REPORT TO THE ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH

National Institute of Occupational Safety and Health 

Audit of Case #PIID* from the Savannah River 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 SAVANNAH 

RIVER SITE

Page 2 of 14 

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 

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TABLE OF CONTENTS 

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

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

1.2 Summary of Audit Findings.................................................................................... 5 

2.0 Audit of External Doses...................................................................................................... 8 

2.1 Occupational Medical Doses .................................................................................. 8 

2.1.1 Reviewer’s Comments................................................................................ 8 

2.2 Onsite Ambient Dose.............................................................................................. 8 

2.2.1 Reviewer’s Comments................................................................................ 8 

3.0 Audit of Internal Doses..................................................................................................... 10 

3.1 Reviewer’s Comments.......................................................................................... 10 

4.0 CATI Report and Radiological Incidents ......................................................................... 11 

4.1 Reviewer’s Comments.......................................................................................... 11 

5.0 Summary Conclusion........................................................................................................ 12 

References..................................................................................................................................... 13 

Appendix A: IREP Input.............................................................................................................. 14 

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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) for an energy employee who 

worked at the Savannah River Site (SRS) intermittently from PIID* through PIID*. The exact 

periods of employment included the following: PIID* to PIID*; PIID* to PIID*; and PIID*. 

The claimant was employed as an electrician at various onsite locations. The energy employee 

was diagnosed with squamous cell skin cancers on PIID*, and was diagnosed with basal cell skin 

caner on PIID*. 

Throughout the employment period, the claimant was not monitored for external exposure by 

means of film dosimeters or TLDs. The claimant was also not monitored for internal exposure 

by any of the standard bioassay methods that include whole-body counting, chest counting, and 

urinalysis. (Note: DOE records show a single whole-body count in PIID*, which was, however, 

a “new hire” baseline count that indicated no body burden of non-natural nuclides and is not 

considered a “monitoring” bioassay.) 

A dose reconstruction was performed by NIOSH that included a total of 60 exposure data entries 

to be used for determining the probability of causation (POC). These dose data entries are #1 

through #60 and are reproduced herein as Appendix A. Throughout this report, reference will be 

made to select portions of Appendix A; for example, exposure entries #1 through #52 identify 

hypothetical internal exposures, and entries #52 through #56 represent onsite ambient doses. 

Table 1 below provides a summary of organ dose estimates/assignments derived by NIOSH that 

correspond to data contained in Appendix A. Using NIOSH’s dose estimate, the POC was 

determined by the Department of Labor (DOL) to be 5.46% at the 99% confidence interval, and 

on this basis, the claim was denied. 

Table 1. Summary of NIOSH-Derived External/Internal Dose Estimates 

Appendix A 

Exposure Entry No. 

Dose 

(rem) 

External Dose: 

 ▪ Photon Dosimeter Dose NC* — 

 ▪ Missed Photon Dose NC* — 

 ▪ Neutron Dosimeter Dose NC* — 

 ▪ Missed Neutron Dose NC* — 

 ▪ Occupational Medical 57 – 60 0.282 

 ▪ Onsite Ambient 53 – 56 0.580 

Internal Dose (Hypothetical): 

 ▪ Tritium 49 – 52 0.568 

 ▪ All Other Radionuclides 1 - 48 1.894 

Total 3.324 

* NC – Not considered 

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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 to SRS 

• 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. 

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. 

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Table 2. Case Review Checklist 

CASE #PIID* ASSIGNED DOSE: 3.324 rem POC: 5.46% 

Audit Response If No, Potential Significance No. Description of Technical Elements of Review YES N/A NO LOW1 MEDIUM2 HIGH3

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 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

C.1.3 - Occupational Medical Dose? T

C.1.4 - Onsite-Ambient Dose? T

C.2 Did the DR properly account for all: 

C.2.1 - Recorded Photon Dose? T

C.2.2 - Missed Photon Dose? T

C.2.3 - Occupational Medical Dose? 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

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

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 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. 
.

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CASE #PIID* ASSIGNED DOSE: 3.324 rem POC: 5.46% 

Audit Response If No, Potential Significance No. Description of Technical Elements of Review YES N/A NO LOW1 MEDIUM2 HIGH3

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

D.3.1 - Recorded Shallow/Electron Dose? T

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 2 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. 
.

2.0 AUDIT OF EXTERNAL DOSES 

Records received from DOE show that the energy employee was never monitored for external 

radiation. Therefore, there is no basis for assigning external dosimeter doses and missed doses 

for photons, electrons, and neutrons. External exposure doses were, therefore, limited to onsite 

ambient doses and occupational medical doses. 

2.1 OCCUPATIONAL MEDICAL DOSES 

Although DOE records provide no indication of occupational medical exposures, NIOSH 

assumed an annual chest x-ray and assumed organ doses of 81 mrem each for PIID*, and 60 

mrem each for PIID*. 

2.1.1 Reviewer’s Comments 

Default values for organ doses associated with occupational medical exposure for SRS are 

defined in Section 2.51 of ORAUT-TKBS-0003. For the corresponding years, Table 2.5.1-1 

identifies 81 mrem and 60 mrem for Group 1, which includes the skin. 

Occupational medical doses assigned by NIOSH were derived by means of applicable 

procedures and quantitatively conform to values provided. The assigned doses are also 

scientifically valid and claimant favorable. 

2.2 ONSITE AMBIENT DOSE 

Because the claimant was not monitored, the External Dose Implementation Guideline (OCASIG-001) requires that onsite ambient doses be included in dose reconstruction. According to 

NIOSH’s dose reconstruction (DR) Report, the onsite ambient doses assigned by NIOSH for 

entries #53 through #56 were based on the maximum average annual doses reported for SRS, as 

given in the Savannah River Technical Basis Document (ORAUT-TKBS-0003). 

Because three independent skin cancers were diagnosed (the first in PIID*, the second in PIID*, 

and the third in PIID*), two different time periods were defined for ambient onsite dose. The 

first period assumes a 50-hour workweek starting the day of employment until the date of the 

first cancer diagnosis; the second period (associated with the second and third skin cancers) 

ended in PIID*, when the claimant terminated employment. 

2.2.1 Reviewer’s Comments 

The assigned onsite doses defined as entries #53 through #56 in Appendix A could not be 

reproduced by means of guidance contained in Section 3.4 of ORAUT-TKBS-0003. Guidance 

herein identifies the following doses for a 50-hour workweek, along with the assumption of a 

lognormal distribution and a geometric standard deviation (GSD) of 1.3: 

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Year Onsite Dose

(rem) 

Uncertainty

PIID* 0.044 1.3 

PIID* 0.093 1.3 

PIID* 0.053 1.3 

PIID* 0.050 1.3 

In summary, NIOSH dose reconstruction failed to comply with the procedural guidance that 

identifies the above-cited doses, and the assumption of a lognormal distribution with a GSD of 

1.3. (Note: Entries #53 through #56 of Appendix A are entered as point values (i.e., constant) 

that represent a dose substantially higher than what would be expected from the median values 

and uncertainty given above.) 

A second, but minor, issue centers on the definition of onsite ambient dose and the means by 

which these values were determined. If the empirically measured onsite dose rates represent a 

deep dose (i.e., HP(10)), then the dose to the skin (or shallow dose) may have been significantly 

underestimated for the claimant. A review of Attachment C.2 of ORAUT-TKBS-0003 provides 

no insight regarding this matter. 

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3.0 AUDIT OF INTERNAL DOSES

In the absence of bioassay monitoring data, NIOSH estimated any potential incidental dose that 

may have been received but not documented. The assigned dose was based on a hypothetical 

intake, as defined in Section 4.5 of ORAUT-TKBS-0003 and Table 4.5.1-1 for the years of 

concern and for radionuclides other than tritium. For tritium, hypothetical doses for 

corresponding years are defined in Table 4.5.3-1 of ORAUT-TKBS-0003. 

3.1 REVIEWER’S COMMENTS 

All NIOSH entries for hypothetical doses for tritium and all other nuclides were compared 

against values in Tables 4.5.1-1 and 4.5.3-1. 

All entry doses matched values provided in the Technical Basis Document. Therefore, internal 

doses assigned by NIOSH comply with applicable procedures, and are conditionally 

scientifically valid and claimant favorable, as explained below. 

The potential exception to scientific validity/claimant favorability reflects two issues. The first 

involves the unconfirmed assumption that all tritium exposures are those involving tritiated 

water. If, in fact, intakes involved a significant fraction of organified tritium, with a 

biological/effective half-life that is about 2.3-fold higher, then the assigned doses herein may be 

too low. 

The second issue is considerably more complex and involves estimated yearly doses from all 

other internal radionuclides, as defined in Table 4.5.1-1 of ORAUT-TKBS-0003, which in turn 

were derived from data contained in ORAUT-OTIB-0001. In brief, ORAUT-TIB-0001 models 

intakes that are based on ICRP 30 biokinetic models instead of the current ICRP 68 models, as 

required in 42 CFR 82. We believe that the use of ICRP 30 calculated intakes may not be 

claimant favorable for several important radionuclides, and that ICRP 68 models should have 

been used to derive intakes. 

 

Although the two issues cited above may impact both recorded internal doses (defined by 

bioassay data and IMBA) and assigned hypothetical doses, an agreement has been reached by 

the Advisory Board, SC&A, and NIOSH to evaluate these issues under Task 1 (i.e., Review of 

Site Profiles). 

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4.0 CATI REPORT AND RADIOLOGICAL INCIDENTS 

Neither the CATI Report nor DOE records identify any radiological incidents involving the 

claimant. However, there are several discrepancies regarding statements contained in the CATI 

Report and DOE records/NIOSH assumptions. These include the following: 

• In the CATI report, claimant states dosimeter badges were worn. DOE records 

provide no supportive data for external monitoring. 

• The claimant also identified the following bioassays: urine, breath, and in vivo 

(assumedly whole-body count). DOE records, however, only acknowledge a 

single pre-hire or baseline WBC, which is not regarded as a monitoring bioassay. 

• The claimant stated that routine self-frisking for external contamination was 

performed, which suggests the claimant must have routinely worked in 

contaminated/radiological-controlled areas (RCAs). DOE records provide no 

information, such as radiation work permits (RWPs), that would support this 

claim. 

• The claimant mentioned once working in an area “with heavy water” and seeing 

people with instruments, but did not know what they were measuring. 

4.1 REVIEWER’S COMMENTS 

In the DR Report, NIOSH only acknowledges the claimant’s statements of having once worked 

in an area with heavy water. It is uncertain if the claimant was re-interviewed to resolve 

discrepancies identified in the first three statements above. Failure to resolve these issues may 

imply that DOE records are missing/incomplete, and that the NIOSH dose reconstruction may 

therefore also be incomplete. However, it is also acknowledged that the assigned hypothetical 

internal exposures are likely to be well in excess of potential exposures involving issues/ 

discrepancies raised by the claimant in the CATI report. 

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5.0 SUMMARY CONCLUSION

For most of the doses assigned by NIOSH to the claimant, we were able to identify the 

procedures and the modifying parameters that were assumed in deriving dose estimates. In 

general, the dose estimates were verified and are viewed as scientifically valid and claimant 

favorable. As noted in the text of this audit, there are some unresolved issues that may justify a 

limited review of this claim. 

A generic concern that is not confined to this DR Report, but characterizes all 20 cases that 

SC&A has reviewed to date, is the brevity of the DR Reports. In its current form, the NIOSH 

Dose Reconstruction Report provides only a brief summary explanation for assigned doses. In 

some instances, the explanation is confined to just a reference of a procedure/TBD. 

The failure to explain how individual categories of internal/external exposures were derived, and 

the absence of a well-defined paper trail, pose limitations on NIOSH’s internal QA review 

process. Similarly, these shortcomings force SC&A reviewers to engage in time-consuming 

speculations regarding the choice of procedures, methodology, and parameters selected by the 

dose reconstructor. 

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REFERENCES 

42 CFR 82. 2002. “Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000.” Final Rule, Federal Register/Vol. 67, 

No 85/Thursday, May 2, 2002, pg. 22314. 

International Commission on Radiological Protection (ICRP). 1980. “Limits for Intake of 

Radionuclides by Workers, Supplement to Part 2.” ICRP Publication 30. Annals of the ICRP,

Vol. 5(1/6). Pergamon Press: Oxford, England. 

International Commission on Radiological Protection (ICRP). 1995. “Dose Coefficients for 

Intakes of Radionuclides by Workers, 68.” ICRP Publication 68. Annals of the ICRP, Vol. 

24(2). Pergamon Press: Oxford, England.

ORAUT-OTIB-0001. 2003. “Technical Information Bulletin: Maximum Internal Dose 

Estimates for Savannah River Site (SRS) Claims,” Rev. 00. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. 

ORAUT-TKBS-0003. 2003. “Technical Basis Document for the Savannah River Site,” Rev. 01. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

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APPENDIX A: IREP INPUT 

Deletions made to the following table -- please see hard copy labeled "#11- Savannah RS" 

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