Page 1 of 5 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for 

use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper 

documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically 

marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

To: Josie Beach, Subcommittee on Procedures Review, Chair

From: John Cardarelli II, PhD, CHP, CIH, PE, Research Health Physicist

Subject: NIOSH Response to SC&A Review Comments of Battelle-TIB-5000,

“Default Assumptions and Methods for Atomic Weapons Employer

Dose Reconstructions” 

Date: July 12, 2022

The purpose of the memorandum is to respond to SC&A’s review comments (January 10, 

2022) on Battelle-TIB-5000, “Default Assumptions and Methods for Atomic Weapons 

Employer Dose Reconstruction,” dated April 2, 2007. As noted in SC&A’s review, since the 

document was released in 2007 many new methods and procedures make many of the 

observations no longer relevant. SC&A had 13 observation and no findings. NIOSH is 

currently assessing the role Battelle-TIB-5000 may have on other programmatic documents 

that provide guidance on dose reconstructions. Once complete, NIOSH will consider 

cancelling this document. Responses to these observations are below. 

SC&A Observation 1 Battelle-TIB-5000 makes extensive use of the computer program 

LOGNORM4, which is no longer publicly available. 

Response: NIOSH concurs that LOGNORM4 is no longer being used. Currently, NIOSH 

employs a variety of freeware statistical programs (e.g. R-code) or commercial Excel add-ins 

(e.g. Vose and @Risk) for dose reconstruction tools and to perform various statistical analysis 

of datasets.

SC&A Observation 2 There are more modern methods for treating censored data.

Response: NIOSH concurs that there are more modern methods for treating censored data. 

Regression on order statistics is discussed in ORAUT-RPRT-0053, Analysis of Stratified 

Coworker Datasets [ORAUT 2014], Multiple imputation is discussed in ORAUT-RPRT-0071, 

External Dose Coworker Methodology [ORAUT 2015], and ORAUT-RPRT-0096, Multiple 

Imputation Applied to Bioassay Co-Exposure Models [ORAUT 2021]. The methods, as 

described in Battelle-TIB-5000, Section 2.1.3, are not currently being used. 
Page 2 of 5

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for 

use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper 

documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically 

marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

SC&A Observation 3 The number of observations in the highest airborne uranium 

concentration group in 1949 is stated to be 64 by Battelle-TIB-5000, 

section 2.1.4.1. This value is inconsistent with the value of 61 shown 

in TIB-5000, table 2.4, and with the 119 total observations in 1949 

listed by TIB-5000.

Response: NIOSH agrees that 61 is most likely the correct number for the fourth data point, 

as noted in the SC&A review, this observation did not alter any conclusions in the TIB.

SC&A Observation 4 The mirror image and preserved mean and variance methods are not 

supported by any technical background in statistical theory of which 

we are aware.

Response: NIOSH concurs that there are more modern methods for assessing data. A more 

modern method to handle the sum of normal noise and lognormal signal is the normallognormal mixture distribution. It is described in ORAUT-RPRT-0096, Multiple Imputation 

Applied to Bioassay Co-Exposure Models [ORAUT 2021]. The methods, as described in 

Battelle-TIB-5000, Section 2.3.1, are not currently being used.

SC&A Observation 5 Battelle-TIB-5000 lacks a sound basis for asserting that the NCRP 

assessment of the reliability of the ICRP Publication 30 models can 

be applied to the currently used ICRP Publication 66 respiratory tract 

and biokinetic models.

Response: NIOSH is currently addressing this observation. We will include it in a separate 

report.

SC&A Observation 6 A GSD of 10, derived from redundant data across seven uranium 

refining plants, is excessive for a sitewide assessment of an 

individual worker.

Response: NIOSH concurs that the use of a GSD of 10 for an entire site, plant, or factory 

might be excessive. A GSD of 10 as described in Battelle-TIB-5000, Section 3.6, is not 

currently being used. As noted in the SC&A comments, NIOSH is using a GSD of 5 as the 

default value in DRs when no other uncertainty data are available [NIOSH 2011]. A minimum 

GSD of 3 is often used for biokinetic modelling.
Page 3 of 5 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for 

use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper 

documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically 

marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

SC&A Observation 7 Dividing the operation - “removing covers from drums” - that was 

observed to take 24 minutes per shift, into two 12-minute periods, 

characterized by low and high radon concentrations, respectively, is 

arbitrary and not claimant favorable.

Response: NIOSH concurs that there are better statistical methods for consolidating data 

into a statistic to be used for dose reconstruction. NIOSH does not employ the results of the 

time-weighted average example in Battelle-TIB-5000, Section 3.8 for dose reconstructions at 

Lake Ontario Ordinance Works (LOOW). 

SC&A Observation 8 The procedure for assessing inadvertent ingestion for residual 

periods at AWE sites has been updated since the issuance of TIB5000. 

Response: NIOSH concurs that the use of OCAS-TIB-009, Estimation of Ingestion Intakes

[NIOSH 2004], to assess inadvertent ingestion during an AWE site’s residual period is not 

appropriate. During an AWE site’s residual period, NIOSH is currently standardizing our

approach to be consistent with NUREG/CR-6755 [NUREG/CR-6755 2002] which is based upon 

NUREG/CR-5512 (1992) Volume 1. Section 6.3.2 for guidance on inadvertent ingestion

[NUREG/CR-5512 1992].

SC&A Observation 9 The revised guidance on dose reconstruction from occupational 

medical x-ray procedures (ORAUT-OTIB-0006, revision 05) should 

be used for the assessments of external doses from such 

procedures. 

Response: NIOSH concurs and is using the current version of ORAUT-OTIB-0006 when 

performing current the dose reconstructions [ORAUT 2018]. 

SC&A Observation 10 Missed doses should be assigned according to the current 

procedures: OCAS-IG-001, revision 3, and ORAUT-OTIB-0020, 

revision 03. Assigning a triangular distribution with minimum = 0, 

mode = 0.5 × LOD, and maximum = LOD is not consistent with 

current guidance.

Response: NIOSH agrees that external missed dose should not be assigned using a 

triangular distribution. Guidance associated with assignment of external missed dose is covered 

in OCAS-IG-001, External Dose Reconstruction Implementation Guideline [NIOSH 2007] and 

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

2011]. The method described in Battelle-TIB-5000, Section 3.14, is not currently being used.
Page 4 of 5 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for 

use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper 

documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically 

marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.

SC&A Observation 11 Ingestion should be added to the pathways of environmental doses.

Response: NIOSH agrees that ingestion is a possible pathway of environmental intakes and 

should be considered when developing an environmental exposure approach. ORAUT-PROC0031, Site Profile and Technical Basis Document Development [ORAUT 2012b], Section 6.7.3., 

call for the ingestion pathway to be evaluated if it is applicable to the site.

SC&A Observation 12 Using a lognormal distribution with a mean value of 0.02 to represent 

an equilibrium factor for thoron is questionable. A bounding, sitespecific equilibrium factor should be derived as needed, based on 

available data.

Response: The equilibrium factor, as described in Battelle-TIB-5000, Section 3.17.3, is not 

currently being used. Guidance associated with the thoron equilibrium factor is provided in 

DCAS-TIB-011, Dose Conversion Factors for Radon WLM [NIOSH 2018]. 

SC&A Observation 13 Even if the true underlying distribution of concentrations were 

lognormal, there is no real reason to assume that the distribution of 

the uncertainty of the representativeness parameter is also 

lognormal.

Response: NIOSH concurs that there are more modern methods for dealing with uncertainty 

distribution. This method, as described in Battelle-TIB-5000, Section 3.20, is not currently being 

used.

References

NIOSH [2004]. Estimation of Ingestion Intakes. OCAS-TIB-09 Rev. 0. Cincinnati, OH: U.S. Department of 

Health and Human Services, Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health. April 13. [SRDB Ref ID: 22397]. 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/oc-t9-ro.pdf

NIOSH [2007]. External Dose Reconstruction Implementation Guideline. OCAS-IG-001 Rev. 03. 

Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health. November 21. [SRDB Ref ID: 88929].

https://www.cdc.gov/niosh/ocas/pdfs/dr/oc-ig-001-r3.pdf

NIOSH [2011]. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals. Battelle-TBD6000 Rev. 1. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control 

and Prevention, National Institute for Occupational Safety and Health. June 17. [SRDB Ref ID: 101251]. 

https://www.cdc.gov/niosh/ocas/pdfs/tbd/bat-6000-r1.pdf
Page 5 of 5

NIOSH [2018]. Dose Conversion Factors for Radon WLM. DCAS-TIB-011 Rev. 05. Cincinnati, OH: U.S. 

Department of Health and Human Services, Centers for Disease Control and Prevention, National 

Institute for Occupational Safety and Health. June 28. [SRDB Ref ID: 175105]. 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/dc-t11-r5-508.pdf

NUREG/CR-5512 [1992]. Residual Radioactive Contamination From Decommissioning: Technical Basis for 

Translating Contamination Levels to Annual Total Effective Dose Equivalent, Final Report and Volume 1; 

NUREG/CR-5512, PNL-7994; October 1992. [SRDB Ref ID: 23558]. 

https://documents.deq.utah.gov/legacy/businesses/e/energysolutions/depleted-uranium/performanceassessment/compliance-report/docs/2014/07Jul/supinfo/appreferences/Kennedy_Strenge1992.pdf

NUREG/CR-6755 [2002]. Technical Basis for Calculating Radiation Doses for the Building Occupancy 

Scenario Using the Probabilistic RESRAD-BUILD 3.0 Code. NUREG/CR-6755, ANL/EAD/TM/02-1. [SRDB 

Ref ID: 91669]. https://www.nrc.gov/docs/ML0205/ML020590035.pdf

ORAUT [2011]. Use of Coworker Dosimetry Data for External Dose Assignment. ORAUT-0TIB-0020. Rev. 

03. Oak Ridge, TN: Oak Ridge Associated Universities Team. November 14. [SRDB Ref ID: 104029] 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t20-r3.pdf

ORAUT [2012b]. Site Profile and Technical Basis Document Development, ORAUT-PROC-0031 Rev. 04. 

Oak Ridge, TN: Oak Ridge Associated Universities Team. November 5. [SRDB Ref ID: 166849]. 

ORAUT [2014]. Analysis of Stratified Coworker Datasets, ORAUT-RPRT-0053 Rev. 02. Oak Ridge, TN: Oak 

Ridge Associated Universities Team. October 8. [SRDB Ref ID: 136245]. 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-53-r2.pdf

ORAUT [2018]. Dose Reconstruction from Occupational Medical X-Ray Procedures, ORAUT-OTIB-0006

Rev. 05. Oak Ridge, TN: Oak Ridge Associated Universities Team. August 13. [SRDB Ref ID: 178310]. 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t6-r5-508.pdf

ORAUT [2015]. External Dose Coworker Methodology. ORAUT-RPRT-71 Rev. 00. Oak Ridge, TN: Oak 

Ridge Associated Universities Team. July 2. [SRDB Ref ID: 145135]

ORAUT [2021]. Multiple Imputation Applied to Bioassay Co-Exposure Models. ORAUT-RPRT-0096 Rev. 

01. Oak Ridge, TN: Oak Ridge Associated Universities Team. June 11. [SRDB Ref ID: 175396]. 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-96-r1-508.pdf

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for 

use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper 

documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically 

marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a

and has been cleared for distribution.