REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH 

National Institute of Occupational Safety and Health 

Audit of Case PIID* from the Oak Ridge National Laboratory − X-10 Site 

Contract No. 200-2004-03805 

Task Order No. 4 

SCA-TR-TASK4-CNPIID* 

Prepared by 

S. Cohen & Associates 

6858 Old Dominion Road, Suite 301 

McLean, Virginia 22101 

February 2005 

NOTICE: This information is protected by Privacy Act 5 USC §552a; disclosure to any third party without 

the written consent of the individual to whom the information pertains is strictly prohibited.
Document No. 

SCA-TR-TASK4-CNPIID* 

Effective Date: 

February 4, 2005 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 1 

AUDIT OF CASE PIID* FROM THE OAK RIDGE 

NATIONAL LABORATORY − X-10 SITE

Page 2 of 18 

Task Manager: ___________________ Date: 02/04/05 

 U. Hans Behling, PhD, MPH 

Project Manager: _________________ Date: 02/04/05 

 John Mauro, PhD, CHP 

Supersedes: 

Draft Rev. 0 

ORNL X-10 Site Case PIID* 2 S. Cohen & Associates 
TABLE OF CONTENTS 

1.0 Summary Background Information .................................................................................... 4 

1.1 Audit Objectives ..................................................................................................... 5 

1.2 Summary of Audit Findings.................................................................................... 6 

2.0 Audit of External Doses...................................................................................................... 9 

2.1 Photon Doses .......................................................................................................... 9 

2.2 Neutron Doses....................................................................................................... 10 

2.3 Occupational Medical Exposures ......................................................................... 10 

3.0 Audit of Internal Doses..................................................................................................... 12 

4.0 CATI Report and Radiological Indicents ......................................................................... 13 

5.0 Summary Conclusions ...................................................................................................... 14

References..................................................................................................................................... 15 

Appendix A: IREP Input.............................................................................................................. 17 

ORNL X-10 Site Case PIID* 3 S. Cohen & Associates 
1.0 SUMMARY BACKGROUND INFORMATION

This report presents the results of an independent audit of a dose reconstruction performed by the 

National Institute of Occupational Safety and Health (NIOSH). The dose reconstruction was 

done for an energy employee who worked at the Oak Ridge National Laboratory (ORNL), 

known historically as the X-10 site, for approximately PIID*, from PIID*, through PIID* This 

period included the time when X-10 conducted research and development as well as production 

activities in support of the Department of Energy (DOE) and its predecessor agencies. Activities 

that involve ionizing radiation and radioactive materials included operating nuclear reactors, 

processing special nuclear materials, radioisotope production and separation, and processing 

radioactive wastes. 

As a PIID*, the covered employee accessed many onsite areas and spent an indeterminate 

amount of time in buildings and vehicles that were contaminated.1

 The employee was monitored 

for external exposure, but the frequency of dosimeter exchange is uncertain and all dosimeters 

read zero (i.e., less than detectable). The employee was not a part of any formal internal 

dosimetry program, and there are no bioassay data available. According to the CATI,2 the 

employee had at least one medical x-ray as part of employment at X-10. On PIID*, the energy 

employee was diagnosed with cancer of the colon and subsequently died on PIID*. 

NIOSH determined external and medical x-ray doses to the colon using the protocols for missed 

doses described in ORAUT-OTIB-0010 and ORAU-OTIB-0006, respectively. In accordance 

with ORAUT-OTIB-0007, onsite ambient doses were not considered. Internal doses were 

determined using a hypothetical protocol described in ORAUT-OTIB-0002, which assumes an 

intake of a mixture of 28 radionuclides and is intended to maximize any potential internal dose 

that may have occurred but was not recorded. Doses from radiological incidents were not 

included. 

The external and internal doses to the organ of interest were determined by NIOSH to be 23.106 

and 13.912 rem, respectively. The probability of causation (POC) was determined by the 

Department of Labor to be 37.16% at the 99% confidence interval, and on this basis, the claim 

was denied. Table 1 summarizes the results of NIOSH’s reconstruction of the doses to the 

energy employee’s colon for the purpose of deriving the POC using the IREP protocol. 

In some cases, the dose estimates were based on overly conservative assumptions. It should be 

noted that such values are intentional overestimates of the energy worker’s dose and differ 

from assumptions defined as claimant favorable. Claimant favorable refers to information 

that is truly lacking or unknowable, and where the employee is given the benefit of the doubt. 

An intentional overestimate applies when applicable data exists, but the dose constructors 

deliberately assume bounding conditions for reasons of process efficiency. 

Table 1. Summary of Internal/External Exposures as Estimated by NIOSH 

 1

 NIOSH Report of Dose Reconstruction under the Energy Employees Occupational Illness Compensation 

Act (EEOICPA), NIOSH id: PIID* 2

 Energy Employees Occupational Illness Compensation Program Act (EEOICPA) Dose Reconstruction 

Telephone Interview, conducted 9/3/2002 

ORNL X-10 Site Case PIID* 4 S. Cohen & Associates 
Appendix A 

Exposure Entry No.

Dose 

(rem) 

External Dose: 

 ▪ Photon Dosimeter Dose NA* 0 

 ▪ Photon Missed Dose 85 – 105 21.363 

 ▪ Neutron Dosimeter Dose NC** — 

 ▪ Neutron Missed Dose NC** — 

 ▪ Occupational Medical 106 – 126 1.743 

 ▪ Onsite Ambient NC** — 

Internal Dose: 1 – 84 13.912 

Total 26.337 

*NA = Not applicable 

**NC = Not considered 

1.1 AUDIT OBJECTIVES 

SC&A’s audit was performed with the following objectives: 

• To determine if NIOSH assigned doses that are consistent with monitoring 

records provided by the DOE and with the information contained in the CATI 

report 

• To determine if the dose reconstruction process complied with applicable 

procedures that include generic procedures developed by NIOSH and ORAUT, as 

well as data/procedures that are site-specific 

• In instances when procedure(s) provide more than one option or require subjective 

decisions, determine if the process is scientifically defensible and/or claimant 

favorable. 

In pursuit of these objectives, a two-step process is followed in this audit. The first step of this 

audit is to independently duplicate, and therefore validate, doses derived by NIOSH. This step of 

the audit process is not only contractually mandated under Task 4, but provides NIOSH and the 

Advisory Board with a high level of assurance that the SC&A reviewer understands which 

procedures, models, site-specific data, and assumptions NIOSH used to perform its dose 

reconstruction. The second step of the audit critically evaluates whether the methods employed 

by NIOSH are technically defensible, consistent with applicable procedures, and claimant 

favorable. 

It is worth noting that the Technical Basis Document(s) for the Oak Ridge National Laboratory 

have not been subjected to a detailed SC&A technical review, as have the equivalent documents 

from several other sites. Review of these documents could uncover other problems or issues 

with the potential to affect this claim. At such time that these site documents are reviewed, it is 

recommended that dose reconstructions performed in behalf of the ORNL site be revisited to 

assess any changes caused by new information. 

ORNL X-10 Site Case PIID* 5 S. Cohen & Associates 
Lastly, in compliance with the Privacy Act, this report makes no reference to the claimant’s 

name, SSN, address, or any personal data that might reveal the identity of the claimant. 

1.2 SUMMARY OF AUDIT FINDINGS 

An overview of SC&A’s audit findings for Case PIID* is provided in Table 2 in the form of a 

checklist. This checklist evaluates the data collection process, information obtained from the 

CATI interview, and all methods used in the dose reconstruction. When deficiencies are 

identified by the audit, such deficiencies are further characterized with regard to their impact(s) 

by means of the following definitions: (1) low means that the deficiency has only a marginal 

impact on dose; (2) medium means that the deficiency substantially impacts the dose, but is 

unlikely to impact the compensability of the case; and (3) high means that the deficiency 

substantially impacts the dose and may also impact the compensability of the case. A full 

description of deficiencies identified in the checklist is provided in the text of the audit that 

follows. 

ORNL X-10 Site Case PIID* 6 S. Cohen & Associates 
Table 2. Case Review Checklist 

CASE PIID* ASSIGNED DOSE: 26.337 rem POC: 37.16% 

Audit Response If No, Potential Significance No. Description of Technical Elements of Review YES N/A NO LOW3 MEDIUM4 HIGH5

A. REVIEW OF DATA COLLECTION: 

A.1 Did NIOSH receive all requested data for the DOE or 

AWE site from any relevant data source? T

A.2 Is the data used by NIOSH for the case adequate to 

make a determination with regard to POC? T

B. REVIEW OF INTERVIEW AND DOCUMENTATION PROVIDED BY CLAIMANT 

B.1 Did NIOSH properly address all work history 

dates/locations of employment reported by claimant? T

B.2 Did NIOSH properly address all 

incidents/occurrences reported by claimant? T

B.3 Did NIOSH properly address monitoring/ personal 

protection/work practices reported by claimant? T

B.4 Is the interview information consistent with data used 

for dose estimate? T

C. REVIEW OF PHOTON DOSES 

C.1 Was the appropriate procedure used for determining: 

C.1.1 - Recorded Photon Dose? T

C.1.2 - Missed Photon Dose? T T

C.1.3 - Occupational Medical Dose? T T

C.1.4 - Onsite-Ambient Dose? T T

C.2 Did the DR properly account for all: 

C.2.1 - Recorded Photon Dose? T

C.2.2 - Missed Photon Dose? T T

C.2.3 - Occupational Medical Dose? T T

C.2.4 - Onsite-Ambient Dose? T

C.3 Is the recorded/assigned dose properly converted to the organ dose of interest for: 

C.3.1 - Recorded Photon Dose? T

C.3.2 - Missed Photon Dose? T

C.3.3 - Occupational Medical Dose? T T

C.3.4 - Onsite-Ambient Dose? T

C.4 Is the organ dose uncertainty properly determined for: 

C.4.1 - Recorded Photon Dose? T

C.4.2 - Missed Photon Dose? T T

C.4.3 - Occupational Medical Dose? T

C.4.4 - Onsite-Ambient Dose? T

D. REVIEW OF SHALLOW (i.e., 7 mg/cm2)/ELECTRON DOSES 

D.1 Was the appropriate procedure used for determining: 

D.1.1 - Recorded Shallow/Electron Dose? T

D.1.2 - Missed Shallow/Electron Dose? T

D.1.3 - Onsite Ambient Dose? T

D.2 Did the DR properly account for all: 

D.2.1 - Recorded Shallow/Electron Dose? T

D.2.2 - Missed Shallow/Electron Dose? T

D.2.3 - Onsite Ambient Dose? T

D.3 Is the recorded/assigned dose properly converted to the organ dose of interest for: 

D.3.1 - Recorded Shallow/Electron Dose? T

 

3 Low means that the deficiency has only a marginal impact on dose. 4 Medium means that the deficiency substantially impacts the dose, but is unlikely to impact the compensability of the case. 5 High means that the deficiency substantially impacts the dose and may also impact the compensability of the case. 

ORNL X-10 Site Case PIID* 7 S. Cohen & Associates 
CASE PIID* ASSIGNED DOSE: 26.337 rem POC: 37.16% 

Audit Response If No, Potential Significance No. Description of Technical Elements of Review YES N/A NO LOW3 MEDIUM4 HIGH5

D.3.2 - Missed Shallow/Electron Dose? T

D.3.3 - Onsite Ambient Dose? T

D.4 Is the organ dose uncertainty properly determined for: 

D.4.1 - Recorded Shallow/Electron Dose? T

D.4.2 - Missed Shallow/Electron Dose? T

D.4.3 - Onsite Ambient Dose? T

E. REVIEW OF NEUTRON DOSES 

E.1 Was the appropriate procedure used for determining: 

E.1.1 - Recorded Neutron Dose? T

E.1.2 - Assigned Neutron Dose? T

E.1.3 - Missed Neutron Dose? T

E.2 Did the DR properly account for all: 

E.2.1 - Recorded Neutron Dose? T

E.2.2 - Assigned Neutron Dose? T

E.2.3 - Missed Neutron Dose? T

E.3 Is the recorded/assigned dose properly converted to the organ dose of interest for: 

E.3.1 - Recorded Neutron Dose? T

E.3.2 - Assigned Neutron Dose? T

E.3.3 - Missed Neutron Dose? T

E.4 Is the organ dose uncertainty properly determined for: 

E.4.1 - Recorded Neutron Dose? T

E.4.2 - Assigned Neutron Dose? T

E.4.3 - Missed Neutron Dose? T

F. REVIEW OF INTERNAL DOSE: BASED ON HYPOTHETICAL MODEL 

F.1 Is the use of the selected hypothetical internal dose 

model appropriate, based on the likely POC value? T

F.2 Is the use of a hypothetical internal dose model 

appropriate/conservative, based on claimant’s 

available bioassay data,? 

T

F.3 Was the hypothetical dose value correctly derived? T

G. REVIEW OF INTERNAL DOSE: BASED ON BIOASSAY/IMBA 

G.1 Was the appropriate procedure (or section of 

procedure) used for determining likely (>50%), 

unlikely (<50%), or undetermined POC and 

compensability? 

T

G.2 Are bioassay data sufficiently adequate for internal 

dose reconstruction? T

G.3 Are assumptions pertaining to dates of uptake 

reasonable/conservative? T

G.4 Are critical parameters (e.g., solubility class, particle 

size, etc.) used for IMBA organ dose estimates 

appropriate? 

T

G.5 Are assigned uncertainties (measurement errors) for 

bioassay data (used as input to IMBA) appropriate? T

H. Total Number of Deficiencies and Their Combined Potential Significance 7 T

_______________________ 

1

 Low means that the deficiency has only a marginal impact on dose. 2

 Medium means that the deficiency substantially impacts the dose, but is unlikely to impact the compensability of the case. 3

 High means that the deficiency substantially impacts the dose and may also impact the compensability of the case. 

ORNL X-10 Site Case PIID* 8 S. Cohen & Associates 
2.0 AUDIT OF EXTERNAL DOSES 

For Case PIID*, NIOSH performed a dose reconstruction that produced a total of 126 dose 

entries for determining the probability of causation (POC). Appendix A of this report reproduces 

the IREP dose input used by NIOSH. Throughout this report, reference will be made to select 

portions of Appendix A; for example, exposure entries #85 through #105 correspond to 

estimated external doses, which are discussed in more detail in Section 3.1 below. 

 2.1 PHOTON DOSES 

This worker was monitored for external exposure, where all of the dosimeter readings were zero 

or less than detectable, but the actual dosimeter exchange frequency was not assessed. To 

provide an intentional overestimate of the external missed photon dose, an exchange of 12 

badges per year was assumed for PIID*, giving a total of 252. Supposedly, missed photon doses 

were derived as described in ORAUT-OTIB-0010. 

For misses dose, the dose reconstructor provided the following explanation in the Dose 

Reconstruction Report: 

 Based on information provided in the Technical Information Bulletin: 

Overestimating External Doses Measured with Film Badge Dosimeters,8

 the total 

number of dosimeter cycles assigned was 252 for photons. This number was 

based on a claimant-favorable assumption of 12 badge exchanges each full or 

partial year of employment and was maximized to ensure that all possible 

instances of a zero badge reading were accounted for in this dose reconstruction. 

Based on information provided in the Technical Information Bulletin: 

Overestimating External Doses Measured with Film Badge Dosimeters,8 this 

results in a maximum potential missed dose . . . of 21.363 rem from photons. For 

the purpose of calculating probability of causation, this value was divided by 2 in 

accordance with the External Dose Reconstruction Implementation Guideline.3

In behalf of uncertainty, the dose reconstructor provided the following: 

 Uncertainty

 Except for missed dose, point estimates (constant values) were used for organ 

dose input into the NIOSH-Interactive RadioEpidemiological Program (NIOSHIREP). Missed doses were divided by 2 and a lognormal distribution was applied 

in accordance with the NIOSH External Dose Reconstruction Implementation 

Guideline.3

SC&A’s audit of Case PIID* identified a total of four misinterpretations of ORAUT=OTIB0010, as summarized below: 

1. In addition to using the LOD of 40 mrem x 12 monthly cycles/year and the organ DCF of 

1.06, the dose reconstructor erroneously also applied the “Standard Correction Factor” of 

2. 

ORNL X-10 Site Case PIID* 9 S. Cohen & Associates 
2. The dose reconstructor corrected the first error by subsequently dividing the abovederived value by 2 “. . . in accordance with NIOSH External Dose Reconstruction 

Implementation Guideline.” 

3. For the IREP input, the dose reconstructor erroneously defined values derived in step #2 

as values defined by a lognormal distribution and assigned a GSD of 1.52 for parameter 2 

in the IREP input code. (Note: Since LOD defined the 95th percentile value of a missed 

dose, there is no need to include uncertainty.) 

4. In behalf of Case PIID*, the dose reconstructor applied the ORAUT-OTIB-0010 

methodology for a period of 21 years, from PIID*. ORAUT-OTIB-0010, however, states 

that this procedure only applies to the “late film badge era” that is defined by the fourelement film badge. For Case PIID*, who was employed at ORNL, the four-element film 

badge was replace by a site-specific TLD in 1976. Thus, the procedure ORAUT-OTIB0010 can only be applied for the years PIID*; and from PIID*, the dose reconstructor 

should have employed ORAUT-OTIB-0008: Technical Information Bulletin for a 

Standard Complex-Wide Conversion/Correction Factor for Overestimating External 

Doses Measured with Thermoluminescent Dosimeters. 

The fact that these errors were consistently claimant favorable is fortunate, but does not negate 

SC&A’s concern about the misinterpretation of procedures used in dose reconstruction. 

2.2 NEUTRON DOSES

The neutron component of external doses was not considered for this employee. Based on the 

information in the X-10 Technical Background Document ORAUT-TKBS-0012-2, there does 

not seem to be any compelling reason to include a neutron component for this worker. ORAUTTKBS-0012-6, page 13, states “Neutron sensitive dosimeters were assigned only to individuals 

whose work involved potential neutron exposure.” SC&A finds no issues with the neutron 

exposure from external dose. 

 2.3 OCCUPATIONAL MEDICAL EXPOSURES

The exact number of medical x-rays for this worker is unknown based on CATI information and 

the absence of applicable DOE records. For claimant favorability, an annual chest x-ray was 

assumed for the PIID*. For each x-ray exam, NIOSH assigned a dose of 82 mrem as an organ 

dose to the colon, which was further multiplied by 1.3, as given in the following statement in the 

DR Report: 

This calculation [i.e., a total x-ray dose of 1.743 rem] is based on an assumed

dose of 0.083 rem per procedure, which represents the highest x-ray dose 

recorded in Table 4.0-1 (post 1969) for any organ other than skin, multiplied by 

1.3 to account for uncertainty. [Emphasis added.] 

ORNL X-10 Site Case PIID* 10 S. Cohen & Associates 
From Table 4.0-1 of ORAUT-OTIB-0006, SC&A determined that the assigned dose of 83 mrem 

represents the organ dose to the breast at 63.8 mrem times 1.3 to account for uncertainty. While 

this value is clearly high and benefits the claimant, use of the breast as the surrogate organ for 

the colon is scientifically difficult to justify in behalf of the definition of “claimant favorable,” 

which is to be used in instances of “unknown” values. Table 4.0-1, in fact, identifies a dose to 

the colon of 1E-04 rem (or 1 mrem), which is nearly a factor of 100-fold lower. 

While SC&A fully endorses the use of claimant-favorable values in instances of unknown(s), the 

deliberate assignment of an excessively higher value may lead to problems if such excess values 

are not assigned consistently among claimants. 

ORNL X-10 Site Case PIID* 11 S. Cohen & Associates 
3.0 AUDIT OF INTERNAL DOSES

This worker was not a part of any formal bioassay or other internal dosimetry program as far as 

the available information indicates. The protocol outlined in ORAU-0TIB-0002 assumes an 

intake of a mixture of 28 radionuclides from reactor and non-reactor sites (Table 3.1.1-2) and 

specifically excludes Tritium (H-3). This is an overestimate, because it is improbable that this 

worker could have had an intake of these radionuclides as described in ORAUT-OTIB-0002, and 

the output derived by NIOSH was verified by independent calculation as described below. The 

value derived from this calculation is not supposed to resemble a realistic determination of the 

internal dose to this worker; by design it is an intentional overestimate. We find no issues with 

the calculation of the internal dose. 

ORNL X-10 Site Case PIID* 12 S. Cohen & Associates 
4.0 CATI REPORT AND RADIOLOGICAL INDICENTS 

The CATI report makes no mention of radiological incidents or to any data that could impact any 

assigned doses that reflect measured or assumed doses. 

ORNL X-10 Site Case PIID* 13 S. Cohen & Associates 
5.0 SUMMARY CONCLUSIONS 

Regarding the dose reconstruction for this worker, SC&A finds the following: 

• In general, the dose reconstruction process for this energy worker was based on 

adequate information. 

• For missed photon dose, the dose reconstructor misuse/misinterpreted the cited 

procedures at multiple steps. The combination of errors in behalf of missed doses 

for this case is nearly identical to those of two other cases (Case # PIID* and Case 

# PIID*. 

• The exclusion of a neutron component for the external dose calculation is 

acceptable. 

• Select dose calculations are intentional overestimates, which exceed the definition 

of claimant favorable and result in doses that are clearly in excess of the actual 

dose. 

ORNL X-10 Site Case PIID* 14 S. Cohen & Associates 
REFERENCES

OCAS-IG-001. 2002. “External Dose Reconstruction Implementation Guideline,” Rev 1. 

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

Support, Cincinnati, Ohio. 

OCAS-IG-002. 2002. “Internal Dose Reconstruction Implementation Guideline,” Rev 0. 

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

Support, Cincinnati, Ohio. 

ORAUT-OTIB-0002. 2004. “Technical Information Bulletin – Maximum Internal Dose 

Estimates for certain DOE Complex Claims,” Revision No. 01. Oak Ridge Associated 

Universities, Cincinnati, Ohio. 

ORAUT-OTIB-0004. 2003. “Technical Information Bulletin: Technical Basis for Estimating 

the Maximum Plausible Dose to Workers at Atomic Weapons Employer Facilities,” Revision 

No. 02. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-OTIB-0006. 2003. “Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Diagnostic X-ray Procedures,” Revision No. 02. Oak Ridge Associated 

Universities, Cincinnati, Ohio. 

ORAUT-OTIB-0007. 2003 “Technical Information Bulletin: Occupational Dose from Elevated 

Levels of External Radiation,” Revision No. 00. Oak Ridge Associated Universities, Cincinnati, 

Ohio. 

ORAUT-OTIB-0008. 2003. “Technical Information Bulletin for a Standard Complex-Wide 

Conversion/Correction Factor for Overestimating External Doses Measured with 

Thermoluminescent Dosimeter,” Revision No. 00. Oak Ridge Associated Universities, 

Cincinnati, Ohio. 

ORAUT-OTIB-0010. 2004. “Technical Information Bulletin: A Standard Complex-Wide 

Correction Factors for Overestimating External Doses Measured with Film Badge Dosimeters,” 

Revision No. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-PROC-0002. 2003. “Use of Integrated Modules for Bioassay Analysis (IMBA),” 

Revision No. 01. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-PROC-0003. 2003. “Internal Dose Reconstruction,” Revision No. 00. Oak Ridge 

Associated Universities, Cincinnati, Ohio. 

ORAUT-PROC-0006. 2003. “External Dose Reconstruction,” Revision No. 00. Oak Ridge 

Associated Universities, Cincinnati, Ohio. 

ORNL X-10 Site Case PIID* 15 S. Cohen & Associates 
REFERENCES (Continued) 

ORAUT-TKBS-0012-2. 2003. “Technical Basis Document for the Oak Ridge National 

Laboratory - Site Description” ORAUT-TKBS-0012-2, Revision 00. Oak Ridge Associated 

Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0012-3. 2004. “Technical Basis Document for the Oak Ridge National 

Laboratory – Occupational Medical Dose,” Revision 00. Oak Ridge Associated Universities, 

Cincinnati, Ohio. 

ORAUT-TKBS-0012-4. 2004. “Technical Basis Document for the Oak Ridge National 

Laboratory – Occupational Environmental Dose,” Revision 00. Oak Ridge Associated 

Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0012-5. 2004. “Technical Basis Document for the Oak Ridge National 

Laboratory – Occupational Internal Dose,” Revision 00. Oak Ridge Associated Universities, 

Cincinnati, Ohio. 

ORAUT-TKBS-0012-6. 2004. “Technical Basis Document for the Oak Ridge National 

Laboratory – Occupational External Dose,” Revision 00. Oak Ridge Associated Universities, 

Cincinnati, Ohio. 

ORNL X-10 Site Case PIID* 16 S. Cohen & Associates 
APPENDIX A: IREP INPUT

Deletions made to the following table -- please see hard copy labeled "#19 - Oak Ridge Natl. 

Lab."

ORNL X-10 Site Case PIID* 17 S. Cohen & Associates 
APPENDIX A (continued) 

Deletions made to the following table -- please see hard copy labeled "#19 - Oak Ridge Natl. 

Lab." 

ORNL X-10 Site Case PIID* 18 S. Cohen & Associates