10) Site – Occupational 

Internal Dose 6/29/2004 Authorized for Review Yes

ORAUT-TKBS-0012-6 0

ORNL (X-10) Site – Occupational 

External Dose 8/11/2004 Authorized for Review Yes

ORAUT-TKBS-0013-1 0 Pantex Site – Introduction 2/18/2004 Out of Scope No

ORAUT-TKBS-0013-2 0 Pantex Site – Site Description 3/30/2004 Out of Scope No

ORAUT-TKBS-0013-3 0

Pantex Site – Occupational Medical 

Dose 8/24/2004 Out of Scope No

ORAUT-TKBS-0013-4 0

Pantex Site – Occupational 

Environmental Dose 8/24/2004 Out of Scope No

ORAUT-TKBS-0014-1 00 PC-1

Y-12 National Security Complex – Site 

Profile 11/24/2004 Previously Reviewed No

ORAUT-TKBS-0014-1 00 PC-2

Y-12 National Security Complex – Site 

Profile 10/11/2005 Out of Scope No

ORAUT-TKBS-0014-2 01 Y-12 National Security Complex – Site 

Description 1/19/2005 Previously Reviewed No

ORAUT-TKBS-0014-2 01 PC-1

Y-12 National Security Complex – Site 

Description 10/11/2005 Out of Scope No

ORAUT-TKBS-0014-3 00 Y-12 Site – Occupational Medical Dose 9/9/2004 Previously 

Reviewed Yes

ORAUT-TKBS-0014-3 00 PC-2 Y-12 Site – Occupational Medical Dose 10/11/2005 Out of Scope Yes

ORAUT-TKBS-0014-4 00 PC-2

Y-12 Site – Occupational 

Environmental Dose 9/9/2004 Previously Reviewed Yes

ORAUT-TKBS-0014-4 00 PC-3

Y-12 Site – Occupational

Environmental Dose 10/11/2005 Out of Scope Yes

ORAUT-TKBS-0014-5 01 Y-12 Site – Occupational Internal Dose 5/10/2005 Previously 

Reviewed Yes

ORAUT-TKBS-0014-5 01 PC-1 Y-12 Site – Occupational Internal Dose 10/11/2005 Out of Scope Yes
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

30 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS (Continued)

ORAUT-TKBS-0014-6 00 Y-12 Site – Occupational External Dose 11/19/2003 Previously 

Reviewed Yes

ORAUT-TKBS-0014-6 01 PC-1 Y-12 Site – Occupational External Dose 10/11/2005 Out of Scope Yes

ORAUT-TKBS-0015-1 0

Portsmouth Gaseous Diffusion Plant –

Introduction 5/11/2004 Out of Scope No

ORAUT-TKBS-0015-2 0

Portsmouth Gaseous Diffusion Plant –

Site Description 11/18/2003 Out of Scope No

ORAUT-TKBS-0015-3 1

Portsmouth Gaseous Diffusion Plant –

Occupational Medical Dose 7/19/2004 Out of Scope No

ORAUT-TKBS-0015-4 0

Portsmouth Gaseous Diffusion Plant –

Occupational Environmental Dose 3/17/2004 Out of Scope Yes

ORAUT-TKBS-0015-5 0

Portsmouth Gaseous Diffusion Plant –

Occupational Internal Dose 11/24/2004 Out of Scope Yes

ORAUT-TKBS-0015-6 0

Portsmouth Gaseous Diffusion Plant –

Occupational External Dose 1/18/2005 Out of Scope No

ORAUT-TKBS-0016-1 0 Mound Site – Introduction 9/9/2004 Authorized for 

Review No

ORAUT-TKBS-0016-2 0 Mound Site – Site Description 3/30/2004 Authorized for 

Review No

ORAUT-TKBS-0016-3 01 PC-1

Mound Site – Occupational Medical 

Dose 7/8/2005 Authorized for Review Yes

ORAUT-TKBS-0016-4 0

Mound Site – Occupational 

Environmental Dose 10/6/2004 Authorized for Review Yes

ORAUT-TKBS-0016-5 0

Mound Site – Occupational Internal 

Dose 9/9/2004 Authorized for Review Yes

ORAUT-TKBS-0016-6 0

Mound Site – Occupational External 

Dose 8/11/2004 Authorized for Review Yes

ORAUT-TKBS-0017-1 1 Fernald Site – Introduction 3/17/2004 Authorized for 

Review No

ORAUT-TKBS-0017-2 0 Fernald Site – Site Description 5/20/2004 Authorized for 

Review No

ORAUT-TKBS-0017-3 0

Fernald Site – Occupational Medical 

Dose 2/11/2004 Authorized for Review Yes

ORAUT-TKBS-0017-4 0

Fernald Site – Occupational 

Environmental Dose 4/6/2004 Authorized for Review Yes

ORAUT-TKBS-0017-5 0

Fernald Site – Occupational Internal 

Dose 5/28/2004 Authorized for Review Yes

ORAUT-TKBS-0017-6 0

Fernald Site – Occupational External 

Dose 4/20/2004 Authorized for Review Yes

ORAUT-TKBS-0018 1

Atomic Energy Operations at the Iowa 

Army Ammunition Plant (IAAP) 3/14/2005 Previously Reviewed No

ORAUT-TKBS-0019-1 0

Paducah Gaseous Diffusion Plant –

Introduction 9/9/2004 Out of Scope No
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

31 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS (Continued)

ORAUT-TKBS-0019-2 0

Paducah Gaseous Diffusion Plant – Site 

Description 5/7/2004 Out of Scope No

ORAUT-TKBS-0019-3 0

Paducah Gaseous Diffusion Plant –

Occupational Medical Dose 2/5/2004 Out of Scope No

ORAUT-TKBS-0019-4 0

Paducah Site – Occupational 

Environmental Dose 8/24/2004 Out of Scope No

ORAUT-TKBS-0019-5 0

Paducah Gaseous Diffusion Plant –

Occupational Internal Dose 9/30/2004 Out of Scope No

ORAUT-TKBS-0019-6 1

Paducah Gaseous Diffusion Plant –

Occupational External Dose 3/29/2005 Out of Scope No

ORAUT-TKBS-0020 0

Exposure Matrix for Tennessee Valley 

Authority, Muscle Shoals, Alabama, 

Period of Operation: 1951 - 1955

3/30/2004 Out of Scope No

ORAUT-TKBS-0021 00 PC-1

Exposure Matrix for Aliquippa Forge, 

Pennsylvania, Period of Operation: 

January 1, 1947 through February 28, 

1950

11/18/2005 Out of Scope No

ORAUT-TKBS-0025 0

An Exposure Matrix for Linde Ceramics 

Plant (including Tonawanda Laboratory) 5/31/2005 Authorized for Review No

ORAUT-TKBS-0026-1 0

Argonne National Laboratory – West -

Introduction 12/1/2004 Out of Scope No

ORAUT-TKBS-0026-2 0

Argonne National Laboratory – West –

Site Description 9/9/2004 Out of Scope No

ORAUT-TKBS-0026-3 00 PC-1

Argonne National Laboratory – West –

Occupational Medical Dose 5/16/2005 Out of Scope No

ORAUT-TKBS-0026-4 0

Argonne National Laboratory – West –

Occupational Environmental Dose 9/30/2004 Out of Scope No

ORAUT-TKBS-0026-5 0

Argonne National Laboratory – West –

Occupational Internal Dose 1/20/2005 Out of Scope No

ORAUT-TKBS-0026-6 0

Argonne National Laboratory – West –

Occupational External Dose 9/30/2004 Out of Scope No

ORAUT-TKBS-0027-1 0

Pacific Northwest National Laboratory –

Introduction 8/22/2005 Out of Scope No

ORAUT-TKBS-0027-2 0

Pacific Northwest National Laboratory –

Site Description 8/5/2005 Out of Scope No

ORAUT-TKBS-0027-3 0

Pacific Northwest National Laboratory –

Occupational Medical Dose 8/9/2005 Out of Scope No

ORAUT-TKBS-0027-4 0

Pacific Northwest National Laboratory –

Occupational Environmental Dose 8/12/2005 Out of Scope No

ORAUT-TKBS-0027-5 0

Pacific Northwest National Laboratory –

Occupational Internal Dose 8/12/2005 Out of Scope No

ORAUT-TKBS-0027-6 0

Pacific Northwest National Laboratory –

Occupational External Dose 8/12/2005 Out of Scope No
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

32 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS (Continued)

ORAUT-TKBS-0028-1 0 Weldon Spring Plant – Introduction 6/28/2005 Out of Scope No

ORAUT-TKBS-0028-2 0 Weldon Spring Plant – Site Description 6/24/2005 Out of Scope No

ORAUT-TKBS-0028-3 0

Weldon Spring Plant – Occupational 

Medical Dose 6/24/2005 Out of Scope No

ORAUT-TKBS-0028-4 0

Weldon Spring Plant – Occupational 

Environmental Dose 6/28/2005 Out of Scope No

ORAUT-TKBS-0028-5 0

Weldon Spring Plant – Occupational 

Internal Dose 6/28/2005 Out of Scope No

ORAUT-TKBS-0028-6 0

Weldon Spring Plant – Occupational 

External Dose

6/24/2005 Out of Scope No

ORAUT-TKBS-0029-1 0 Pinellas Plant – Introduction 4/11/2005 Authorized for 

Review No

ORAUT-TKBS-0029-2 0 Pinellas Plant – Site Description 8/5/2005 Authorized for 

Review No

ORAUT-TKBS-0029-3 0

Pinellas Plant – Occupational Medical 

Dose 5/6/2005 Authorized for Review No

ORAUT-TKBS-0029-4 0

Pinellas Plant – Occupational 

Environmental Dose 4/5/2005 Authorized for Review No

ORAUT-TKBS-0029-5 0

Pinellas Plant – Occupational Internal 

Dose 10/7/2005 Authorized for Review No

ORAUT-TKBS-0029-6 0

Pinellas Plant – Occupational External 

Dose 9/15/2005 Authorized for Review No

ORAUT-TKBS-0030 0

An Exposure Matrix for Bridgeport 

Brass: Havens Laboratory and Adrian 

Plant

9/15/2005 Out of Scope No

ORAUT-TKBS-0031 0 Site Profile for the Kansas City Plant 5/31/2005 Out of Scope No

ORAUT-TKBS-0032 00 PC-1 Site Profile for Simonds Saw and Steel 7/8/2005 Out of Scope No

ORAUT-TKBS-0033 0

Exposure Matrix for Chapman Valve 

Manufacturing, Indian Orchard, 

Massachusetts, Period of Operation: 

January 4, 1948 through April 30, 1949

2/22/2005 Out of Scope No

ORAUT-TKBS-0034 00 PC-1

An Exposure Matrix for Superior Steel, 

Carnegie, Pennsylvania, Period of 

Operation: January 1, 1952 through 

December 31, 1957

8/9/2005 Out of Scope No

ORAUT-TKBS-0035-1 00 PC-1

Lawrence Livermore National 

Laboratory – Introduction 9/12/2005 Authorized for Review No

ORAUT-TKBS-0035-2 00 PC-1

Lawrence Livermore National 

Laboratory – Site Description 10/26/2005 Authorized for Review No

ORAUT-TKBS-0035-3 00 PC-1

Lawrence Livermore National 

Laboratory – Occupational Medical 

Dose

10/26/2005 Authorized for 

Review Yes
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

33 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 1.2-1 Listing of Documents

Document Number Rev. 

Num. Document Title Effective Date

Review 

Status

DR 

Tool

ORAU TEAM TECHNICAL BASIS DOCUMENTS (Continued)

ORAUT-TKBS-0035-4 0

Lawrence Livermore National 

Laboratory – Occupational 

Environmental Dose

11/18/2005 Authorized for 

Review Yes

ORAUT-TKBS-0035-5 0

Lawrence Livermore National 

Laboratory – Occupational Internal 

Dose

10/7/2005 Authorized for 

Review Yes

ORAUT-TKBS-0035-6 0

Lawrence Livermore National 

Laboratory – Occupational External 

Dose

10/7/2005 Authorized for 

Review Yes

ORAUT-TKBS-0036-3 0

Argonne National Laboratories – East –

Occupational Medical Dose 11/18/2005 Out of Scope No

ORAU TEAM PLANS

ORAUT-PLAN-0001 2 Quality Assurance Program Plan 9/9/2005 Previously 

Reviewed No

ORAUT-PLAN-0002 01 PC-1 Internal Management Review Plan 6/21/2005 Previously 

Reviewed No

ORAUT-PLAN-0003 00 PC-1

Information Systems Quality Assurance 

Plan 11/18/2005 Previously Reviewed No

ORAUT-PLAN-0004 0

Records and Information Management 

Plan 1/6/2004 Previously Reviewed No

ORAUT-PLAN-0007 0 SQL Server Backup Plan 7/20/2004 Out of Scope No

ORAUT-PLAN-0008 0 SQL Server Recovery Plan 7/20/2004 Out of Scope No

ORAUT-PLAN-0009 0 Project Management Plan 8/25/2005 Out of Scope No

ORAUT-PLAN-0010 0 Worker Outreach Program 4/16/2004 Out of Scope No

ORAUT-PLAN-0011 0 Analysis Record File Management 7/20/2004 Out of Scope No

ORAUT-PLAN-0012 0 Computer Security 8/31/2004 Out of Scope No

ORAUT-PLAN-0014 0

Coworker Data Exposure Profile 

Development 11/24/2004 Out of Scope No

ORAUT-PLAN-0015 0

Claimant Communications Quality 

Control 4/20/2005 Out of Scope No

ORAUT-PLAN-0016 0 Staffing 12/17/2004 Out of Scope No

ORAUT-PLAN-0017 1 Baseline Milestone Schedule 6/17/2005 Out of Scope No

ORAUT-PLAN-0018 0 Baseline Budget 3/16/2005 Out of Scope No

ORAUT-PLAN-0019 1 Schedule for Site Profile Documents 6/22/2005 Out of Scope No

ORAUT-PLAN-0020 1

Strategic Dose Reconstruction 

Processing 7/29/2005 Out of Scope No

ORAUT-PLAN-0022 0

Disaster Recovery for the ORAU-COC 

Network 4/13/2005 Out of Scope No

ORAUT-PLAN-0023 0

Verification and Validation of Project 

Software 7/28/2005 Out of Scope No

ORAUT-PLAN-0025 0 Manual Database Replication 6/13/2005 Out of Scope No
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

34 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

1.2.1 OCAS Procedures

The following are the OCAS procedures authorized for review. Nore that some of the 

procedures were deleted from consideration and replaced with other procedures.

OCAS-COT-0007: OCAS Asessment Report: Efficiency of the Dose Reconstruction Process,

Rev. 00, 7/20/2004 (deleted and replaced)

This report presents the results of an assessmment of the performance of ORAU with respect to 

the efficiency of the dose reconstruction process. This document was deleted from the list of 

documents for review by SC&A because it is not within the intended scope of work for Task 

Order 3. The review of this report was replaced with a review of Guidance on Wound Modeling 

for Internal Dose Reconstruction, ORAUT-OTIB-021, Rev. 00, 11/18/2005, which is described 

below. 

OCAS-PR-004: Internal Procedures for the Evaluation of Special Exposure Cohort 

Petitions, Rev. 00, 9/23/2004 (deleted and replaced) 

This document sets forth NIOSH’s procedures for evaluating Special Exposure Cohort (SEC) 

petitions in accordance with the requirements of the EEOICPA and its implementation regulation 

as set forth in 42 CFR Part 83. This NIOSH procedure is not reviewed in this SC&A report 

because it was reviewed as part of SC&A Task 5. SC&A’s draft review of this NIOSH 

procedure was delivered to NIOSH and the Advisory Board on November 23, 2005. The draft 

report is entitled Review of NIOSH/ORAU Special Exposure Cohort Evaluation Procedures, 

Task 5, Subtask 1, SCA-TR-TASK5-0001, November 23, 2005. 

The review of OCAS-PR-004 was replaced with the review of ORAUT-PROC-0060, External 

OnSite Ambient Dose Reconstruction, Rev. 00, 3/7/05. This ORAU Team procedure provides 

direction to dose reconstructors on how to reconstruct external onsite ambient doses to workers.

OCAS-PR-005: Conduct of Assessments, Rev. 00, 12/3/2004

This procedure provides guidance to OCAS personnel involved in the assessments of the 

performance of contractor, contractor personnel, and self-assessments in all matters related to 

NIOSH’s scope of reponsibility under the EEOICPA. It is part of the quality assurance and 

quality control procedures employed by NIOSH. 

OCAS-PR-007: Dose Reconstruction Review, Rev. 01, 4/18/2005

This procedure provides guidance to OCAS personnel involved in the assessments of the 

performance of contractor, contractor personnel, and self-assessments in matters specifically 

related to dose reconstruction under 42 CFR Part 82. It is part of the quality assurance and 

quality control procedures employed by NIOSH.
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

35 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

OCAS-TIB-009: Estimation of Ingestion Intakes, Rev. 00, 4/13/2004

This TIB provides guidance to be used for estimating intakes of radioactive material through 

inadvertent ingestion of paticulate material that may be deposited directly onto food items and 

drinks or onto work-area surfaces and inadvertently ingested by hand-to-mouth behaviors. It 

does not adddress the ingestion of material that is deposited in the upper respiratory tract from 

inhalation and then ingested due to muco-ciliary clearance. That mode of “ingestion” is 

evaluated as part of the inhahation dosimetry protocols incorporated into IMBA.

OCAS-TIB-010: Special Dose Reconstruction Consideration for Glovebox Workers, Rev. 01, 

5/18/2005

This TIB provides guidance on performing minimum and maximum dose calculations for 

workers that may have experienced external exposres while working in the vicinity of a glovebox 

(or dry box, as it was referred to in the early years). Procedures for performing realistic dose 

estimates for this exposure scenario are (or will be) provided in a separate guideline.

OCAS-TIB-011: Lung Dose Conversion Factor for Thoron WLM, Rev. 01, 4/15/2005

This TIB provides the dose conversion factors for calculating lung dose from radon-220 decay 

products in working-level months (WLMs). The guide was prepared because, though 

considerable guidance has been developed for estimaing the doses to lungs from radon progeny, 

expressed in working levels (WL), less attention has been given to guidance on deriving 

exposures to thoron progeny, the concentrations of which are also often expressed in terms of 

WL. However, the lung dose rate per WL of radon progeny is different than the lung dose rate 

per WL of thoron progeny. This guide presents a method for converting thoron progeny 

exposure expressed in units of WL to lung dose rate. 

1.2.2 ORAU Team Technical Information Bulletins

ORAUT-OTIB-0004: Estimating the Maximum Plausible Dose to Workers at Atomic 

Weapons Employers Facilities, Rev 03, PC-1, 11/18/2005 (authorized for review at the 

January 26, 2006 Board meeting)

The stated purpose of this document “is to provide guidance for estimating the maximum 

plausible dose at Atomic Weapons Employers (AWEs). This document may also be used to 

estimate doses at Department of Energy facilities when exposures would be adequately estimated 

by the methods in this document... This document describes an efficiency process that may be 

used to expedite the processing of claims requiring dose reconstruction under the EEOICPA.”

ORAUT-OTIB-0011: Tritium Calculated and Missed Dose Estimates, Rev. 00, 6/29/2004

This OTIB provides a method for estimating the effective dose from tritium in the body from 

urine data, where a complete set of urine data may not be available and extrapolation methods 

are required to fill in the missing dose, taking into consideration the minimum detectable activity 

(MDA) of the uranalysis .
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ORAUT-OTIB-0012: Monte Carlo Methods for Dose Uncertainty Calculations, Rev. 00, 

2/14/2005

This OTIB presents an efficiency method applied to Monte Carlo methods, which yield bestestimate organ doses. Implementation of this method allows the generation of site-specific 

reference tables for use in best-estimate dose reconstructions without requiring individual Monte 

Carlo simulations.

ORAUT-OTIB-0014: Assessment of Environmental Internal Doses for Employees Not 

Exposed to Airborne Radionuclides, Rev. 00, 6/22/2004

This OTIB provides guidance on the methods for assigning environmental internal doses to 

workers who may have experienced such doses, and when such doses could have the potential to 

contribute significantly to internal doses relative to the doses that may have been experienced by 

the workers in the workplace. 

ORAUT-OTIB-0017: Interpretation of Dosimeter data for Assessment of Shallow Dose,

Rev. 01, 10/11/2005

This OTIB provides guidance for assigning shallow doses to the skin, testes, and breast from 

non-penetrating radiation, including beta exposures and exposures to low-energy photons.

ORAUT-OTIB-0018: Internal Overdose Estimates for Facilities with Air Sampling 

Programs, Rev. 01, 8/9/2005

This OTIB provides guidance for assigning upper-end doses using site-specific air-sampling 

data. It is designed to be used as an alternative, less conservative, method for deriving high-end 

internal doses than that provided in ORAUT-OTIB-0002.

ORAUT-OTIB-0019: Analysis of Coworker Dosimetry Data for Internal Dose Assignment,

Rev. 01, 10/7/2005

This OTIB provides guidance for assigning internal doses to workers using co-worker bioassay 

data for workers who do not have bioassay data, but the possibility exists that the worker may 

have experienced internal exposures. 

ORAUT-OTIB-0020: Use of Coworker Dosimetry Data for External Dose Assignment,

Rev. 01, 10/7/2005

This OTIB provides guidance for assigning external doses to workers using co-worker data for 

workers who have no or inadequate external dosimetry data for use in dose reconstruction and 

the possibility exists that the worker may have experienced external exposures. 

ORAUT-OTIB-0022: Guidance on Wound Modeling for Internal Dose Reconstruction,

Rev. 00, 11/18/2005 (not in original scope but was added as a replacement for a procedure that 

was deleted from the original list of procedures authorized for review)
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This OTIB provides guidance for assigning internal doses from plutonium and other 

radionuclides associated with contaminated wounds.

ORAUT-OTIB-0023: Assignment of Missed Neutron Doses Based on Dosimeter records,

Rev. 00, 3/7/2005

This OTIB provides guidance for assigning neutron doses to workers using the LOD/2 method 

for cases where the neutron dosimetry records are considered reliable.

ORAUT-OTIB-0024: Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in 

Uranium and Thorium Compounds, Rev. 00, 4/7/2005

This OTIB provides a quick method for assigning neutron doses at sites that processed uranium 

and thorium compounds, did not perform neutron monitoring, and the potential existed for alpha 

particle collisions with low atomic number materials at the site, thereby creating the potential for 

neutron exposures. 

ORAUT-OTIB-0025: Estimation of Ra-226 Activity in the Body from Breath Radon-222 

Measurements, Rev. 00, 4/5/2005

This OTIB provides guidance for assigning the Ra-226 body burden, and associated organ doses, 

of individuals based on radon breath analysis.

ORAUT-OTIB-0028: Validation of Thorium Annual Dose Conversion Factors, Rev. 01, 

3/7/2005

This OTIB verifies the annual dose conversion factors used for the assessment of Th-232 and 

Th-228 doses. This verification was needed because IMBA does not explicitly model the 

dosimetry of these radionuclides and the independent kinetics of their progeny chain. As a 

result, a separate set of dose conversion factors were developed for these radionuclides, which 

are verified in this document.

ORAUT-OTIB-0033: Application of Internal Doses Based on Claimant-Favorable 

Assumptions for Processing as Best Estimates, Rev. 00, 4/20/2005

This OTIB supplements ORAUT-OTIB-18, titled Internal Dose Overestimates for Facilities 

with Air sampling Programs, which is intended to be used to deliberately overestimate inhalation 

exposures for workers with no significant intakes. This OTIB provides guidance for performing 

more realistic dose reconstructions, taking into consideration time period of employment, 

process knowledge, job location and category, and any available bioassay data. 
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1.2.3 ORAU Team Procedures

ORAUT-PROC-0022: Additional Requests for DOE Information, Rev. 00, 3/15/2005

The purpose of this procedure is to outline the methods for requesting additional energy 

employee information from various DOE sites for the purpose of dose reconstruction for specific 

energy employees, and not in support of the preparation site profile reviews. 

ORAUT-PROC-0031: DOE Site Profile Development, Review, and Approval Process, Rev. 00 

PC-1, 3/15/2005

The purpose of this procedure is to document and describe the process used to develop site 

profiles.

ORAUT-PROC-0042: Accounting for Incomplete Personal Monitoring Data on Penetrating 

Gamma-Ray Doses to Workers in Radiation Areas at the Oak Ridge Y-12 Plant Prior to 1961, 

Rev 00, 9/9/2004 (Deleted since it is part of the Y-12 Site profile review process)

The purpose of this procedure is to provide dose reconstructors with guidance they can use to 

account for incomplete monitoring of penetrating gamma doses to workers in radiation areas at 

Oak Ridge Y-12 plant prior to 1961. Since this procedure was reviewed as part of the site profile 

and SEC petition review process, it was deleted from review under this task and replaced with 

another procedure.

ORAUT-PROC-0060: External On-Site Ambient Dose Reconstruction, Rev. 00, 3/7/2005

(Not in the original set of procedures authorized for review, but is included as a replacement for 

one of the previously authorized procedures that were deleted)

The purpose of this procedure is to provide guidance to dose reconstructors regarding the 

assignment of external doses from onsite ambient radiation. This guide supercedes ORAUTPROC-0006.

ORAUT-PROC-0061: Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 00, 

12/1/2004

The purpose of this procedure is to provide guidance to dose reconstructors regarding the 

assignment of organ dose from medical x-ray exams that were required as a condition of 

employment. This guide supercedes the guidance on this subject provided in ORAUT-PROC0006.

ORAUT-PROC-0065: Internal Finding and Corrective Action to Prevent Recurrence, 

Rev. 00 PC-1, 11/3/2005

The purpose of this procedure is to provide guidance for initiating and documenting internal 

findings, determining the root cause, developing corrective actions to rectify existing conditions 

and to prevent recurrence, monitoring and implementing corrective actions to completions, and 
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verifying complete corrective actions. This procedure addresses findings and observations 

identified during ORAU quality assurance audits, and not those of NIOSH or other organizations 

external to ORAU.

ORAUT-PROC-0066: Quality Assurance Records Management, Rev. 00, 9/3/2004

The purpose of this procedure is to describe the activities and responsibilities necessary for the 

identification, control, storage, retrieval, and disposition of ORAU quality assurance audits.

ORAUT-PROC-0067: Conduct of Quality Assurance Surveillances, Rev. 00, 9/14/2004

The purpose of this procedure is to describe the process and responsibilities for administering 

and conducting surveillances of the ORAU dose reconstruction project, as performed by ORAU.

ORAUT-PROC-0069: External Nonconformance and Corrective Action to Prevent 

Recurrence, Rev. 00, 9/9/2004

This procedure establishes the process for responding to nonconformances issued by external 

auditors, and instructions for identifying the root cause, developing corrective actions, and 

preventing recurrences.

ORAUT-PROC-0077: Dose Reconstruction Error Tracking and Reporting, Rev. 00, 

3/28/2005

This procedure provides the process for review, disposition, correction, tracking, and trending of 

dose reconstruction errors and comments received by ORAU.

ORAUT-PROC-0080: Conduct of Quality Assurance Audits, Rev. 00, 9/9/2004

The purpose of this procedure is to establish the process and responsibilities for the 

administration and performance of formal independent quality assurance audits and assessments 

of activities performed by ORAU dose reconstructors.

ORAUT-PROC-0090: Computer Assisted Telephone Interview Process, Rev. 00, 6/21/2005

This purpose of this procedure is to provide the process for the scheduling, performance, and 

review of computer-assisted telephone interviews (CATIs). 

ORAUT-PROC-0091: Dose Reconstruction Submittal, Rev. 00, 6/29/2005

This procedure establishes the process for the receipt, modification, and submittal of draft dose 

reconstruction reports.
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ORAUT-PROC-0092: Close-Out Interview Process, Rev. 00, 8/17/2007

The purpose of this procedure is to provide the process for the scheduling, performance, and 

follow-up of a closeout interview. (Not in the original set of procedures authorized for review, 

but is included as a replacement for one of the previously authorized procedures that were 

deleted.)

1.3 SC&A’S APPROACH FOR TASK 3

The approach used to perform the reviews contained in this report follows the SC&A procedures 

provided in A Protocol for the Review of Procedures and Methods Employed by NIOSH for Dose 

Reconstruction (SCA-PR-Task3, Rev 1, Final, April 29, 2004). In the original Statement of 

Work specified by NIOSH for Task 3, key technical elements to be addressed in the review 

included the following:

(a) Review the internal and external radiation dose reconstruction technical basis documents 

(including procedures for performing internal dose reconstructions and external dose 

reconstructions)

(b) Review of methods for estimating “missed dose” and “unmonitored dose” (for cases 

related to monitoring technology and for cases where monitoring was not performed, 

monitoring data are not available or incomplete, or otherwise inadequate)

(c) Review of the statistical approaches developed for multiple dose reconstructions

(d) Review procedures used for determining whether data are sufficient to make a reasonable 

dose estimate

(e) Review methods or procedures used for substituting exposure information for unavailable 

or incomplete information

(f) Review methods for estimating uncertainty in dose and uncertainty distributions 

surrounding internal and external dose reconstructions on a facility- and time-specific

basis, and evaluate whether the benefit of the doubt was resolved in favor of the claimant 

where there were uncertainties

(g) Review procedures and questionnaires used for work history telephone interviews 

(includes review of CATI scheduling, performance, and review procedures)

(h) Review quality assurance plan and related procedures

(i) Review procedures related to document acquisition (records request, management, 

assembly, and handling)

(j) *Review procedures related to completing a Site Profile (Site and Exposure Profiles), 

Worker Profiles, and Special Exposure Cohort petition review, and procedures on how 

Worker Profile and Site Profile data will be used for individual case dose reconstructions

 

* Note: This element was excluded from the review process for this task order because it is being 

addressed under Task Order 1 and Task Order 5.
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(k) Review the NIOSH methods, procedures, and performance in evaluating, analyzing, and 

validating all contractor work products

In addition to technical elements, SC&A also recognized that the review of methods and 

procedures must also address non-technical issues that reflect the philosophy, intent, and/or 

statutory directives cited in EEOICPA and the Final Rule for 42 CFR Part 82.

The Act (as stated in the Final Rule) requires that “... HHS establish by regulation, methods for 

arriving at reasonable estimates of the radiation doses incurred by covered employees in 

connection with claims seeking compensation for cancer...” [Emphasis added].

Other directives issued to the U.S. Department of Health and Human Services (HHS) mandated, 

by regulation, the establishment of methods that are (1) efficient, (2) consistently applied, 

(3) reasonable dose estimates, (4) complete, and (5) well grounded in the best available 

science.

As acknowledged in the Act, the level of effort involved in dose reconstructions depends largely 

on the quantity and quality of available dose monitoring data, and the extent to which these data 

are, in fact, complete. The EEOICPA further recognized the complexity of traditional

approaches for dose reconstruction, which frequently require extensive research and analysis, 

and in instances of “...health research studies dose reconstruction may take from months to years 

to complete.”

Owing to the large number of claims requiring dose reconstruction, EEOICPA, 42 U.S.C. § 

7384d(b) states, “PURPOSE OF PROGRAM—The purpose of the compensation program is to 

provide for timely, uniform, and adequate compensation of covered employees . . .” [Emphasis 

added], and Section E of the Preamble of 42 CFR Part 82 states that, “...An additional critical

factor affecting how doses are reconstructed is the amount of time available... In compensation 

programs, however, a balance must be struck between efficiency and precision.” [Emphasis 

added.]

According to these directives, SC&A’s evaluation of procedures cannot limit itself to a process 

that simply determines whether applicable procedures are technically correct and make use of the 

most current ICRP biokinetic models, dose conversion factors, cancer risk coefficients, computer 

codes, etc., but must equally address the more difficult and subjective question of whether a 

proper balance has been struck between efficiency and precision.

SC&A’s review of the technical and scientific methods prescribed in applicable procedures must, 

therefore, also assess non-technical issues and the impacts of scientific detail that are required 

procedurally, and weigh the incremental precision gained against the reduced efficiency and 

higher costs for reconstruction and added delay in the adjudication of claims.

In brief, SC&A identified the following objectives in its protocol to the Advisory Board, which 

form the basis for conducting the review:
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Objective 1: Determine the degree to which procedures support a process that is expeditious 

and timely for dose reconstruction.

Objective 2: Determine whether procedures provide adequate guidance to be efficient in select 

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

the outcome.

Objective 3: Assess the extent to which procedures account for all potential exposures, and 

ensure that resultant doses are complete and based on adequate data.

Objective 4: Assess procedures for providing a consistent approach to dose reconstruction 

regardless of claimants’ exposures by time and employment locations.

Objective 5: Evaluate procedures with regard to fairness and the extent to which the claimant 

is given the benefit of doubt when there are unknowns and uncertainties 

concerning radiation exposures.

Objective 6: Evaluate procedures for their approach to quantifying the uncertainty distribution 

of annual dose estimates that is consistent with and supports a U.S. Department of 

Labor POC estimate at the upper 99% confidence level.

Objective 7: Assess the scientific and technical quality of methods and guidance contained in 

procedures to ensure that they reflect the proper balance between current/ 

consensus scientific methods and dose reconstruction efficiency.

1.4 STRUCTURE AND ORGANIZATION OF THE REPORT

Structure: For each of the above-cited seven general objectives, the review protocol was 

structured on a series of relevant questions contained in a checklist, which the SC&A reviewer 

used for rating a given procedure. A rating system of 1 through 5 corresponded to the following 

answers: 1=No (or Never), 2=Infrequently, 3=Sometimes, 4=Frequently, 5=Yes (or Always). 

For example, Objective 1 focused on timeliness. The need for NIOSH to perform large numbers 

of dose reconstructions in a timely manner places specific demands on procedures and the dose 

reconstruction process as a whole. SC&A’s evaluation of procedures for their support of a 

timely reconstruction process was, therefore, based on rating the answers to the following 

questions:

 Is the procedure written in a style that is concise and unambiguous?

 Is the procedure written in a manner that presents the data in a logical sequence?

 Is the procedure complete in terms of required data (i.e., does not reference other sources 

that are needed for additional data)?

 Is the procedure consistent with and doesn’t avoid duplication of other procedures that 

are part of the hierarchy of procedures employed by NIOSH for dose reconstruction?

 Is the procedure sufficiently prescriptive to minimize the need for subjective decisions 

and data interpretation?

Answers that resulted in a rating other than a 5 (or a perfect score) in the checklist were 

supported with specific review Comments. Table 1.4.1 below identifies the Procedure Review 
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Outline/Checklist that is used in this report to assess the degree to which a given procedure meets 

the seven objectives, as applicable to the procedure. This table is slightly different than the table 

used in our original Task 3 report (dated January 17, 2005), in that it includes item 7.3, which 

explicitly addresses the scientific validity of the methodology employed in the procedure to 

perform or support dose reconstruction.

Organization. The individual procedures/documents for review are grouped by topic in the 

following sections:

 Section 2.0, External Dosimetry Procedures/Documents

 Section 3.0, Internal Dosimetry Procedures/Documents

 Section 4.0, Quality Assurance Procedures/Documents

For a specific section, procedures/documents are sequenced as given in the table of contents for 

this report.
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Table 1.4-1. Procedure Review Outline/Checklist

Document No.: Effective Date:

Document Title:

Reviewer:

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?

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence?

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation?

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?

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?

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?

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? 

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias?

3.1.4 Is the interview process sensitive to the claimant?

3.1.5 Does the interview process protect information as required 

under the Privacy Act?

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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)

3.2.2 In vivo/In vitro bioassays

3.2.3 Missing dosimetry data

3.2.4 Unmonitored periods of exposure

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?

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2?

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?

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates?

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored?

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)?

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution?

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?

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses?

__________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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2.0 EXTERNAL DOSIMETRY PROCEDURES/DOCUMENTS

The review of OCAS-TIB-0010, Rev. 1, dated May 18, 2005, was prepared by Robert Anigstein, 

PhD, and approved by John Mauro, PhD, CHP, on March 31, 2006. Several modifications to the 

checklist were made in July 2007 by Robert Anigstein.

2.1 OCAS-TIB-0010: BEST ESTIMATE EXTERNAL DOSE RECONSTRUCTION 

FOR GLOVEBOX WORKERS

2.1.1 Purpose of Procedure

The stated purpose of this procedure “...is to provide guidance on dose reconstructions for 

glovebox workers. This TIB discusses the special exposure characteristics that may be 

encountered by energy employees who work with gloveboxes and provides special dose 

correction factors or modifiers that should be applied to affected energy employee's dose.” 

2.1.2 Review Protocol

Our evaluation of OCAS-TIB-0010: Best Estimate External Dose Reconstruction for Glovebox 

Workers, is summarized in Table 2.1-1 below. This table presents a checklist containing 

objectives that SC&A developed under the first phase of Task 3 to evaluate whether a procedure 

adequately supports the dose reconstruction process, as described in the introduction to this 

report.
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Table 2.1-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0010 Effective Date: 04/20/2005

Document Title: Best Estimate External Dose Reconstruction for Glovebox Workers

Auditor: Robert Anigstein, PhD

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? 3

See review 

Comments

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4

“Lower torso” organs 

are not specified

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) 5

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? N/A

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 2

Correction factors do 

not represent worstcase assumptions

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 3

Analysis is needlessly 

complex

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 2

See Review 

Comments

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

2.1.3 General Comments

This document presents the results of an analysis designed to determine the degree to which the 

external dose to organs in the lower torso could be underestimated “if the energy employee wore 

his/her dosimeter on the lapel and not the center area of the chest or on the waist.” The analysis 
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calculates the particle2flux rates from a radioactive source inside a glovebox at 30 locations on 

the surface of an anthropomorphic phantom, using the ATTILA computer code, which solves the 

3D multi-group transport equations for neutrons, charged particles, and infrared radiation on an 

unstructured tetrahedral mesh. Ratios of flux rates at randomly selected locations on the lower 

torso to those at randomly selected locations on the upper torso were calculated using Crystal 

Ball, a Monte Carlo sampling program. The resulting distribution appears to be lognormal, with 

a geometric mean of 2.3 and a geometric standard deviation (GSD) of 1.13.

We performed our own analysis to verify these results, using the MCNP5 computer code (LANL 

2004) to calculate Hp(10) dose rates at two hypothetical locations; one corresponding to a 

dosimeter worn on the waist along a horizontal line centered on the radiation source, and another 

corresponding to a dosimeter worn just outside the clavicle, approximately the level of the lapel. 

We utilized a detailed MCNP model constructed by Crawford (2006). Crawford (2004) 

describes gloveboxes used at the Los Alamos National Laboratory (LANL) for handling 

plutonium, as well as at other facilities. The LANL gloveboxes, in use since the 1970s and 

believed to be based on still earlier designs, were the basis of Crawford's model. The radiation 

source, which is the same as was used in the NIOSH analysis (Macievic 2006), has the same 

composition as the generic objects containing weapons-grade plutonium described by Traub et 

al. (2005). We utilized the photon spectrum presented by Traub et al., but calculated the neutron 

spectrum independently, using the SOURCES-4C computer code (LANL 2002), a code system 

that determines neutron production rates and spectra from (α,n) reactions, spontaneous fission, 

and delayed neutron emission due to radionuclide decay. Our calculated neutron yield matched 

that of Traub et al.

The results of our analysis showed that the total Hp(10) dose rate at the dosimeter location on the 

waist was about 2.1 times the dose rate for the lapel location. This is consistent with the results 

of the NIOSH analysis.

2.1.4 Review Comments

Review Objective 1.1

The first issue is the lack of transparency of the OTIB analysis. Figure 7 of the OTIB shows a 

diagram of the side view of the exposure geometry. Neither the exact dimensions, the exact 

location of the source, nor the thickness of the walls are presented.3 More importantly, the 

radioactive source4is not identified. This lack of detailed information required extensive private 

communications with the author of the OTIB to enable us to understand and confirm the 

analysis.

 

2

 Erroneously referred to as “photon flux” in the TIB. See discussion in Section 2.1.4.

3

 Curiously, the anthropomorphic phantom depicted in the diagram seems to be suspended in air.

4

 The TIB variously referred to a “radiological source” or a “radiation source”—“radiation source” is the 

term listed in the NRC's “Glossary of Nuclear Terms” (NRC n/d), while the term “radioactive source” is widely 

used in health physics.
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Review Objective 7.3

Although we concur with the correction factor for a dosimeter worn on the lapel, we nevertheless 

find a number of issues with this OTIB.

The first issue is the design of the analysis. NIOSH/OCAS has procedures for translating 

personal dosimeter readings into organ doses. We therefore question the design of the analysis 

that compares the particle flux over locations on the upper and lower torso, rather than modeling 

the variation of dosimeter response with location. If the purpose of the analysis is to develop a 

correction factor for dosimeters worn on the lapel when the source is at the level of the waist, 

those are the locations that should be analyzed. Furthermore, since a dosimeter—by definition—

registers dose, not particle flux, that is the quantity that should have been analyzed. As stated 

earlier, our analysis of the comparison of dose rates happens to produce results that fall into the 

range of the OTIB analysis. That does not, however, validate the methodology used in the 

OTIB.

A second issue is the design of the glovebox. The OTIB presents a general description of 

gloveboxes, including illustrations of gloveboxes at various plutonium processing facilities. The 

actual analysis, however, utilized the engineering design drawings of a glovebox from Innovative 

Technology (n/d) (Crawford 2006). That glovebox was designed for inert atmosphere 

applications, such as the manufacture of light bulbs. More important, the OTIB glovebox has 

walls of steel and Lexan that are over 4 cm thick (Crawford 2006). Such a thickness, based on 

an apparent misinterpretation of the Innovative Technology engineering drawings, is unrealistic. 

By contrast, the LANL glovebox has walls that are about 4.8 mm thick. The choice of Lexan for 

the OTIB model is questionable (Innovative Technology does not specify the material of the 

viewing window). Lexan is a relatively new plastic—large-scale production of Lexan sheets did 

not start until 1972 (GE 2004). Curiously, the OTIB states that the view window is made of 

Lucite, the DuPont trade name for poly(methyl methacrylate), which has a different composition 

than Lexan, the General Electric trade name for its polycarbonate resin. The LANL glovebox 

has glass view windows. Although the OTIB glovebox design does not significantly alter the 

relative particle flux over the torso of the anthropomorphic phantom, it calls into question the 

credibility of the analysis.

A third issue is the use of an anatomical illustration of a human torso as a basis for the 

anthropomorphic phantom used in the OTIB analysis. ORNL has developed a series of 

anthropomorphic phantoms (e.g., Eckerman et al. 1996) based on the ICRP Reference Man 

(ICRP 1975). These phantoms form the basis of most external dose simulations and would be 

more appropriate for the OTIB analysis.

A fourth issue is the use of the Attila software. Attila is a discrete ordinate code, which solves 

radiation transport problems deterministically. Discrete ordinate codes treat the spatial domain, 

the energies, and the angles as discrete variables. The accuracy of such codes need not be 

limited by spatial resolution, since the mesh in principle could be made as fine as desired, 

depending on limitations on computer memory. However, the energy discretization is an issue 

for neutron transport, as neutron cross-sections often feature resonance structure that is typically 

approximated by a single group in a multi-group cross-section approximation. Scattering-angle 
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discretization is also an issue. This can lead to non-physical results, called "ray effects," along 

the boundaries between angle bins. In contrast, MCNP5 samples from continuous energy crosssection tables, preserving the full accuracy of the original evaluations.

A discrete ordinate code can offer some advantages in execution time for complex geometries; 

furthermore, Attila offers an advantage in efficiency of the user's time by allowing direct import 

of the output of a computer-aided design (CAD) program. In the present case, however, the 

glovebox geometry used in the OTIB analysis is extremely simple; a rectangular box with one 

sloping face, uniform thickness, and only two materials, as well as an anthropomorphic phantom 

made up of water. Our MCNP calculations required two runs (one for photons and another one 

for neutrons) of 90 minutes each on a desktop computer with a 1.7 GHz Pentium IV processor 

running under Windows XP. The statistical uncertainties in these results indicate that a precision 

of ±0.1% could have been achieved by running for less than 10 minutes. Although we did have 

the advantage of a detailed MCNP model of the glovebox that had already been constructed at 

LANL, we could have replicated the simple model used in the OTIB analysis in a relatively brief 

time.

Another objection to the use of Attila in the OTIB analysis is related to the issue of transparency. 

The Attila code is not well know and not widely available. A prospective user has to acquire a 

license from Transpire, Inc., and the license must be renewed annually at a substantial fee. By 

contrast, MCNP is well known and widely used. It is readily available from the Radiation Safety 

Information Computational Center (RSICC) at Oak Ridge National Laboratory.

Finally, the OTIB refers to the calculation of photon flux, whereas the analysis actually 

calculated the particle flux (photons plus neutrons).

In an appendix to the OTIB, NIOSH reports an attempt to validate the use the calculational 

model used in the OTIB, based on the Attila code, by comparing the model predictions to the 

ratios of wrist-to-whole body exposures of Rocky Flats workers. These data were apparently the 

deep-dose components of doses recorded by dosimeters worn on the wrist, as well as by 

dosimeters worn elsewhere on the body. The ratios of wrist-to-whole body doses, as calculated 

from the dosimetry data on both glovebox and nonglovebox workers, were compared to the 

ratios of the fluxes over the wrist area and the upper torso, presumably using the same phantom 

and glovebox geometry. 

The distributions of wrist-to-whole body ratio dosimetry data had geometric means ranging from 

2.24 to 3.08, depending on which data set was being analyzed. The corresponding GSDs ranged 

from 2.14 to 2.68. The Attila model yielded ratios with a geometric mean of 2.64 and a GDS of 

3.13.

Although the geometric mean of the ratios calculated by the Attila model falls within the range 

of the distributions of the ratios of the dosimetry data, the Attila GSD is significantly higher than 

those calculated from the dosimetry data. 

The Rocky Flats data is based on glovebox and nonglovebox workers. Therefore, it is 

questionable how well these data represent the situation that is modeled by Attila. Furthermore, 
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the Attila model is used to calculate the ratio of particle flux (neutron plus photon) to the upper 

torso, while the dosimetry data represents dose to the whole body. Absent specific knowledge of 

where the whole-body dosimeters were worn (the whole point of the OTIB), the comparison of 

the model to the measured data is questionable. 

Further issues regarding the use of the Rocky Flats dosimetry data concern lack of information 

about the radiation sources; the Attila model utilizes the neutron and photon spectra from a 

plutonium weapon, while the Rocky Flats workers were exposed to both uranium and plutonium 

in various configurations and stages of purification.

Finally, the appendix suffers from the same lack of transparency as does the main body of the 

OTIB. One issue is the lack of detail regarding the Rocky Flats dosimetry data. Much more data 

should be presented than just the geometric means and the GSDs of six classes of workers. The 

reader cannot deduce how the dosimetry data were selected, what criteria were used for 

including or excluding individual readings (e.g., did the < 30 mrem and <100 mrem exclusions 

apply to the wrist or the whole-body dose, or to both?), and how the neutron dose corrections 

were applied to individual workers. If the purpose is to validate the model using real-world data, 

what is the reason for selecting the maximum value of the annual, quarter, and cycle data? 

It is implied, although not clearly stated, that the same model geometry used in the main body of 

the OTIB was utilized in the analysis described in the appendix.

In conclusion, the OTIB accomplishes its stated purpose in that it provides guidance for 

reconstructing doses from external exposures of glovebox workers. The correction factors to 

dosimeter readings are consistent with the results of our own analyses. However, the 

methodology of the analysis presented in the OTIB is not transparent. Furthermore, the methods, 

assumptions, and parameters used in the analysis should be revised to more appropriately address 

the problem at hand.

The use of the Rocky Flats dosimetry data, which do not necessarily represent the exposure 

conditions embodied in the Attila model, calls the model validation into question. Absent better 

correspondence between the Rocky Flats exposures and the model, the partial agreement 

between the model predictions and the dosimetry data can only be termed fortuitous.

References

Crawford, A.B. 2004. “Evaluation of the Impact of Non-Uniform Neutron Radiation Fields on 

the Dose Received by Glove Box Radiation Workers.” Unpublished doctoral dissertation, 

University of Texas at Austin.

Crawford, A.B. 2006. Crawford, HSR-12 Radiological Engineering Team, Los Alamos 

National Laboratory, private communication with Richard H. Olsher, SC&A, Inc., March 2006.

Eckerman, K. F. M. Cristy, and J. C. Ryman. 1996. “The ORNL Mathematical Phantom 

Series.” <http://homer.hsr.ornl.gov/VLab/mird2.pdf> (October 21, 2005).
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General Electric Company (GE). 2004. “Happy Birthday: LEXAN® Resin Turns 50!” 

<http://www.google.com/search?q=cache:YWLh3SWC0wUJ:www.geplastics.com/gelexan/turn

s_50.html+Lexan+history&hl=en&gl=us&ct=clnk&cd=2> (March 29, 2006)

International Commission on Radiological Protection (ICRP). 1975. “Reference Man:

Anatomical, Physiological and Metabolic Characteristics,” ICRP Publication 23. Oxford: 

Pergamon Press.

Innovative Technology (n/d). “Glove Box Systems.” <http://www.gloveboxes.com/glove-boxsystems.htm> (March 29, 2006)

Los Alamos National Laboratory (LANL) and Texas A&M University. 2002. SOURCES-4C: 

Code System For Calculating alpha,n; Spontaneous Fission; and Delayed Neutron Sources and 

Spectra, RSICC Code Package CCC- 661. Oak Ridge, Tennessee: Oak Ridge National 

Laboratory.

Los Alamos National Laboratory (LANL). 2004. MCNP5: Monte Carlo N-Particle Transport 

Code System, Version 1.30, RSICC Code Package CCC-710 [Computer software and manual]. 

Oak Ridge, Tennessee: Oak Ridge National Laboratory.

Macievic, Gregory V., Health Physicist, Office of Compensation Analysis and Support, National 

Institute for Occupational Safety and Health, private communication with Robert Anigstein, 

SC&A, Inc., March 2006.

National Institute of Occupational Safety and Health–Office of Compensation Analysis and 

Support (OCAS). 2005. “Best Estimate External Dose Reconstruction for Glovebox Workers,” 

OCAS-TIB-0010, Revision No. 2.

Nuclear Regulatory Commission (U.S.) (NRC). (n/d). “Glossary of Nuclear Terms.” 

<http://www.nrc.gov/reading-rm/basic-ref/glossary/full-text.html> (June 8, 2003).

Traub, R. J., R. J. Scherpelz, and T. D. Taulbee. 2005. “Personal Dose Equivalent Rates from 

Three Plutonium Objects,” PNWD-3544, Rev. 0.

Transpire, Inc. 2005. Attila Radiation Transport Software. Gig Harbor, WA: Author.

2.2 ORAUT-PROC-0061: OCCUPATIONAL X-RAY DOSE RECONSTRUCTION 

FOR DOE SITES

The review of ORAUT-PROC-0061, Occupational X-ray Dose Reconstruction for DOE Sites, 

Rev. 00, dated December 1, 2004, was prepared by Harry Pettingill, PhD, and approved by John 

Mauro, PhD, CHP, on March 22, 2006.
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2.2.1 Purpose of Procedure

The stated purpose of this procedure is to provide guidance “...for the assignment of organ dose 

from medical X-ray exams that were required as a condition of employment. This procedure 

relies upon information contained in the Technical Basis Documents (TBDs), and it supercedes 

the instructions pertaining to X-ray dose reconstruction in ORAUT-PTOC-0006 Rev. 00.”

2.2.2 Review Protocol

SC&A’s evaluation of ORAUT-PROC-0061 is summarized in Table 2.2-1 below. Table 2.2-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 2.2-1. Procedure Review Outline/Checklist

Document No.: ORAUT-PROC-0061 Effective Date: 12/01/2004

Document Title: Occupational Dose reconstruction for DOE Sites, Rev. 00

Auditor: Harry Pettengill

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 5

It references other 

related NIOSH and 

ORAUT documents, 

but this is not a 

problem.

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

4

See review 

Comments

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is

 it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 4

See Review 

Comments

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 4

See Review 

Comments

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 4

See Review 

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

2.2.3 General Comments

The procedure is intended to guide dose reconstructors on a methodology for estimating the 

occupational medical dose to claimants. Notably, the procedure is based upon 17 separate 

references of which the first 12 are references to the 12 separate site profile medical TBDs 

completed as of the date of this procedure. The most recent TBD is for the Portsmouth site, 

dated July 19, 2004. A number of site TBDs have been completed or revised after this date, but 

the procedure has not been updated, accordingly. We suggest that NIOSH implement a system 

that updates all references in any procedure where it is cited. 
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The procedure correctly advises the dose constructor to use the latest TBD revision; however, 

failure to do this automatically could lead to confusion and unnecessary rework of dose 

constructions. Of the five remaining references, it appears that only two are pertinent to the 

procedure; NIOSH (2002) External Dose Reconstruction Implementation Guideline and the 

Technical Information Bulletin: Dose Reconstruction from Occupationally Related Diagnostic 

X-ray Procedures. Unfortunately, both are dated and require that a new revision be cited. This 

is of importance, because information in both documents can appreciably affect claimant dose. 

This is particularly true of ORAUT-OTIB-0006, which is currently in Revision 3, while 

Revision 2 is being cited. The remaining three references add little value, with the possible 

exception of the Handbook of Health Physics and Radiological Health. Notably missing in the 

reference list are both ICRP Publication 34 and NCRP Report 102, upon which most of the 

TBDs rely quite heavily.

The most important comment relates to the very first sentence in this section. It states that, 

“...doses from occupational x-ray procedures provided to employees that are required as a 

condition of employment must be included.” It further states that doses must rely on information 

provided in site TBDs and the TIBs. However, it appears that dose reconstructors and subject 

matter experts who write the TBDs are being unduly restrictive as to what constitutes, “required 

as a condition of employment.” More times than not, the only exams considered are a preemployment x-ray and any annual chest x-rays taken as part of the physical. Therefore, exams 

from injury or incidents, special monitoring and surveys, etc., are mostly not included in the dose 

estimate to the disadvantage of the claimant. We have pointed out this important gap to NIOSH 

on prior site TBD reviews and shown that it is not consistent with guidelines in the subject 

OTIB.

The section also provides guidance to dose constructors regarding how to estimate medical dose, 

based upon a presumed probability of causation. Instructions are provided regarding when to use 

the Maximizing, Best Estimate, or Minimizing approach. In the case of using the Maximizing 

approach, the dose constructor is told to use all x-rays in the record, and/or prescribed in the 

TBD. However, the TBD often declares that only chest x-rays are of importance; thus, it is not 

necessarily a maximum approach.

In the case of the Best Estimate approach, the guide instructs the dose reconstructor to use only, 

“potentially-required x-rays,” which means that the dose constructor may use only chest or 

lumbar spine x-rays to assess dose. The guide is silent on the use of the TBD.

In the case of the Minimizing approach, the dose reconstructor is directed t assume that the only 

x-ray exposures experienced by the worker are those that are explicitly required for employment. 

The dose reconstructor may not use assumptions from TBDs, and must rely on claimant records 

only. This strategy is appropriate for a minimizing approach. 

In the case of assessing the presumed probability of causation for skin cancer, the protocol states 

that backscatter included in ESE measurements would overestimate the dose and is therefore 

appropriate for a maximizing approach, but is not appropriate for best estimate and minimizing 

approaches. It suggests using an alternative organ dose that is proximal to the site of the skin 

cancer for a best estimate or minimizing approach. This strategy is considered reasonable.
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2.2.4 Review Comments

Review Objectives 2.1, 5.1, 5.2, and 5.3

The procedure allow for consideration of exposures in excess of those delineated in the 

procedure if the case records indicate that the worker received additional x-ray examinations or if 

the TBD indicates that additional examinations were performed at the site. Also, the procedure 

recommends multiplying the TBD derived doses by 1.3 to account for uncertainty. However, the 

dose reconstructor is not advised to make corrections for retakes or additional exposures due to 

poor technique or processing. Most TBDs viewed to date do not account for this important 

component of estimating dose. It would seem that using this procedure for “maximizing” does 

may not be claimant favorable.

2.3 ORAUT-OTIB-0020: USE OF COWORKER DOSIMETRY DATA FOR 

EXTERNAL DOSE ASSIGNMENT

The review of ORAUT-OTIB-0020, Revision 01, dated October 7, 2005, was prepared by U. 

Hans Behling, PhD, MPH, and approved by John Mauro, PhD, CHP on March 31, 2006.

2.3.1 Purpose of Procedure

The purpose of this OTIB is to provide general information to the dose reconstructor for 

assigning external doses to workers at DOE sites with little or no personal monitoring data. 

Dose reconstruction in behalf of such individuals is to be based on site co-worker external 

dosimetry data. Thus, guidance provided in this OTIB is to be used in conjunction with other 

TIBs or approved documents that provide site-specific external co-worker data.

2.3.2 Review Protocol

The evaluation of ORAUT-OTIB-0020 is summarized in Table 2.3-1 below. Table 2.3-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as directed by the 

EEOICPA and defined under Title 42, Part 82, Methods for Radiation Dose Reconstruction 

Under the Energy Employees Occupational Illness Compensation Program Act of 2000 of the 

Code of Federal Regulations (42 CFR Part 82).
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Table 2.3-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0020, Rev 01 Effective Date: 10/07/2005

Document Title: Use of Coworker Dosimetry Data for External Dose Assignment

Reviewer: U. Hans Behling

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? 3

See Review 

Comments

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3

See Review 

Comments

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

N/A

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

3

See Review 

Comments

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 2

See Review 

Comments

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?

3

See Review 

Comments

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?3

See Review 

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data 3See Review 

Comments

3.2.4 Unmonitored periods of exposure 3See Review 

Comments

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? 1

See Review 

Comments

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? N/A

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? 3

See Review 

Comments

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3

See Review 

Comments

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 3

See Review 

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)?

3

See Review 

Comments

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 3

See Review 

Comments

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? N/A

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 3

See Review 

Comments

__________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

2.3.3 General Comments

In order to facilitate the evaluation of this procedure, select portions of ORAUT-OTIB-0020 are 

reproduced here verbatim. Statements contained therein will be critically evaluated in context 

with SC&A’s Review Objectives.
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The following statements/guidance are the focus of this review. Line numbers are assigned to 

the quoted material because the commentary that follows refers back to specific line numbers in 

the quotes. 

 From Section 2.0 Background 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

. . . For the purpose of this document, coworkers are considered to be workers at a 

site (potentially grouped by work location, job description, or other appropriate 

category) whose measured doses are considered representative of those received 

by one or more claimants with no individual monitoring data. 

Cases without individual external monitoring data may fall into one of several 

categories, including:

 the worker was unmonitored and, even by today’s standards, did not need to

be monitored (e.g., a non-radiological worker).

 the worker was unmonitored, but by today’s standards would have been

monitored.

 the worker may have been monitored but the data are not available to the dose

reconstructor.

 the worker may have partial information, but the available information is

insufficient to facilitate a dose reconstruction.

Some cases with little or no individual monitoring data can be processed in the 

absence of completed coworker studies, most notably those falling under the first 

category listed above. For example, nonradiological workers with no potential for 

workplace radiation exposures may be assigned on-site ambient doses. Even some 

cases falling under the second and third categories above do not require coworker 

studies, e.g., radiological workers who may in some cases be assigned reasonable 

upper limits provided that the total probability of causation (POC) is less than 

45%. Regarding the last category above, if sufficient information is available, a 

prorated dose could be assigned in certain circumstances.

 From Section 3.0 General Approach 

1

2

3

4

5

6

7

The general approach to applying coworker data for cases with little or no 

individual external monitoring data is to assign either 50th or 95th percentile doses 

with the intent that the doses assigned represent, but do not underestimate, the 

doses that would be assigned had the employee been monitored. As described in 

Section 6.0, the percentile doses include consideration of missed dose. This is 

necessary because the coworker data are intended to represent the results for 

unmonitored workers had they been monitored, and missed doses are assigned to 
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8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

null monitoring results for monitored workers.

Site-specific coworker data sets containing 50th and 95th percentile penetrating 

and non-penetrating doses are provided in separate, site-specific TIBs. In 

general, the 50th percentile dose may be used as a best estimate of a worker’s dose 

when professional judgment indicates the worker was likely exposed to 

intermittent low levels of external radiation. The 50th percentile dose should not 

be used for workers who were routinely exposed. For routinely exposed workers 

(i.e., workers who were expected to have been monitored), the 95th percentile dose 

should be applied. For workers who are unlikely to have been exposed, external 

on-site ambient dose should be used rather than co-worker doses. The sitespecific TIBs also provide information on the sources of the site data, validation of 

the data, and conversion of the data into annual doses to be applied in dose 

reconstructions.

The coworker doses presented in the site-specific TIBs shall be treated as constant 

values. However, they do not include all factors that must be applied by the dose 

reconstructor in order to assign doses. Specifically, site-specific adjustments 

based on technical considerations (e.g., dosimeter bias) must be incorporated by 

the dose reconstructor based on the site Technical Basis Documents (TBDs). 

Additionally, organ dose conversion factors based on OCAS-IG-001 must be 

applied; for likely compensable or likely non-compensable cases, they shall be 

applied in the same manner in which they are applied for monitored employees, 

and otherwise they shall be applied as a triangular distribution.

 From Section 4.0 Applications and Limitations

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

19

In parallel with the development of site-specific TIBs that document the external 

coworker data sets to be used in dose reconstructions, cases not yet completed are 

screened to identify those cases requiring external coworker data to facilitate case 

processing. As described previously, some cases with little or no individual 

monitoring data have been processed using methods not dependent on coworker 

data. Cases identified as requiring coworker data shall be processed as described 

in Section 7.0.

Some workers are concerned that their dose records are not accurate because they 

were encouraged or instructed by a supervisor not to wear their badges 

(dosimeters), or they were not given badges while doing jobs that could have 

resulted in exposures sufficient to exceed an administrative or regulatory dose limit. 

If this concern is expressed by a claimant verbally in the CATI interview or in 

written correspondence, the dose reconstructor should try to determine if this could 

have happened by examining the dose records and considering the workplace 

conditions, potential source terms, and incident reports. In cases in which the dose 

reconstructor believes this could have happened, it may be necessary to modify the 

dose reconstruction and/or perform additional research.
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2.3.4 Review Comments

Review Objectives 1.1, 1.2, 1.3, and 1.5

This procedure lacks clarity and repeatedly demands the dose reconstructor’s opinion and/or 

subjective interpretation of information. For example, under Section 2.0, lines 9, 10, 12, and 13 

require the dose reconstructor to make a highly subjective comparison between present 

monitoring requirements/standards and those that may extend over a long period of time (and as 

far back as the 1940s). Moreover, the absence of available monitoring records may equally be 

due to the loss of records of a monitored worker.

Equally perplexing is the applicability (or need for) ORAUT-OTIB-0020, as given in Section 

2.0, lines 21 through 29. For each of the “four categories” of workers for whom OCAS-OTIB0020 may apply, reasons are provided as to why the ORAUT-OTIB-0020 co-worker dose may 

not apply or may not be needed for dose reconstruction.

In brief, the applicability of ORAUT-OTIB-0020 lacks clarity and prescriptive guidance.

Review Objectives 2.1, 2.2, 3.2.3, and 3.2.4

Section 2.0, lines 26 through 29, stipulate that site-specific co-worker data, as defined in 

ORAUT-OTIB-0020, may not be necessary for dose reconstruction. Thus, in lieu of sitespecific co-worker data, the dose reconstructor may select “. . . reasonable upper limits, provided 

that the total probability of causation (POC) is less than 45%.”

Side-stepping the use of ORAUT-OTIB-0020 and co-worker data, however, requires the dose 

reconstructor to make a quantitative determination of what corresponds to “reasonable” upper 

exposures that the unmonitored person may have received.

Review Objective 4.1

See discussion that references Review Objectives 2.1, 2.2, 2.3, 3.2.3, and 3.2.4 above.

Review Objectives 5.1, 5.2, and 5.3

If, in fact, the dose reconstructor elects to employ site-specific co-worker data for dose 

reconstruction, a decision must be made whether to use the 50th or the 95th percentile dose of a 

representative co-worker population.

Section 3.0, lines 1 through 21 contain guidance for selecting the 50th and 95th percentile values. 

Again, the dose reconstructor is placed into a situation where “professional judgment” must be 

made whether (1) the unmonitored worker was exposed only intermittently or routinely and/or 

(2) the assigned dose is to represent a “best estimate” or a bounding value.

It is SC&A’s opinion that data needed for these decisions are unlikely to be available to the dose 

reconstructor.
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Review Objective 6.1

Lines 23 and 25 of Section 3.0 state that co-worker data (which SC&A assumes to include the 

50th percentile value) will be treated as a constant (i.e., without any estimate of uncertainty). 

While SC&A concurs with the use of a 95th percentile value as a constant, SC&A considers the 

50% percentile constant value as one that is without scientific basis and not claimant favorable.

Review Objective 7.1

As already discussed above, there are multiple elements described in the guidance/use of this 

OTIB that require the dose reconstructor to make subjective decisions or require information that 

is not likely to be available.

In addition to previously cited examples, Section 4.0, lines 9 through 19, prompts the dose 

reconstructor to resolve complex issues involving work practices, radiological incidents, etc. 

Resolution of such complex issues is will require a great deal of judgment by dose 

reconstructors, and these judgments may not be made in a consistent manner among different 

dose reconstructors. 

2.4 ORAUT-OTIB-0023: ASSIGNMENT OF MISSED NEUTRON DOSES BASED 

ON DOSIMETER RECORDS

The review of ORAUT-OTIB-0023, Rev. 00, dated March 7, 2005, was prepared by U. Hans 

Behling, PhD, MPH, and approved by John Mauro, PhD, CHP on March 31, 2006.

2.4.1 Purpose of Procedure

The purpose of this OTIB is to provide information to allow ORAU Team dose reconstructors to 

determine when it is appropriate to assign missed neutron doses at DOE sites using the nLOD/2 

method or an “alternative” method. Use of the “alternative” method should be applied when the 

missed neutron central estimate (i.e., nLOD/2) exceeds 75% of the assigned photon dose (i.e., 

from recorded dosimeter dose + missed dose). A description of the alternative method is 

provided below in behalf of Review Objective 1.4.

2.4.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0023 is summarized in Table 2.4-1 below. Table 2.4-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedures adequately support the dose reconstruction process as directed 

under the EEOICPA and defined in 42 CFR Part 82.
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Table 2.4-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0023, Rev. 00 Effective Date: 03/07/2005

Document Title: Assignment of Missed Neutron Doses Based on Dosimeter Records

Reviewer: U. Hans Behling

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? 3

See Review 

Comments

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 3

See Review 

Comments

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

2

See Review 

Comments

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

2

See Review 

Comments

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3

See Review 

Comments

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?

N/A

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?N/A

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? N/A

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 3

See Review 

Comments

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? N/A

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A

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)?

N/A

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 3

See Review 

Comments

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 3

See Review 

Comments

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 2

See Review 

Comments

__________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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2.4.3 Review Comments

Review Objectives 1.1 and 1.2

The procedure lacks clarity by failing to provide clear definition(s), and is inconsistent in its 

terminology. References/descriptions pertaining to neutron monitoring in Section 2.0, 

Background, that relates to “unreliable” neutron dosimeters is not only irrelevant to the OTIB, 

but introduces unnecessary confusion, since this OTIB is intended only for accurate neutron 

monitoring data that are considered the “dose of record.” 

Review Objective 1.3

For the alternative method (when nLOD/2 is not used), detailed information is required that will 

not be readily available to the dose reconstructor. (For a more detailed explanation, see Review 

Objective 7.1, 7.2, and 7.3 below.)

Review Objective 1.4

ORAUT-OTIB-0023 references OCAS-IG-001 as the basis for its guidance. Guidance contained 

in ORAUT-OTIB-0023 and OCAS-IG-001, however, is inconsistent. The key discrepancies are 

as follows:

(1) Reference to the dosimeter data that reflect reliable versus unreliable neutron dosimeters 

differs between the two guidance documents.

(2) The need for use of neutron survey data and stay times when missed neutron doses 

exceed 75% of photon doses is only prescribed in OCAS-IG-001.

(3) The same 75% condition in ORAUT-OTIB-0023, however, is only invoked in 

combination with a second condition in order to avoid the assignment of missed neutron 

dose altogether. Thus, if the second condition is not met, ORAUT-OTIB-0023 provides 

no guidance for assigning missed neutron dose.

The following provides a more detailed description of these discrepancies:

 OCAS-IG-001, Section 2.2.2.2.1, provides the following guidance:

An exception to the method is needed for unreasonably high neutron missed 

doses. Generally the neutron dose is significantly less than the photon dose. 

Therefore when the neutron missed dose central estimate (nLOD/2) exceeds 

75% of the photon dose (dosimeter dose + missed dose), the exposure should be 

treated as an unmonitored exposure and radiation survey data combined with 

stay times (frequency of exposure) should be used to estimate the missed dose. 

The reason for this deviation is that early monitoring of neutrons was sufficiently 

poor that the missed dose was virtually an unmonitored exposure. With accurate 

stay time information and numerous neutron measurements, a reasonable 
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estimate of exposure can be derived for recorded exposures below the limit of 

detection. [Emphasis added.]

In summary, OCAS-IG-001 cites the 75% photon criteria in behalf of neutron 

dosimeters judged to be unreliable, and proposes to use “radiation survey data 

combined with stay times” as the alternative method for estimating missed 

neutron doses.

 ORAUT-OTIB-0023, Section 3.0, Applications and Limitations, provides the 

following:

The guidance in this TIB applies to cases in which the neutron monitoring devices 

in use at the site produced results that were considered the dose of record. It 

does not apply to periods during which the monitoring was unreliable and some 

method other than the monitoring data (e.g., neutron-gamma ratios) is normally 

used to assign neutron dose based on information in the site TBD or other 

reliable source. [Emphasis added.]

And,

 ORAUT-OTIB-0023, Section 6.0, Guidance, provides the following:

Workers who were monitored for neutrons using reliable dosimeters should 

generally be assigned missed doses in accordance with OCAS-IG-001 (i.e., using 

the LOD/2) method for any null results. As described in the IG, however, an 

exception to the method is needed for unreasonably high neutron doses. 

Missed neutron doses do not need to be assigned if both of the following 

conditions are met:

1. The neutron missed dose central estimate (nLOD/2) would exceed 75% of the 

photon dose (dosimeter dose + missed dose).

2. Based on the employee’s work location(s) and relevant information in the site 

TBD or other documentation (e.g., neutron source term information, neutron 

survey results, and the potential for neutron exposures), the dose 

reconstructor determines that the employee’s neutron dose was zero or 

incidental relative to the external dose assigned.

If both of the above conditions are met, dose reconstructors should include 

appropriate explanatory language in the dose reconstruction (DR) report. This 

should include a discussion in the DR report of the available information 

regarding work locations and the rationale for the conclusion that neutron doses 

could not have exceeded incidental levels. [Emphasis added.]
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Review Objective 1.5

For the dose reconstructor, potentially subjective decisions may include (1) the determination of 

neutron dosimeters as being reliable or unreliable, and (2) the need to assign a quantitative value 

to the term “incidental levels” of neutron exposures. (Note: SC&A assumes that this OTIB is 

intended for dose reconstructions that are classified as “best estimates.”). It is questionable 

whether dose reconstructors are in a position or have the information to make such judgments. 

In addition, when such judgments are made, there is a high potential for different dose 

reconstructors to come to different judgments; i.e., by its very nature, it is unlikely that the OTIB 

can be implemented in a consistent manner.

Review Objective 4.2

ORAUT-OTIB-0023 defers to OCAS-IG-001 with regard to the technical basis for its guidance. 

However, a comparison between the two documents identifies significant differences as 

described under Review Objective 1.4 above.

Review Objective 7.1

At this time, it is uncertain whether guidance contained in OCAS-IG-001 (which requires the 

assignment of neutron doses based on neutron survey data and worker stay times) applies to 

ORAUT-OTIB-0023 in instances when only condition #1 is met.

If the answer is yes, then the reconstruction of missed neutron doses from “. . . numerous

neutron measurements and accurate time information” [emphasis added] can only be regarded 

as unrealistic.

Review Objective 7.2

SC&A interprets the current guidance in ORAUT-OTIB-0023 as providing two options:

 Option #1. Missed neutron doses are assigned for “reliable neutron dosimeters” on the 

basis of nLOD/2. Since NTA film at most facilities is not considered reliable, LOD 

values for TLNDs are generally given at 10 or 20 mrem. For TLND, common exchange 

cycles involve quarterly or monthly exchange periods and would result in nLOD/2 

missed neutron doses of as little as (4)(10)/2 or 20 mrem per year to (12)(20)/2 or 

120 mrem per year.

 Option #2. When both conditions are met, missed neutron doses may be ignored 

altogether and a zero dose is assigned.

Thus, the difference between Option #1 and Option #2 may vary between 20 mrem per year to 

120 mrem per year. Given these trivial doses and the need to provide compelling rationale/ 

explanation for selecting Option #2, the regulatory recommendation for “striking a balance 

between the need for technical precision and process efficiency” has clearly been ignored.
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Review Objective 7.3

A key element in ORAUT-OTIB-0023 (as well as in OCAS-IG-001) is the unsupported 

assumption that when the missed neutron dose exceeds 75% of recorded + missed photon dose, 

such a missed neutron dose must be regarded as inflated/unrealistic.

A review of several TBDs identifies multiple locations where the neutron-to-photon ratios 

exceed 0.75. For example, ORAUT-TKBS-0014-6 identifies several locations at Y-12 with 

neutron-to-photon ratios well in excess of 1:1 and as high as 25:1. Thus, the generic assumption 

of a neutron-to-photon ratio of 0.75:1 as a limiting value for the application of nLOD/2 is neither 

technically defensible nor claimant favorable.

2.5 ORAUT-OTIB-0017: INTERPRETATION OF DOSIMETRY DATA FOR 

ASSIGNMENT OF SHALLOW DOSE

The review of OCAS-OTIB-0017, Interpretation of Dosimetry Data for Assignment of Shallow 

Dose, Rev. 01, dated January 11, 2005, was prepared by John Hunt, PhD, and approved by John 

Mauro, PhD, CHP, on March 31, 2006.

2.5.1 Purpose of Procedure

This OTIB provides guidance for assigning shallow doses to the skin, testes, and breast from 

non-penetrating radition, including beta exposures and exposures to low-energy photons.

2.5.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0017 is summarized in Table 2.5-1 below. Table 2.5-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report. 
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Table 2.5-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0017 Effective Date: 10/11/2005

Document Title: Interpretation of Dosimetry Data For Assignment of Shallow Dose, Rev. 01

Auditor: John Hunt, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 4

See Review 

Comments

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 5

It references other 

related NIOSH and 

ORAUT document, 

but this is not a 

problem.

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

1

See Review 

Comments

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) 5

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3

See Review 

Comments

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 3

See Review 

Comments

_______________

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

2.5.3 General Comments

ORAUT-OTIB-0017 presents a comprehensive and thoughtful discourse on the challenges 

associated with reconstructing shallow doses from soft photons and beta emitters. It provides 

detailed and comprehensive guidance regarding the difficulties in interpreting external dosimetry 

data for several target tissues and organs and for a range of facilities and times periods, 

considering their different monitoring techniques and reporting practices. However, we would 
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like to offer the following observations and suggestions that we believe would further improve 

the document. The format used here is to first quote the statement made in the guide (the 

statement in italics) followed by our comment(s).

Page 6, item 3: Assign the non-penetrating dose as electrons >15 keV (corrected for attenuation 

where applicable) or photons < 30 keV if the employee worked in a plutonium facility.

It is suggested that the dose reconstructor should check whether the site was reporting dose due 

to electrons or photons, and whether the dosimetry system had been calibrated for that type of 

radiation. For example, consider an employee that worked with plutonium. If his individual 

dosimeter had been calibrated for beta radiation, the result would have been reported as 40 mrem 

(due to beta radiation). It is not procedurally correct to now say that he was exposed to 40 mrem 

of low-energy photon radiation. If the above-mentioned employee had, in fact, been exposed to 

low-energy photon radiation and not beta radiation, then the case is more complicated. 

Unless a calibration factor that would convert the beta dose into a low-energy photon dose can be 

calculated, then it could be stated that the dosimetry system at the time was not capable of 

measuring low-energy photons, and therefore, the employee’s dose due to low-energy photons is 

unknown.

Electron attenuation

Page 7: an acceptable minimizing approach is to assume a transmission of 0.6. 

The protective clothing used for each case was known in the great majority of the cases. The 

transmission factors for this clothing should be used.

Exposure geometry

Page 7: The nature of beta particles suggests that some recorded doses may significantly 

overestimate or underestimate the actual dose to the skin at the cancer diagnosis location.

Unless there were fundamental mistakes in the calibration of the dosimeters, the beta dose will 

never have been overestimated. However, we agree that the recorded dose can and will 

significantly underestimate the real beta dose. It is SC&A’s opinion, from a practical 

occupational exposure point of view, individual monitoring for beta particles only works on a 

“yes there was a beta dose/no there was no beta dose” basis. Consider the following examples, 

which cover most, if not all, working place geometries:

(1) Directly handling uranium, as in the OCAS-IG-001 example, or directly handling other 

beta/gamma emitters (hopefully with thick gloves). Dose to dosimeter less than 1% of 

the dose to the skin of the hand or forearm.

(2) Hot particle or evenly distributed skin contamination, to the lip or to the shoulder as in 

the OCAS-IG-001 example – dose to dosimeter less than 1% of the skin dose.

(3) Working in a confined contaminated space, such as pipe, vessel, or duct, or lying face 

down on a contaminated surface – in this case, the beta dose to the dosimeter 

approximates the dose to skin if the beta energy spectrum is similar to the beta calibration 

spectrum. The front of the dosimeter has to be facing the contaminated surface.
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(4) Standing, sitting, kneeling, or on all fours on a contaminated surface – beta dose to 

dosimeter less than 10% of the overall skin beta dose and less than 1% of the dose to the 

skin in contact with the surface. The dosimeter held perpendicular to the contaminated 

surface considerably reduces the response.

(5) Standing facing a contaminated surface – if the distance to the surface is lower than 

around 50 cm, the dose to dosimeter approximates the dose to skin if the beta energy 

spectrum experienced by the worker is the same as that used for calibration. If the 

distance from the dosimeter to the contaminated surface is higher than around 50 cm, the 

dose is too low to be relevant for POC calculations. For any other relative position, the 

dose to the dosimeter is less than 1% of the skin dose.

Looking at the five irradiation geometries above suggests that, unless the employee spent most of 

his day doing maintenance work in confined spaces or supervising a contaminated control panel, 

the beta dose to his or her dosimeter (basically zero) will have no relation to the real beta skin 

dose.

For dosimeters that discriminate beta radiation (with a true OW and a plastic filter for the betas), 

and if it is clear that the dosimeter has been exposed to beta radiation, it is a good practice to 

make a workplace survey with portable equipment to determine the location and count rate 

(which can then be used to approximate dose rate) of the beta-gamma radiation fields. Once 

located, the beta-gamma contamination should be removed or reduced. Loose beta-gamma 

contamination poses a greater hazard from the point of view of internal contamination than as an 

external hazard. As part of the site profile and dose reconstruction, an attempt should be made to 

determine whether these practices were employed if beta exposures are of concern for particular 

facilities and claimants. 

Film dosimeters are also useful to detect loose beta-gamma contamination in the workplace; a 

particle or dust deposited on the outside of the film badge holder will leave a distinctive circular 

black mark on the film. The film is a very sensitive detector of a beta-gamma emitter on the film 

badge, as the source is almost in contact with the film, and the film integrates the dose over the 

interval between the contamination and the film change. This was also the way that radioactivity 

was discovered in the first place. It is not possible, of course, to estimate the shallow dose; only 

to give a yes/no beta contamination indication.

The particle may be deposited on the film badge as dust or by holding the film badge with 

contaminated hands. If there was sufficient removable beta-gamma contamination in the 

workplace to produce a relevant beta dose, then there is a high probability that this would have 

been seen directly on a few of the film badges over a number of the dosimeter changes. From 

our experience, for each month of monitoring a NPP, we would see on average one film with a 

characteristic mark of beta-gamma contamination on the film badge. The dose report would then 

contain the observation, “Film badge holder contaminated, please change.” The nuclear 

medicine clinics were worse; the incidence rate of beta-gamma contamination marks was higher.
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If this film badge contamination was not seen, it could be concluded that beta radiation fields 

from open beta-gamma contamination were not an occupational radiation protection problem for 

the specific DOE facility operation.

Non-uniform exposure of the skin

Page 8: if it is known that the cancer occurred in an area not within the area for contamination 

or partial-body irradiation, no dose should be assigned to that cancer location.

As discussed in the item on exposure geometry, it is possible to state definitely where the cancer 

site is, but not where the contamination was, if film or TLD dosimetry were the only detection 

methods available.

Page 8: For example, a hot particle skin exposure for 1cm2in accordance with OCAS-IG-001 

should be modified to account for total skin area...

As stated previously, a skin dose due to hot particle exposure will not be detected by individual 

dosimetry because of the localized nature of the exposure. There is a high probability that 

employees were exposed to hot particles if their activities included entering workplaces where 

the following may have existed:

 Particles from damaged and used fuel elements

 Fission products from nuclear device testing or a criticality accident

 Fission products in hot-labs, canyons or hot-cells (maintenance work)

 Particle releases from facility stacks (Hanford)

The employees were normally “frisked” out of the control area, but the success of detection of 

hot particles is not 100%. Normally, only the hands, shoes, and possibly hair are “frisked.” 

It would help the dose reconstructors if a “reference hot-particle skin dose” could be calculated 

that would establish (1) a “standard hot particle,” (2) the time expected before “frisking” and 

removal of the contamination, (3) the calculation of the dose, due to the hot particle placed on 

the skin or placed on protective clothing, and (4) the uncertainties due to the non-uniform 

exposure of the skin. This “standard hot-particle exposure” would then be used for the cases of 

skin cancer for employees whose jobs included the above-mentioned activities. However, using 

the example and the procedure given in the OTIB, the skin dose due to a “hot particle” will not 

generate a POC higher than around 30%. Specifically, the case given in the OTIB (skin – basal 

cell cancer, electrons > 15 keV – acute, GM = 0.01 rem, GSD = 14, birth 1925, exposure 1945, 

diagnosis 1980) gives a POC of 27%.

The mathematics of probability can be used to show that if 1,000 such employees suffered skin 

doses due to hot particles, with the above POC, around 270 of them would develop skin – basal 

cell cancers, and not zero, as calculated through the IREP methodology.

There is also the question of how many hot-particle irradiations per person should be considered 

for the dose reconstruction. Exposure to three of the OTIB hot particles will give a POC above 

50%.
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Over-response of film to low-energy photons

Page 9: .....by factors of 8.5-12 and 14-19.

We assume that these factors represent over-response of film to low energy photons relative to 

exposure to photons with energies greater than 250 keV photons. This should be made clear in 

the document.

Page 9: ...a factor of 0.6 is prescribed....

Considering the order-of-magnitude factors given above, a factor of 0.6 is very claimant 

favorable.

Page 9: Missed doses assigned as < 30 keV photons should also include this correction factor 

(0.6)...

If a dosimetry service recorded, for example, 30 mrem as the LOD for OW and S dose, then this 

value (30 mrem) should be used as the basis for the missed dose calculation.

Attachment A

Page 15: the thickness of each garment is 2 mm, giving a total of 4 mm....

It is not claimant favorable to consider that the employee had 4 mm of clothing thickness. Our 

own measurements made with a micrometer determined the thickness of a number of items of 

clothing, such as a laboratory overcoat (0.4 mm), a thin sweater (0.8 mm), and a thick shirt 

(0.6 mm). We would suggest checking the basis for the 4 mm assumption (or 5 mm assumption 

on page 17), and recalculating the shielding and correction factors accordingly.

Page 17: The source was modeled as a 10-cm2 infinitely thin disk source located 2 cm away 

from the skin.

For the breast area, the film dosimeter would give a reasonable dose estimate. If the source was 

near the testicles, the film dosimeter would not measure anything.

Page 17: Tables A-1 and A-2

In almost all real cases, it is not possible to state that the beta dose was due to Ru/Rh-106, 

Sr/Y-90, Nb-95, and so on. All that can be said is that “the beta dose was due to a mixture of 

fission products” or “the beta dose was due to decay products of U-238 and U-235.” Therefore, 

this table and the other tables should include correction factors for a “standard” fission product 

mix and for uranium series decay products in equilibrium.

Page 18: ...a significant fraction of the X-rays being absorbed by the 1 cm thick shield (on the 

film dosimeter). 

The correct thickness of the shield should be given.

Page 18:...sensitive issues

Should read, “sensitive tissues.”

Page 18: ...is more notable for the low energy beta sources, especially those with maximum 

energies below 500 keV.

As indicated in the Portsmouth TKBS (ORAUT-TKBS-0015-6), for low-energy beta radiation, 

the dosimeters were likely incapable of furnishing accurate doses in terms of Hp(0.07). 
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Attachments B and C 

Pages 21 and 24...

It is not clear why the two tables of examples give the recommendation to assign a 30–250 keV 

for missed dose to the skin for 0 “OW reading” and 0 “S reading,” as this does not follow the 

general logic of the table, and this energy range is not claimant favorable.

Attachment D 

Page 25.....in general, the contribution to skin dose at GDPs from low energy photons is 

extremely small compared to the contribution from beta particles.

It is likely that the beta doses to the skin (mainly the hands) of employees doing maintenance or 

decontamination work at the GPDs will be higher than the low-energy photon doses. However, 

considering the arguments in this report, it is also likely that the dosimeters used did not record 

this beta dose, only the low-energy photon dose. The employees in operation areas with closed 

systems with UF6 or other uranium compounds would be more exposed to low-energy photons 

(E < 30 keV) than beta particles. In any case, the photon dose rate would be low.

2.5.4 Review Comments

Review Comments 1.2: 

The title of the OTIB “Interpretation of dosimetry data for the assignment of shallow dose” does 

not correspond to the content of the OTIB as the assignment of both shallow and penetrating 

doses are discussed. A more correct title would be “Interpretation of dosimetry data for the 

assignment of dose to the skin and other shallow organs.” The logical order of the information in 

Chapter 3: General approach could be improved.

Review Comments 2.1

The OTIB does not identify any cases where a possibly high POC can be determined early in the 

investigation. It does identify assumptions to be made to minimize the POC in likely 

compensable cases.

Review Comment 5.2 

The procedure is not claimant favorable in instances of unknown parameters effecting dose 

estimates. In summary, due to the localized form of beta irradiation, the beta dose as measured 

on the thorax or extremity dosimeter has no relationship to the worker’s skin dose at the point of 

cancer incidence. There are two exceptions to this general rule:

(a) Immersion in a cloud of beta-gamma emitters.

(b) Skin cancer on the wrist for a wrist extremity dosimeter or on the chest for a thorax 

dosimeter.

It is convenient to say “the beta dose was as measured on the dosimeter”. However, the 

dosimeter will give at best a “yes, there was a beta radiation field” or “no, there was no beta 

radiation field.” In almost all cases, the dosimeter dose will substantially underestimate the beta 
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dose. This substantial underestimation by the dosimeter is mentioned in the OTIB, but not dealt 

with in any way.

Review Comment 7.3 

The procedure does not employ scientifically valid protocols for reconstructing doses, as 

follows:

(a) Page 6, item 3 of the OTIB states, “Assign the non-penetrating dose as electrons >15 keV 

(corrected for attenuation where applicable) or photons <30 keV if the employee worked 

in a plutonium facility.” Either the dose was originally calculated as being due to 

electrons using the dosimeter calibration factor for betas, or the equivalent calculation 

was made for photons. It is not possible to change a beta dose to a photon dose and visaversa.

(b) The assumption of 4 mm thickness of clothing for beta radiation shielding is not claimant 

favorable.

(c) The treatment of hot spots is not adequate. There is not enough information to allow the 

POC to be calculated. Open points are the beta energies, the dose to the skin, and the 

number of hot spots per worker that could be considered as reasonable. 

2.6 ORAUT-OTIB-0024: ESTIMATION OF NEUTRON DOSE RATES FROM 

ALPHA-NEUTRON REACTIONS IN URANIUM AND THORIUM 

COMPOUNDS

The review of ORAUT-TIB-0024, Rev. 00, dated April 7, 2005, was prepared by Robert 

Anigstein, PhD, and approved by John Mauro, PhD, CHP, on March 31, 2006. Several 

modifications to the checklist were made in July 2007 by Robert Anigstein.

2.6.1 Purpose of Procedure

The stated purpose of this document “. . . is to provide a quick estimate of neutron doses from 

alpha particle collisions with low atomic number materials. This document provides an estimate 

of neutron doses at sites that processed thorium and uranium compounds with low atomic 

number components, but did not perform neutron measurements” (Hysong et al. 2005).

2.6.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0024: Estimation of Neutron Dose Rates from AlphaNeutron Reactions in Uranium and Thorium Compounds, is summarized in Table 2.6-1 below. 

This table presents a checklist containing objectives that SC&A developed under the first phase 

of Task 3 to evaluate whether a procedure adequately supports the dose reconstruction process, 

as described in the introduction to this report.
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Table 2.6-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0024 Effective Date: 04/07/2005

Document Title: Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium 

and Thorium Compounds

Reviewer: Robert Anigstein, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

3

User must calculate 

fraction of U or Th in 

compound or mixture

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

3

See Review 

Comments

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?3

See Review 

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 3

See Review 

Comments

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? 1

See Review 

Comments

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 1

See Review 

Comments

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 1

See Review 

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)?

N/A

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 

5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 1

See review 

Comments

______________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

2.6.3 General Comments

Summary of Document

This document aims to “. . . estimate neutron production and dose rates from the alpha-neutron 

reaction in uranium and thorium compounds. The chemical forms of uranium considered were 

UF4 and UF6, as well as the uranium oxide forms (UO2, UO3, U3O8) and “soda salt” (Na2U2O7) 
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(Hysong et al. 2005). These estimates are based on a review of published results of experimental 

measurements, and involve interpolating and, in some cases, extrapolating the published data. 

Published data on the average and maximum energies of the spectra of neutrons produced by the 

(α,n) reaction for α -particle energies of 4.0–5.5 MeV incident on oxygen and fluorine targets are 

extrapolated to α energies of 6.0–8.8 MeV, based on “scaling” the published data. Only one 

datum is listed for a sodium target; the maximum energy of neutrons produced by bombardment 

by 239P α rays. Based on these values, Hysong et al. conclude that the average energy of 

neutrons produced by the (α,n) reaction is 2.0 MeV. 

Next, the authors present tables of the neutron yield from the isotopes in natural uranium and 

from 232Th mixed with oxygen, fluorine, and sodium, respectively. These tables are based on 

values from three sources; DOE Standard–1136 (DOE 2000), Salmon and Hermann (1992), and 

Auguston and Reilly (1974). These references are secondary sources. DOE 2000 cites data from 

Reilly et al. (1991), which itself is a reference manual that cites other sources. Salmon and 

Hermann (1992, Table 3) present a table of neutron yields vs. α energies, which are interpolated 

from data published in other reports. Auguston and Reilly (1991, Table 7.1) list neutron yields 

for different light elements bombarded by α particles from 210Po, while Table 7.2 lists neutron 

yields for beryllium bombarded by α particles from various actinides. Hysong et al. combined 

the data in these two tables and attributed their results to Auguston and Reilly. After comparing 

data derived from these three sources, Hysong et al. selected the Salmon and Hermann data to 

use in estimating the neutron yields from compounds of uranium and thorium. 

The yield from each radionuclide was derived on the basis of its average α-particle energy by 

interpolating the Salmon and Hermann data, which are themselves interpolations of data 

published between 1960 and 1982. The neutron yields of compounds of separated natural 

uranium and separated natural thorium, as well as of compounds of uranium and thorium in 

secular equilibrium with their progenies, are calculated by summing the contributions of α

particles from each isotope in the mixture.

The dose from each mixture of α-emitting nuclides and light elements is then estimated by 

calculating the neutron flux at distances of 1 ft and 3 ft from a point source and multiplying these 

fluxes by a conversion factor of 1.3 × 10-4rem/h per neutron cm-2s

-1

.

Independent Verification of Neutron Doses

SC&A independently calculated the dose rates from neutrons emitted by compounds of separated 

natural uranium, as well as by compounds of natural uranium in secular equilibrium with its 

entire radioactive progeny. The neutron yields and energy spectra were calculated by use of the 

SOURCES-4C computer code (LANL 2002), a code system that determines neutron production 

rates and spectra from (α,n) reactions, spontaneous fission, and delayed neutron emission due to 

radionuclide decay. 

The SOURCES-4C code package includes a data file with (α,n) reaction cross-sections for 

19 target isotopes of various light elements. Each data set encompasses a range of α energies; 

the maxima of these energy ranges vary from 6.5 to 11.5 MeV, depending on the target nuclide. 
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These data sets can enable the calculation of neutron yields from the (α,n) reaction with each of 

the target nuclei over the corresponding range of α energies.

The energy spectrum of the neutrons produced by the (α,n) reaction depends on the target 

nucleus, the energy of the incident α particle, and the energy level of the excited state of the 

nucleus produced by the reaction. As an example, if the target nuclide is 18O, a naturally 

occurring isotope of oxygen, the reaction is written as 18O(α,n)21Ne. The product nuclide, 21Ne, 

is left in an excited state. Calculating the energy spectrum of the neutrons requires a knowledge 

of the branching fractions of the excited-state energy levels of the product nuclide. SOURCES4C includes energy level branching fractions for 16 of the 19 nuclides for which cross-section 

data are provided. The maxima of the α-particle energy ranges in these 16 data sets vary from 

6.0 to 12 MeV.

The SOURCES-4C code includes decay data on 107 source nuclides. In principle, the user can 

specify any combination of these nuclides. However, in its current release, the code will not 

execute if any source nuclide emits any α particles with an energy, Eα >6.5 MeV.

Our calculations of the neutron energy spectra omitted the contributions of source nuclides with 

E α greater than the range of α energies in the branching fraction data for each target nuclide. 

The maximum value of Eα for a 19F target (the only stable isotope of fluorine) is 6.0 MeV; it is 

6.5 MeV for all other target nuclides in our analysis. In calculating the uranium oxide neutron 

energy spectra, we omitted 214Po, which would be in secular equilibrium with 238U, and 219Rn, 

215Po, and 211Bi, which are in equilibrium with 235U. In the case of uranium fluorides, we also 

omitted 218Po, which would also be in secular equilibrium with 238U, and 227Th, part of the 235U 

progeny. We then used the MCNP5 computer code (LANL 2004) to calculate effective doses 

based on these spectra, utilizing the fluence-to-dose coefficients for the anterioposterior (AP) 

exposure geometry listed in ICRP Publication 74 (ICRP 1996). Table 2.1-2 presents the results 

of our calculations and compares them to values presented by Hysong et al. It should be noted 

that our results are listed in terms of 1 g of compound, while the OTIB values are for 1 g of 

uranium. In calculating the comparisons in the last column, the dose rates are renormalized to a 

common basis. 

In the case of uranium compounds with progenies, we calculated the dose rate at 1 ft by 

multiplying the average dose per neutron (based on the neutron spectra without high-Eα isotopes) 

by the neutron yield for the entire decay chain.5 For example, the row “Progeny: <6.5 MeV” 

lists the doses from the compound in equilibrium with all daughters except for high-energy alpha 

emitters, while the rows “Progeny: all” lists the dose rate that is the product of the neutron yield 

from the entire decay chains and the average dose per neutron in the previous row. All neutron 

spectra and yields include neutrons from the spontaneous fission of the uranium isotopes and 

their progenies. Except for spontaneous fission, we omitted decay modes with an effective 

 

5

 We calculated the neutron yield for target nuclides and values of Ea for which the appropriate crosssection data was included in the data file. This was accomplished by deleting the lines of the SOURCES-4C Fortran 

source code that prevented the calculation of neutron yields for Eα >6.5 MeV. This is consistent with modifications 

that had been made by one of the authors of the code for a similar purpose (Shores 2006).
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branching ratio—the product of the branching ratio and the activity fraction of the parent nuclide 

in natural uranium—of ~0.01% or less.

Table 2.6-2. Dose Rates from Neutrons at 1 Foot from Point Sources of 

Various Uranium Compounds

Compound

U Decay Series Ave. Dose

(pSv/neutron)

Yield

(n/s)

Dose (rem h-1g

-1

) Δ

a

Formula %U Calculatedb OTIBc

Na2U2O7 75.1% Separatedd2.64E-02 1.11E-02 1.06E-10 2.89E-11 -79%

UCL4 62.7% Separated 2.69E-02 8.54E-03 8.26E-11 6.62E-10 403%

UF4 75.8%

Separated 2.45E-02 3.89E-02 3.43E-10 6.62E-10 46%

Progeny: < 6.0 MeVe2.50E-02 1.68E-01 1.51E-09

Progeny: allf4.87E-01 4.38E-09 1.19E-8 106%

UF6 67.6%

Separated 2.44E-02 4.01E-02 3.51E-10 6.62E-10 27%

Progeny: < 6.0 MeV 2.50E-02 1.79E-01 1.61E-09

Progeny: all 5.25E-01 4.72E-09 1.19E-8 70%

UO2 88.2%

Separated 2.71E-02 1.22E-02 1.19E-10 7.91E-12 -94%

Progeny: < 6.5 MeVg2.76E-02 1.33E-02 1.32E-10

Progeny: all 1.40E-02 1.39E-10 1.04E-10 -34%

UO3 83.2%

Separated 2.71E-02 1.15E-02 1.13E-10 7.91E-12 -94%

Progeny: < 6.5 MeV 2.78E-02 1.31E-02 1.31E-10

Progeny: all 1.41E-02 1.41E-10 1.04E-10 -39%

Note: Due to limitations in the cross-section data, we did not calculate the doses from Na2U2O7 and UCl4 in the 

presence of the entire uranium decay chains.

a

Difference between dose rates in previous two columns, renormalized to 1 g of uranium.

b

Dose rate at 1 ft calculated using SOURCES-4C, per gram of compound (see text).

c

Dose rate presented by Hysong et al. 2005, per gram of uranium. A single dose rate is assigned to every oxide, 

regardless of chemical composition. The same is done for fluorides; the fluoride dose rates are also assigned to 

chlorides.

d

Uranium isotopes in ratios of natural abundance, separated from α -emitting progeny

e

Uranium isotopes in secular equilibrium with entire decay chain, omitting nuclides with Eα < 6.0 MeV

f

Uranium isotopes in secular equilibrium with all members of decay chain

g

Uranium isotopes in secular equilibrium with entire decay chain, omitting nuclides with Eα < 6.5 MeV

2.6.4 Review Comments

Review Objective 1.3

The OTIB expresses the dose rates per gram of source isotopes, rather than per gram of 

compound. This requires the dose reconstructor, who is more likely to have data on the total 

mass of the material, to do an additional calculation to determine the mass of uranium or thorium 

in each compound, adding a needless level of complexity and increasing the opportunity for 

errors.
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Review Objectives 2.1, 2.2, 4.2, 5.1, 5.2, and 5.3 

 

The first issue of concern is that the OTIB limits the neutron generation to the (α,n) reaction. 

Although this limitation is stated in the text, the brunt of the OTIB, and of the Excel workbook 

that embodies the calculated results (see Section 2.1.5), would be to cause the dose reconstructor 

to rely on these results for estimating the neutron dose from compounds containing separated 

uranium, and overlook the much larger contribution of the neutrons from spontaneous fission of 

the uranium isotopes. This leads to understating the dose rate by 94% in the case of UO2 and 

UO3, and by 79% for Na2U2O7. 

The second issue is the listing of doses from uranium decay chains that are truncated at 226Ra for 

the 238U decay series, and at 223Ra for the 235U decay series. The use of such truncated uranium 

decay chains in dose reconstruction implies that all of the 222Rn, the next member of the 238U 

decay chain, has escaped during the previous 200 or more years (the time that it would take for 

210Pb, the longest-lived member of the 222Rn decay chain, to come to secular equilibrium). Such 

an assumption is non-conservative and not scientifically supported. There are few conditions 

under which all (or almost all) of the radon escapes from a solid matrix. The emanation fraction 

(the fraction of 222Rn that escapes the granules of a divided matrix, such as soil) has a range of 

.05–.7 in soil, with a typical value of .25 used for environmental assessments (Sextro et al. 1987). 

Even then, not all of the radon that leaves the matrix completely escapes the matrix within which 

it is contained; some of it decays before it escapes to the atmosphere. Therefore, most of the 

radon remains with the uranium, and its progeny contributes to the neutron yield. This is also 

true of 219Rn (the next member after 223Ra in the 235U decay chain), which has a 4-second halflife. Similar observations apply to the doses from the 232Th decay chain that are truncated at 

224Ra; the next member is 220Rn, which has a half-life of less than 1 minute.

Review Objectives 7.3

The overriding issue with the OTIB is its reliance on outdated experimental results collected 

from secondary or even tertiary sources, and that it overlooks a current computer code, 

SOURCES-4C, which is readily available, easy to use, and has been extensively benchmarked.

The remaining issues concern the details of the neutron dose calculations and the scientific 

validity of these calculations. Table 3-3 of the OTIB presents average and maximum energies of 

the neutron spectra from oxygen and fluorine for alpha particle energies of 4.0–8.8 MeV. The 

neutron energies for alpha energies of 4.0–5.5 MeV are based on published data; the values 

corresponding to higher alpha energies are based on “scaling” that is not further explained. Any 

such extrapolation ignores the complex nature of the (α,n) reaction, which is strongly dependent 

on the energy of the alpha emitter. These tabulated results are not scientifically valid.

Table 3-4 of the OTIB lists quality factors and fluence per unit dose equivalent for a range of 

neutron energies, based in part on a 1971 NCRP report. Use of these values is contrary to 

NIOSH policy as stated in 42 CFR 82, which requires the use of the latest scientific data. ICRP 

Publication 74 (1996, Table A.41) lists a more recent set of neutron fluence-to-dose coefficients. 

For 0.5 MeV neutrons in the AP exposure geometry, the ICRP 74 coefficient is 188 pSv cm2

(1.88 × 10-8rem cm

2

), in contrast to 2.6 × 10-8rem listed in Table 3-4. For 5.0 MeV neutrons, 
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the ICRP value is equivalent to 4.74 × 10-8rem cm

2

vs. 4.3 × 10-8rem cm

2

, listed in Table 3-4. 

In the end, the OTIB adopts a value of 1.3 × 10-4rem/h per neutron cm-2s

-1

, which is equivalent 

to ~360 pSv cm2, whereas the ICRP 74 coefficient for 2 MeV neutrons is 383 pSv cm2. While 

the difference is not large, the failure to use current ICRP data undermines the scientific validity 

of the OTIB.

Tables 4-1 and 4-2 of the OTIB present neutron yields for oxygen, fluorine, and sodium in 

contact with uranium isotopes and with 232Th, and include data attributed to Auguston and Reilly 

(1974, Tables 7.1 and 7.2). In fact, Table 7.1 lists neutron yields for various light elements, 

including beryllium, bombarded by alpha particles from 210Po, while Table 7.2 lists the yields 

from beryllium bombarded by alpha particles emitted by various other nuclides. Hysong et al. 

combined these two disparate sets of data, based on the unstated assumption that the ratio of the 

neutron yield of beryllium to that of other light elements is independent of the energy of the 

incident alpha particles. As with the extrapolation of average and maximum neutron energies in 

Table 3-3, such an assumption is not scientifically valid. Although these results are not used in 

the dose calculations, their inclusion undermines the scientific validity of the OTIB.

Table 4-3 of the OTIB presents neutron yields for the members of 238U decay series. These data 

are interpolated from Salmon and Hermann (1992, Table 3), which itself is based on 

interpolations of published data. Table 4-3 lists 218At with an alpha-emission abundance of 

100%. While this is technically correct in one sense—the branching ratio for alpha decay of this 

nuclide is 99.9%—218At is produced by the beta decay of 218Po. The branching ratio for that 

decay mode is only 0.02%; thus, the relative activity of 218At in the 238U decay chain is 0.02%, 

not 100%, as presented in the table and used in the calculations. Similar errors are found in 

Table 4-4, which lists neutron yields for the 235U decay series. 227Th is given an alpha emission 

abundance of 100%; in fact, although 100% of the disintegration are by alpha decay, its 

abundance is 98.62%, which is the branching ratio of the beta decay of its parent, 227Ac. More 

important, 215At is also listed with an alpha emission abundance of 100%, while its relative 

activity is only 2.3 x 10-4 %, the branching ratio for beta decay of its parent, 215Po. Likewise, 

211Po is given an abundance of 98.9%. In fact, it undergoes alpha decay in 100% of the 

disintegrations; however, its activity relative to 235U is only 0.276%, the branching ratio of its 

parent, 211Bi. Finally, Table 4-5, which presents neutron yields for the 232Th decay series, lists 

212Po as being 100% abundant, whereas the correct value is 64.06%. These errors cause 

significant overestimates of the doses and further undermine the scientific validity of the OTIB.

Conclusions

Limiting the scope of the OTIB to doses from neutrons produced by the (α,n) reaction while 

omitting neutrons from spontaneous fission could lead dose reconstructors to understate the 

neutron dose from uranium oxides and Na2U2O7 by as much as 94% in the case of separated 

uranium, as shown in Table 2.1-2 of the present review. The alternative would be for NIOSH to 

issue separate guidance on neutron doses from spontaneous fission; the preferable solution would 

be to expand the scope of this OTIB to include spontaneous fission. The risk of understating 

these doses is magnified by the use of the Excel workbook, which embodies the calculations in 

the OTIB but does not require dose reconstructors to read the OTIB and understand its 

limitations. 
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Save for the omission of spontaneous fission, the doses from all uranium compounds would have 

been overstated. This is evident in the case of the uranium fluorides, where the spontaneous 

fission plays a much smaller role, due to the much larger yield from the (α,n) reaction on 

fluorine. Here, the dose rate is overstated by over 100% in the case of UF4 in equilibrium with 

the uranium progenies.

We also have reservations about presenting dose rates at 1 ft and 3 ft from a point source. Such a 

situation does not appear to be a realistic representation of actual working conditions. It would 

be more useful to calculate the ratios of neutron-to-photon doses for uranium and thorium 

compounds in various generic configurations (e.g., small objects, 55-gal drums, large piles, etc.) 

The best solution would be to present dose reconstructors with a methodology (e.g., a suite of 

computer codes) which can be applied to specific situations.

The SOURCES-4C code is, to the best of our knowledge, the state-of-the-art methodology for 

calculating neutron spectra and yields. In the publicly distributed version, the code is limited to 

source nuclides with E < 6.5 MeV. NIOSH might consider contacting LANL to develop a 

customized version of the code that could be used as an aid to dose reconstruction.6 The spectra 

produced by the SOURCES code can be directly imported into MCNP5, providing an efficient 

way of applying the entire set of ICRP Publication 74 fluence-to-dose coefficients to the entire 

neutron spectrum, rather than applying a single value to an assumed average neutron energy.

One limitation to the calculated doses presented in Table 2.1-2 is the use of the average dose per 

neutron, calculated from a neutron spectrum that does not embody source nuclides with E

greater than the maxima in the level branching data for the given target nuclide, to calculate the 

neutron dose from the entire uranium decay chain. The neutrons from the entire decay chain 

would have somewhat higher energies, which leads to an increase in the dose due to the slightly 

higher values of the fluence-to-dose coefficients. This effect would increase the discrepancy 

between our calculations and the OTIB values for uranium oxides with progenies, while 

somewhat reducing the discrepancy with the corresponding calculation for fluorides.

2.6.5 Review of Workbook

We have reviewed the Excel workbook, ORAUT-OTIB-0024Rev00-Calphaneutrondose.xls, 

which is furnished to dose reconstructors as a tool for utilizing the results of the OTIB. We start 

the discussion with the second sheet of the workbook, entitled “Alphan.” This sheet embodies 

the calculations presented in Tables 5-1 – 6-3 of the OTIB. Since we have reviewed these 

calculations in the preceding sections of the present report, they will not be discussed further at 

this time. The first sheet of the workbook, “AlphanCalcs,” contains 13 blocks of data formatted 

as tables—an example is illustrated in Table 2.6-3.

 

6 Data for the (α,n) reaction for α energies up to 15 MeV have recently been calculated by the Japan Atomic 

Energy Agency (JAEA 2006). It is likely that these data, suitably formatted, could be imported into the SOURCES4C data files.
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Table 2.6-3. User Input Field in ORAU Workbook

Natural Uranium in UO2/UO3/U3O8 

(No Progeny)

ENTER Mass (grams) of Unat 1

NEUTRON DOSE RATES (rem/h)

1 ft from source 7.91E-12

3 ft from source 8.79E-13

Each table corresponds to natural uranium isotopes, or natural thorium, in the form of different 

chemical compounds, as described in the OTIB. Each table contains a cell, highlighted in 

yellow, in which the user enters the mass of uranium or thorium (not the mass of the oxide or 

other compound—see discussion earlier in this review). The neutron dose rates at distances of 1 

ft and 3 ft from the point source that contains the mass of uranium or thorium entered by the user 

are displayed in the table. The cells displaying these doses are linked to the dose rates, per gram 

of uranium or thorium, calculated in the worksheet Alphan; the cells in the table multiply the 

mass of uranium (or thorium, as the case may be) input by the user by the dose rate in worksheet 

Alphan. The multiplication is performed correctly. The only additional findings concerning this 

workbook are errors in the text in AlphanCalcs!F9 and AlphanCalcs!K9. The legend in 

AlphanCalcs!F9 is incorrectly formatted: “Na2/U2/O7” should be “Na2U2O7,” as in 

AlphanCalcs!A9, where it is entered correctly. In AlphanCalcs!K9, the material is incorrectly 

listed as UO2/UO3/U3O8, whereas the dose rates are those for Na2U2O7.

Other than the above comments, the workbook embodies the calculations in the OTIB. The 

issues raised regarding the dose calculation in the OTIB in Sections 2.6.3 and 2.6.4 of this review 

apply equally to this workbook.

References

Auguston, R. H., and T. D. Reilly. 1974. “Fundamentals of Passive Nondestructive Assay of 

Fissionable Material,” LA-5651-M, Manual. <http://www.fas.org/sgp/othergov/doe/lanl/libwww/la-pubs/00377304.pdf>

Department of Energy (U.S.) (DOE). 2000. “DOE Standard: Guide of Good Practices for 

Occupational Radiation Protection in Uranium Facilities,” DOE-STD-1136-2000, Change Notice 

No. 3. <http://www.eh.doe.gov/techstds/standard/std1136/std11362000.pdf>.

Hysong, R., W. C. Proctor, and J. J. Vollmer. 2005. “Estimation of Neutron Dose Rates from 

Alpha-Neutron Reactions in Uranium and Thorium Compounds,” ORAUT-OTIB-0024, 

Revision No. 00.

International Commission on Radiological Protection (ICRP). 1996. “Conversion Coefficients 

for use in Radiological Protection against External Radiation,” ICRP Publication 74. Annals of 

the ICRP, 26 (3/4). Tarrytown, New York: Elsevier Science, Inc.
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Nuclear Data Center, Japan Atomic Energy Agency (JAEA). 2006. “JENDL (alpha,n) Reaction 

Data File 2005.” http://wwwndc.tokai-sc.jaea.go.jp/

Los Alamos National Laboratory (LANL) and Texas A&M University. 2002. SOURCES-4C: 

Code System For Calculating alpha,n; Spontaneous Fission; and Delayed Neutron Sources and 

Spectra, RSICC Code Package CCC- 661. Oak Ridge, Tennessee: Oak Ridge National 

Laboratory.

Los Alamos National Laboratory (LANL). 2004. MCNP5: Monte Carlo N-Particle Transport 

Code System, Version 1.30, RSICC Code Package CCC-710 [Computer software and manual]. 

Oak Ridge, Tennessee: Oak Ridge National Laboratory.

Reilly, D., N. Ensslin, and H. Smith, Jr. 1991. “Passive Nondestructive Assay of Nuclear 

Materials,” NUREG/CR-5550. Washington, DC: U.S. Nuclear Regulatory Commission.

Salmon, R., and O. W. Hermann. 1992. “ALPHN: A Computer Program for Calculating (", n) 

Neutron Production in Canisters of High-Level Waste,” ORNL/TM-12239. 

<http://www.ornl.gov/info/reports/1992/3445603684010.pdf>

Sextro, R. C., et al. 1987. “Investigations of Soil as a Source of Indoor Radon.” In P. K. Hopke 

(Ed.), ACS Symposium Series 331: Radon and Its Decay Products—Occurrence, Properties, and 

Health Effects. Washington, DC: American Chemical Society.

Shores, E. F., Los Alamos National Laboratory, X-1, Transport Applications. 2006. 

<eshores@lanl.gov> “Re: SOURCES-4C” March 27, 2006, personal e-mail to Robert Anigstein, 

SC&A, Inc.

Wilson, W. B., et al. 2002. “SOURCES 4C: A Code for Calculating (alpha,n), Spontaneous 

Fission, and Delayed Neutron Sources and Spectra,” LA-UR-02-1839. Los Alamos, New 

Mexico: Los Alamos National Laboratory.
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3.0 INTERNAL DOSIMETRY PROCEDURES/DOCUMENTS

3.1 OCAS-TIB-009 (REVISION NO. 0, 4/13/2004): ESTIMATION OF INGESTION 

INTAKES

The review of OCAS-TIB-009, Estimation of Ingestion Intakes, Rev. 0, dated April 13, 2004, 

was prepared by John Mauro, PhD, CHP, and approved by Hans Behling, MPH, PhD, on May 

30, 2006.

3.1.1 Purpose of Procedure

This TIB provides guidance to be used for estimating intakes of radioactive material through 

inadvertent ingestion of particulate material that may have been deposited directly onto food 

items and drinks, or deposited onto work-area surfaces and inadvertently ingested by hand-tomouth behaviors. The procedure is to be used when bioassay data are not available, and it is 

necessary to estimate ingestion dose based on information related to the airborne concentration 

of radioactive particles. The procedure does not adddress the ingestion of material that is 

deposited in the upper respiratory tract from inhalation and then ingested due to muco-ciliary 

clearance. That mode of “ingestion” is evaluated as part of the inhahation dosimetry protocols 

incorporated into IMBA.

3.1.2 Review Protocol

SC&A’s evaluation of OCAS-TIB-009 is summarized in Table 3.1-1 below. Table 3.1-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report. 
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Table 3.1-1. Procedure Review Outline/Checklist

Document No.: OCAS-TIB-009 Effective Date: April 13, 2004 

Document Title: Estimation of Ingestion Intakes

Reviewer: John Mauro

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? NA

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? NA

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) NA

3.2.2 In vivo/In vitro bioassays NA

3.2.3 Missing dosimetry data NA

3.2.4 Unmonitored periods of exposure NA

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 3 See comments below

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3 See comments below

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 3 See comments below

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 3

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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3.1.3 Review Comments

Review Objectives 5.1-5.3 and 7.2

As indicated in Table 3.1.1, all review criteria received a score of 5 except for criteria 5.1, 5.2, 

5.3, and 7.3. These criteria were assigned a score of 3 because we believe that the fundamental 

scientific approach to reconstructing ingestion exposures has certain flaws that could lead to an 

underestimate of ingestion doses under certain circumstances. 

The method recommended in OCAS-TIB-009 is based on the assumption that the amount of 

radioactive material that may be inadvertently ingested by a worker is directly proportional to the 

airborne concentration and settling velocity of the radionuclide. NIOSH assumed that ingestion 

involves two modes. The first mode involves the transfer of surface contamination to the hand 

and subsequently from the hand to the mouth. The fundamental assumptions are as follows:

 Airborne radionuclides deposit onto surfaces continually with a deposition velocity of 

0.00075 m/sec. This is the settling velocity of particles with an AMAD of 5 microns. 

This deposition rate continues 24 hours after which an equilibrium is reached where the 

removal rate equals the deposition rate.

 The worker’s hand, which has a surface area of 0.0155 m2(4 inches by 6 inches), is 

assumed to be contaminated at the same level as surfaces in the building after 365 days of 

continual deposition, and that 10% of the activity on the worker’s hand is ingested per 

day.

 The fraction of the ingested radionuclides that is absorbed in the gastrointestinal (GI) 

tract is the same as the f1 values for inhaled radionuclides.

The outcome of this calculation is that the daily ingestion rate is assumed to be 0.1 the airborne 

radionuclide concentration expressed in units of pCi/m3. For example, if the airborne 

radionuclide concentration is 10 pCi/m3, the inadvertent ingestion rate is 1 pCi/day. This is as 

compared to the daily inhalation rate, which would be 1.2 m3/hr × 8 hrs/day × 10 pCi/m3= 

96 pCi/day, or about 100 times the ingestion rate. 

The second mode involves the 8-hour deposition of airborne contaminants into a drinking cup 

with a diameter of 3 inches. Using the same deposition velocity, a daily ingestion is derived that 

is also about 10% of the activity in a single cubit meter of air. In summary, TIB-009 assumes a 

total daily ingestion that is 20% of the activity contained in one cubic meter of air.

Model Limitations that are Likely to Results in Underestimates of Intakes

NIOSH’s ingestion model is highly simplistic and is likely to yield intakes that are too low and 

unrealistic. Our concern centers primarily on mode 1, which firstly models the activity on 

surfaces and secondly models the transfer of surface contamination to the hand and subsequently 

to the mouth. This model suffers from the following deficiencies:
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 Surface contamination levels are likely to be orders of magnitude higher than predicted 

by the settling velocity of airborne contaminants assumed at 5 microns. For example, at 

uranium rolling mills, airborne particulates are likely to represent a distribution of 

particles that range from a few microns to large/visible particles. For larger particles, 

settling velocities increase dramatically and while large particles limit internalization by 

inhalation, there are no limitations for their ingestion.

 Surface contamination is likely to build up over time that may extend to weeks/months or 

longer before reaching equilibrium. NIOSH’s assumption that this equilibrium is reached 

in a 24-hour period is without scientific basis and highly unconservative.

 For select processes, surface contamination may not be the result of settling, but may 

include liquid spills, or result from milling, grinding, cutting, welding, etc.

 The modeled transfer of surface contaminations to the mouth that assumes a 10% transfer 

from the surface area of one hand during a full workday appears unrealistic. In a 

hot/dusty work environment, a “radiologically uninformed/untrained” worker is likely to 

contact/wipe his/her face with both hands repeatedly over the course of a full workday.

 Ingestion may involve other modes such as direct deposition on lips, smoking of 

cigarettes, etc.

These and other issues related to the ingestion model were discussed with NIOSH as part of the 

issues resolution process for the Bethlehem Steel site profile review. NIOSH and SC&A agreed 

that many of fundamentals assumptions used in the TIB model described above suffer from the 

above-described limitations. Based on these discussions, NIOSH has agreed to revise its 

approach to deriving radionuclide ingestion rates using empirical data relating the amount of 

radionuclides deposited on surfaces to the amount of radionuclides ingested. The revised 

strategy described by NIOSH in these conversations appears to be more scientifically valid and 

claimant favorable than the methods described in OCAS-TIB-009. SC&A recommends that the 

Advisory Board revisit this issue after NIOSH issues its revised procedures.

References:

EPA (Environmental Protection Agency) 1997. “Exposure Factors Handbook,” 

EPA/600/P-95/002, August 1997.

NCRP (National Council on Radiation Protection and Measurement) 1996. “Screening Models 

for Releases of Radionuclides to Atmosphere, Surface Water, and Ground.” Report No. 123, 

January 22, 1996.

3.2 OCAS-TIB-011: LUNG DOSE CONVERSION FACTORS FOR THORON, WLM 

The review of OCAS-TIB-011, Lung Dose Conversion Factors for Thoron, WLM, Rev 01, dated 

April 15, 2005, was prepared by Joyce Lipsztein, PhD, and approved by John Mauro, PhD, CHP, 

on February 11, 2005.
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3.2.1 Purpose of Procedure

This TIB provides the dose conversion factors for calculating lung dose from radon-220 decay 

products in working level months (WLMs). The guide was prepared because, though 

considerable guidance has been developed for estimating exposures to lungs from radon 

progeny, expressed in WL, less attention has been given to guidance on deriving exposures to 

thoron progeny, which are also often expressed in terms of WL. However, the lung dose per 

WLM of radon progeny is different than the lung dose per WLM of thoron progeny. This guide 

presents a method for converting thoron progeny exposure, expressed in units of WL, to lung 

dose.

3.2.2 Review Protocol

SC&A’s evaluation of OCAS-TIB-011 is summarized in Table 3.2-1 below. Table 3.2-1 is a 

checklist containing objectives that SC&A developed under the first phase of Task 3 to evaluate 

whether the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report.

3.2.3 General Comments

The document provides an excellent description of why the dose rate per WL associated with 

radon progeny for a given time period is different than that associated with thoron progeny, even 

though they both are defined in terms of the amount of short-lived progeny in air that delivers 

1.3E5 MeV alpha energy to the respiratory tract. As described in the TIB, the difference in dose 

rate per WL between 1 WL of radon progeny and 1 WL of thoron progeny is thoron progeny 

have a much longer half-life than radon progeny. As a result, there is more time for the thoron 

progeny deposited in the lung to be redistributed to other regions in the respiratory tract, 

specifically the extrathoracic (ET) region of the respiratory tract, which includes the anterior 

nasal passages, nose, mouth, larynx, and pharynx. In addition, the longer half-life of the thoron 

progeny increases the amount of progeny that are attached to aerosols, thereby changing the 

particle size distribution and behavior of the inhaled progeny in the lungs.
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Table 3.2-1. Procedure Review Outline/Checklist

Document No.: OCAS-TIB-011, Rev. 01 Effective Date: 04/15/2005

Document Title: Lung Dose Conversion Factor for Thoron, WLM

Reviewer: Joyce Lipsztein

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? 5

1.2 Is the procedure written in a manner that presents the 

data in a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., 

does not reference other sources that are needed for 

additional data)?

5

1.4 Is the procedure consistent with all other procedures that 

are part of the hierarchy of procedures employed by 

NIOSH for dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to 

minimize the need for subjective decisions and data 

interpretation?

5

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?

5

2.2 Conversely, for claims with suspected cumulative low 

doses, does the procedure provide clear guidance in 

defining worst-case assumptions?

5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, 

and is it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as 

required under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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?

5

5.2 Is the procedure claimant favorable in instances of 

unknown parameters affecting dose estimates?

5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored?

5

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)?

5

6.2 Does the procedure give appropriate guidance in the use 

of random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its 

POC? 

5

7.3 Does the procedure employ scientifically valid protocols 

for reconstructing doses? 4

See comment below

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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In order to calculate the doses, some parameters were chosen for Rn-220 using literature data. 

SC&A agrees that those are reasonable choices, including the following:

 Absorption half-life of 10 hours for Pb-212 and Bi-212

 2% unattached fraction for the working environment

 Median particle size of 0.25μm for the attached fraction and 0.0015 μm for the 

unattached fraction, with a GSD of 2.5, in accordance with ICRP 66

 Use of a range of equilibrium values (i.e., 0.2 to 0.8 for Bi-212 to Pb-212)

3.2.4 Review Comments

Review Objectives 7.3

NIOSH should provide further clarification on how the values of Table 1 of the TBD were 

derived. We were not able to reproduce the values of Table 1, even using the same assumptions 

as the ones provided in the document. SC&A also does not agree with the following statement 

on page 5 of the TIB: “This causes Pb-212 to produce less lung dose per unit activity inhaled 

than that of Bi-212,” because the lung dose per Bq intake of Pb-212 is about 4 times higher than 

the lung dose per Bq intake of Bi-212 for particle sizes of 0.25 μm and 0.0015 μm. 

3.3 ORAUT-OTIB-0028: VALIDATION OF THORIUM ANNUAL DOSE 

CONVERSION FACTORS

The review of ORAUT-OTIB-0028, Validation of Thorium Annual Dose Conversion Factors, 

Rev 01, dated March 7, 2005, was prepared by Joyce Lipsztein, PhD, and approved by John 

Mauro, PhD, CHP, on February 24, 2006.

3.3.1 Purpose of Procedure

This OTIB verifies the annual dose conversion factors used for the assessment of 232Th and 228Th 

doses. This verification was needed, because IMBA does not explicitly model the dosimetry of 

these radionucldes and the independent kinetics of their progeny chain. As a result, a separate 

set of dose conversion factors were developed for these radionuclides, which are verified in this 

document.

3.3.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0028 is summarized in Table 3.3-1 below. Table 3.3-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 3.3-1. Procedure Review Outline/Checklist

Document No.: OCAS-TIB-0028 Effective Date: 09/29/2003

Document Title: Use of ICRP 66 to Calculate Respiratory Tract Dose

Reviewer: Joyce Lipsztein

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4

See Review 

Comments

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?

N/A

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?N/A

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 4

See Review 

Comments

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 4

See Review 

Comments

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? N/A

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? N/A

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A

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)?

N/A

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 4

See comments below

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

3.3.3 General Comments

The document is meant to validate the Tables of Annual Dose Conversion Factors for 232Th and 

228Th, generated by Dr Keith Eckerman. The tables were validated by comparing committed 

equivalent dose coefficients (Sv/Bq) for 232Th and 228Th, computed using ORNL’s DCAL code 
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system (apparently the code system used by Dr. Keith Eckerman) with values tabulated by the 

ICRP. The document cites the files provided by Dr. Eckerman that should be used in dose 

calculations instead of the doses provided by IMBA, including the following:

 Th228AM5.INT- annual dose coefficient (Sv/Bq) for each year for 228Th, adult, Type M, 

AMAD 5μm, following an acute intake at time zero.

 Th228AS5.ANN- annual dose coefficient (Sv/Bq) for each year for 228Th, adult, Type S, 

AMAD 5μm, following chronic uniform intake of 1 Bq during year1.

 Th232AM5.INT- annual dose coefficient (Sv/Bq) for each year for 232Th, adult, Type M, 

AMAD 5μm, following an acute intake at time zero.

 Th232AM5.ANN- annual dose coefficient (Sv/Bq) for each year for 232Th, adult, 

Type M, AMAD 5μm, following chronic uniform intake of 1 Bq during year1.

It was not possible for SC&A to perform an independent verification of the dose conversion 

factors reported in this TIB. However, the methods employed appear to be in accordance with 

ICRP approved protocols.

3.3.4 Review Comments

Review Objectives 4 and 7

The TIB refers to a number of files that are not provided and are required in order to 

independently verify the dose conversion factors presented in Table 1 of the document. In 

addition, the document is incomplete in terms of clarifying the following:

 What should be used when there is a chronic intake of Type M 232Th or 228Th.

 What should be used when there is an acute intake of Type S 232Th or 228Th.

 What should be used when there is an intake of 232Th or 228Th, with AMAD different 

from 5μm.

3.4 ORAUT-OTIB-0022: GUIDANCE ON WOUND MODELING FOR INTERNAL 

DOSE RECONSTRUCTION

The review of ORAUT-OTIB-0022, Guidance on Wound Modeling for Internal Dose 

Reconstruction, dated November 18, 2005, was prepared by Joyce Lipsztein, PhD, and approved 

by John Mauro, PhD, CHP, on March 1, 2006.

3.4.1 Purpose of Procedure

The stated purpose of this procedure is to provide “information and guidance to dose 

reconstructors regarding the best estimate of internal dose from a contaminated wound.”
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3.4.2 Review Protocol

Our evaluation of ORAUT-OTIB-0022 is summarized in Table 3.4-1. Table 3.4-1 is a checklist 

containing objectives that SC&A developed under the first phase of Task 3 to evaluate whether 

the procedure adequately supports the dose reconstruction process, as described in the 

introduction to this report.

Table 3.4-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0022 Effective Date: 11/18/2005

Document Title: Guidance on Wound Modeling for Internal Dose Reconstruction

Reviewer: Joyce Lipsztein, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

N/A

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?N/A

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? N/A

 

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity and is it 

free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

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) N/A

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant-favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant-favorable in instances where 

claimant was not monitored? N/A

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

___________________________ 

* Rating System of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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3.4.3 General Comments

The National Council on Radiation Protection and Measurements (NCRP) is currently working 

on a wound model, which will be adopted by the ICRP. The suggested wound model provided 

in this procedure for Pu absorbed from the wound site into the blood stream is a reasonable 

model to be used as a starting point for input of parameters into the IMBA wound model. The 

suggested wound model for other nuclides is not specific, but can be applied if there is sufficient 

bioassay data available. In summary, in the absence of an official NCRP/ICRP wound model, 

the suggested approach to wound modeling is a good interim alternative to calculate doses to the 

systemic organs, following an uptake via wound.

3.4.4 Review Comments

SC&A’s review of this document produced no comments, and SC&A agrees with its contents 

and conclusions.

3.5 ORAUT-OTIB-0011: TRITIUM CALCULATED AND MISSED DOSE 

ESTIMATES

The review of ORAUT-OTIB-0011, Tritium Calculated and Missed Dose Estimates, Rev. 00, 

dated June 29, 2004, was prepared by Bruce Murray and approved by John Mauro, PhD, CHP, 

on March 1, 2006. The ORAUT-OTIB-0011 review was amended by Kathleen Behling in July 

2007.

3.5.1 Purpose of Procedure

The stated purpose of the OTIB is to provide “documentation of the method for estimating 

tritium missed and calculated doses from urine data. To facilitate entry of organ doses into the 

Interactive RadioEpidemiological Program (IREP) computer code, an Excel workbook (entitled 

“Tritium Doses from Urine Data Workbook.xls”) was developed to create the IREP annual organ 

dose input data.”

3.5.2 Review Protocol

As part of the first set of procedures/guidance documents selected by the Advisory Board for 

review, SC&A evaluated ORAUT-OTIB-0003, Savannah River Site Tritium Dose Assignment, 

which has been replaced by ORAUT-OTIB-0011. Our findings were published in The Review of 

NIOSH/ORAUT Procedures and Methods Used for Dose Reconstruction, dated January 2005 

(SCA-TR-Task3). Following the submission of this report and its findings, an expanded review 

and issues-resolution process was initiated. The process began by NIOSH providing written 

responses to each of SC&A’s findings. Under the direction of a Board-appointed Work Group, a 

series of meetings was held between representatives of NIOSH and SC&A auditors to discuss 

and resolve each finding. This process resulted in the preparation of an issues-tracking matrix, 

whereby the closeout status of each finding is tracked. 
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The resolution of many findings identified during our review of ORAUT-OTIB-0003 required 

NIOSH to incorporate appropriate changes into their replacement document (i.e., ORAUTOTIB-0011). Our evaluation of ORAUT-OTIB-0011, therefore, was designed to ensure that 

(1) the findings identified in ORAUT-OTIB-0003 were adequately resolved, and (2) the 

document adequately supports the dose reconstruction process. Table 3.5-1 provides a list of 

applicable findings from our review of OTIB-0003 and the results of our evaluation to assess 

whether those findings were adequately addressed in this replacement document. As is shown in 

the Table 3.5-1, all findings that were identified in OTIB-0003 have been resolved with the 

issuance of OTIB-0011. 

Table 3.5-2 is a checklist containing SC&A’s evaluation of procedural objectives developed 

under the first phase of Task 3, as described in the introduction to this report.

Table 3.5-1. Evaluation of Findings Identified in the Review of ORAUT-OTIB-0003, 

Rev. 0

Review 

Objective

ORAUT-OTIB-00003 Rev. 0 

Finding Description

Corrected in 

OTIB-0011 Comments

1.1/1.3 Document contains flowcharts 

intended to provide the logic for 

assignment of tritium dose at SRS 

that are not self-explanatory or clear. 

(Finding No. OTIB-0003-1)

Yes Flowcharts have been eliminated in OTIB0011. A “Tritium Doses from Urine Data 

Workbook.xls” workbook has now been 

designed to automate the reconstruction of 

these doses.

1.4 Guidance in this document describes 

an approach for assigning missed 

dose for tritium, while ORAUTOTIB-0001 provides another 

approach. There is no guidance 

regarding when OTIB-0003 should be 

used as opposed to OTIB-0001. 

(Finding No. OTIB-0003-2)

Yes OTIB-0003 was written specifically for SRS; 

however, the replacement guidance (i.e., 

OTIB-0011) is a generic document that can 

apply to all sites. In addition, guidance in 

OTIB-0001 specifically states that it is to be 

used for SRS maximizing (noncompensable) 

cases.

5.1–5.3 Doses due to organically bound 

tritium are not included in this 

procedure for calculating tritium and 

are, therefore, not claimant favorable. 

(Finding No. OTIB-0003-3)

Yes The issue of organically bound tritium has 

been addressed in OTIB-0011. It is assumed 

that 3% of tritiated water incorporated into 

the body represents organically bound 

tritium.
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Table 3.5-2. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0011, Rev. 00 Effective Date: 06//29/2004

Document Title: Tritium Calculated and Missed Dose Estimates

Reviewer: Bruce Murray

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? 5

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does not 

reference other sources that are needed for additional data)? 4

See Review 

Comments

1.4 Is the procedure consistent with all other procedures that are part 

of the hierarchy of procedures employed by NIOSH for dose 

reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize the 

need for subjective decisions and data interpretation? 4

See Review 

Comments

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?

5

2.2 Conversely, for claims with suspected cumulative low doses,

does the procedure provide clear guidance in defining worst-case 

assumptions?

5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is it 

free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

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) N/A

3.2.2 In vivo/In vitro bioassays 5

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure 4See Review 

Comments

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? 5

4.2 Does the procedure adhere to the hierarchical process as defined 

in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where claimant 

was not monitored? 5

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)? 5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only limited 

significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

____________

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

3.5.3 General Comments

ORAUT-OTIB-0011 provides guidance for reconstructing doses for workers exposed to tritiated 

water using the results of either complete or incomplete bioassay programs. It also addresses 

special situations where two different bioassay measurements have the same bioassay date and 

time. 

The algorithm described in ORAUT-OTIB-0011 is based on the assumption that dose to the 

whole body is proportional to the area under a urine concentration curve. The ORAUT-OTIB0011 algorithm is currently implemented in an EXCEL worksheet (“Tritium Doses from Urine 

Data Workbook.XLS”). The basic assumptions used in this OTIB are as follows: 
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 Tritiated water is assumed to be completely and instantly absorbed into the systemic 

circulation, whether taken in by inhalation, injection, or absorption by the intact skin.

 Tritiated water equilibrates with the body water, and therefore, all body fluids, including 

urine, is assumed to be equal.

 Instantaneous measurements of the concentration of tritium in urine can be used to 

directly estimate the effective dose from intakes of tritiated water. 

 Urine measurements of tritium are considered to be in direct proportion to a body’s water 

tritium concentration.

 The area under a urine concentration “curve” is directly proportional to effective dose. 

Using these basic assumptions, a two-compartment biokinetic model is used to reconstruct the 

doses from urine data, and is in accordance with ICRP Publication 56, where 97% is 

incorporated as tritiated water and 3% as organically bound tritium (OBT). The dosimetry 

factors are as follows:

Radiological Half-Life 12.35 years See footnote 7

Biological Half Life 9.7 days ICRP 66 rounds to 10 days

HTO Dose Coefficient 1.8E-11 Sv/Bq From ICRP publication 68 

Clearance Rate Constant (k) 7.14E-2 d-1 Discussed below as a note

Effective dose to decay value 1.5 E-15 rem/decay

In addition, the OTIB algorithm uses as a “k” clearance constant of 7.14E-2 d-1derived from a 

reference man removal of 3 liters/day of the 42 liters of body water (i.e., 1.4 L/day are removed 

as urine). 

The algorithm in the workbook is designed to calculate the doses using sequential and 

comparative “If” statements. The comparative process uses sample data, time intervals, and 

sample sensitivity (Minimum Detectable Activity (MDA)). The OTIB provides a thorough 

description of the formulas used in the Excel workbook. The workbook presents simplified 

equations with graphic illustrations of the urine concentrations over sampling time intervals. The 

area under each curve representing each time interval is directly proportional to the dose 

delivered to internal organs over those time intervals. 

3.5.4 Review Comments

Our review of the assumptions employed in the model reveals that, overall, they are consistent 

with the referenced and pertinent literature. SC&A finds that this document has been 

satisfactorily prepared; however, we have identified a few minor issues, as follows:

 

7 Radioactive decay is insignificant in this determination, because the biological clearance “... surpasses 

the physical half-time of 12 years” (PNNL–MA-860, Chapter 4).
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Review Objectives 1.3, 1.5, and 3.2.4

A full understanding of this OTIB requires a review of the workbook. In this regard, the OTIB is 

not entirely complete. It is not until the workbook is reviewed that the user is informed that an 

assumed tritium level can be input into the calculation for those time periods when no urine 

samples were taken, but there is reason to believe that the worker, in fact, could have 

experienced exposure to tritium. Section 4.1 of the OTIB would benefit from a discussion of the 

fact that the workbook provides for this contingency. In addition, some guidance is needed 

regarding when the dose reconstructor should take advantage of this feature of the workbook. 

For example, if 40 days have passed since the last urine sample, and there is reason to believe 

that the worker may have experienced continual exposure to tritium, the dose reconstructor 

should consider inputting a surrogate bioassay result for that time period. This situation could 

arise if the worker’s job description remained unchanged and air sampling indicates that the 

worker likely continued to experience exposure to tritium.

Review Objective 7.3

ORAUT-OTIB-0011 is based on the assumption that tritiated water is instantaneously absorbed 

and distributed throughout body water. Our review of relevant literature (e.g., Methods and 

Models of the Hanford Internal Dosimetry Program, Hanford Internal Dosimetry Technical 

Basis Manual, PNNL-MA-860) indicates that absorption and distribution of tritium requires 

about 2 hours. This may be relevant for the special circumstance when multiple samples of urine 

are collected the same day, but have markedly different tritium concentrations. The document 

would benefit from a discussion of this matter as it applies to the special conditions discussed in 

Section 3 of the OTIB.

3.6 ORAUT-OTIB-0019: ANALYSIS OF COWORKER BIOASSAY DATA FOR 

INTERNAL DOSE ASSIGNMENT

The review of ORAUT-OTIB-0019, Analysis of Coworker Bioassay Data for Internal Dose 

Assignment, Rev 01, dated October 7, 2005, was prepared by Harry Chmelynski, PhD, and 

approved by John Mauro, PhD, CHP, on March 3, 2006.

3.6.1 Purpose of Procedure

This OTIB provides guidance for assigning internal doses to workers using co-worker bioassay 

data for workers who do not have bioasssay data, but the possibility exists that the worker may 

have experienced internal exposures. 

3.6.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0019 is summarized in Table 3.6-1 below. Table 3.6-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 3.6-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0019, Rev. 01 Effective Date: 10/07/2005

Document Title: Analysis of Coworker Bioassay Data for Internal Dose Assignment

Reviewer: Harry Chmelynski, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ----

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

N/A

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 4

See review comments

_________________

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

3.6.3 General Comments

The purpose of ORAUT-OTIB-0019 is to provide guidance for the use of bioassay data in the 

statistical analysis of worker intake rates. The recommended statistical methods are designed to 

provide estimates of lognormal distribution parameters based on minimal information. The 

proposed method has two components; (1) obtain estimates of the geometric mean and the GSD 

from the ranked observations, and (2) perform a regression analysis to verify that the lognormal 

distribution provides a good fit to the data. The recommended procedures are not necessarily the 

most efficient methods for estimating parameters of the lognormal distribution, but were 
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designed to provide estimates of the lognormal parameters for a relatively large number of 

disparate data sets, many of which include recorded data entries that are below the minimum 

detectable level, or data entries that are recorded as zero or “less than x.” The recommended 

statistical methods avoid many of the problems commonly encountered when fitting the 

lognormal distribution to censored data sets of this type.

Assuming the data are well fitted by a lognormal distribution, the 50th percentile (i.e., the 

median) is used to estimate the geometric mean of the lognormal distribution. The OTIB 

recommends that an estimate of the GSD is obtained from the ratio of the 84th percentile to the 

50th percentile (see Strom and Stansbury 2000, Equation 7). The recommended procedures 

eliminate the need to define a minimum detectable activity (MDA) or amount that is appropriate 

for the measurements by basing all parameter estimates on the 50th and 84th percentiles. Hence, 

if no more than 50% of the measurements are below the MDA, no assumption concerning the 

MDA is necessary to obtain the lognormal parameter estimates. 

The ORAUT-OTIB proposes that a determination of the goodness-of-fit of a lognormal 

distribution to a data set of size n is to be based on regression analysis. Specifically, the 

following recommendations are made in Section 3.4 of ORAUT-OTIB-0019:

Calculate the associated R2fit parameter. A value greater than 0.9 indicates a 

very good fit; however, values as low as 0.7 are acceptable, and even lower 

values may be acceptable if no better equation seems appropriate.

3.6.4 Review Comments

Review Objective 7.3

It is difficult to determine the source and applicability of the OTIB recommendations regarding 

goodness of fit. Our concerns are based on the known dependencies that exist in the regression 

derived from ranked data.

The regression model addressed in this recommendation is written as follows:8

ln(yi) = a + b xi

where the independent variables yi (i = 1, ... , m ≤ n) denote the observed values, the explanatory 

variables xi denotes the normal score of each observation, and a and b denote the intercept and 

slope of the regression line, respectively. If the data follow a lognormal distribution with 

parameters μ and σ, then a scatterplot of the points ( xi , ln(yi) ) will lie on a straight line with 

slope b = σ and intercept a = μ.

Note that the regression method may be used not only to verify that the data follow a lognormal 

distribution, but also to provide alternative estimates for the parameters of the lognormal 

distribution when there are values in the data set below the MDA. Since the regression-based 

 

8

 It is far more common to use the symbol zi for the normal score variate, but the use of xi as the 

explanatory variable in a regression takes priority in this discussion.
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estimates are based on the entire set of data above the MDA, they may be preferred over the 

minimal information estimates currently recommended. This is particularly true for the estimate 

of the GSD, which is based on the ratio of the 84th to the 50th percentiles.

When the points in the scatterplot do not all lie on a straight line, it is recommended that the R2

of the regression be examined to determine if the data is fitted approximately by a lognormal 

distribution. The authors fail to warn that the R2of this regression should be interpreted with 

care. Note that the data values in the scatterplot are not independent observations. Indeed, if 

xi ≤ xj then it is known with certainty that yi ≤ yj. This dependence among the observations 

violates the usual assumption of conditional independence of the y values in the regression, 

given the corresponding x values. 

In general, the interpretation of R2 when there is known conditional dependence and censored 

data is not a simple matter. As a result of the dependency, the observed R2value may be 

seriously over-inflated. The subject was explored long ago by Looney and Gulledge. Using a 

very similar scatterplot and regression-model approach to estimate the parameters of a normal 

distribution, they provide tables based on simulation studies that may be used to adjust the 

observed R2values to account for conditional dependence (with no censored data). 

Extrapolation to the censored data case does not appear to be a straightforward extension of their 

results. 

The recommendations quoted above from Section 3.4 for interpreting the regression R2do not 

appear to take this deviation from the standard regression model assumptions into account. Note 

that the conditional dependence does not result in biased regression parameter estimates for μ 

and σ, only the interpretation of the R2value as a goodness-of-fit statistic. Hence, the regression 

estimates remain a valid “reality check” for the minimal information parameter estimates 

currently recommended.

References:

Looney, S.W. and T.R. Gulledge, Jr. 1985. “Use of the Correlation Coefficient with Normal 

Probability Plots,” American Statistician, Vol. 39, No. 1, February 1985, pp. 75–79.

Strom, D.J., and P.S. Stansbury 2000, “Determining Parameters of Lognormal Distributions from 

Minimal Information.” American Industrial Hygiene Association Journal, Volume 82, pp. 877–

880, eq. 7. 

3.7 ORAUT-OTIB-0012: MONTE CARLO METHODS FOR DOSE UNCERTAINTY 

CALCULATIONS

The review of ORAUT-OTIB-0012, Monte Carlo Methods for Dose Uncertainty Calculations, 

Rev 00, dated January 14, 2005, was prepared by Harry Chmelynski, PhD, and approved by John 

Mauro, PhD, CHP, on March 3, 2006.
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3.7.1 Purpose of Procedure

This OTIB presents an efficiency method applied to Monte Carlo methods which yields best 

estimate organ doses. Implementation of this method allows the generation of site-specific 

reference tables for use in best-estimate dose reconstructions without requiring individual Monte 

Carlo simulations.

3.7.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0012 is summarized in Table 3.7-1 below. Table 3.7-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.

3.7.3 General Comments

This ORAUT-OTIB presents a method for estimating doses by multiplying the annual dosimeter 

dose by an organ-specific dose conversion factor (DCF). Both quantities in this product have 

associated probability distributions, which reflect measurement error in the dosimeter readings 

and uncertainty in the DCF. The organ dose is thus a product of two random variables. NIOSH 

has assigned normal distributions for the dosimeter measurements and triangular distributions for 

the DCFs. Since the product of a normal variate times a triangular variate has no simple 

mathematical expression, the distribution of the products is simulated using a Monte Carlo 

simulation program, such as Crystal Ball.

The ORAUT-OTIB-0012 methodology provides a way to avoid the need for simulation by 

preparing tables that allow the user to approximate the distribution of the product doses for each 

organ. The approximation is derived by fitting normal distributions to samples of the organ dose 

products obtained for normal distributions with measurement errors ranging from 5% to 100%. 

The authors provide an example of the fitted normal distribution obtained for one organ and one 

level of measurement error.
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Table 3.7-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0012, Rev. 00 Effective Date: 02/14/2005

Document Title: Monte Carlo Methods for Dose Uncertainty Calculations

Reviewer: Harry Chmelynski

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure N/A

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? N/A

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? N/A

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? 5

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

___________________________ 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). NA indicates not applicable.

3.7.4 Review Comments

As part of this review, the Excel add-in program Crystal Ball 2000 was used to determine if the 

fitted normal distribution obtained in this example is appropriate. A set of 10,000 values was 

generated as the product of a normal random variable and an independent random variable with a 

triangular distribution. The normal random variable, which reflects the uncertainty in the 
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dosimeter reading, has a mean of zero and a standard deviation9of 0.10. The triangular 

distribution chosen as an example of the procedure reflects the error for the 30 to 250 keV 

photon DCF for the colon. The selected triangular distribution is one example of many such 

distributions used in the dose reconstruction modeling. The selected triangular distribution has 

parameter values of Min=0.23, Mode=0.75, and Max=0.80.

Crystal Ball was used to simulate 10,000 products of these two random variables. The batch-fit 

feature in Crystal Ball was used to fit a distribution to the 10,000 products. The KomolgorovSmirnov (K-S) and the Anderson-Darling (A-D) test statistics were used as criteria to determine 

the best-fitting distribution. The K-S test is based on the maximum vertical distance between the 

empirical CDF of the 10,000 observations and the fitted distribution. The A-D test is similar to 

the K-S test, but more weight is given to the fit in the tails of the distribution. For both tests, the 

lowest value of the test statistic indicates the best fit. 

The results, shown in Figure 1, indicate that the beta distribution was found to be the best-fitting 

distribution under both criteria. In both cases, the second-best fit was obtained using a Weibull 

distribution. The normal distribution ranks third when using the A-D criterion, and fourth when 

using the K-S criterion. 

The parameters of the best-fitting beta and normal distributions were determined using the 

Crystal Ball distribution-fitting procedure. The best-fitting beta and normal distributions are 

shown in Figures 2 and 3. The beta distribution with the best fit has parameters alpha=6.981, 

beta=5.292, and scale=1.044. The best-fitting normal distribution has a mean of 0.594 and a 

standard deviation of 0.142. Note that the normal distribution parameter estimates exactly match 

those reported in Section 3.1 of ORAUT-OTIB-0012.

Two samples of size 10,000 were simulated in Crystal Ball 2000 using the fitted beta and normal 

distribution with parameters stated above. Despite the clearly better fit of the beta distribution 

based on the statistical tests, there is little difference in the statistics obtained from the two 

simulated data sets, as shown in Figure 4. This confirms that the best-fitting normal distribution 

provides a good approximation for the distribution of the product organ doses in the example 

selected. If the normal distributions for the dosimeter reading have a larger standard deviation 

than the 0.10 value in this example, it is likely that a normal distribution will continue to provide 

a good approximation to the distribution of the product’s organ doses.

Care must be taken to ensure that the appropriate row in the tables is used, as determined by the 

estimated percent measurement error in the dosimeter readings for each case.

 

9

In the second paragraph of ORAUT-OTIB-0012, Section 3.1, the standard deviation for the dosimeter 

readings in Table 1 is stated as 0.32 (32%). This appears to be a typographical error, perhaps one that remains from 

a previous version of the document. The referenced Table 1 shows that the standard deviation of the dosimeter 

readings is 0.10 (10%). Results obtained here using a 10% standard deviation agree with subsequent results quoted 

in the document.
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Figure 3.7-1. K-S and A-D Statistics for All Distributions Fitted to a Sample of 10,000 Products using 

Crystal Ball 2000 Batch Fit Procedure 
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Figure 3.7-2. The Best-Fitting Beta Distribution, Fitted to the Sample of 10,000 Produc

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Figure 3.7-3. The Best-Fitting Normal Distribution, Fitted to the Sample of 10,000 Produ

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Figure 3.7-4. Comparison of Statistics Obtained from Samples of Size 10,000 from the Best-Fitting Beta Distribution and the 

Best-Fitting Normal Distribution
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3.8 ORAUT-OTIB-0033: APPLICATION OF INTERNAL DOSES BASED ON 

CLAIMANT-FAVORABLE ASSUMPTIONS FOR PROCESSING BEST 

ESTIMATES 

The review of ORAUT-OTIB-0033, Application of Internal Doses Based on ClaimantFavorable Assumptions for Processing Best Estimates, Rev. 00, dated April 20, 2005, was 

prepared by John Mauro, PhD, CHP, and approved by Hans Behling, PhD, on May 30, 2006.

Before proceeding with this review, it is important to point out that, during the preparation of this 

report, SC&A participated in the full Board meeting held in Denver CO on April 25–27, 2006. 

During that Board meeting, Knut Ringen, DrPH., MHA., MPH, Science Advisor to the Center to 

Protect Worker Rights, gave a presentation and provided handouts that contained a wealth of 

information pertinent to the reconstruction of doses to construction workers. In addition, Mr. 

Ringen provided SC&A with the names of experts on this subject. This OTIB could be 

considered especially relevant to construction workers because these workers often were not 

monitored, and the default protocols provided in this OTIB may appear to be appropriately 

applied to this class of workers, but, as indicated by Dr. Ringen, the potential for exposure of 

construction workers among sites and at different times and locations at a give site, were highly 

variable. Hence, this OTIB may have certain limitations as applied to some construction 

workers. In addition, it is SC&A’s understanding that data and protocols specifically for the 

reconstruction of doses to construction workers are areas of active investigation at NIOSH. 

Given the complexity of the issues and the fact that it is an area of active investigation, SC&A 

believes that the findings of this review be used with caution as they apply to construction 

workers. This concern is especially pertinent to OTIB-0018, which is subsumed within this 

OTIB-0033.

3.8.1 Purpose of Procedure

The stated purpose of this OTIB is to provide the following: 

...a graded approach to the application of overestimated internal doses in Oak 

Ridge Associated Universities (ORAU) Team TIB (ORAUT-OTIB) ORAUT-OTIB0018, Internal Dose Overestimates for Facilities with Air Sampling Programs, for 

processing cases in the absence of complete information. ORAUT-OTIB-0018 

was written to be applied as an overestimate for workers with no significant 

intakes of particulate radioactive material. Because it was intended to be used 

only as an overestimate, it did not consider additional factors that could limit the 

upper bound for certain types of workers.

These factors include:

 The period during which the energy employee worked,

 The processes conducted at the site at which the energy employee worked,

 The job category and work location of the energy employee, and

 The results of bioassay measurements for the energy employee.
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These factors are addressed here to enable application of the values in ORAUTOTIB-0018 in a graded manner as the best available estimate in the absence of 

specific site or individual information, when appropriate.

3.8.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0033 is summarized in Table 3.8-1 below. Table 3.8-1 is 

a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.

3.8.3 General Comments

This OTIB is important because it represents the integration of several OTIBs (i.e., ORAUTOTIB-0014, ORAUT-OTIB-0018, ORAUT-OTIB-0002, and ORAUT-OTIB-0033) in a manner 

that allows for a graded approach for reconstructing best estimates of internal doses in a 

claimant-favorable manner, and under a wide range of conditions where there may be limited 

bioassay data. In addition, since this OTIB is considered a realistic approach to dose 

reconstruction, it can be used to grant or deny claims. Though it is represented as being a 

realistic approach, it is also represented as claimant-favorable for (1) a wide range of exposure 

settings, (2) conditions where bioassay and air sampling data are of limited availability, and (3) a 

wide range of job descriptions. In many respects, this OTIB establishes a framework for dose 

reconstructions for classes of workers that may be considered potential Special Exposure Cohort 

candidates. As such, the philosophy adopted in this OTIB, along with the strategy for 

implementing that philosophy, is fundamental to the reconstruction of doses for many classes of 

workers at virtually every facility, including construction workers.

This section describes the OTIB strategy for the reconstruction of internal doses (as understood 

by SC&A), and discusses the areas where we believe the approach may or may not be entirely 

scientifically sound and/or claimant favorable, and areas where considerable judgment is 

required by the dose reconstructor in order to implement this OTIB. This latter aspect of our 

review is considered important because, if a great deal of judgment is required to implement this 

OTIB, it raises concerns about the degree to which the OTIB can be implemented in a consistent 

manner. Before proceeding with the review, it is important to understand that ORAUT-OTIB0033 is the culmination to date of a complex array of guidelines that have evolved over time as a 

means to complete the dose reconstruction process. As a result, in order to understand ORAUTOTIB-0033 and its strengths and limitations, the role and strengths and limitations of ORAUTOTIB-0002, ORAUT-OTIB-0014, and ORAUT-OTIB-0018 are needed. Hence, this review also 

addresses these OTIBs.

 
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Table 3.8-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0033 Effective Date: 04/20/2005

Document Title: Application of Internal Doses Based on Claimant-Favorable Assumptions for 

Processing as Best Estimates

Auditor: John Mauro

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 3

It references other 

related NIOSH and 

ORAUT document, 

but this is not a 

problem.

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3

See review comments

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is it 

free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

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) N/A

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 3

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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ORAUT-OTIB-0033 uses a 3-dimensional matrix for identifying and reconstructing the internal 

doses to classes of workers, as follows:

By Exposure Potential

 Seldom exposed to airborne radionuclide concentrations above outdoor environmental 

levels

 Intermittently exposed above outdoor environmental levels

 Routinely exposed above outdoor environmental levels

By Time Period of Exposure

 Pre- vs. post-1989. This date demarcates the implementation of DOE Order 5480.11, 

Radiation Protection for Occupational Workers. Following this date, radiation protection 

programs became more robust, and there is a high degree of confidence that, if a worker 

entered an area where the airborne radionuclide concentrations exceed 10% of the 

derived air concentrations (DACs), that worker would wear respiratory protection and 

would be covered by a bioassay program. 

By Bioassay Program

 A distinction is made between individuals who were routinely monitored versus 

unmonitored under a bioassay program.

For workers without routine bioassay, the dose reconstructor is instructed to place the worker 

into one of five categories based on exposure potential and time period of exposure. Category 1 

is defined as all workers over all time periods that had very little potential for internal exposure. 

Under these conditions, the dose reconstructor is instructed to use ORAUT-OTIB-0014. 

ORAUT-OTIB-0014 assists the dose reconstructor in identifying workers with a low potential 

for internal exposure by providing a list of job categories and work locations with very limited 

potential for inhalation exposure. However, ORAUT-OTIB-0014 cautions the dose 

reconstructor that there will be exceptions to the general guidance provided. Once it is 

determined that the worker did, in fact, have very little potential for internal exposure, ORAUTOTIB-0014 instructs the dose reconstructor to assume that the only source of internal exposure 

for that worker was to the radionuclide levels in the outdoor environment onsite. Under these 

circumstances, the dose reconstructor is directed to Part 4 of the site profile for that facility, 

which provides instruction on reconstructing outdoor environmental doses to workers at that site. 

This general strategy certainly appears reasonable, as long as there is a high level of assurance 

that the worker did not encounter any unusual conditions while working, including exposures 

resulting from incidents that are not addressed in the site profiles. In addition, during the early 

years of operations at a given facility, it may not be self-evident that the worker did not 

experience elevated levels of airborne radionuclides, notwithstanding his job category. Hence, in 

principal, the guidance is reasonable, but in practice it may be difficult to implement with a high 

degree of confidence, especially for the early years at a given facility. However, the OTIB 

acknowledges this limitation.
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Unmonitored worker Categories 2 and 3 in ORAUT-OTIB-0033 consist of workers with only 

intermittent potential for internal exposure. Category 2 applies to pre-1989 workers, and 

Category 3 applies to post-1989 workers. For Category 2 workers, the dose reconstructor is 

instructed to assume that the worker was exposed to airborne particulates that are at 50% of the 

concentrations listed in ORAUT-OTIB-0018, while for post-1989 workers, 5% of the 

concentrations in ORAUT-OTIB-0018 are to be used. 

ORAUT-OTIB-0018 is reviewed separately in this report. However, in order to place the role of 

ORAUT-OTIB-0018 into proper context in terms of its integration into ORAUT-OTIB-0033, a 

brief overview of ORAUT-OTIB-0018 is in order. ORAUT-OTIB-0018 is designed to be used 

to deliberately overestimate internal doses for unmonitored workers at facilities with airborne 

monitoring programs. It is intended to be used as an alternative to ORAUT-OTIB-0002. Hence, 

before discussing ORAUT-OTIB-0018, a brief overview of ORAUT-OTIB-0002 is needed.10 

ORAUT-OTIB-0002 is to be used as an efficiency tool for placing an unrealistic upper bound on 

the internal doses to workers who could not possibly have experienced organ doses that even 

approach a POC of 50%. This judgment could be based on data from air-sampling programs, 

bioassay data, job descriptions, and process knowledge, and with due consideration of the organ 

of concern. However, ORAUT-OTIB-0002 acknowledges that there could be undiscovered 

intakes that were missed by the monitoring programs. In light of this possibility, and in the 

interest of avoiding the investment of large amounts of time and resources that would be required 

to investigate such a possibility, ORAUT-OTIB-0002 simply postulates that the worker 

experienced an unrealistically high, one-time intake of radionuclides on the first day of the 

worker’s employment at the facility. The postulated intake is based on multiples of the 

maximum permissible body burdens (MPBBs) for radionuclides, as listed in NCRP 1989. This 

fundamental approach is premised on the assumption that it is unlikely that a one time exposure 

of 10% of the MPBB would go unnoticed by an air sampling or bioassay program for 

radionuclides with low solubility. For radionuclides with higher solubility (i.e., Type M and F), 

a bioassay program could, in theory, miss such an exposure, because Type M and S materials are 

rapidly cleared from the body. For Type M and S radionuclides, the intakes are assumed to 

correspond to 1 times the MPBB and 2 times the MPBB, respectively. The ORAUT-OTIB also 

makes a distinction between reactor and non-reactor facilities in the list of radionuclides to be 

used in the calculation. ORAUT-OTIB-0002 also gives special consideration to tritium, 

radioiodines, and uranium; the employee’s date of initial hire; the target organ; the extent of his 

bioassay program; and numerous other constraints and considerations described in the ORAUTOTIB and reviewed in SC&A’s January 2005 Task 3 report. A workbook that has been 

reviewed by SC&A implements the entire ORAUT-OTIB-0002 guideline. The bottom line is 

that ORAUT-OTIB-0002 is appropriate when used for its intended purposes and when there is 

assurance that unusual circumstances don’t exist where the approach may not necessarily be 

bounding.

ORAUT-OTIB-0018 provides an alternative to ORAUT-OTIB-0002 as a means to overestimate 

internal doses with somewhat more realistic assumptions than those employed in ORAUTOTIB-0002. ORAUT-OTIB-0018 goes a step further than ORAUT-OTIB-0002, because it 

describes and presents the limits on airborne radionuclide concentrations that were established at 

 

10 Note that ORAUT-OTIB-0002 was reviewed as part of SC&A Task 3 report dated January 2005.
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different times by standard-setting bodies and by regulation. The time period covered in 

ORAUT-OTIB-0018 begins with the NBS guidelines established in 1953 and goes up to limits 

established by DOE in 10 CFR Part 835, which were implemented in 1993. For some 

radionuclides, the standards became more restrictive over time, but for other radionuclides, the 

standards were actually slightly relaxed.

ORAUT-OTIB-0018 provides direction that takes into consideration the standards that were in 

place at a given point in time. This OTIB can be used for employment periods from 1953 to the 

present, and for workers who, in all likelihood, did not experience significant exposure to 

airborne particles. In addition, ORAUT-OTIB-0018 is only to be used for facilities that 

rigorously monitored airborne particulates, and met a number of other constraints and 

qualifications. Given the standards as a function of time, and the applicability and limitations of 

the guidance as specified in ORAUT-OTIB-0018, ORAUT-OTIB-0018 presents a recommended 

array of default airborne radionuclide concentrations that are recommended for dose 

reconstructions for different facilities and time periods of exposures, along with default breathing 

rates and exposure durations. Mr. Ringen makes specific reference to this OTIB and its 

assumptions as being inappropriate for at least some construction workers. 

For facilities that handled recycled uranium, ORAUT-OTIB-0018 recommends default intakes of 

Pu-238, Np-237, Tc-99, Th-232, and Ru-106, expressed in terms of pCi of each radionuclide per 

pCi of U. For sites where the specific airborne radionuclides are not known because only gross 

alpha and gross beta/gamma counts were made, ORAUT-OTIB-0018 recommends assuming that 

the airborne activity is entirely comprised of the radionuclide and chemical forms with the 

highest dose conversion factors for the organs of concern. Finally, in light of the many 

uncertainties associated with characterizing the airborne radionuclide concentrations actually 

inhaled by a given worker, ORAUT-OTIB-0018 recommends assuming that each recommended 

default radionuclide concentration is the geometric means of lognormal distribution with a 

standard deviation of 3. Again, this assumption regarding the variability and uncertainty in the 

potential airborne exposures, as applied to construction workers, was criticized by Mr. Ringen. 

Given the array of guidance provided in ORAUT-OTIB-0018, ORAUT-OTIB-0033 recommends 

using 50% of the ORAUT-OTIB-0018 default values for workers exposed before 1989 and 5% 

of the default values for those exposed following 1989. It is clear that these recommendations 

appear somewhat arbitrary. However, when one considers that these guidelines only apply to 

workers that were intermittently exposed, the guidance does not appear to be unreasonable. 

ORAUT-OTIB-0033 defines unmonitored worker Category 4 and Category 5. Both categories 

apply to workers who routinely experienced exposures above environmental levels. Category 4 

applies to pre-1989 workers and Category 5 applies to post-1989 workers. For Category 4, 

ORAUT-OTIB-0033 recommends using co-worker data to reconstruct doses, and, if these data 

are not available, it recommends using ORAUT-OTIB-0018. For post-1989 workers, ORAUTOTIB-0033 recommends using co-worker data, and, if these data are not available, it 

recommends using 10% of ORAUT-OTIB-0018 default values.

This overall strategy for reconstructing the internal doses to unmonitored workers seems well 

considered and reasonable. It acknowledges the limitations of the methodologies and properly 
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cautions the dose reconstructor to conditions where the default assumptions may not be claimantfavorable. A limitation of the procedure is its heavy reliance on the judgment of the dose 

reconstructor in categorizing the workers and factoring in special circumstances. Also, no 

guidance is provided on how to use co-worker data. For example, should the dose reconstructor 

use the full distribution of the co-worker data, or the 95th percentile value?

For all monitored workers and all time periods, if the results of bioassays are less than the MDAs 

(as defined in Table 7-1 of ORAUT-OTIB-0018), ORAUT-OTIB-0033 recommends using coworker data. Again, no guidance is given regarding how this is accomplished.11 If the co-worker 

data are judged to be inadequate, ORAUT-OTIB-0033 recommends using missed dose protocols. 

However, the OTIB is deficient, in that it neglects to refer the reader to the missed dose 

guidance. ORAUT-OTIB-0033 also provides the dose reconstructor with the option of 

defaulting to ORAUT-OTIB-0018 guidance as a third means of reconstructing the internal doses 

for workers whose bioassay results are below the MDAs. However, ORAUT-OTIB-0033 

cautions the dose reconstructor not to default to ORAUT-OTIB-0018 under these circumstances 

if the POC is greater than 47%. If it is, a missed dose calculation should be employed. Again, 

no reference or guidance is provided on how to perform a missed dose calculation.

Finally, for all workers that have positive bioassay results, or are known to have been involved in 

incidents, ORAUT-OTIB-0033 recommends using IMBA to reconstruct internal doses. As an 

alternative, ORAUT-OTIB-0018 may be used, along with bioassay results, as long as the results 

are less than a POC of 47%. In referring to using IMBA as a means to reconstruct internal doses 

from bioassay data, which could reflect chronic, intermittent, or incident exposures, reference 

should be made to the guidance provided in OCAS-IG-002.

3.8.4 Review Comments

Review Objectives 1.5 and 7.1

A considerable amount of judgment is required by the reviewer in assigning workers to a given 

exposure category and determining how best to go about using co-worker data and performing 

missed dose calculations. 

Reference:

NCRP 1959, National Bureau of Standards, Maximum Permissible Body Burdens and Maximum 

Permissible Concentrations in Air and Water for Occupational Exposures. NBS Handbook 69 

(also referred to as NCRP Publication 22), NBS, Washington, DC.

 

11 At the time of the preparation of this review, SC&A was informed that numerous initiatives are underway 

at NIOSH to develop guidance pertaining to the use of co-worker data.
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3.9 ORAUT-OTIB-0004, REVISION 3: ESTIMATING THE MAXIMUM 

PLAUSIBLE DOSE TO WORKERS AT ATOMIC WEAPONS EMPLOYER 

FACILITIES

The review of ORAUT-OTIB-0004, Estimating the Maximum Plausible Dose to Workers at 

Atomic Weapons Employer Facilities, Rev. 03 PC-1, dated November 18, 2005, was prepared by 

Nicole Briggs, John Mauro, and Robert Anigstein, and approved by John Mauro, PhD, CHP, on 

May 23, 2006. The ORAUT-OTIB-0004 review was amended by Kathleen Behling in July 

2007.

3.9.1 Purpose of Procedure

The purpose of this document is to provide guidance for estimating the maximum plausible dose 

to workers at AWEs. This document describes an efficient process that may be used to expedite 

the processing of claims requiring dose reconstruction under EEOICPA. The exposure matrix in 

this document is designed for estimating the maximum plausible annual dose in all organs with 

the exception of the lung, skin, breast, eye, and testes, except when the testes dose is used as 

an analog for the prostate. 

3.9.2 Review Protocol

As part of the first set of procedures/guidance documents selected by the Advisory Board for 

review, SC&A evaluated ORAUT-OTIB-0004, Rev. 02, dated December 4, 2003. Our findings 

were published in The Review of NIOSH/ORAUT Procedures and Methods Used for Dose 

Reconstruction, dated January 2005 (SCA-TR-Task3). Following the submission of this report 

and its findings, an expanded review and issues-resolution process was initiated. The process 

began by NIOSH providing written responses to each of SC&A’s findings. Under the direction 

of a Board-appointed Work Group, a series of meetings was held between representatives of 

NIOSH and SC&A auditors to discuss and resolve each finding. This process resulted in the 

preparation of an issues-tracking matrix, whereby the closeout status of each finding is tracked. 

The resolution of many findings identified during our review of ORAUT-OTIB-0004, Rev. 02, 

required NIOSH to incorporate appropriate changes into a future revision of the guidance 

document. Our evaluation of ORAUT-OTIB-0004, Rev. 03 PC-1, therefore, was designed to 

ensure that (1) the findings identified in ORAUT-OTIB-0003 were adequately resolved, and 

(2) the document adequately supports the dose reconstruction process. Table 3.9-1 provides a 

list of applicable findings from our review of OTIB-0004 and the results of our evaluation to 

assess whether those findings were adequately addressed in this replacement document. 

Table 3.9-2 is a checklist containing SC&A’s evaluation of procedural objectives developed 

under the first phase of Task 3, as described in the introduction to this report.
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Table 3.9-1. Evaluation of Findings Identified in the Review of ORAUT-OTIB-0003, 

Rev. 0

Review 

Objective

ORAUT-OTIB-0004 Rev. 02

Finding Description

Corrected in

OTIB-0004, 

Rev. 03 PC-1

Comments

1.1 Several sections of the document 

are ambiguous (e.g., procedure not 

explicit on how to add ingestion and 

inhalation doses). (Finding OTIB0004-01)

Yes OTIB-0004, Rev. 03 PC-1, is a complete 

rewrite of Rev. 02, and clarifies the previously 

cited ambiguities and provides the dose 

reconstructor with more prescriptive 

information.

1.3 Procedure is incomplete regarding 

required data (i.e., data used in 

deriving assumptions for maximum 

levels of exposures are not 

provided). (Finding OTIB-0004-02).

Partially Although OTIB-0004, Rev. 03, includes a 

significant amount of additional data, there are 

still assumptions for which the technical basis 

is not provided (see discussion under Review 

Objectives 2.1, 5.1, 5.2, 5.3, and 7.3 below.)

1.4 Guidance not consistent with other 

procedures that are part of the 

hierarchy of data (e.g., ORAUTOTIB-0005). (Finding OTIB-0004-

03)

Yes The statement in Rev. 02 of OTIB-0004 that 

identifies the testes as the surrogate target 

organ for the prostate was inconsistent with 

OTIB-0005. This statement has been removed 

in Rev. 03. 

1.4 Data provided in Table 5 (pg. 7) is 

inconsistent with data provided in 

ORAUT-OTIB-0006. (Finding 

OTIB-0004-04)

Yes OTIB-0004, Rev. 03, has removed Table 5 

and now references ORAUT-OTIB-0006 for 

doses associated with chest x-rays.

1.4 For purposes of consistency with 

OCAS-PER-0002, this OTIB should 

identify a maximum liver dose that 

was equal to the lung dose. 

(Finding OTIB-0004-05)

Yes Rev. 03 to OTIB-0004 refers the dose 

reconstructor to OTIB-0006, which identifies 

the lung as the surrogate organ for the liver 

dose.

5.1–5.3 Guidance is not claimant favorable 

in instances of (1) unknown 

parameters affecting dose estimates 

and (2) breathing rate used to 

evaluate intake. (Finding OTIB0004-06)

Partially SC&A still believes that the selection of a 

breathing rate associated with a “light worker” 

is not claimant favorable, as discussed below 

under Review Objectives 2.1, 5.1, 5.2, 5.3, and 

7.3.

5.1–5.3, 7.2 Guidance does not provide data 

regarding assumptions for 

maximum levels of exposure; 

therefore, it is not possible to judge 

if estimates are claimant favorable. 

(Finding OTIB-0004-07)

Yes OTIB-0004, Rev. 03, is a total rewrite of the 

previous revision and includes a more 

thorough description of the assumptions used 

for determining maximum levels of exposure.

Technical 

Issue

Section 2.0 (pg. 3) justifies the 

choice of using 100 MAC based on 

incomplete data from Vulcan 

Crucible facility, which cannot 

necessarily be considered claimant 

favorable (Finding OTIB-0004-09)

Yes OTIB-0004, Rev. 03, includes additional data 

for their justification for recommending 

100 MAC as a claimant-favorable assumption. 

The 100 MAC issue is further explored below, 

as stated under Review Objectives 2.1, 5.1, 

5.2, 5.3, and 7.3.

Technical 

Issue

Section 2.0 (p.4-5) regarding 

ingestion should be updated 

according to OCAS-TIB-009, 

Estimation of Ingestion Intakes. 

(Finding OTIB-0004-11)

Yes Section 3.1.2 Uranium Ingestion of OTIB0004, Rev. 03 references OCAS-TIB-009.
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Table 3.9-2. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0004, Rev. 03 PC-1 Effective Date: 11/18/2005

Document Title: Estimating the Maximum Plausible Dose to Workers at Atomic Weapons Employer 

Facilities

Reviewer: Nicole Briggs, Robert Anigstein PhD, and John Mauro

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? 5

1.2 Is the procedure written in a manner that presents the data in a 

logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

Reference is made to 

other documents, but it 

is appropriate

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

4

See Review 

Comments

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?N/A

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is it 

free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 4

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? 3

See Review 

Comments

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 3

See Review 

Comments

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 3

See Review 

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)? 5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 3

See Review 

Comments

3.9.3 General Comments

There were approximately 102 AWE facilities that handled uranium in support of the atomic 

weapons program. The processes employed at these facilities included reduction, recasting, 

rolling, machining, and extruding of uranium; fuel element fabrication; scrap recovery; and 

recovery of uranium from phosphoric acid. This OTIB is intended to be used for AWE facilities 

that handled only uranium, including uranium metal, various forms of uranium associated with 

the uranium conversion and fuel fabrication process, enriched uranium, and recycled uranium 

that included trace amounts of activation and fission products and transuranics. This OTIB does 
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not address exposures from processing of thorium, radium, uranium ores, or other radioactive 

materials (except as recycled uranium contaminants). 

As noted above, this procedure excludes the lung and several surficial tissues from 

consideration. Its chief purpose is to expedite the processing of AWE claims that may involve 

various metabolic cancers with POCs that are unlikely to be compensable even under 

assumptions of high uranium intakes and conservative biokinetic model parameters.

Demonstration of non-compensability under worst-case (or highly conservative) assumptions is 

efficient, since it reduces the effort that would normally be required for a more realistic dose 

reconstruction. This approach to efficiency is also encouraged under 42 CFR 82.10(k)(2).

This review is organized according to the major topics addressed in ORAUT-OTIB-0004, 

including the following:

 Inhalation of airborne uranium oxide particulates

 Inhalation of other radionuclides associated with recycled uranium

 Ingestion of uranium

 Internal dose from depleted or enriched uranium

 External dose to penetrating radiation

 External dose to non-penetrating radiation

 Occupationally required medical exposures

 Exposure to residual radioactivity (i.e., the inhalation and inadvertent ingestion of 

uranium that has deposited on surfaces (floors, tables, equipment) in the workplace) 

In the sections that follow, a brief description is provided of the guidance addressing each of 

these areas, including a discussion and analysis of the scientific validity and claimant favorability 

of the guidance.

3.9.3.1 Inhalation of Airborne Uranium Oxide

Inhalation of airborne uranium particles is the dominant pathway for AWE facilities and is, 

therefore, addressed in more detail than the other pathways.

ORAUT-OTIB-0004 recommends using a default airborne uranium dust loading of 100 MAC as 

a reasonable default upper bound for continuous inhalation exposures for workers at AWE 

facilities. ORAUT-OTIB-0004 cites air-sampling data compiled in a 1949 report prepared by the 

New York Operations office (NYOO) of the Atomic Energy Commission as the basis for this 

guideline.

In 1949, the AEC’s publication, Health Hazards in NYOO Facilities Producing and Processing 

Uranium: A Status Report – April 1, 1949, summarized the uranium dust concentration surveys 

performed to that date at seven uranium processing plants. All of the studies presented average 

daily exposures collected from the breathing zone and weighted for 8 hours of exposure per day. 

The data are presented as multiples of the preferred level (PL) of exposure of 70 alpha 
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disintegrations per minute per cubic meter of air. The methodology is described in Appendix II

of AEC 1949 as follows:

Dust samples are then collected from the workers breathing zone and the general 

workroom air in such a way as to provide an estimate of the exposure for each job 

component. By properly weighting the samples with respect to time, we are then 

able to obtain the average daily concentrations to which the various employees 

are exposed.

The following presents a summary of the data provided for each of these seven facilities.

Mallinckrodt Chemical Works

Mallinckroft operated two plants; #6, which was the refinery, and #4, which was the metal plant. 

Plant #6 produced brown oxide from pitchblend. Plant #4 converted the UF4 to uranium metal. 

A dust survey was performed at these sites in 1948. The AEC 1949 report does indicate that the 

results were published, but the available copy did not contain those figures. A summary of the 

results is reproduced here in Table 3.9-5 toward the end of this section.

Harshaw Chemical Company

Harshaw employed 90 people and operated a uranium conversion process plant, which converted 

brown oxide to green salt, and green salt to UF6. Dust concentration surveys were performed at 

this plant in September 1948. Of the seven plants included in this summary report, Harshaw had 

the largest number of workers exposed to high dust concentration levels for long periods of time. 

Of the 88 employees, 33 were exposed to dust concentration levels ranging from 140 to 

370 MAC. Figure 11 of AEC 1949 indicates that 4 Brown Oxide Loaders were exposed to 

140 MAC, another 4 Brown Oxide Loaders were exposed to 188 MAC, 1 Fume Recovery Room 

Operator was exposed to 216 MAC, and a total of 24 Hex Area Loaders were exposed to 

374 MAC. In addition, these workers were exposed to these high dust concentration levels for 

extended periods of time. Table 3.9-3 is a reproduction of Table 5 of AEC 1949, which presents 

the exposure duration of the Harshaw employees as a function of dust concentration levels. 

Table 3.9-3. Distribution of Employees by Length of Employment and Level of Dust 

Exposure at Harshaw Chemical Company

Multiple of Preferred 

Alpha Level

Number of Months of Exposure

0– 6 6–12 12–24 24–36 36–48 > 48 Total

0–1 1 2 2 0 1 1 7

1–5 1 1 0 0 2 0 4

5–25 0 5 5 12 10 11 43

25–125 0 0 0 0 0 0 0

> 125 0 17 10 3 4 0 34

Total Personnel 2 25 17 15 17 12 88
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Linde Air Products

The Linde plant converted brown oxide from Mallinckrodt to UF4 for shipment to ElectroMetallurgical Company. Dust is dispersed in the plant through the transfer of “brown oxide to 

the weighing drums, scooping of oxide onto trays, and transfer of the trays to and from the green 

salt reactor.” Dust concentration surveys were performed at this plant in October and November 

1948. None of the 65 employees were exposed to dust concentration levels above 32 MAC.

Electro Metallurgical Company, Division of Union Carbide & Carbon Co.

Electro Metalurgical Company converted green salt from Linde to uranium metal billets. Dust 

concentration surveys were performed at this plant in November 1948. The majority of the 

plant’s 50 employees were exposed to dust levels below 40 MAC. However, some of the Green 

Salt Room Operators involved in bomb concentration operations were exposed to dust levels of 

more than 550 MAC. 

Simonds Saw & Steel

Uranium rolling processes at both Simonds Saw and Vulcan Crucible were described in AEC 

1949 as the following: 

Because of the pyrophoric character of uranium, this operation results in profuse 

atmospheric contamination. In addition to the fuming of the cherry-hot billets, 

continuous oxidation produces a scale which consistently spills from the billets. 

This material after falling to the floor is ground to dust by heavy floor traffic 

incidental to the rolling operation.

Several dust concentration surveys were performed between 1948 and 1949, which are 

summarized here in Table 3.9-4.

Table 3.9-4. Summary of Weighted Daily Exposures at Simonds Saw & Steel

Operator No. of Employees

Multiples of Preferred Level for Continuous Exposure

10/27/48* 12/1/48** 1/10/49***

[redacted] [redacted] 25 13 5

[redacted] [redacted] 17 13 4

[redacted] [redacted] 155 28 13

[redacted] [redacted] 25 10 28

[redacted] [redacted] 8 4 1.4

[redacted] [redacted] 9 10 1.6

* No dust control measures.

** Vacuum cleaner, and exhausts for rolls installed.

*** Exhaust for desoaler installed.

Table 3.9-4 reveals that prior to the use of dust control measures, some employees at Simonds 

Saw were exposed to dust concentrations of 155 MAC.
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Vulcan Crucible Steel Company

Uranium rolling processes at Vulcan were similar to those at Simonds Saw. Dust concentration 

surveys were performed at Vulcan in February 1949. The results indicate that some Hookman 

and Roughing Rolls workers were exposed to over 5,000 MAC. AEC 1949 does indicate that all 

the data presented are time-weighted averages, but it does not seem possible that these 

employees could have been exposed to over 5,000 MAC for any extended period of time. All of 

the other employees had exposures below 40 MAC.

Vitro Manufacturing Company

The Vitro plant converted scrap materials to black oxide. The majority of the plant’s 44 

employees received dust concentration exposures below 40 MAC.

Summary

Table 3.9-5 summarizes the chronic uranium dust loading exposures of the 7 facilities 

investigated in the NYOO report. As can be seen, 100 MAC corresponds to about the upper 90th

percentile level. The implications are that the use of 100 MAC as a default upper bound is 

reasonable, but certainly not overly conservative. In fact, it could be argued that it is not a truly 

bounding value.

Table 3.9-5. Summary of Average Daily Exposures to Alpha-Emitting Dust at 

Seven Uranium Plants

Uranium Plants

Multiples of PL*

0 – 1 1 – 5 5 - 25 25 - 125 125 Total

Mallinckrodt Chemical Works

 Plant #6

 Plant #4

53 (31%)**

11 (14%)

73 (43%)

[redacted]

24 (14%)

27 (35%)

[redacted]

30 (39%)

18 (11%)

[redacted]

170

77

Harshaw Chemical Company 9 (9%) 11 (11%) 45 (46%) 0 33 (34%) 98

Linde Air Products 119 (87%) [redacted] 0 15 (11%) 0 137

Electro-Metallurgical 19 (28%) 21 (31%) 21 (31%) [redacted] [redacted] 67

Simonds Saw & Steel (1/48) 0 16 (53%) [redacted] [redacted] 0 30

Vulcan Crucible Steel 0 [redacted] 17 (68%) 0 [redacted] 25

Vitro Manufacturing Company 23 (52%) 16 (36%) [redacted] [redacted] 0 44

Total 234 (36%) 151 (23%) 146 (23%) 57 (9%) 60 (9%) 648

* PL = Preferred Level for alpha emitting dust = 50 g of uranium/m3= 70 d/m/m3on the average for an 8-hour 

workday.

** The first figure denotes the number of personnel. The second, in parenthesis, expresses the first as a 

percentage of the total in the last column.

Given a chronic uranium dust loading of 100 MAC, ORAUT-OTIB-0004 recommends assuming 

a breathing rate of 1.2 m3/h, Absorption Type M or S (whichever gives the higher dose for the

organ of concern), and an AMAD of 5 microns. These assumptions are generally scientifically 

valid and reasonable. The OTIB also recommends assuming that the radionuclide of concern is 
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entirely U-234. SC&A agrees with this simplifying assumption since U-238, U-234, and U-235 

each have similar organ dose conversation factors when expressed in terms of Sv/Bq inhaled.

The choice of 1.2 m3/h may not be justified. This breathing rate is characteristic of the ICRPclassified “light worker” (time budget distributed between 5.5 hours light exercise and 2.5 hours 

sitting). The rate and amount of air breathed through the nose versus the mouth should be better 

estimated. These details should be evaluated for the workers’ level of effort, according to the job 

and workplace temperature and humidity for each installation.

3.9.3.2 Inhalation of Other Radionuclides Associated with Recycled Uranium

Table 3-3 of the guide provides explicit instructions pertaining to the reconstruction of doses 

associated with the processing and handling of recycled uranium, which includes the presence of 

several radioactive fission impurities and transuranic elements (i.e., technetium-99, plutonium 

(Pu), and neptunium (Np)-237) in the recycled uranium feed or waste streams. A review of 

selected publications was performed as a check on the activity fractions recommended in 

Table 3-3. The DOE Report of the Joint Task Force on Uranium Recycle Materials Processing

(DOE 1985) studied past practices at the Fernald, Y-12, and Ashtabula sites, and recognized that 

early practices regarding the processing of recycled material would have been improved with 

better understanding of contaminant levels in the feed material. Our review of this document 

revealed that the amount of fission products varies with the recycle uranium source and process. 

For example, the task force report indicates that 50% of Pu received at Fernald since plant 

startup (a period of 24 years) came in one shipment of Paducah ash in 1980. Another 32% is 

believed to have come from Hanford. The balance of the Pu received at Fernald was from SRS 

and West Valley. The report estimated that Pu-239 constituted an average of 6.7 parts per billion 

(uranium basis) in the recycled materials received between 1961 and 1985. Air sampling results 

at Fernald for Np-237, Pu-238, Pu-239, thorium (Th)-228, and Th-232 were also presented, as 

were similar data for Paducah, Y-12, and other DOE sites. 

In 2000, Idaho National Laboratory published a report (Lewis et al. 2000) demonstrating that the 

type of processing can influence the concentrations of the isotopic contaminants in recycled 

uranium. The concentrations of impurities vary in each waste stream as well. Additional 

information assessing data confidence and technical analysis of recycled uranium within the 

DOE complex was presented in DOE 2000 and DOE 2001. 

Accordingly, and in reviewing Table 4.2 of ORAUT-OTIB-0018, SC&A was concerned that the 

empirical information and findings in the DOE Joint Task Force report (DOE 1985) and other 

documents (Lewis et al. 2000; DOE 2000 and 2001) were not considered and integrated in the 

development of the fission material concentrations in recycled uranium. This deficiency raises 

additional concerns about the sources of data regarding the radioactive contaminants in the 

recycled uranium, the calculation methods, and the bounding significance and uncertainties of 

the values presented. SC&A is also concerned that the uncertainties associated with these values 

would not allow us to give the benefit of the doubt to claimants. The procedures also ignored the 

relationships between the concentrations of the radioactive impurities and the recycled uranium 

process phases and associated waste streams. This section of the guide needs to be more 

thoroughly discussed, along with the rationale for the recommended values in Table 4.2
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3.9.3.3 Ingestion of Uranium

This ORAUT-OTIB adopts the procedure recommended in OCAS-TIB-009, Rev 0, Estimation 

of Ingestion Intakes, which is reviewed above in Section 3.1 of this report and is not repeated 

here. In brief, there are several aspects of the default procedure for estimating ingestion intakes 

that are not scientifically sound. Some aspects of the procedure are overly conservative, while 

other aspects are not claimant favorable. These matters have been discussed with NIOSH as part 

of the review of the Bethlehem Steel site profile, and NIOSH is in the process of revising the 

protocol. 

3.9.3.4 Internal Dose from Depleted or Enriched Uranium

As discussed above, the primary objective of ORAUT-OTIB-0004, Rev. 3, is to provide 

guidance for deriving internal doses to uranium workers at AWE facilities when there is little or 

no reliable data upon which to base a dose reconstruction. The most important recommendation 

of the guide is the use of a default airborne uranium dust loading of 100 MAC (or 

70,000 dpm/m3). We have found this to be a reasonable upper-bound assumption. In addition, it 

can be used for facilities that work with natural, depleted, or enriched uranium, because the dose 

conversion factors for these different isotopes of natural uranium all have essentially the same 

dose conversion factor. However, the OTIB recognizes that there may be time when site-specific 

airborne sample or bioassay data are available, but they are provided in units of mg (e.g., mg/m3

or mg/L). When the data were in this form, the isotopic mix is an extremely important 

consideration because of the widely different specific activities (i.e., Bq/mg) of U-234, U-235, 

and U-238). 

In the case of depleted uranium, the OTIB recommends simply using the activity-to-mass ratio 

for natural uranium as a simplifying claimant-favorable assumption, because depleted uranium 

has a lower specific activity than natural uranium. SC&A considers this to be a reasonable and 

claimant-favorable assumption.

For enriched uranium, the OTIB provides multiplication factors to the intake of natural uranium 

that accounts for the greater specific activity of various degrees of enriched uranium if the 

workers actually experienced exposures to enriched uranium. For example, natural uranium has 

a specific activity of 0.68 pCi/ug, while highly enriched uranium (93.5%) has a specific activity 

of 68.11 pCi/ug. Hence, the ratio of the specific activity of highly enriched uranium to natural 

uranium is 99.7. This means that the lung dose from inhaling a mg of highly enriched uranium 

would be 99.7 times higher than inhaling a mg of natural uranium. We find that the 

recommended correction factors are scientifically sound. 

3.9.3.5 External Dose to Penetrating Radiation

For the purpose of estimating default external exposures at AWE facilities, this OTIB 

recommends assuming a worker spends 2,000 hours per year 1 foot away from a pure natural 

uranium rectangular ingot with dimensions of 24 in long, 16 in wide, and 4 in high, with AP 

geometry. It is also assumed that the short-lived progeny of U-238 are in equilibrium. Using 
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MCNP, the OTIB estimates a dose rate of 4.16 rem/yr. SC&A concurs that this default external 

dose rate is scientifically sound and claimant favorable. 

The OTIB also presents default values for external exposure to contaminated surfaces. The 

model adopted in this OTIB uses the same assumptions and models employed in OCAS-TIB-009 

for estimating ingestion intakes, and suffers from the same deficiencies; i.e., it assumes that the 

contamination on surfaces is directly proportional to the airborne dust loading and does not take 

into consideration the possibility that surfaces at AWE facilities can become contaminated by the 

direct deposition of large flakes of uranium oxide. Since NIOSH is in the process of revising this 

generic methodology as part of its revisions to the Bethlehem Steel site profile, we assume that 

this deficiency in this OTIB will also be corrected.

3.9.3.6 External Dose to Non-Penetrating Radiation

SC&A is in accordance with the calculations in Section 3.2.2 for maximum shallow dose from

handling of uranium metal. This matter was previously reviewed by SC&A in the context of the 

review of Rev. 01 of the Bethlehem Steel site profile. Hence, SC&A agrees that a dose rate of 

0.126 rad per hour is an appropriate maximum dose rate to use for external shallow dose from 

uranium metal handling of various kinds. However, it is not appropriate to restrict this only to 

hands and forearms. Specifically, SC&A provided worker interview data in its site profile 

review that workers carried uranium rods against their bodies (Finding 8, SCA-TR-TASK1-

0001, October 2004). Further, there is direct evidence from the Fernald plant that some workers 

sat on uranium ingots to stamp numbers on them (see Exhibit A photograph by Robert del 

Tredici, taken in 1987). In view of the foregoing, inclusion of male genitalia and other areas of 

skin could be exposed in broadly similar ways to the hands or forearms. This needs to be taken 

into account in a technical document that seeks to estimate “maximum plausible dose.”

SC&A suggests that the dose of 252 rad per year be more broadly applied to male genitalia. It 

should also be applied to other parts of the skin as appropriate; for instance, stomach area of the 

skin, groin, thighs, and buttocks.

ORAUT-OTIB-0004 does not include a shallow dose component from contamination of 

clothing. NIOSH agreed as part of the comment resolution procedure for the Bethlehem Steel 

Site Profile that it would add a dose rate of 0.15 mrad/hour for this pathway (Bethlehem Steel 

Site Profile Review, Summary Matrix of Findings, November 28, 2005, Item 6).
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Exhibit A: Fernald Uranium Meal Worker Stamping an ID Number on an Ingot

Photo by Robert del Tredici, 1987, used with permission

3.9.3.7 Occupationally Required Medical Exposures

This OTIB adopts the procedures recommended in ORAUT-PROC-0061, Occupational X-Ray 

Dose Reconstruction for DOE Sites, and ORAUT-OTIB-0006, Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures. A review of ORAUT-PROC-0061, along 

with ORAUT-OTIB-0006, is reviewed in Section 2.2 of this report and is not repeated here. In 

brief, we find that the only exams considered are a pre-employment and any annual chest x-rays 

taken as part of the physical. Therefore, exams from injury or incidents, special monitoring and 

surveys, etc., are mostly not included in the dose estimate to the disadvantage of the claimant. 

Also, the guidance instructs the dose reconstructor to multiply the doses by 1.3 to account for 

uncertainty. However, no guidance is provided for addressing uncertainties associated with poor 

technique or film processing. We believe these deficiencies also apply to this OTIB.
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3.9.3.8 Exposure to Residual Radioactivity (i.e., the inhalation and inadvertent ingestion 

of uranium that has deposited on surfaces (floors, tables, equipment) in the 

workplace following termination of operations)

The OTIB assumes that the airborne activity in the working environment at a given AWE facility 

following termination of uranium operations is due to resuspension processes, and that 

resuspension processes are responsible for 50% of the airborne dust loading. As a result, 

immediately after termination of operations, the OTIB recommends assuming that the airborne 

dust loading from resuspension of uranium contamination on surfaces is 50 MAC 

(i.e., 3,500 dpm/m3). This certainly appears to be a claimant-favorable assumption as an initial 

set of conditions.

The OTIB then recommends that the dust loading on surfaces and in the air gradually declines at 

a rate of 1% per day due to natural attenuation. When integrated over infinity, this assumption 

results in a total uranium intake from residual radioactivity that is 20% of the annual intake 

associated with uranium operations, where the dust loading is assumed to be 100 MAC. 

Intuitively, this appears to be a reasonable approach. However, NIOSH needs to provide a 

technical basis for the assumed 1% per day natural attenuation rate, or at least demonstrate that 

this is a claimant-favorable assumption. Alternatively, NIOSH may wish to make use of the data 

that are available for AWE facilities, such as the data from Simonds Saw, to estimate the amount 

of surface contamination during operations and how that activity declines as a function of time 

after the termination of operations, and/or employ an appropriately conservative set of 

assumptions regarding resuspension factors and building air turnover rates.

In order to evaluate the reasonableness of NIOSH’s approach to evaluating doses to residual 

radioactivity, we performed a series of calculations using available data, and found that the 

approach adopted by NIOSH is scientifically sound and claimant favorable. Attachment A to 

this review presents the results of this analysis.

3.9.4 Review Comments

Review Objectives 2.1, 5.1, 5.2, 5.3, and 7.3

As discussed above, some default assumptions are employed that may not be claimant favorable 

(such as those dealing with breathing rate and medical exposures). In some cases, no technical 

basis is provided for the assumption (such as the assumed natural attenuation rate of 1% per 

day). In addition, some of the methods employed in this OTIB are undergoing revision (such as 

the inadvertent ingestion model). The OTIB should be revised, as appropriate, to take into 

considerations these findings.

Attachment A - Review of the ORAUT-OTIB-0004 Resuspension Model

We have examined the generic procedure used to estimate the exposure of workers to 

resuspended uranium dust after cessation of uranium operations at an AWE. The procedure 

recommends that the dose reconstructor assume a uranium dust concentration of 50 MAC 

immediately after the cessation of uranium operations, and an exponential decline of 1% per day. 
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The following presents scoping calculations as a means to verify these assumptions. 

First, we define two commonly used measures of resuspension; the resuspension factor and the 

resuspension rate.

Resuspension Factor

The resuspension of radioactive material from contaminated surfaces is typically modeled by a 

resuspension factor or a resuspension rate. A resuspension factor “is the ratio of airborne 

contaminant concentration per unit air volume, χ, divided by the contaminant surface 

concentration per unit area [S] . . .” (Sehmel 1984). Although the theoretical inadequacies of 

both the resuspension factor and the resuspension rate have been discussed in the literature (e.g., 

Healy 1971, Horst 1982), both are commonly used in assessments in the absence of more exact 

models. The following equations present the definition of the resuspension factor and its 

relationship to the resuspension rate:

Fr = resuspension factor (m-1)

χi = concentration of radionuclide i in ambient air (dpm/m3)

ku = units conversion factor

= 100

Si = areal activity concentration of radionuclide i on contaminated surface 

(dpm per 100 cm

2

)

A = area of residually radioactive surface (m2)

Rr = resuspension rate (h-1)

V = volume of affected region (m3)

Ra = air exchange rate (h-1)

Resuspension Rate

The resuspension rate is derived by solving Equation 1:

The depletion of the uranium available for resuspension is equal to the resuspension rate, Rr. To 

evaluate this rate, we first need an estimate of Fr, the resuspension factor. Although estimates of 

Fr span many orders of magnitude, the NIOSH assumption of an initial airborne activity 

concentration of 50 MAC (3,500 dpm/m3) places a lower limit on this value. Table 3.9-6 

presents the results of surface contamination measurements of the mill area at Simonds Saw & 
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Steel. The tabulated areal alpha activity concentrations span a range of 2,500 to 80,000 dpm per 

100 cm2. Using the highest of these values, an assumed airborne concentration of 50 MAC 

would correspond to Fr ≈ 4.4 × 10-4m

-1

. To allow for possibly higher surface contamination 

levels at other facilities, we round down to Fr = 10-4m

-1

. 

Table 3.9-6. Alpha Radiation Measurements Taken at Simonds Saw 

(dpm/100 cm2)

Location

Date

10/27/48 12/1/48 2/15/49

East Roller 1 50,000 12,000 12,000

East Center Line 25,000 16,000 18,000

East Bench 5,000 10,000 3,000

Desk 2,500 2,500 2,500

West Roller 2 15,000 11,000 8,000

West Roller 1 35,000 35,000 3,000

West Center Line 18,000 7,500 5,000

Furnace Area 50,000 80,000 10,000

Shear 30,000 25,000 6,000

West Bench 3,000 3,000 2,500

Source: AEC 1949, Table II

To evaluate the expression presented in Equation 2, we assume a nominal building air exchange 

rate of 1 h-1, and a nominal height of 10 m. Assuming that all the contamination resides on the 

floor, = 10 m. Substituting these values into Equation 2 yields Rr = 10-3h

-1

. To estimate the 

daily resuspension rate, we assume that the building ventilation system operates only when the 

building is occupied. Assuming a nominal occupation of 10 h/d, we obtain an air exchange rate 

of 10 d-1, which yields a daily resuspension rate, Rr′ = 10-2d

-1

. Thus, a depletion rate of 1% per 

day, coupled with an initial airborne activity concentration of 50 MAC, is a plausible, claimantfavorable assumption. 

We further observe that the integrated worker exposure over a long period of time is given by the 

following expression:

Xint = Time-integrated exposure (0 < t < ∞) (MAC∙d)

χ0 = Initial airborne activity concentration (MAC)

Rr′ = Resuspension rate (d-1)

As we see, the integrated exposure rate depends on the ratio of the initial concentration to the 

resuspension rate. Since a lower resuspension rate would necessarily lead to a lower 

concentration, the time-integrated exposure is a more robust quantity than either the initial 

concentration or the resuspension rate.
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References

Atomic Energy Commission (AEC). 1949. “Simonds Saw & Steel: Summary Report of Three 

Surveys.” (Unpublished).

DOE, 1985. Report of the Joint Task Force on Uranium Recycle Materials Processing, 

DOE/OR-859. Oak Ridge Operations. September 1985.

DOE, 2000. Recycled Uranium Mass Balance Project Y-12 National Security Complex Site 

Report, Y/LB-16,036, Rev. 1. Y-12 National Security Complex, BWXT Y-12, LLC. December 

2000.

DOE, 2001. A Preliminary Review of the Flow and Characteristics of Recycled Uranium 

Throughout the DOE Complex 1952–1999. Project Overview and Field Site Reports, F-001-

001. 2001.

Healy, J. W. 1971. “Surface Contamination: Decision Levels,” LA-4558-MS. Los Alamos, 

New Mexico: Los Alamos Scientific Laboratory.

Horst, T. W. 1982. “The Estimation of Airborne and Surface Contamination Resulting from the 

Deposition-Resuspension Process.” Health Physics, 43(2), 269-272.

Lewis, L.C., D.C. Barg, C.L. Bendixon, J.P. Henscheid, Wenzel, and B.L. Denning, 2000. Idaho 

Engineering and Environmental Laboratory Site Report on the Production and Use of Recycled 

Uranium, INEEL/EXT-2000-00959. Idaho National Engineering and Environmental 

Laboratory. September 2000.

Sehmel, G. A. 1984. “Deposition and Resuspension.” In D. Randerson, (Ed.), Atmospheric 

Science and Power Production, DOE/TIC-27601, (pp. 533–583). Oak Ridge, Tennessee: 

Technical Information Center, office of Scientific and Technical Information, U.S. Department 

of Energy (NTIS No. DE84005177). 

3.10 ORAUT-OTIB-0018: INTERNAL DOSE OVERESTIMATES FOR FACILITIES

WITH AIR SAMPLING PROGRAMS

The review of ORAUT-OTIB-00018, Internal Dose Overestimates for Facilities with Air 

Sampling Programs, Rev 0, dated June 22, 2004, was prepared by Steven Schaffer, PhD, and 

approved by John Mauro, PhD, CHP, on March 20, 2006. The ORAUT-OTIB-0018 review was 

amended by Kathleen Behling on July 17, 2007.

3.10.1 Purpose of Procedure

This document provides an alternative and less conservative method for determining 

radionuclide intake and internal doses when compared to the maximum exposure method used in 

ORAUT-OTIB-0002. Analysts may use this document when they need a more realistic but still 

claimant-favorable method to estimate internal dose, provided that the facility rigorously 
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sampled particulate air concentrations and rigorously controlled exposures based on air 

measurements. 

3.10.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0018 is summarized in Table 3.10-1 below. Table 3.10-1 

is a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 3.10-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0018, Rev 0 Effective Date: 08/09/2005

Document Title: Internal Overdose estimates for Facilities with Air Sampling Programs

Auditor: Steven Schaffer, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

4

See Review 

Comments

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 3

See Review 

Comments

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?N/A

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

3.2 Assess whether the procedure adequately addresses generic 

as well as site-specific data pertaining to: ----

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 3

See Review 

Comments

________________________

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

3.10.3 General Comments

ORAUT-OTIB-0018 describes and presents a generic methodology for placing a reasonable 

upper estimate on the inhalation of particulate radionuclides for workers who had no significant 

intakes, no bioassay measurement or bioassay results below the MDL, and at sites where the 

airborne radionuclide concentrations were rigorously monitored. The basic philosophy adopted 

by this guide is that individuals that meet the applicability criteria for this guide were unlikely to 
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have experienced exposures in excess of the maximum allowable airborne particulate 

concentration in effect at the time period and facility of concern. 

Fundamental to the guideline are the limits on airborne radionuclide concentrations that were 

established at different times by standard-setting bodies and by regulation. The time periods 

covered in ORAUT-OTIB-0018 begin with the NBS guidelines established in 1953 and extend 

to the time period covered by the limits established by DOE in 10 CFR Part 835, which were 

implemented in 1993. As such, the guide is not to be used for time periods prior to 1953.

Given the standards as a function of time, and the applicability and limitations of the guidance, 

ORAUT-OTIB-0018 presents an array of default airborne radionuclide concentrations that are 

recommended for dose reconstructions for different facilities and time periods of exposures, 

along with default breathing rates and exposure durations. For facilities that handled recycled 

uranium, ORAUT-OTIB-0018 recommends default intakes of Pu-238, Np-237, Tc-99, Th-232, 

and Ru-106, expressed in terms of pCi of each radionuclide per pCi of U. For sites where the 

specific airborne radionuclides are not known because only gross alpha and gross beta/gamma 

counts were made, ORAUT-OTIB-0018 recommends assuming that the airborne activity is 

entirely comprised of the radionuclide and chemical forms with the highest dose conversion 

factors for the organs of concern. Finally, in light of the many uncertainties associated with 

characterizing the airborne radionuclide concentrations actually inhaled by a given worker, 

ORAUT-OTIB-0018 recommends assuming that each recommended default radionuclide 

concentration is the geometric mean of a lognormal distribution with a standard deviation of 3.12 

The recommended approach would seem to place a reasonable upper bound on inhalation 

exposures for the sites, time periods, conditions, and classes of workers for which it is 

applicable; however, this is conditional based on whether the air sampling program at the DOE 

facility is able to accurately measure air concentrations breathed by a given worker, as discussed 

in detail under Review Objective 7.3 below.

In summary, SC&A identified several issues of concern associated with Review Objectives 1.4, 

1.5, and 7.3. It should also be noted that this guidance document adopts OCAS-TIB-009, 

Estimation of Ingestion Intakes, as the basis for deriving ingestion intakes. Therefore, OTIB0018 recommends assuming that the ingestion intake is 0.021 of the inhalation intake. The 

deficiencies associated with this approach are discussed in our evaluation of OCAS-TIB-0009, 

which is in Section 3.1 of this report. However, in general, the recommended approach is likely 

appropriate for the facilities for which this guide applies, because the applicable facilities do not 

include AWE facilities, where the radionuclide intake rates via ingestion are not necessarily 

proportional to the radionuclide intake rates via inhalation.

 

12 It is worth noting that ORAUT-OTIB-0033 recommends using 50% of the ORAUT-OTIB-0018 default 

values for workers exposed before 1989, and 5% of the default ORAUT-OTIB-0018 values exposed following 1989. 

ORAUT-OTIB-0018 does not provide for this additional flexibility in reconstructing doses. 
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3.10.4 Review Comments

Review Objective 1.4

The guidance provided in OTIB-0018 establishes a method for estimating intakes and internal 

doses when overestimated dose are acceptable. In other words, this OTIB is designed to be used 

only for dose reconstructions that use maximizing assumptions, and where the case is not

compensable. In order to use the methodology prescribed in OTIB-0018 for best estimates or 

compensable cases, additional guidance must be applied, as cited in ORAUT-OTIB-0033, 

Application of Internal Doses Based on Claimant-Favorable Assumptions for Processing as Best 

Estimates. SC&A recommends that OTIB-0018 be revised to include a discussion of ORAUTOTIB-0033 and its application for best-estimate dose reconstructions.

In addition, the guidance cited this document has been automated in an OTIB-0018-specific 

workbook. The OTIB-0018 guidance should acknowledge the existence of this workbook, and 

provide a brief description of its use and functionality.

Review Objectives 1.5

Though the OTIB is highly prescriptive, it is limited to workers and sites that meet specific 

criteria that may not be readily discernable by the dose reconstructor. For example, Sections 3.1 

and 3.2 of the OTIB, Applicability and Limitations, require the dose reconstructor to make 

judgements regarding whether the site had a rigorous air particulate monitoring program; 

whether the worker was unlikely to have experienced significant exposure to airborne particultes; 

whether exposures were limited to only airborne particles and did not include iodines, C-14, 

radon, or H-3, and other conditions. SC&A questions how the dose reconstructor determines 

whether a site has a rigorous air particulate monitoring program. The OTIB could benefit from 

a listing of facilities considered by NIOSH to have an air monitoring progam that is considered 

adequate. With regard to judgments on a worker’s potential exposures, different dose 

reconstructors could easily come to different conclusions for the same worker regarding these 

matters. Such judgments may be especially difficult for construction and maintenance workers.

Review Objective 7.3

Under Section 3.1 (Applicability) of OTIB-0018, it states that this guidance document applies to, 

“Sites or facilities that rigorously sampled particulate air concentrations in areas of risk and 

controlled exposure to intakes according to the measured concentrations.” SC&A questions 

whether the air monitoring program in place throughout the operation of the various DOE 

facilities was adequate to accurately measuring air concentrations to which a worker was 

exposed. The primary types of air sampling strategies used to monitor worker exposures are 

fixed station or general area (GA) sampling and breathing zone (BZ) sampling. Because sources 

of airborne contamination are highly localized, GA sampling only may not accurately represent 

air concentrations breathed by the workers.

In a 2-year study conducted at the Nuclear Materials and Equipment Corporation (NUMEC), BZ 

lapel air samplers (worn by uranium and plutonium workers) were compared to stationary GA 
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samples. Figure 3.10-1 below illustrates the strong tendency of GA samples to underestimate the 

air concentrations to which a worker is exposed. Important to note is that this discrepancy 

increases with air concentrations, and at the MPC level is, on average, about 70-fold too low. 

Based on these data, a “rigorous” air monitoring program would require a comprehensive 

breathing zone air sampling program for individual workers and facility processes that is best 

defined by periodic low-volume lapel air sampling that extends over the total (or a large 

fraction) of an 8-hour workday. When BZ air sampling is not performed or not adequately 

performed in the workplace and general area air sampling is used as the basis of the air 

monitoring program, established monitoring guidelines may not have been adequately met. 

Figure 3.10-1.Comparison of Lapel to Fixed Station Air Sampling

(Source: Caldwell et al. 1967)

A second deficiency identified as a result of our review involves limitations of OTIB-0018. 

Section 3.2 identifies a list of conditions where the use of OTIB-0018 is not appropriate. One 

limitation of the guidance document is that for cancers associated with organs of the respiratory 

tract, the OTIB may not provide an overestimate for monitored workers. However, the 

document fails to also identify the thoracic lymph nodes as a target issue where the use of the 

OTIB may not result in an internal dose that is claimant favorable.

The third concern is that the OTIB is lacking an explanation of the basis for the activity fractions 

for isotopes associated with recycled uranium, as prescribed in Table 4-2 of the guide. Without 
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this derivation, we do not know if the fractions are appropriate and tend to overestimate the dose. 

NIOSH should document the derivations of these fractions and provide evidence that they result 

in upper-estimate doses

3.10.5 Review of OTIB-0018 Workbook

A workbook has been designed to automate the guidance provided in OTIB-0018. This 

workbook (i.e., OTIB-0018 v. 4.02) was evaluated separately under SC&A’s Task 3 and 

published in SCA-TR-TASK3-0002, Supplement 2, Rev. 1, June 2007.

3.11 ORAUT-PROC-0060, REVISION 00: EXTERNAL ONSITE AMBIENT DOSE 

RECONSTRUCTION

The review of ORAUT-PROC-0060, External Onsite Ambient Dose Reconstruction, Rev 00, 

dated March 7, 2005, was prepared by Steven Schaffer, PhD, and approved by John Mauro, PhD, 

CHP, on March 20, 2005. A correction to this document number was made by Kathleen Behling 

in July 2007.

3.11.1 Purpose of Procedure

This document provides specific instructions to a dose analyst on how to estimate external 

ambient doses. It provides specific instructions on how to determine if the ambient dose 

estimates are needed, how to estimate a maximizing dose to expedite cases that clearly will not 

result in compensation, how to perform a reasonably conservative analysis where ambient doses 

should be included for completeness, and how to perform a realistic analysis when ambient doses 

are important to the probability of causation.

3.11.2 Review Protocol

SC&A’s evaluation of ORAUT-PROC-0060 is summarized in Table 3.11-1 below. Table 3.11-1 

is a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 3.11-1. Procedure Review Outline/Checklist

Document No.: ORAUT-PROC-0060, Rev. 00 Effective Date: 03/07/2005

Document Title: External On-Site Ambient dose Reconstruction for DOE Sites

Auditor: Steven Schaffer, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)? 5

It references other 

related NIOSH and 

ORAUT document, 

but this is not a 

problem.

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 4

See Review 

Comments

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

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) 5

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

5

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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3.11.3 General Comments

The document explains the different procedures in a clear and concise manner. A comparison of 

the table of maximized ambient doses in Attachment B to site data supplied in selected site 

profiles suggests that the table values are, in fact, maximum. The method for calculating a 

conservative best-estimate ambient dose is reasonable. 

3.11.4 Review Comments

Review Objective 1.5

The method for maximum doses should address what the analyst should do when there is no data 

in the table in Attachment B. For example, what should the analyst do for someone who was at 

the Nevada Test Site (NTS) prior to 1963. The table has no doses listed for this site for the years 

prior to 1963. Should the analyst use the best-estimate approach?

3.12 ORAUT-OTIB-0014, REVISION 00: ASSIGNMENT OF ENVIRONMENTAL 

INTERNAL DOSES FOR EMPLOYEES NOT EXPOSED TO AIRBORNE 

RADIONUCLDES IN THE WORKPLACE

The review of ORAUT-OTIB-0014, Assignment of Environmental Internal Doses for Employees 

Not Exposed to Airborne Radionuclides in the Workplace, Rev. 00, dated June 22, 2004, was 

prepared by Steven Schaffer, PhD, and approved by John Mauro, PhD, CHP, on March 31, 2006. 

2005.

3.12.1 Purpose of Procedure

The stated purpose of this procedure “is to provide guidance to dose reconstructors on (1) when 

they can assign environmental internal doses rather than potential workplace exposures to 

workers, and (2) the methodology for asigning such doses.”

3.12.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0014 is summarized in Table 3.12-1 below. Table 3.12-1 

is a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 3.12-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0014, Rev. 00 Effective Date: 06/22/2004

Document Title: Assignment of Environmental Internal Doses for Employees Not Exposed to 

Airborne Radionuclides in the Workplace

Auditor: Steven Schaffer, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?5

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) 5

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

N/A

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

_________________________

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

3.12.3 General Comments

This is a very general guidance document that explains when a dose analyst should assign 

environmental internal doses rather than workplace exposures, and the methodology for 

assigning such doses. The approach to identifying who should be assigned environmental 

internal doses is reasonable and considers the important factors of job category, work location, 

time frames, monitoring data, and co-worker information. The attachment (A) presents a 
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reasonably comprehensive list of job categories with no, some, or probable potential for work 

place exposure.

The methodology for assigning environmental internal dose is left up to the dose analyst, but the 

document gives some generalized guidance on how to assign internal doses. This guidance 

seems reasonable and covers most types of situations that the analyst may encounter by referring 

the dose reconstructor to the appropriate sections of the site profiles. As is the case for many of 

the other procedures reviewed in this report, particular care must be taken when assigning a 

construction worker to a given category of exposures due to the highly diverse nature of the 

exposures that some construction workers experienced. 

3.13 ORAUT-OTIB-0025, REVISION 00: ESTIMATION OF RADIUM-226 

ACTIVITY IN THE BODY FROM BREATH RADON MEASUREMENTS 

The review of ORAUT-OTIB-0025, Estimation of Radium 226 Activity in the Body from Breath 

Radon Measurements, Rev. 00, dated June 5, 2005, was prepared by Michael Thorne, PhD and 

approved by John Mauro, PhD, CHP, on May 16, 2006.

3.13.1 Purpose of Procedure

The purpose of this procedure is to provide a methodology that can be used to estimate the Ra226 body burden in an individual based on the amount of radon exhaled by that individual. The 

procedure was developed because of the existance of historical radon breath analyses for some 

workers, and that these data might be useful in estimating the Ra-226 body burden, thereby 

facilitating the reconstruction of their internal doses to Ra-226.

3.13.2 Review Protocol

SC&A’s evaluation of ORAUT-OTIB-0025 is summarized in Table 3.13-1 below. Table 3.13-1 

is a checklist containing objectives that SC&A developed under the first phase of Task 3 to 

evaluate whether the procedure adequately supports the dose reconstruction process, as described 

in the introduction to this report.
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Table 3.13-1. Procedure Review Outline/Checklist

Document No.: ORAUT-OTIB-0025, Rev. 00 Effective Date: 04/05/2005

Document Title: Estimation of Radium 226 Activity in the Body from Breath Radon 

Measurements 

Auditor: Michael Thorne, PhD

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? 5

1.2 Is the procedure written in a manner that presents the data in 

a logical sequence? 5

1.3 Is the procedure complete in terms of required data (i.e., does 

not reference other sources that are needed for additional 

data)?

5

1.4 Is the procedure consistent with all other procedures that are 

part of the hierarchy of procedures employed by NIOSH for 

dose reconstruction?

5

1.5 Is the procedure sufficiently prescriptive in order to minimize 

the need for subjective decisions and data interpretation? 5

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?

5

2.2 Conversely, for claims with suspected cumulative low doses, 

does the procedure provide clear guidance in defining worstcase assumptions?N/A

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? N/A

3.1.2 Is the interview process sufficiently flexible to permit 

unforeseen lines of inquiry? N/A

3.1.3 Does the interview process demonstrate objectivity, and is 

it free of bias? N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required 

under the Privacy Act? N/A

 

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.
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No. Description of Objective Rating

1-5*

Comments

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) N/A

3.2.2 In vivo/In vitro bioassays 5

3.2.3 Missing dosimetry data 5

3.2.4 Unmonitored periods of exposure 5

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? 5

4.2 Does the procedure adhere to the hierarchical process as 

defined in 42 CFR 82.2? 5

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? 5

5.2 Is the procedure claimant favorable in instances of unknown 

parameters affecting dose estimates? 5

5.3 Is the procedure claimant favorable in instances where 

claimant was not monitored? 5

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)?

N/A

6.2 Does the procedure give appropriate guidance in the use of 

random sampling in developing a final distribution? N/A

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? 5

7.2 Does the procedure avoid levels of detail that have only 

limited significance to the final dose estimate and its POC? 5

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses? 5

_________________________

* Rating system of 1 through 5 corresponds to the following: 1=No (Never), 2=Infrequently, 

 3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable.

3.13.3 General Comments

Summary of the OTIB

The OTIB presents a brief review of the literature and concludes that for every pCi/L of radon 

measured in breath, it can be assumed that the whole body contains 0.25 uCi and, of this, 

0.13 uCi is in the bone. The equation used to derive this relationship is quite simple, as follows:
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Q = (CRn × I) / (Rn x f)

where:

Q = the quantity of Ra-226 present in the body (pCi)

I = the breathing rate of the subject (L/hr)

CRn = the concentration of Rn-222 in the breath sample (pCi/L)

Rn = the decay constant of Rn-222 (per hr)

The procedure explains that the protocol must ensure that the breath sample is not contaminated 

by ambient radon by taking the sample in a low radon area and having the subject’s breath as 

free as possible of ambient radon prior to collecting the sample (e.g., bottled oxygen prior to 

collecting the breath sample). In addition, the procedure recommends taking the breath sample 

on a Monday morning at least 2 hours after having breakfast. Taking the sample on Monday 

morning (after a work-free weekend) is recommended because it helps to minimize the presence 

of residual radon in breath due to ambient radon in the workplace. Delaying the collection of the 

breath sample until about 2 hours after breakfast is recommended because of evidence that the 

radon concentrations in breath samples taken immediately following a meal are temporarily 

elevated by a factor of about 2.

The procedure also recommends using an f value of 0.63, which is based on empirical data and is 

believed to result in a high-end estimate of the Ra-226. A breathing rate of 1.2 L/hr is 

recommended in the OTIB, since this is the default breathing rate for light activity recommended 

by the ICRP.

SC&A performed an independent review of the literature on this subject, and concurs with the 

OTIB’s recommended relationship of 0.1 uCi of ra-226 body burden per pCi/L of radon in 

breath.

The only observation we would like to make has to do with the fact that the higher the breathing 

rate, the lower the lower the concentration of radon in exhaled air for a specified Ra-226 body 

burden. The implications are that, if the radon breath analysis records for a given worker are 

expressed in terms of radon concentration in breath (e.g., pCi/l of breath), then it may be 

preferable to derive the Ra-226 body burden assuming a resting level breathing rate (which is 

likely the condition under which the sample was originally collected). This will result in a more 

realistic (in this case lower) estimate of the Ra-226 body burden. Conversely, if the radon breath 

analysis record are expressed in units of radon expired per unit time, and no information is 

provided on the individual’s breathing rate, then it would be preferable to derive the radon 

concentration in the exhaled air assuming a lower breathing rate, thereby deriving a slightly 

higher Ra-226 body burden.
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4.0 QUALITY ASSURANCE PLANS 

4.1 OCAS-PR-005: CONDUCT OF ASSESSMENTS

This review of OCAS-PR-005, Conduct of Assessments, Rev. 0, December 3, 2004, was 

prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, PhD, CHP, on March 31, 

2006.

4.1.1 Purpose of Procedure

The stated purpose of this procedure is “. . . to provide the process for the conduct, 

documentation, and finalization of assessments performed by the office of Compensation 

Analysis and Support (OCAS)” (Section 1.0). 

4.1.2 Review Protocol

Since the OCAS procedure specifies the conduct of assessments, which is part of an OCAS 

quality assurance program, it is reviewed according to SC&A’s Procedure to Perform QA 

Reviews of NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). 

Table 4.1-1, which is a checklist taken from Attachment A of the SC&A procedure, summarizes 

the review. 

4.1.3 General Comments

The subject procedure applies to “OCAS personnel involved in conducting assessments of 

contractor performance and OCAS self-assessments” (Section 2.0). The procedure contains 

sections on purpose, project, scope, references, responsibilities, procedures, records, applicable 

documents, and definitions. It describes the overall process by which OCAS personnel conduct 

assessments; outlines the responsibilities and interactions of the OCAS Contract Oversight Team 

Leader, OCAS Assessor, office Automation Assistant, and Health Science Administrator; and 

describes the record generation process. The procedure also includes as attachments several 

checklists and report formats, which may be applicable depending on the circumstances of a 

particular review. 
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Table 4.1-1: QA-related Document Compliance Checklist

Document No.: OCAS-PR-005, Rev. 0 Effective Date: 12/3/04

Document Title: Conduct of Assessments

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N The procedure needs to 

refer to other QA 

procedures.
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No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Health Science 

Administrator and the 

Associate Director for 

Science. 

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y

2.5 Are revisions clearly indicated on affected pages? N/A The document is Rev. 0.

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y In text. 

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.1.4 Review Comments

Review Objectives 1.8 and 2.2

The Conduct of Assessments procedure is clear and provides adequate guidance to OCAS for the 

conduct of such assessments. The following comments, observations, and suggestions are made 

to improve the procedure in future revisions:

(1) Section 3.0, References, does not contain any citations, although it is unlikely that this 

procedure is sui generis, without antecedents. It is expected that the subject procedure, 

which covers material that is customarily part of a quality assurance program, is an 

implementing procedure of a higher-level OCAS quality assurance plan; that plan, as 

well as any other related plans and procedures, should be referenced in Section 3.0, and, 

perhaps, referred to in other sections of the procedure as well. As now presented, the 

subject procedure stands without context related to how it fits into an overall quality 

program.
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In addition, since assessments may consist of dose reconstruction reviews or blind dose 

reconstructions, the subject procedure should reference appropriate technical plans and 

procedures to perform these assessments; e.g., OCAS-PR-007 for dose reconstruction 

reviews. 

(2) Although the responsibilities of various personnel (i.e., OCAS Contract Oversight Team 

Leader, OCAS Assessor, office Automation Assistant, and Health Science Administrator) 

are delineated in the procedure, the procedure does not mention any required 

qualification or training of these personnel. This deficiency may be particularly 

significant in some cases where the assessments are technical, such as for dose 

reconstructions. As we indicated earlier, these procedures should reference the overall 

quality program. If personnel training and qualifications considerations are treated 

elsewhere, the appropriate plans or procedures should be referenced in this document.

 

(3) It is not clear whether an Assessment Checklist is always required in an assessment, or 

whether use is at the discretion of the OCAS Assessor and whether the OCAS Assessor 

has the freedom to create his or her own checklist, appropriate for conduct of a particular 

assessment. 

Section 6.2.5 states that one of the responsibilities of the OCAS Assessor is to, 

“document the criteria to be assessed on an Assessment Checklist. Use the appropriate 

attachment for the checklist to be used during the assessment.” This paragraph seems to 

require using one of the attached checklists. However, Section 6.2.3 states that the 

OCAS Assessor should “establish the criteria to be assessed through review of the 

pertinent requirements. Examples of checklists that may be used are included as 

Attachments 2 and 3.” The use of the word “examples” in this paragraph seems to imply 

that other checklists may also be used. The subject procedure should clarify this apparent 

discrepancy and present the requirements related to an Assessment Checklist in a 

straightforward fashion. 

(4) Attached assessment checklist examples and report formats all pertain to dose-related 

assessments and functions, such as for dose reconstruction reviews and blind dose 

reconstructions. We found that no similar attachments are provided for non-technical 

assessments that are covered in Section 5.1 of the procedures. If the subject procedures 

pertain only to dose-related assessments, the current document should be made clear, 

otherwise checklist examples and report formats should be provided as well. 

4.2 OCAS-PR-007: DOSE RECONSTRUCTION REVIEW

This review of OCAS-PR-007, Dose Reconstruction Review, Rev. 1, dated April 18, 2005, was 

prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, PhD, CHP, on March 31, 

2006.
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4.2.1 Purpose of Procedure

The stated purpose of this procedure is “. . . to provide the process for the conduct, 

documentation, and performance of dose reconstruction (DR) reviews performed by the office of 

Compensation Analysis and Support (OCAS)” (Section 1.0). 

4.2.2 Review Protocol

Since the OCAS procedure pertains to the dose reconstruction review process, rather than to the 

dose reconstruction performance process itself, the procedure is part of the OCAS quality 

assurance program, and is reviewed according to SC&A’s Procedure to Perform QA Reviews of 

NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). Table 4.2-1, 

which is a checklist taken from Attachment A of the SC&A procedure, summarizes the review. 

4.2.3 General Comments

The subject procedure applies to “OCAS personnel involved in reviewing DR [dose 

reconstruction] reports” (Section 2.0). The procedure contains sections on purpose, project, 

scope, references, responsibilities, procedure, records, applicable documents, and definitions. It 

describes the overall process by which OCAS personnel review dose reconstruction reports 

(using three different levels of review—Basic, Detailed, and Blind DR Verification), and 

outlines the responsibilities and interactions of the OCAS Health Science Administrator, OCAS 

HP Team Leader, office of the Director, OCAS HP, and office Automation Assistant. The 

procedure also includes a sample Dose Reconstruction Review Checklist and a sample DR 

Review Form as attachments. 
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Table 4.2-1: QA-related Document Compliance Checklist

Document No.: OCAS-PR-007, Rev. 1 Effective Date: 4/18/05

Document Title: Dose Reconstruction Review

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
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No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Health Science 

Administrator and the 

Associate Director for 

Science. 

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y

2.5 Are revisions clearly indicated on affected pages? N (See 4.2-4(8))

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y In text, but a separate 

section may be advisable 

(See 4.2-4(9))

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical”

4.2.4 Review Comments

Review Objectives 2.2 and 2.5

The Dose Reconstruction Review procedure is, with a few exceptions noted below, generally 

clear, and provides adequate guidance to OCAS for the conduct of such reviews at three different 

levels of scrutiny; Basic, Detailed, and Blind DR Verification. The following comments, 

observations, and suggestions are made to improve the procedure in future revisions:

(1) The procedure needs to clarify the authority that establishes the frequency for performing 

the three different types of reviews. Section 5.1.2, discussing Detailed Reviews, states 

that “the minimum frequency of such reviews will be specified by the Contract Oversight 

Team Leader.” No similar statement is made about this person specifying the frequency 

of Basic Reviews or Blind DR Verifications. The preceding statement also may 

contradict the one in Section 4.1.3, which states that the OCAS Health Science 

Administrator “establish[es] the frequency for each type of DR report review,” which 

would imply that the OCAS Health Science Administrator would specify the frequency 

of Detailed Reviews. Perhaps the procedure is trying to make a distinction between the 

Contract Oversight Team Leader setting the minimum frequency of the Detailed Reviews 
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(why not also the minimum frequency of the other two types of reviews?), while the 

OCAS Health Physics Administrator establishes the actual frequency of all the reviews. 

Further, Section 6.2 states the OCAS Health Science Administrator “establish[es] the 

frequency for performing DRRRC [Dose Reconstruction Report Review Checklist]” 

(Section 6.2.1) and “establish[es] the frequency for performing BDRV [Blind Dose 

Reconstruction Verification]” (Section 6.2.2). No mention is made of the frequency of 

performing the Basic Reviews. In addition, the usage of DRRRC in Section 6.2.1 does 

not appear to make sense; earlier in the procedure, DRRRC is given as an acronym for 

Dose Reconstruction Report Review Checklist. Section 6.2.1 probably means to refer 

instead to the Detailed Review, which uses the DRRRC as part of the process. 

(2) The role of the Contract Oversight Team Leader should be delineated in Section 4.0 on 

Responsibilities, if, indeed, he or she has the responsibility of establishing the frequency 

of any of the three types of review. 

(3) The procedure is not clear on how the cases chosen for review. Are they chosen 

randomly from the entire cohort of dose reconstructions; chosen randomly, but in 

proportion to a stratification criterion (e.g., proportional representation by facility, cancer 

type, worker type, or time period); or according to some other scheme? Section 6.3.1 

mentions that the OCAS HP “select[s] a DR report for review from the NIOSH OCAS 

Claims Tracking System (NOCTS) Review Queue or the Unassigned Queue,” but does 

not say how a dose reconstruction report gets on these queues. The procedure should 

include details of the selection process or a reference to where such information can be 

found. 

(4) The procedure mentions training for the Health Physics personnel reviewers in 

Section 6.1, but does not reference the procedure (if it exists) covering the “training 

process.” 

(5) Section 5.1.3, on Blind DR Verification, states that “using the OCAS Conduct of 

Assessment procedure and other OCAS approved technical manuals and procedures as a 

guide [sic], perform an independent DR to compare with the ORAU DR,” and Section 

5.1.3.1 goes on to say that “this [the dose review] should be documented as an 

assessment per the requirements of OCAS-PR-005 ...” The OCAS-PR-007 procedure, 

however, does not reference the OCAS Conduct of Assessment procedure (OCAS-PR005) for Basic Reviews (Section 5.1.1) or for Detailed Reviews (Section 5.1.2). Since 

OCAS-PR-005 appears to cover all three types of reviews (“assessments”), why does 

OCAS-PR-007 cite that procedure for only one of the three types? The subject procedure 

should be corrected if this is only an oversight. 

(6) Section 5.2.1.2 on accuracy of probability of causation consideration in dose 

reconstruction reviews states that, “for cases resulting in a probability of causation of 

50% or greater, ensure that the dose assigned is not a significant overestimate of the dose 

potentially received considering all of the available information.” The procedure should 

provide guidance on what is meant by a “significant overestimate,” since the dose 

reconstructions are supposed to be claimant favorable. 

(7) Section 5.2.2.2 defines “radiological worker” and subsequent sections discuss the 

likelihood of exposure of such a worker when no or incomplete records are available. 
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However, as seen in several site profile TBDs, in some cases, non-radiological workers, 

such as office personnel, may have been inadvertently exposed to radiation. Section 

5.2.3.3 presents an example of an administrative office energy employee, who, in this 

case, received only minimal lifetime dose; such may not always be the case, however. 

(8) As noted in Table 4.2-1, Item 2.5, the procedure does not indicate the details of the 

changes made from the original issue to the first revision, although the Record of 

Issue/Revisions makes the general statement, “Revision to incorporate improved method 

of DR review.” An experienced reviewer using this procedure would have to do a 

paragraph-by-paragraph comparison of the two generations of the procedure to determine 

what has changed and how it affects the review process (a new reviewer would be 

coming to the procedure fresh, without any expectations or routines). It is suggested that 

the Record of Issue/Revisions provide more detailed information, and that revised 

sections are denoted. 

(9) As noted in Table 4.2-1, Item 2.6, the procedure liberally sprinkles acronyms throughout 

the text. Although they are explained at first usage, it would be helpful to the reader to 

include an acronym section in the procedure to facilitate understanding and to minimize 

hunting through the procedure to find their first usage. 

4.3 ORAUT-PROC-0022: ADDITIONAL REQUESTS FOR DOE INFORMATION

This review of ORAUT-PROC-0022, Additional Requests for DOE Information, Rev. 0, dated 

March 15, 2005, was prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, PhD, 

CHP, on March 31, 2006.

4.3.1 Purpose of Procedure

The stated purpose of this procedure is as follows:

. . . to outline the method for requesting additional energy employee (EE) 

information from various U.S. Department of Energy (DOE) sites for purposes of 

dose reconstruction (DR) for the Oak Ridge Associated Universities (ORAU) 

Team Dose Reconstruction Project for the National Institute for Occupational 

Safety and Health (NIOSH) (Section 1.0).

The designation “Energy Employee” can refer to a former or current employee of DOE, a DOE 

contractor or subcontractor, or an Atomic Weapons Employee (AWE). 

4.3.2 Review Protocol

Since the procedure pertains to the gathering of information for dose reconstructions, rather than 

to the performance of dose reconstructions, it is reviewed according to SC&A’s Procedure to

Perform QA Reviews of NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, Draft, April 12, 

2004). Furthermore, Section 8.1 of the procedure lists as one of the drivers, ORAUT-PLAN-
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0001, Quality Assurance Program Plan. Table 4.3-1, which is a checklist taken from 

Attachment A of the SC&A procedure, summarizes the review. 

Table 4.3-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0022, Rev. 0 Effective Date: 3/15/05

Document Title: Additional Requests for DOE Information

Reviewer: Stephen L. Ostrow

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A
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No. Question Y/N Comments

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 2 Manager, 

Project Director, and 

Associate Director for 

Science. 

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y

2.5 Are revisions clearly indicated on affected pages? N/A The document is Rev. 0

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Both in text and in a 

separate section (9.0)

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical”

4.3.3 General Comments

The subject procedure applies to “requests for radiation exposure information or records 

associated with an EE’s employment from DOE” (Section 2.0). The procedure contains sections 

on purpose, scope, references, responsibilities, procedure, records, applicable documents, and 

definitions and acronyms. It describes the overall process by which ORAU personnel request 

additional radiation exposure information from DOE, necessary to complete a dose 

reconstruction. The procedure also includes an Additional Request Form as an attachment.

4.3.4 Review Comments

The Additional Requests for DOE Information procedure is generally clear with a few exceptions 

noted below, and provides adequate guidance to ORAU for requesting additional dosimetry 
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information from DOE for individual energy employees. The following comments, 

observations, and suggestions are made to improve the procedure in future revisions:

(1) The subject procedure refers in several places (Sections 3.0, 5.7, and 6.1.5.2) to the 

ORAU procedure for complying with the Privacy Act (The Privacy Act of 1974, 5 U.S.C. 

§ 552a – As Amended) requirements for safeguarding claimant personal information. 

Citations are not made consistently, as Section 3.0 refers to the procedure as Protecting 

Privacy Act Data, and Sections 5.7 and 6.1.5.2 as Protecting Privacy Act Information. 

More seriously, however, in all three citations, the subject procedure refers to ORAUTPROC-0077 as the Privacy Act procedure, while examination of ORAUT-PROC-0077 

reveals that it is entitled Dose Reconstruction Error Tracking and Reporting. This 

apparent discrepancy suggests that the subject procedure misidentified the ORAU 

Privacy Act procedure and should be revised.

(2) It is suggested that the subject procedure provide such an overview for requesting 

information as a guide the reader. The subject procedure refers in several places to Task 

2, Task 4, and Task 5, and assumes that the reader is familiar with the responsibilities of 

each task (the subject procedure appears to be part of Task 2) and their interrelationships. 

This assumption may confuse the some staff who have to use the procedure without 

benefit of having an overview of the project task organization. 

4.4 ORAUT-PROC-0031: DOE TECHNICAL BASIS DOCUMENT 

DEVELOPMENT, REVIEW, AND APPROVAL PROCESSS

This review of ORAUT-PROC-0031, DOE Technical Basis Document Development, Review, 

and Approval Process, Rev. 01, dated December 15, 2005, was prepared by Stephen L. Ostrow, 

PhD, and approved by John Mauro, PhD, CHP, on March 31, 2006.

4.4.1 Purpose of Procedure

The stated purpose of this procedure is to: “... document and describe the process used to 

develop site profile (SP) technical basis documents (TBDs) for the Oak Ridge Associated 

Universities (ORAU) Team Dose Reconstruction Project as implemented by the National 

Institute for Occupational Safety and Health (NIOSH)” (Section 1.0). As noted in Section 2.0, 

“this procedure applies to all SP TBDs developed for the U.S. Department of Energy (DOE) and 

Atomic Weapons Employee (AWE) Facilities,” and “to all ORAU Team personnel who 

contribute to the development of TBDs and/or who are involved in the internal review and 

approval process for those documents, including the external review and approval by NIOSH” 

(Section 2.0). 

4.4.2 Review Protocol

Since the subject procedure is procedural rather than technical, it is reviewed according to 

SC&A’s Procedure to Perform QA Reviews of NIOSH/ORAU Dose Reconstruction Procedures

(Rev. 0, Draft, April 12, 2004). Table 4.4-1, which is a checklist taken from Attachment A of 

the SC&A procedure, summarizes the review. 
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Table 4.4-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0031, Rev. 01 Effective Date: December 15, 2005

Document Title: DOE Technical Basis Document Development, Review, and Approval Process

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
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No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 3 Manager, 

Project Director, and 

Project officer

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y

2.5 Are revisions clearly indicated on affected pages? N Revision log notes that 

Rev. 1 is a “total rewrite 

of the document”

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.4.3 General Comments

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions (which includes acronyms). It 

describes the responsibilities and interactions of various project personnel as they implement the 

different steps of the procedure. The procedure also includes five attachments, including 

(A) Examples of Tables for the Development of Technical Basis Documents, (B) Typical DOE 

Technical Basis Document Timeline, (C) Technical Basis Document Review and Approval 

Process, (D) Typical Site Profile Content, and (E) Site Profile Team Leader TBD Review 

Declaration. 
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4.4.4 Review Comments

The DOE Technical Basis Document Development, Review, and Approval Process procedure provides 

adequate guidance to ORAU to develop, review, and revise site profile TBDs. It is detailed and 

clear, and specifies the information to be provided in each TBD section; useful examples of 

tables are included. Attachment 3 contains flowcharts for the internal and external review and 

approval process, which should aid the procedure user. The following comments, observations, 

and suggestions are made to improve the procedure in future revisions:

(1) Section 4.2.1 appears to incorrectly reference other sections in the procedure. The correct 

reference should be: “Sections 6.3.10 through 6.2.15.” 

(2) Section 4.2.7 refers to “sensitive information,” but does not define what is meant by that 

term. The definition section (Section 9.0) likewise does not define that term. 

(3) The procedure covers TBD revision reflecting comments from NIOSH and worker 

outreach activities, but does not mention those received from reviews by the Advisory 

Board or its contractors. Is it assumed that such comments come through NIOSH and are 

considered that organization’s comments?

4.5 ORAUT-PROC-0065: INTERNAL FINDING AND CORRECTIVE ACTION TO 

PREVENT RECURRENCE

This review of ORAUT-PROC-0065, Internal Finding and Corrective Action to Prevent 

Recurrence, Rev. 00 PC-1, dated November 30, 2005, was prepared by Stephen L. Ostrow, PhD, 

and approved by John Mauro, PhD, CHP, on March 31, 2006

4.5.1 Purpose of Procedure

The stated purpose of this procedure is “... to establish a methodology to respond to and rectify 

deficiencies identified by employees and/or internal Auditors. The process provides a means for 

developing corrective actions or improvement plans, completing these actions or plans on 

schedule, and addressing preventive measures to ensure continual process improvements” 

(Section 1.0). 

4.5.2 Review Protocol

Since the ORAU procedure is part of that organization’s quality assurance program (and is 

referenced in Section 3.1 of ORAUT-PLAN-0001, Quality Assurance Program, Rev. 1, 

January 31, 2005), it is reviewed according to SC&A’s Procedure to Perform QA Reviews of 

NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). Table 4.5-1, 

which is a checklist taken from Attachment A of the SC&A procedure, summarizes the review. 
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Table 4.5-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0065, Rev. 00 PC-1 Effective Date: 11/03/05

Document Title: Internal Finding and Corrective Action to Prevent Recurrence 

Reviewer: Stephen L. Ostrow

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
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No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 9 Manager, 

Project Director, and 

Associate Director for 

Science

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 00 PC-1

2.5 Are revisions clearly indicated on affected pages? Y Sidebars added on revised 

pages referred to in 

revision log

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.5.3 General Comments

Section 6.12.2.2, Internal Audits, Assessments, and Surveillances, of the ORAU Quality 

Assurance Program requires a mechanism for “developing, implementing, and tracking 

corrective actions and improvement plans to resolve findings and observations;” ORAUTPROC-0065 is listed and provides that mechanism. As emphasized in Section 2.0 of the subject 

procedure, it addresses only internal findings and observations, not external ones (e.g., those 

developed by NIOSH), which are treated in ORAUT-PROC-0069. 

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions and acronyms. It describes 
Effective Date:

August 3, 2007

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the responsibilities and interactions of various project personnel as they implement the different 

steps of the procedure. It also includes an Internal Finding form, a Root Causes form, and an 

Observation Response form as attachments. 

4.5.4 Review Comments

The Internal Finding and Corrective Action to Prevent Recurrence procedure is clear and 

provides adequate guidance to ORAU to comply with the requirements of the ORAU Quality 

Assurance Program (as expressed in ORAUT-PLAN-0001). Section 6, Procedure, is especially 

clear in outlining all the steps to be taken from the identification of a deficiency (finding, 

observation, or neither) to its disposition. The following comments, observations, and 

suggestions are made to improve the procedure in future revisions:

(1) The procedure ought to provide a general discussion of how this implementing procedure 

fits into the overall ORAU Quality Assurance Program.

(2) A flowchart keyed to the sections of the procedure would be helpful to the reader given 

the length and level of detail of the procedure. 

4.6 ORAUT-PROC-0066: QUALITY ASSURANCE RECORDS MANAGEMENT

This review of ORAUT-PROC-0066, Quality Assurance Records Management, Rev. 0, dated 

September 3, 2004, was prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, 

PhD, CHP, on March 31, 2006.

4.6.1 Purpose of Procedure

The stated purpose of this procedure is as follows:

. . . to describe the activities and responsibilities necessary for the identification, 

control, storage, retrieval, and disposition of Task 9 Quality Assurance (QA)-

related records and documents for the Oak Ridge Associated Universities 

(ORAU) Team Dose Reconstruction Project for the National Institute for 

Occupational Safety and Health (NIOSH). (Section 1.0). 

4.6.2 Review Protocol

Since the ORAU procedure is part of that organization’s quality assurance program, it is 

reviewed according to SC&A’s Procedure to Perform QA Reviews of NIOSH/ORAU Dose 

Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). Table 4.6-1, which is a checklist 

taken from Attachment A of the SC&A procedure, summarizes the review. 
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

181 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 4.6-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0066, Rev. 0 Effective Date: 9/03/04

Document Title: Quality Assurance Records Management 

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

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Page No.

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has been edited accordingly, and is now cleared for distribution.

No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 9 Manager 

and Project Director

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 0

2.5 Are revisions clearly indicated on affected pages? N/A The document is Rev. 0

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.6.3 General Comments

Section 6.12.2.2 of the ORAU Quality Assurance Program (ORAUT-PLAN-0001) mandates 

quality assurance-related record keeping on the project to support audits, assessments, and 

surveillances: 

Requirements, responsibilities, and procedures for conducting internal QA audits, 

assessments, and surveillances; for developing, implementing, and tracking corrective 

actions and improvement plans to resolve findings and observations; and for reporting 

and maintaining QA records related to these activities are included in the following 

Project documents [ORAUT-PROC-0066 is listed]: (ORAUT-PLAN-0001, Rev. 1, 

1/31/05, Section 6.12.2.2).

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions and acronyms. It describes 
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

183 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

the responsibilities and interactions of various project personnel as they implement the different 

steps of the procedure. It also includes attachments; (1) “Guidance for Identification of QA 

Records and Nonrecords,” (2) “Guidance for QA Numbering of Audits, Assessments, and 

Surveillances,” and (3) “Audit/Assessment/Surveillance Record File Checklist.” 

Section 5.6 presents the requirement for personnel training in the provisions of the Privacy Act to 

protect records containing personal information of claimants; training is provided in ORAUTPROC-0079.

4.6.4 Review Comments

The Quality Assurance Records Management procedure is clear and provides adequate guidance 

to ORAU for the management of quality assurance records and “nonrecords” (it defines this 

term) in accordance with the requirements of the ORAU Quality Assurance Program (as 

expressed in ORAUT-PLAN-0001). The following comment, observation, and/or suggestion is 

made to improve the procedure in future revisions:

(1) A general discussion of how this implementing procedure fits into the overall ORAU 

Quality Assurance Program would help orient the reader. 

4.7 ORAUT-PROC-0067: CONDUCT OF QUALITY ASSURANCE 

SURVEILLANCES 

This review of ORAUT-PROC-0067, Conduct of Quality Assurance Surveillances, Rev. 0, dated 

September 14, 2004, was prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, 

PhD, CHP, on March 31, 2006.

4.7.1 Purpose of Procedure

The stated purpose of this procedure is as follows:

. . . to establish the process and responsibilities for administering and conducting 

independent Quality Assurance (QA) surveillances of the Oak Ridge Associated 

Universities (ORAU) Team Dose Reconstruction Project for the National Institute 

for Occupational Safety and Health (NIOSH). (Section 1.0)

4.7.2 Review Protocol

Since the ORAU procedure is part of that organization’s quality assurance program, it is 

reviewed according to SC&A’s Procedure to Perform QA Reviews of NIOSH/ORAU Dose 

Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). Table 4.7-1, which is a checklist 

taken from Attachment A of the SC&A procedure, summarizes the review. 
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

184 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 4.7-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0067, Rev. 0 Effective Date: 9/14/04

Document Title: Conduct of Quality Assurance Surveillances

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

185 of 199

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has been edited accordingly, and is now cleared for distribution.

No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 9 Manager,

Project Director, and 

Associate Director for 

Science. 

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 0

2.5 Are revisions clearly indicated on affected pages? N/A The document is Rev. 0.

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of 

some key terms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.7.3 General Comments

Section 6.12.2.2 of the ORAU Quality Assurance Program (ORAUT-PLAN-0001) mandates the 

performance of surveillances on the project: 

The Project shall conduct internal audits, assessments, and surveillances at 

planned intervals to determine whether the QMS [Quality Management System] 

conforms to its plan and to the QMS requirements established by the Project and 

whether QMS implementation and maintenance has been effective. (ORAUTPLAN-0001, Rev. 1, 1/31/05, Section 6.12.2.2)

The Quality Assurance Program document, which is a high-level project plan, goes on to 

delineate the requirements of surveillances, and references the subject procedure (an 
Effective Date:

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implementing procedure), Conduct of Quality Assurance Surveillances, as part of the quality 

management system. The subject procedure applies to the following:

...all qualified ORAU team personnel that conduct a QA surveillance on a Project 

process, activity, or item including participating subcontractors, vendors and 

suppliers at their various locations and facilities to verify conformance to 

specified requirements and to evaluate the adequacy and effectiveness of the 

process, activity or item (Section 2.0). 

The procedure contains sections on purpose, project, scope, references, responsibilities, 

procedure, records, applicable documents, and definitions. 

A surveillance, which “is generally more limited in scope than an audit or assessment,” may be 

either scheduled or unscheduled; the latter may arise from a request by project personnel or by 

the Customer (i.e., NIOSH) (Section 5.1). The procedure describes the overall process by which 

ORAU personnel conduct assessments, outlines the responsibilities and interactions of key 

personnel, describes the record generation and documentation process, and references other 

relevant ORAU procedures relating to surveillances. An example of the latter is reference to 

ORAUT-PROC-0070, Qualification of Quality Assurance Auditors, which establishes training 

requirements of all personnel conducting surveillances (Surveillants). The procedure also 

includes as illustrative attachments a surveillance report form (ORAUT-FORM-0021) and a 

Quality Assurance Checklist.

4.7.4 Review Comments

The Conduct of Quality Assurance Surveillances procedure is generally clear and provides 

adequate guidance to ORAU for the conduct of such surveillances in accordance with the 

requirements of the ORAU Quality Assurance Program (as expressed in ORAUT-PLAN-0001). 

Section 6.0, Procedure, provides numerous helpful notes commenting on some of the 

requirements. The following comments, observations, and suggestions are made to improve the 

procedure in future revisions:

(1) The procedure leads the reader through the surveillance process, delineating 

requirements, responsibilities, and actions at each step. Nonetheless, it would be 

beneficial for greater clarity to provide a flowchart at the beginning of Section 6.0, 

Procedure, with the section text keyed to particular locations in the chart. 

(2) A general discussion of how this implementing procedure fits into the overall ORAU 

Quality Assurance Program would help orient the reader. 

4.8 ORAUT-PROC-0069: EXTERNAL NONCONFORMANCE AND CORRECTIVE 

ACTION TO PREVENT RECURRENCE

This review of ORAUT-PROC-0069, External Nonconformance and Corrective Action to 

Prevent Recurrence, Rev. 0, dated September 9, 2004, was prepared by Stephen L. Ostrow, PhD, 

and approved by John Mauro, PhD, CHP, on March 31, 2006.
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

187 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

4.8.1 Purpose of Procedure

The purpose of this procedure is stated in Section 1.0: 

This procedure establishes the process for responding to nonconformances issued 

by External Auditors and provides instruction for identifying the root cause, 

developing corrective actions to rectify existing conditions and to prevent these 

nonconformances from recurring.”

4.8.2 Review Protocol

Since the ORAU procedure is part of that organization’s quality assurance program, it is 

reviewed according to SC&A’s Procedure to Perform QA Reviews of NIOSH/ORAU Dose 

Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). Table 4.8-1, which is a checklist 

taken from Attachment A of the SC&A procedure, summarizes the review. 

Table 4.8-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0069, Rev. 0 Effective Date: 9/09/04

Document Title: External Nonconformance and Corrective Action to Prevent Recurrence 

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

188 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

No. Question Y/N Comments

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 9 Manager 

and Project Director

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 0

2.5 Are revisions clearly indicated on affected pages? N/A The document is Rev. 0

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

189 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

4.8.3 General Comments

Section 6.12.2.2 of the ORAU Quality Assurance Program (ORAUT-PLAN-0001) mandates 

quality assurance-related record keeping on the project to support audits, assessments, and 

surveillances: 

Requirements, responsibilities, and procedures for conducting internal QA audits, 

assessments, and surveillances; for developing, implementing, and tracking 

corrective actions and improvement plans to resolve findings and observations; 

and for reporting and maintaining QA records related to these activities are 

included in the following Project documents [ORAUT-PROC-0066 is listed]: 

(ORAUT-PLAN-0001, Rev. 1, 1/31/05, Section 6.12.2.2).

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions and acronyms. It describes 

the responsibilities and interactions of various project personnel as they implement the different 

steps of the procedure. It also includes as attachments; (1) “Guidance for Identification of QA 

Records and Nonrecords,” (2) “Guidance for QA Numbering of Audits, Assessments, and 

Surveillances,” and (3) “Audit/Assessment/Surveillance Record File Checklist.” The subject 

procedure, which treats external findings of nonconformance, is companion to ORAUT-PROC0065, which treats internal findings. 

Section 5.6 presents the requirement for personnel training in the provisions of the Privacy Act to 

protect records containing personal information of claimants; training is provided in ORAUTPROC-0079. 

4.8.4 Review Comments

The Quality Assurance Records Management procedure is clear and provides adequate guidance 

to ORAU for the management of quality assurance records and “nonrecords” (it defines this 

term) in accordance with the requirements of the ORAU Quality Assurance Program (as 

expressed in ORAUT-PLAN-0001). The following comment, observation, and/or suggestion is 

made to improve the procedure in future revisions:

(1) A general discussion of how this implementing procedure fits into the overall ORAU 

Quality Assurance Program would help orient the reader. 

4.9 ORAUT-PROC-0077: DOSE RECONSTRUCTION ERROR TRACKING AND 

REPORTING

This review of ORAUT-PROC-0077, Dose Reconstruction Error Tracking and Reporting, 

Rev. 00, dated March 28, 2005, was prepared by Stephen L. Ostrow, PhD, and approved by John 

Mauro, PhD, CHP, on March 31, 2006.
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

190 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

4.9.1 Purpose of Procedure

The stated purpose of this procedure is to provide “... the process for review disposition, 

correction, tracking, and trending of Dose Reconstruction Report errors and comments received 

by the Oak Ridge Associated Universities (ORAU) Team Dose Reconstruction Project for the 

National Institute for Occupational Safety and Health (NIOSH)” (Section 1.0). The “errors and 

comments” referred to are those generated directly by NIOSH reviewers, who review all dose 

reconstruction reports, or by Department of Labor or Final Adjudication Board personnel. 

Section 1.0 also notes that, “This procedure is incorporated by reference into ORAUT-PLAN0009, Project Management Plan.” 

4.9.2 Review Protocol

Since the ORAU procedure is part of that organization’s quality assurance program (ORAUTPLAN-0001, Quality Assurance Program, Rev. 1, 1/31/05), it is reviewed according to SC&A’s 

Procedure to Perform QA Reviews of NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, 

Draft, April 12, 2004). Table 4.9-1, which is a checklist taken from Attachment A of the SC&A 

procedure, summarizes the review. Section 2.0 of the Quality Assurance Program states that 

“Implementation of this procedure, in conjunction with ORAUT-PROC-0059, Peer Review of 

Dose Reconstructions, shall constitute a quality review process as defined by ORAUT-PLAN0001, Quality Assurance Program.”

4.9.3 General Comments

Section 6.12.2.1 of the ORAU Quality Assurance Program discusses NIOSH requirements and 

processes to evaluate and process nonconformances:

The following Project management documents have been established to define the 

requirements and processes to be used to evaluate any nonconformances 

identified by NIOSH and to develop, implement, verify, track, and report 

completion of corrective actions (ORAUT-PLAN-0001, p. 25).

The subject procedure is referenced and described in the list following the above quotation. As 

previously mentioned, in addition to NIOSH comments, there may also be comments from the 

Department of Labor or the Final Adjudication Board. 

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions and acronyms. It describes 

the responsibilities and interactions of various project personnel as they implement the different 

steps of the procedure. It also includes a Dose Reconstruction Review form (ORAUT-FORM0035) as an attachment. 
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

191 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

Table 4.9-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0077, Rev. 0 Effective Date: 3/28/05

Document Title: Dose Reconstruction Error Tracking and Reporting 

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
Effective Date:

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No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 5 Manager, 

Project Director, and 

Associate Director for 

Science

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 00

2.5 Are revisions clearly indicated on affected pages? N/A This is Rev. 00

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.9.4 Review Comments

The Dose Reconstruction Error Tracking and Reporting procedure is clear and provides 

adequate guidance to ORAU to comply with the requirements of the ORAU Quality Assurance 

Program (as expressed in ORAUT-PLAN-0001). The Procedure section (No. 6.0) is especially 

thorough and clear in describing the five major reasons why NIOSH would return dose 

reconstruction reports, and outlining the subsequent steps to be taken by the ORAU Team. The 

following comments, observations, and suggestions are made to improve the procedure in future 

revisions:

(1) A general discussion of how this implementing procedure fits into the overall ORAU 

Quality Assurance Program and Project Management Plan would help orient the reader. 
Effective Date:

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(2) Although the procedure (Section 6.0) is fairly straightforward, it is lengthy and somewhat 

detailed; the user would benefit from a flowchart keyed to text sections. 

(3) Section 4.5, describing the responsibilities of the Claims Processing Support Manager, 

refers to ensuring processing in a “timely manner in accordance with the applicable Cost 

Plus Award Fee (CPAF) goals.” Reference to financial incentives does not belong in a 

QA procedure. 

4.10 ORAUT-PROC-0080: CONDUCT OF QUALITY ASSURANCE AUDITS

This review of ORAUT-PROC-0080, Conduct of Quality Assurance Audits, Rev. 00, dated 

September 9, 2004, was prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, 

PhD, CHP, on March 31, 2006.

4.10.1 Purpose of Procedure

The stated purpose of this procedure is presented in Section 1.0:

... establish the process and responsibilities for the administration and 

performance of formal independent quality audits and assessments of activities 

performed for the Oak Ridge Associated Universities (ORAU) Team Dose 

Reconstruction Project for the National Institute for Occupational Safety and 

Health (NIOSH).” 

4.10.2 Review Protocol

Since the ORAU procedure is part of that organization’s quality assurance program (ORAUTPLAN-0001, Quality Assurance Program, Rev. 1, 1/31/05), it is reviewed according to SC&A’s 

Procedure to Perform QA Reviews of NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, 

Draft, April 12, 2004). Table 4.10-1, which is a checklist taken from Attachment A of the 

SC&A procedure, summarizes the review. Section 3.1 of the Quality Assurance Program lists 

the subject procedure as a Quality Management System document incorporated by reference. 
Effective Date:

August 3, 2007

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Table 4.10-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0080, Rev. 0 Effective Date: 9/9/04

Document Title: Conduct of Quality Assurance Audits 

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

195 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 9 Manager, 

Project Director, and 

Associate Director for 

Science

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 00

2.5 Are revisions clearly indicated on affected pages? N/A This is Rev. 00

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.10.3 General Comments

Section 6.12.2.2 of the ORAU Quality Assurance Program states that “Requirements, 

responsibilities, and procedures for conducting internal QA audits, assessments, and 

surveillances; for developing, implementing, and tracking corrective actions and improvement 

plans to resolve findings and observations; and for reporting and maintaining QA records related 

to these activities are included in the following Project documents,” and references the subject 

procedure. 

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions and acronyms. It describes 

the responsibilities and interactions of various project personnel as they implement the different 
Effective Date:

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steps of the procedure. It also includes Quality Assurance Audit Plan (coversheet), Quality 

Assurance Checklist, and Model Format for Quality Assurance Audit Reports as attachments.

4.10.4 Review Comments

The Conduct of Quality Assurance Audits procedure is clear and provides adequate guidance to 

comply with the requirements of the ORAU Quality Assurance Program. The Procedure section 

(No. 6.0) is especially detailed in presenting the sequence of events from planning an audit, to 

conducting it, to documenting it, and to following it up. The following comments, observations, 

and suggestions are made to improve the procedure in future revisions:

(1) A general discussion of how this implementing procedure fits into the overall ORAU 

Quality Assurance Program would help orient the reader. There are many interrelated 

procedures mentioned in the course of the discussion of the subject procedure, and an 

overview would be welcome. 

(2) The procedure (Section 6.0) is quite lengthy and detailed. With many activities 

conducted by different people at different times, the user would benefit from a flowchart 

keyed to text sections. 

4.11 ORAUT-PROC-0091: DOSE RECONSTRUCTION SUBMITTAL

This review of ORAUT-PROC-0091, Dose Reconstruction Submittal, Rev. 00, dated June 29, 

2005, was prepared by Stephen L. Ostrow, PhD, and approved by John Mauro, PhD, CHP, on 

March 31, 2006.

4.11.1 Purpose of Procedure

The stated purpose of this procedure is to establish “... the process for the receipt, modification, 

and submittal of draft dose reconstruction reports (DRRs) once the dose reconstruction has been 

completed by Task 5. These DRRs are generated by the Oak Ridge Associated Universities 

(ORAU) Team Dose Reconstruction Project for the National Institute for Occupational Safety 

and Health (NIOSH)” (Section 1.0). As noted in Section 5.1, the procedure applies to all dose 

reconstruction reports submitted by ORAU to NIOSH. 

4.11.2 Review Protocol

The subject procedure lists the ORAU Quality Assurance Program (ORAUT-PLAN-0001, 

Quality Assurance Program, Rev. 1, 1/31/05) as a driver; hence, the procedure (which is 

administrative rather than technical) is reviewed according to SC&A’s Procedure to Perform QA 

Reviews of NIOSH/ORAU Dose Reconstruction Procedures (Rev. 0, Draft, April 12, 2004). 

Table 4.11-1, which is a checklist taken from Attachment A of the SC&A procedure, 

summarizes the review. 
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

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Page No.

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Table 4.11-1: QA-related Document Compliance Checklist

Document No.: ORAUT-PROC-0091, Rev. 0 Effective Date: June 29, 2005

Document Title: Dose Reconstruction Submittal 

Reviewer: Stephen L. Ostrow, PhD

No. Question Y/N Comments

1.0 Quality Assurance Program Plan (QAPP)

1.1 Have the organizations originating the procedures and related 

documents established a QA program appearing in a Quality 

Assurance Program Plan (QAPP), and do the implementing 

documents reflect higher-level regulatory and project 

requirements and nuclear industry good practices?

N/A

1.2 When more than one organization is involved in the execution 

of activities, are the responsibilities and authorities of each 

organization clearly established in the QAPP to the extent 

necessary to smoothly perform the activities? 

N/A

1.3 Does the QAPP identify the management position responsible 

for QA development, implementation, assessment, and 

improvement?

N/A

1.3.1 Are there adequate procedures for assuring that personnel 

performing project tasks have proper levels of experience and 

education?

N/A

1.4 Are there adequate procedures for training of project personnel? N/A

1.4.1 Have staff training requirements been identified? N/A

1.4.2 Has staff received general orientation training? N/A

1.4.3 Has staff received training in the requirements of the Privacy 

Act of 1974 and the Freedom of Information Act?

N/A

1.4.4 Has staff received training in the provisions of the QAPP? N/A

1.4.5 Is a master record of staff training maintained in project files? N/A

1.5 Are there adequate procedures for Management and QA 

surveillance, inspection, and audit of work products and 

processes to achieve continuous quality improvement?

N/A

1.6 Do procedures provide for adequate corrective action for 

identified deficiencies and non-conformances in work products 

and processes?

N/A

1.7 Is there an adequate procedure for the maintenance of project 

QA records in identifiable, legible, and retrievable condition?

N/A

1.8 Are there procedures covering all work activities of the project? N/A
Effective Date:

August 3, 2007

Revision No.

1 - Draft

Document No.

SCA-TR-TASK3-0001 (Supplement 1)

Page No.

198 of 199

NOTICE: This document has been reviewed for Privacy Act information, 

has been edited accordingly, and is now cleared for distribution.

No. Question Y/N Comments

2.0 Individual Procedures and Documents

2.1 Is the procedure or document properly identified by title, 

document number, revision number, and date?

Y

2.2 Do the title, document number, revision number, page number, 

and date appear on each page?

N Title appears only on the 

first page; however, the 

other items appear on 

each page and 

unambiguously identify 

the document.

2.3 Has the procedure been reviewed and approved by an 

independent reviewer familiar with the subject matter?

Y Reviewed and approved 

by the Task 4 Manager, 

Project Director, and 

Associate Director for 

Science

2.4 Does the procedure or document include a revision log showing 

revision number, date, and brief description?

Y Log shows internal 

revisions before final 

issue of Rev. 00

2.5 Are revisions clearly indicated on affected pages? N/A This is Rev. 00

2.6 Are all abbreviations, acronyms, and technical terms, which 

may not be generally known by the average reader, adequately 

defined in the text or in a separate section?

Y Abbreviations and 

acronyms are explained as 

they occur in the text. In 

addition, Section 9 

provides definitions of

some key terms and 

acronyms.

2.7 Are all scientific and engineering constants, values, equations, 

and assumptions, which may not be known by the average 

reader, clearly presented and referenced? 

N/A The procedure is 

“administrative,” not 

“technical.”

4.11.3 General Comments

The subject procedure contains sections on purpose, scope, references, responsibilities, general 

matters, procedure, records, applicable documents, and definitions and acronyms. It describes 

the responsibilities and interactions of various project personnel as they implement the different 

steps of the procedure. As Section 5.9 of the procedure states, “There are no paper records 

generated during the submittal process;” all records are electronic, so much of the procedure 

deals with details of creating, modifying, or transferring records on various databases.

4.11.4 Review Comments

The Dose Reconstruction Submittal procedure provides adequate guidance to ORAU to process 

the dose reconstruction records submitted to Task 4 by Task 5 (within ORAU), and to transmit 
Effective Date:

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them to NIOSH for review. The following comments, observations, and suggestions are made to 

improve the procedure in future revisions:

(1) A general discussion of how the subject procedure fits into the overall ORAU dose 

reconstruction process would help orient the reader. There are many interrelated 

procedures in the process and an overview would be welcome. 

(2) The dose reconstruction records treated in the subject procedure contain Privacy Act 

Records, yet the procedure does not reference the appropriate ORAU procedure for 

compliance with the Privacy Act; it should do so.