DRAFT 

OCAS-PER-014, SUBTASK 4 

REVIEW OF SELECT CASES REWORKED FOR THE 

EVALUATION OF CONSTRUCTION TRADE WORKER 

COWORKER DOSE 

Revision 1 

Contract No. 200-2009-28555

Rose Gogliotti 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182

April 2013 

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 predecisional 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. 
Effective Date:

April 30, 2013

Revision No.

1 (Draft)

Document No.

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Page No.

2 of 44

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

S. Cohen & Associates:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No. 

OCAS-PER-014 Subtask 4

Effective Date: 

Draft – April 30, 2013

OCAS-PER-014, SUBTASK 4

REVIEW OF SELECT CASES REWORKED 

FOR THE EVALUATION OF 

CONSTRUCTION TRADE WORKER

COWORKER DOSE

Page 2 of 44

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD

Supersedes:

Rev. 0

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer:

 Rose Gogliotti

 Kathleen Behling

 John Stiver

Record of Revisions

Revision 

Number Effective Date Description of Revision

0 (Draft) 04/12/2013 Initial issued.

1 (Draft) 04/30/2013 Subtask 4 finding numbers were changed to reflect a continuation of the review 

of OCAS-PER-014 Subtasks 1–3 (SCA-TR-PR2012-0014). After discussions 

with the Procedures Subcommittee, observation 3 was changed to a finding.
Effective Date:

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

TABLE OF CONTENTS 

1.0 Relevant Background Information ...................................................................................... 6

2.0 Evaluation of Selection Criteria Execution ....................................................................... 10

3.0 Review of OCAS-PER-014 Issues Related to Savannah River Site ................................. 12

3.1 Savannah River Site Case Selection ..................................................................... 12

3.2 Background Information for Case #[Redacted].................................................... 12

3.3 Comparison of NIOSH’s Original and Reworked Dose Reconstruction .............. 12

3.4 SC&A’s Review of OCAS-PER-014 Issues Related to Case #[Redacted].......... 13

4.0 Review of OCAS-PER-014 Issues Related to Oak Ridge National Laboratory X-10 ..... 15

4.1 Oak Ridge National Laboratory X-10 Case Selection .......................................... 15

4.2 Background Information for Case #[Redacted].................................................... 15

4.3 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ............ 15

4.4 SC&A’s Review of OCAS-PER-014 Issues Related to Case #[Redacted].......... 16

5.0 Review of OCAS-PER-014 Issues for Portsmouth Gaseous Diffusion Plant .................. 19

5.1 Portsmouth Case Selection ................................................................................... 19

5.2 Background Information for Case #[Redacted].................................................... 19

5.3 Comparison of NIOSH’s Original and Reworked Dose Reconstruction .............. 19

5.4 SC&A’s Review of OCAS-PER-014 Issues Related to Case #[Redacted].......... 20

6.0 Review of OCAS-PER-014 Issues for Los Alamos National Laboratory ........................ 23

6.1 Los Alamos National Laboratory Case Selection ................................................. 23

6.2 Background Information for Case #[Redacted].................................................... 23

6.3 Comparison of NIOSH’s Original and Reworked Dose Reconstruction .............. 23

6.4 SC&A’s Review of OCAS-PER-014 Issues Related to Case #[Redacted].......... 24

7.0 Review of OCAS-PER-014 Issues for the Case for Y-12 Plant ....................................... 27

7.1 Y-12 PLant Case Selection ................................................................................... 27

7.2 Background Information for Case #[Redacted].................................................... 27

7.3 Comparison of NIOSH’s Original and Reworked Dose Reconstruction .............. 27

7.4 SC&A’s Review of OCAS-PER-014 Issues Related to Case #[Redacted].......... 28

8.0 Review of OCAS-PER-014 Hanford Issues ..................................................................... 30

8.1 Hanford Case Selection ......................................................................................... 30

8.2 Background Information for Case #[Redacted].................................................... 30

8.3 Comparison of NIOSH’s Original and Reworked Dose Reconstruction Case 

#[Redacted] ........................................................................................................... 30

8.4 SC&A’s Review of OCAS-PER-014 Issues Related to Case #[Redacted].......... 31

9.0 Review of OCAS-PER-014 Issues for the Kansas City Plant .......................................... 35
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9.1 Kansas City Plant Case Selection ......................................................................... 35

9.2 Kansas City Plant Documentation Evaluation ...................................................... 35

10.0 Review of OCAS-PER-014 Issues for Pantex Plant ......................................................... 36

10.1 Pantex Plant Case Selection .................................................................................. 36

10.2 Pantex PLant Documentation Evaluation ............................................................. 36

11.0 Review of OCAS-PER-014 Issues for Pacific Northwest National Laboratory ............... 37

11.1 Pacific Northwest National Laboratory Case Selection ........................................ 37

11.2 Pacific Northwest National Laboratory Documentation Evaluation .................... 37

12.0 Review of OCAS-PER-014 Issues for Weldon Springs Plant .......................................... 38

12.1 Weldon Springs Plant Case Selection ................................................................... 38

12.2 Weldon Springs PLant Documentation Evaluation .............................................. 38

13.0 Summary Conclusions ...................................................................................................... 39

14.0 References ......................................................................................................................... 42
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

LIST OF TABLES 

Table 1-1. DOE Sites with External Coworker Model Issued Prior to August 31, 2006, 

that Must Be Evaluated under OCAS-PER-014 ...........................................................7

Table 2-1. Selection Criteria Applied to Potentially Affected Cases ...........................................10

Table 2-2. Selection Criteria per Site ...........................................................................................10

Table 3-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Prostate in the Original and Reworked DRs for Case #[Redacted] ......................13

Table 4-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Prostate in the Original and Reworked DRs for Case #[Redacted] ......................16

Table 5-1. Summary of Case #[Redacted] Cancers .....................................................................19

Table 5-2. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Skin in the Original and Reworked DRs for Case #[Redacted] ...........................20

Table 6-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Prostate in the Original and Reworked DRs for Case #[Redacted] ......................24

Table 6-2. Summary of Coworker Dose for Case #[Redacted] ...................................................25

Table 7-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Prostate in the Original and Reworked DRs for Case #[Redacted] ......................28

Table 8-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Breast in the Original and Reworked DRs for Case #[Redacted] .........................31

Table 8-2. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned for 

the Skin of the Nose in the Original and Reworked DRs for Case #[Redacted] ........31

Table 8-3. Summary of External CTW Coworker Dose for Case #[Redacted] ...........................32
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

1.0 RELEVANT BACKGROUND INFORMATION 

During a meeting of the Advisory Board on Radiation and Worker Health (Advisory Board) on 

October 22, 2009, SC&A was tasked by the Board to conduct a review of OCAS-PER-014, 

Construction Trade Workers. OCAS-PER-014 was initiated following the issuance of ORAUTOTIB-0052, Parameters to Consider When Processing Claims for Construction Trade Workers. 

This document provided guidance for assessing exposure to construction trade workers (CTWs) 

with inadequate internal or external monitoring for radiation exposure. SC&A previously 

evaluated the technical adequacy of ORAUT-OTIB-0052 (SCA-TR-PR2011-0004). Thereafter, 

OCAS-PER-014 was issued to determine which previously completed claims required reevaluation for the affect of ORAUT-OTIB-0052.

On March 16, 2012, SC&A submitted to the Subcommittee on Procedures Review our review of 

the National Institute for Occupational Safety and Health’s (NIOSH’s) program evaluation report 

(PER) OCAS-PER-014 (SCA-TR-PR2012-0014). In conducting a PER review, SC&A is 

committed to perform five subtasks, as specified below: 

Subtask 1: Assess NIOSH’s evaluation/characterization of the “issue” and its potential impacts 

on dose reconstruction (DR). Our assessment intends to ensure that the “issue” was fully 

understood and characterized in the PER. 

Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where the PER 

involves a technical issue that is supported by document(s) [e.g., white papers, technical 

information bulletins (TIBs), procedures] that have not yet been subjected to a formal 

SC&A review, Subtask 2 will include a review of the scientific basis and/or sources of 

information to ensure the credibility of the corrective action and its consistency with 

current/consensus science. Conversely, if such technical documentation has been 

formalized and previously subjected to a review by SC&A, Subtask 2 will simply provide 

a brief summary/conclusion of this review process. 

Subtask 3: Evaluate the PER’s stated approach for identifying the universe of potentially 

affected DRs, and assess the criteria by which a subset of potentially affected DRs was 

selected for re-evaluation. The second step may have important implications in instances 

where the universe of previously denied DRs is very large and, for reasons of practicality, 

NIOSH’s re-evaluation is confined to a subset of DRs that, based on their scientific 

judgment, have the potential to be significantly affected by the PER. In behalf of 

Subtask 3, SC&A will also evaluate the timeliness for the completion of the PER. 

Subtask 4: Conduct audits of DRs affected by the PER under review. The number of DRs 

selected for audit for a given PER will vary, based on important elements such as (1) the 

number of target organs/tissues that may be impacted by a PER, (2) the method/data that 

were employed in the original DR, and (3) the time period, work location, and job 

function(s) that characterize the DR of a claim. (It is assumed that the selection of the 

DRs and the total number of DR audits per PER will be made by the Advisory Board.) 
Effective Date:

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Subtask 5: Prepare a comprehensive written report that contains the results of the above-stated 

subtasks, along with our review conclusions.

This report fulfills the requirement defined in Subtask 4, “Conduct audits of DRs affected by the 

PER under review.” To determine the total population of claims that had the potential of being 

“affected” by ORAUT-OTIB-0052, NIOSH limited the scope to claims completed from sites that 

had external coworker models employed prior to the issue of ORAUT-OTIB-0052. These sites 

are listed in Table 1-1. 

Table 1-1. DOE Sites with External Coworker Model Issued Prior to August 31, 2006,

that Must Be Evaluated under OCAS-PER-014 

Site First Published Coworker

Date Document

Hanford 3/23/2005 ORAUT-OTIB-0030 

PNNL 3/23/2005 ORAUT-OTIB-0030 

Kansas City Plant 5/31/2005 ORAUT-TKBS-0031

LANL 5/10/2005 ORAUT-TKBS-0010-6 

Pantex Plant 7/27/2006 ORAUT-TKBS-0013-6 

Portsmouth Gaseous Diffusion Plant (PGDP) 7/29/2005 ORAUT-OTIB-0040 

SRS 5/31/2005 ORAUT-OTIB-0032

Weldon Spring Plant 6/24/2005 ORAUT-TKBS-0028-6

ORNL (X-10) 12/29/2004 ORAUT-OTIB-0021 

Y-12 Plant 9/9/2004 ORAUT-OTIB-0013

NIOSH then implemented a keyword search for 31 CTW job functions to define the universe of 

potentially affected claims. Using this search method, NIOSH identified a total of 977 

potentially affected cases. The following criteria were then used for each case: 

(1) External coworker dose was assigned. 

(2) Verify the claim involves a CTW. 

(3) Determine if the probability of causation (POC) is less than the trigger values, 36.8% or 

29.0% for Hanford. 

(4) Verify no other PERs affect the claim. If there is no increase in dose based on other 

PERs, the claim does not need a new DR. 

The application of ORAUT-OTIB-0052, under the most conservative assumption (i.e., when the 

organ dose/POC was exclusively based on external coworker dose), can be increased by a factor 

of 1.4 for non-Hanford cases and 2.0 for Hanford claims. Thus, for the revised POC of 45% as a 

screening criterion, any of the 4,865 claims with POCs less than 16.97% can be eliminated from 

further consideration, as shown in Equation 1 below: 

POC

ERR

ERR

 x

1 

100 Eq. 1 
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For a revised POC to reach 45%, the Excess Relative Risk (ERR) must equal 0.81818, or 4 times 

the original ERR value of 0.20454, which corresponds to the original POC of 36.8% for nonHanford cases and 29.0% for Hanford Cases. 

SC&A’s review of OCAS-PER-014, Subtasks 1 through 3, resulted in the identification of 6 

findings. All findings were closed prior to the start of this Subtask 4 review. However, it should 

be noted that although SC&A concluded that the selection and screening criteria of claims 

described in Section 3.0 of OCAS-PER-014 are scientifically sound, these criteria may not be 

inclusive of all potentially affected claims. SC&A identified the following instances that may be 

missed by the screening criteria (SCA-TR-PR2012-0014, pg. 16):

 Claims representing CTWs who were unmonitored or inadequately monitored 

and whose DR was adjudicated before the issue date of the site-specific external 

coworker (as well as the internal coworker) model. 

 For CTW claims completed/adjudicated before the issuance of a coworker 

model(s), DR for the unmonitored CTW would have been limited to environmental 

dose and possible medical dose with resultant POC values that would likely be 

well below the trigger PC values of 38.6% (and 29% for Hanford) and, therefore, 

be excluded from further consideration. 

 Even for those CTW claims that exceed the POC trigger value, the absence of an 

assigned coworker dose excludes the eligibility of these claims for a new DR. 

At the time of SC&A’s review, the screening criteria had not been applied to the initial 977 cases 

identified as potentially impacted by ORAUT-OTIB-0052. When applied, the screening criteria 

eliminated 925 cases from further consideration. Notably of the 925 cases, 221 cases were 

returned to NIOSH because of another PER, and 84 cases were returned to NIOSH for other 

reasons. These cases will be subject to re-evaluation, taking into account ORAUT-OTIB-0052; 

however, since they were already being re-evaluated, they do not need to be re-accounted for by 

OCAS-PER-014. Therefore, it was necessary for NIOSH to perform a dose re-evaluation for 52 

claims from among the initial 977 cases. 

To satisfy Subtask 4, SC&A indicated the need for dose re-evaluation for all 10 sites listed in 

Table 1-1. This was discussed further at the Procedures Review Subcommittee meeting held in 

Cincinnati, Ohio, on July 31, 2012. At the meeting, it was decided that SC&A would review 

1 case, revised to incorporate ORAUT-OTIB-0052, from each site listed in Table 1-1 (10 cases 

total). During the course of this review, SC&A was tasked with also evaluating the site technical 

basis document (TBD) and applicable workbooks to ensure they were properly updated to 

incorporate ORAUT-OTIB-0052’s CTW coworker recommendations. If any site did not have a 

case that was revised specifically because of ORAUT-OTIB-0052, cases could be pulled from 

the 305 cases that were revised to incorporate ORAUT-OTIB-0052 outside of OCAS-PER-014. 

If no case was modified for any site, SC&A was asked to review the TBD guidance and 

applicable workbooks for the site. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

It was determined by the Procedures Review Subcommittee that SC&A’s audit of selected DRs 

should be limited to (1) evaluating those methods and corrective actions introduced in the 

reworked DRs that relate strictly to issues addressed in OCAS-PER-014, and (2) evaluating 

applicable TBD documentation and workbooks to ensure they properly reflect the 

recommendations of ORAUT-OTIB-0052. Presented in Sections 3 through 12 is SC&A focused 

review to determine whether reworked coworker CTW doses were appropriately handled. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

2.0 EVALUATION OF SELECTION CRITERIA EXECUTION

At the time SC&A reviewed OCAS-PER-014 (SCA-TR-PR2012-0014), the selection criteria had 

not yet been applied to the 977 potentially impacted cases. Thereafter, this process was 

completed and SC&A received a list of the 977 claims potentially impacted with selection 

criteria applied. Using this list, SC&A generated the following two tables. 

Table 2-1. Selection Criteria Applied to Potentially Affected Cases 

Result of Selection 

Criteria Meaning of Designation Cases Affected

No Return Necessary NIOSH requested that the case NOT be returned for a new DR 620

Return Requested for 

Another PER NIOSH requested the case be returned based on a different PER 221

Returned to NIOSH NIOSH requested the case be returned for a new DR 52

Returned Prior to 

Evaluation

Case was returned to NIOSH prior to completing the PER 

evaluation 84

Total 977

Table 2-2. Selection Criteria per Site 

Site Total Number 

of Claimsa

Returned 

to NIOSH

Return Requested 

for Another PER

Returned Prior 

to Evaluation

No Return 

Necessary

Hanford 166 14 80 14 58

PNNL 18 0 8 3 7

Kansas City Plant 56 5 1 0 50

LANL 49 1 29 9 10

Pantex Plant 1 0 1 0 0

PGDP 112 4 2 4 102

SRS 162 5 61 29 67

Weldon Spring 19 1 1 0 17

ORNL (X-10) 159 10 41 28 80

Y-12 392 24 44 25 299

 a 258 cases had employment at 2 or more sites. These cases are included in the site totals and potentially appear 

in multiple site totals. 

While SC&A was selecting cases to review as part of Subtask 4, it was discovered that many of 

the 52 cases identified as “Return to NIOSH” were not revised. Further investigation revealed 

that many of these cases did not meet the selection criteria to be included in the subset, as 

discussed in Finding 7 below. (Please note that, since the review under Subtasks 1–3 identified 6 

findings, the first Subtask 4 finding will begin with number 7.) 

Finding 7: Application of Selection Criteria in Question 

SC&A found that many of the cases identified as requiring rework did not meet all requirements 

of the selection criteria that should have been used to define the cases that needed to be 

evaluated. For instance, 5 Kansas City Plant (KCP) cases were included in the set of 52 cases 

requiring rework. None of these five cases had a POC greater than the selection criteria of 

36.8%; therefore, none of the five DRs were revised. Inclusion of cases that did not meet the 

selection criteria was not limited to Kansas City cases or POC selection criteria cases. SC&A 

questions why cases that did not meet the selection criteria were included in the set of cases 
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requiring re-evaluation. Furthermore, if the criteria were not applied correctly to this subset, 

SC&A remains concerned that they not have been appropriately applied elsewhere.

Finding 8: Not All Cases “Returned to NIOSH” Were Re-evaluated

Cases that are returned to NIOSH as a result of a PER are revised using the most current 

technical guidance. Because it is assumed that all cases returned are completely updated, these 

cases are no longer eligible for rework under other PER evaluations that occurred at about the 

same time. During the course of this review, SC&A noted that some cases were returned to 

NIOSH as a result of OCAS-PER-014, yet were not revised. Although these cases were not 

revised due to OCAS-PER-014, they were nonetheless precluded from revision under other

recently issued relevant PERs presumably because they were returned to NIOSH for OCASPER-014. This is potentially indicative of a larger issue that encompasses all PER evaluations. 

To SC&A’s knowledge, there is no designation for cases that were returned to NIOSH yet not 

revised that would allow them to re-enter the pool of cases eligible for re-evaluation. Thus, there 

is a possibility that all cases that are returned and not revised have been missed inadvertently by 

subsequent PER evaluations. NIOSH needs to investigate this issue further.
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

3.0 REVIEW OF OCAS-PER-014 ISSUES RELATED TO SAVANNAH 

RIVER SITE

3.1 SAVANNAH RIVER SITE CASE SELECTION

OCAS-PER-014 identified 162 Savannah River Site (SRS) claims as potentially impacted by 

ORAUT-OTIB-0052. Of these claims, only five were sent back to NIOSH for revision. SC&A 

selected Case #[redacted] at random from these five cases. Prior to evaluation, SC&A 

confirmed this case was revised to include CTW dose.

3.2 BACKGROUND INFORMATION FOR CASE #[REDACTED]

Case #[redacted] represents an energy employee (EE) who worked at the SRS during 

[redacted], through [redacted]. The EE’s job function during employment was a construction 

worker from 1952 to 1955 and [redacted] worker from 1956 to 1983.

The EE was monitored for external photon exposures during 1959–1983 and neutron exposures 

during 1971–1983. The EE was unmonitored prior to this time. Internal exposure monitoring 

was also conducted by means of whole-body counting and occasional in-vitro urinalysis 

bioassays. The EE was diagnosed with prostate cancer (ICD Code 185.0) on January 9, 1988.

3.3 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTION

NIOSH performed the original DR of Case #[redacted] in May 2006. The claim was reworked 

in May 2009 to evaluate the potential for additional dose based on new guidance for processing 

claims of construction workers. Both the original and revised DRs stated that the EE’s radiation 

dose was overestimated using efficiency measures. In the original DR, NIOSH calculated a dose 

of 74.424 rem to the prostate. Based on this assigned dose estimate, the Department of Labor 

(DOL) determined the POC to be 43.49% and the claim was denied.

Using the most current technical guidance documents, NIOSH recalculated a prostate dose of 

78.254 rem in the revised DR. Table 3-1 provides a comparison of the original and revised 

external and internal organ dose estimates for the prostate. It should be noted that the values 

cited in Table 3-1 were extracted directly from NIOSH’s reworked DR. With the exception of 

potential coworker external dose, SC&A has not assessed the accuracy or correctness of these 

doses, since performing such an assessment is beyond the scope of this Subtask 4 report.
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Table 3-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Prostate in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

External Measured and Missed 55.454 56.052

External Coworker 12.862 13.998

Ambient External 2.719 2.721

Medical X-ray 0.346 0.380

Internal 3.043 5.103

Total 74.424 78.254

Using the EE’s Department of Energy (DOE) records and claimant-favorable assumptions, a 

prostate dose of 78.254 rem resulted in a POC of 44.85%, and on this basis, the revised claim 

was denied.

3.4 SC&A’S REVIEW OF OCAS-PER-014 ISSUES RELATED TO CASE 

#[REDACTED]

As directed by the Procedures Review Subcommittee, SC&A’s review of Case #[redacted]

strictly focused on external coworker models for CTWs. Case #[redacted] was included in the 

pool of claims that required the DR to be reworked because it met the OCAS-PER-014 criteria of 

(1) original DR was performed prior to August 31, 2006, (2) the EE worked as a CTW, 

(3) coworker dose was assigned, and (4) the POC was less than 50% but greater than 36.8%. 

This case was selected for review by SC&A because it represented application of CTW coworker

dose at SRS.

The EE was unmonitored for external exposure until 1959. In the original DR, NIOSH 

identified the time period 1952–1955 as the time when the EE was performing non-radiological 

work. During this period, NIOSH assigned a 50th percentile coworker photon dose. During the 

remainder of the period for which the EE was not monitored for external exposure (1956–1959), 

NIOSH identified the EE as being at high risk of exposure due to the presence of routine internal 

monitoring records and assigned the 95th percentile coworker photon dose. NIOSH assumed the 

EE was exposed to 100% 30–250 keV photons and applied a 1.119 correction factor (CF), as 

recommended by the SRS TBD. After 1959, the EE was routinely monitored for external 

exposure, so no coworker dose was assigned. This resulted in a total photon unmonitored 

coworker dose of 12.862 rem.

In the reworked DR, NIOSH identified two distinct periods during the time the EE was 

unmonitored for external exposure, which included (1) 1956–1959, when the EE was monitored 

internally, and (2) 1952–1955, when the EE was not monitored. Based on the ComputerAssisted Telephone Interview (CATI) report and DOE files, it is unclear the exact time period 

the EE worked as a construction worker and when the EE began working in operations. The 

CATI indicates the EE started work as a construction worker for a few years, then worked in 

operations for the remainder of the employment period. NIOSH assumed that the EE was a 

construction worker during the years that the EE was unmonitored both internally and externally. 

SC&A believes this is a reasonable and likely assumption, lacking other evidence to the contrary. 

NIOSH used Table 3 of ORAUT-OTIB-0032, External Coworker Dosimetry Data for the 

Savannah River Site, to assign the 50th percentile SRS CTW coworker dose. NIOSH assumed 
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the EE was exposed to 100% 30–250 keV photons and applied a CF of 1.119, as recommended 

by the SRS TBD. The 1952 coworker dose was prorated to account for a partial year of 

employment, and the dose for 1952–1955 was adjusted using the appropriate maximizing dose 

conversion factor (DCF) for the prostate. The remaining unmonitored dose for the years 1956–

1959 was unchanged from the original DR, because it was determined that the EE was not a 

CTW during this time. Using the updated CTW coworker modeling, a total coworker dose of 

13.998 rem was assigned to the prostate.

In evaluating this case, SC&A compared the guidance provided in ORAUT-OTIB-0052 for 

assessing unmonitored CTW coworker dose with the guidance from the SRS External Coworker 

TIB (ORAUT-OTIB-0032). For the convenience of the reader, ORAUT-OTIB-0052 guidance is 

cited below: 

Use the guidance in ORAUT-OTIB-0020 (ORAUT 2008) to assign a penetrating 

dose that is favorable to unmonitored CTWs. Apply an adjustment factor of 1.4 to 

the appropriate percentile of the measured coworker data for the site, plus the 

assigned coworker missed dose, to determine the total assigned penetrating dose 

that is favorable to unmonitored CTWs.

SC&A reviewed ORAUT-OTIB-0032, which was revised on November 7, 2006, due to the 

issuance of ORAUT-OTIB-0052. The revision added Table 3 for CTW coworker dose. It was

found that missed and measured doses are reported in a single value for each percentile of 

coworker dose and, therefore, an adjustment of 1.4 could not be applied directly.

SC&A requested that NIOSH provide separate values for missed and measure coworker doses

from Table 2 of ORAUT-OTIB-0032, so that SC&A could independently confirm that the 

guidance from ORAUT-OTIB-0052 was properly executed and recorded in Table 3. NIOSH 

was unable to provide these values to SC&A during the course of SC&A’s review of OCASPER-014. Because these values were unavailable, SC&A preformed a cursory check of the 

values assuming NIOSH properly executed the 1.4 adjustment to measured dose. SC&A found 

the following to be true for each year and percentile:

(CTW dose – Coworker dose)/ 0.4 = Measured dose

Coworker dose – Measured dose = Missed dose

Measured dose *1.4+ Missed dose = CTW dose

Finding 9: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at Savannah River Site

Although our above-cited cursory check of the application of the 1.4 adjustment factor is true for 

the values presented in Tables 2 and 3 of ORAUT-OTIB-0032, it cannot be used to prove 

conclusively that the adjustment was properly made, because there are many possible 

combinations of adjustment factors to missed and measured doses that could yield the final 

adjusted values listed in Table 3. Source data are needed to conclusively show the adjustment 

was correctly preformed.
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SC&A obtained the SRS Dose Calculation Workbook (Version 1.63) used by the dose 

reconstructor to calculate unmonitored coworker dose for Case #[redacted]. SC&A found that 

the “Coworker Dose” Tab was properly updated to include CTW coworker dose for the 99th, 

95th, and 50th percentiles. SC&A confirmed that these values also matched the values listed in 

Tables 2 and 3 of ORAUT-OTIB-0032. SC&A verified that NIOSH selected the proper years of 

50th percentile CTW coworker dose in the workbook. Using the values from Table 3 and 

assuming 100% 30–250 keV photons and a CF of 1.119, SC&A calculated the 50th percentile 

CTW coworker dose from the years 1952–1955. SC&A’s calculated values match those listed in 

IREP Table entries #75–#78.

SC&A believes that NIOSH’s DR assumptions were appropriate and claimant favorable and the 

data were entered into all workbooks correctly. SC&A also verified the IREP input, which 

indicated that the doses were entered with the appropriate distribution and uncertainty 

parameters. Although it appears that the rework was done in accordance with guidance provided 

in ORAUT-OTIB-0052, SC&A can only conclusively verify that the 1.4 adjustment factor was 

accurately applied to CTW doses if we have a breakdown of missed versus measured external 

dose.

4.0 REVIEW OF OCAS-PER-014 ISSUES RELATED TO OAK RIDGE 

NATIONAL LABORATORY X-10

4.1 OAK RIDGE NATIONAL LABORATORY X-10 CASE SELECTION

OCAS-PER-014 identified 159 Oak Ridge National Laboratory (ORNL) X-10 claims as 

potentially impacted by ORAUT-OTIB-0052. Of these claims, only 10 were sent back to 

NIOSH for revision. Each of these claims had two or more other employment sites also 

associated with it. From these claims, SC&A selected Case #[redacted] at random. Prior to the 

evaluation, SC&A confirmed this case was revised to include CTW dose.

4.2 BACKGROUND INFORMATION FOR CASE #[REDACTED]

Case #[redacted] represents an EE who worked at the ORNL X-10 site during [redacted],

through [redacted]. The EE also worked at the Oak Ridge Y-12 Plant and the Gaseous 

Diffusion Plant (K-25) from [redacted], through [redacted]. The CATI report and DOE files 

indicate the EE was an [redacted] throughout employment.

The EE was not monitored for internal or external exposure prior to 1980. The EE was 

monitored for the intake of radioactive materials by chest and whole-body counts beginning in 

1989. The EE was diagnosed with prostate cancer (ICD Code 185) on October 6, 1998.

4.3 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS

NIOSH performed the original DR of Case #[redacted] in June 2005. The claim was reworked 

in January 2010, based on current practices used in DR. This was predominately done to 

incorporate changes in coworker dose; however, updates were also made to incorporate Type 
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Super S plutonium and revisions to missed dose methodology. The original DR stated that the 

EE’s radiation dose was overestimated using claimant-favorable assumptions. The revised DR 

states that the DR was done using a best-estimate approach. In the original DR, NIOSH 

calculated a dose of 47.070 rem to the prostate. Based on this assigned dose estimate, the DOL 

determined the POC to be 44.52% and the claim was denied.

Using the most current technical guidance documents and considering CTW coworker dose 

modifications, NIOSH calculated a prostate dose of 14.246 rem in the revised DR. Table 4-1 

provides a comparison the original and revised external and internal organ dose estimates for the 

prostate. It should be noted that the values cited in Table 4-1 were extracted directly from 

NIOSH’s reworked DR. With the exception of external CTW coworker doses, SC&A has not 

assessed the accuracy or correctness of these doses, since performing such an assessment is 

beyond the scope of this Subtask 4 report.

Table 4-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Prostate in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

External Measured and Missed 0.628 0.311

External Coworker 30.422 13.438

Medical X-ray 0.232 0.308

Internal 15.788 0.189

Total 47.070 14.246

Using the EE’s DOE records and best-estimate assumptions, a prostate dose of 14.246 rem 

resulted in a POC of 24.14%, and on this basis, the revised claim was denied.

4.4 SC&A’S REVIEW OF OCAS-PER-014 ISSUES RELATED TO CASE 

#[REDACTED]

As directed by the Procedures Review Subcommittee, SC&A’s review of Case #[redacted] is 

strictly focused on external coworker models for CTW. Case #[redacted] was included in the 

pool of claims that required the DR to be reworked because it met the OCAS-PER-014 criteria of

(1) original DR was performed prior to August 31, 2006, (2) the EE worked as a CTW, 

(3) coworker dose was assigned, and (4) the POC was less than 50% but greater than 36.8%. 

This case was selected by SC&A because it represented an individual who likely received 

unmonitored CTW dose at X-10.

The EE was unmonitored until 1980. In the original DR, NIOSH identified that the EE was 

likely exposed to external radiation prior to 1980. During this period, NIOSH assigned a 

95th percentile coworker photon dose. Since the EE worked at X-10, Y-12, and K-25 sites, 

NIOSH evaluated 95th percentile coworker dose from the three sites and assigned the highest to 

the EE as the yearly coworker dose.

In the reworked DR, NIOSH identified that the EE qualified as a CTW with some risk of 

exposure. Based on the CATI report and DOE files, it is unclear at what times the EE worked at 

each of the three sites. NIOSH, using best-estimate rather than maximizing assumptions, 

compared the 50th percentile CTW coworker dose from ORAUT-OTIB-0021, Table 3; ORAUT-
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OTIB-0064, Table 7-2; and ORAUT-OTIB-0026, Table 3. NIOSH then did a yearly comparison 

and assigned the highest CTW coworker dose to each year. From 1962 to 1974, K-25 

50th percentile CTW coworker doses yielded the highest dose and were assigned to the prostate. 

From 1975 to 1979, X-10 coworker doses yielded the highest dose and were assigned to the 

prostate. This resulted in a total CTW coworker dose of 13.348 rem.

SC&A could not find guidance on how coworker dose should be assigned when the EE worked 

at multiple sites simultaneously. However, SC&A believes that the method used by NIOSH to 

assign coworker dose from the three sites simultaneously is claimant favorable and consistent 

with other dose-estimating protocols used in DR.

In evaluating this case, SC&A compared the guidance provided in ORAUT-OTIB-0052 for 

assessing unmonitored CTW coworker dose with the guidance from the Oak Ridge External 

Coworker TIBs (ORAUT-OTIB-0021, ORAUT-OTIB-0026, and ORAUT-OTIB-0064). Each 

site is discussed independently below for clarity.

X-10: SC&A reviewed the X-10 External Coworker TIB (ORAUT-OTIB-0021), which was 

revised on November 7, 2006, due to the issuance of ORAUT-OTIB-0052. The revision added 

Table 3 for CTW coworker dose at X-10. It was found that missed and measured doses are 

reported as a single value for each percentile of coworker dose. Therefore, an adjustment of 1.4

could not be applied directly.

SC&A requested that NIOSH provide separate values for missed and measure coworker doses 

from Table 2, so that we could independently confirm that the guidance from ORAUT-OTIB0052 was properly implemented and recorded in Table 3 of ORAUT-OTIB-0021. NIOSH was 

unable to provide these values to SC&A during the course of our review of OCAS-PER-014.

K-25: SC&A reviewed the K-25 External Coworker TIB (ORAUT-OTIB-0026), which was 

revised on November 15, 2006. The revision added Table 3 for CTW coworker dose at K-25. It 

was found that missed and measured doses are reported as a single value for each percentile of 

coworker doses. Therefore, an adjustment of 1.4 could not be applied directly.

SC&A requested that NIOSH provide separate values for missed and measure coworker doses

from Table 2, so that SC&A could independently confirm that the guidance from ORAUTOTIB-0052 was properly implemented and recorded in Table 3. NIOSH was unable to provide 

these values to SC&A during the course of our review of OCAS-PER-14.

Y-12: SC&A reviewed the Y-12 External Coworker TIB (ORAUT-OTIB-0064) and found that 

missed and measured doses are reported in a single value for each percentile of coworker dose. 

Because of this, an adjustment of 1.4 cannot be applied directly. Unlike the K-25 and X-10 

TIBs, ORAUT-OTIB-0064 was issued as a replacement to ORAUT-OTIB-0013 after the 

publication of ORAUT-OTIB-0052. In ORAUT-OTIB-0064, Tables 7-1b and 7-1c contain 

coworker dose, and Table 7-2 contains CTW coworker dose. It was found that missed and 

measured doses are reported as a single value for each percentile of coworker dose. Therefore, 

an adjustment of 1.4 cannot be applied directly.
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SC&A requested that NIOSH provide separate values for missed and measure coworker dose 

from Tables 7-1b and 7-1c, so that SC&A could independently confirm that the guidance from 

ORAUT-OTIB-0052 was properly implemented and recorded in Table 7-2 of ORAUT-OTIB0064. NIOSH was unable to provide these values to SC&A during the course of SC&A’s review 

of OCAS-PER-014.

Because separated missed and measured coworker dose data were unavailable, SC&A performed 

a cursory check of the values assuming NIOSH properly executed the 1.4 adjustment to 

measured dose for each of the three sites. SC&A found the following to be true for each site, 

year, and percentile:

(CTW dose – Coworker dose)/0.4 = Measured dose

Coworker dose – Measured dose = Missed dose

Measured dose *1.4 + Missed dose = CTW dose

Finding 10: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at X-10, Y-12, and K-25

Although our above-cited cursory check of the application of the 1.4 adjustment factor is true for 

the values presented in the coworker and CTW coworker models for ORNL sites X-10, Y-12,

and K-25, it cannot be used to prove conclusively that the adjustment was properly applied for 

any of the three sites, because there are many possible combinations of adjustment factors to 

missed and measured doses that could yield the final adjusted values for each site’s CTW 

coworker doses. Source data are needed to conclusively show that the adjustment was correctly 

applied.

SC&A reviewed the EE’s files and found that only the Y-12 calculation workbook was included 

in the EE’s files. The workbook was version 1.16 and does not have a tab for coworker dose. 

Instead, NIOSH used a manually created workbook, “External Calcs_006579,” to compare CTW 

coworker dose for each year. SC&A compared the values listed in this table with the 

corresponding values from ORAUT-OTIB-0021, Table 3; ORAUT-OTIB-0064, Table 7-2; and 

ORAUT-OTIB-0026, Table 3 and found them to match. The highest yearly 50th percentile CTW 

doses from the three sites were selected to represent the EE’s CTW coworker dose. Using the 

50th percentile values from this selection and assuming 100% 30–250 keV photons and an organ 

DCF of 1.244, SC&A calculated the 50th percentile CTW coworker dose from the years 1962–

1979. SC&A’s calculated values match those listed in IREP Table entries #1–#18.

SC&A was able to verify that NIOSH’s assumptions were appropriate and claimant favorable 

and that data were entered into all workbooks correctly. SC&A also verified the IREP input, 

which indicated that the doses were entered with the appropriate dose distribution and 

uncertainty parameters. Although it appears that the rework was done in accordance with 

guidance provided in ORAUT-OTIB-0052, SC&A can only conclusive verify that the 1.4 

adjustment factor was accurately applied to CTW doses if we have a breakdown of missed 

versus measured external dose.
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5.0 REVIEW OF OCAS-PER-014 ISSUES FOR PORTSMOUTH

GASEOUS DIFFUSION PLANT

5.1 PORTSMOUTH CASE SELECTION

OCAS-PER-014 identified 112 Portsmouth Gaseous Diffusion Plant (PGDP) claims as 

potentially impacted by ORAUT-OTIB-0052. Of these claims, only four were sent back to 

NIOSH for revision, and only two of these claims were actually revised to include CTW 

coworker dose. From these two claims, SC&A selected Case #[redacted] at random. Prior to 

evaluation, SC&A confirmed that this case was revised to include coworker dose.

5.2 BACKGROUND INFORMATION FOR CASE #[REDACTED]

Case #[redacted] represents an EE who worked at PGDP during [redacted], to [redacted]. The 

EE worked as a [redacted] during this time. No information concerning the EE’s work location 

is available in the CATI report or DOE records. The EE has no available internal or external 

monitoring results. The EE was diagnosed with [redacted] cases of squamous cell carcinoma

(SSC) (skin cancer) on the scalp (ICD Code 162) between 1989 and 1996. These cancers are 

summarized in Table 5-1.

Table 5-1. Summary of Case #[Redacted] Cancers

This table has been [redacted] in full.

5.3 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTION

NIOSH performed the original DR of Case #[redacted] in April 2006. The claim was reworked 

in October 2008 to re-evaluate this case based on new guidance on assigning CTW coworker 

dose. Both the original and revised DRs stated that the EE’s radiation dose was overestimated 

using claimant-favorable assumptions. In the original DR, NIOSH calculated skin doses of 

16.854 rem (1989 diagnosis), 17.259 rem (1991 diagnosis), 17.460 rem (1992 diagnosis), and 

18.253 rem (1996 diagnosis). Based on this assigned dose estimate, the DOL determined the 

POC to be 36.79% and the claim was denied.

Using the most current technical guidance documents and considering new CTW coworker dose 

guidance, NIOSH recalculated a dose ranging from 1.068 to 1.102 rem to the skin in the revised 

DR. Table 5-2 provides a comparison the original and revised external and internal organ dose 

estimates for the skin. It should be noted that the values cited in Table 5-2 were extracted 

directly from NIOSH’s reworked DR. With the exception of external CTW coworker dose, 
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SC&A has not assessed the accuracy or correctness of these doses, since performing such an 

assessment is beyond the scope of this Subtask 4 report

Table 5-2. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Skin in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

Unmonitored External 2.495 0.909

Medical X-ray 5.265 0.008

Internal 9.094–10.493 0.151–0.185

Total 16.856–18.253 1.068–1.102

Using the EE’s DOE records and claimant-favorable assumptions, a skin dose ranging from 

1.068 rem to 1.102 rem resulted in a POC of 4.07% and, on this basis, the revised claim was 

denied.

5.4 SC&A’S REVIEW OF OCAS-PER-014 ISSUES RELATED TO CASE 

#[REDACTED]

As directed by the Procedures Review Subcommittee, SC&A’s review of Case #[redacted]

strictly focused on external coworker models. Case #[redacted] was included in the pool of 

claims that required the DR to be reworked because it met the OCAS-PER-014 criteria of (1) the 

original DR was performed prior to August 31, 2006, (2) the EE worked as a CTW, (3) coworker 

dose was assigned, and (4) the POC was less than 50% but greater than 36.8%. This case was 

selected by SC&A because it represented an individual who likely received unmonitored CTW 

dose at PGDP.

The EE was unmonitored during the entire year of employment. In the original DR, NIOSH 

identified that the EE was potentially exposed to external photons, electrons, and neutrons. 

NIOSH assumed the EE was likely exposed to 100% 30–250 keV photons and assumed a DCF 

equal to 1.00. No photon adjustment factor was applied. NIOSH assigned each cancer the 95th

percentile coworker photon dose from 1954. This resulted in a total photon dose of 1.736 rem to 

each cancer site. Since the EE’s cancer originated in the skin, unmonitored external >15 keV 

electron dose was also assigned. NIOSH assigned the PGDP 95th percentile non-penetrating 

dose to each skin cancer. This resulted in a coworker dose of 0.055 rem from electrons to each 

skin cancer location. No workers at PGDP were monitored for external neutron exposure prior 

to 1996. In order to estimate neutron dose to the EE, NIOSH multiplied the annual photon 

coworker dose by 0.20. This resulted in a total modeled neutron dose based on coworker photon 

doses of 0.704 rem.

In the reworked DR, NIOSH identified that the EE qualified as a CTW with some risk of 

exposure. Based on the CATI report and DOE files, it is unclear where on the site the EE 

worked and the type of work the EE performed as a [redacted]. NIOSH compared the 

50th percentile CTW coworker dose from ORAUT-OTIB-0040, Table 8-3. Notably, this is a 

smaller percentile than was used in the original maximizing DR. NIOSH assumed the EE was 

likely exposed to 100% 30–250 keV photons and applied an adjustment factor of 1.165, as 

recommended by the site external dose TBD (ORAUT-TKBS-0015-6). This resulted in a CTW 
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coworker dose of 0.909 rem to each skin cancer. No external coworker electron or neutron dose 

was assigned in the reworked DR. The DR states that, given the early era of employment, it is 

unlikely the EE had significant exposure potential.

As part of this Subtask 4 report, SC&A reviewed the PGDP guidance, ORAUT-OTIB-0040, 

which was revised on November 7, 2006, to include an additional table (Table 8-3) for 

calculation of coworker dose to CTWs. It was found that missed and measured doses are 

reported as a single value for each percentile of coworker dose in Table 8-2. Therefore, an 

adjustment of 1.4 cannot be applied directly to the values in Table 8-2.

SC&A requested that NIOSH provide separate values for missed and measure coworker doses

from Table 8-2, so that SC&A could independently confirm that the guidance from ORAUTOTIB-0052 was properly implemented and recorded in Table 8-3. NIOSH was unable to 

provide these values to SC&A during the course of SC&A’s review of OCAS-PER-014.

Because separated missed and measured coworker dose data were unavailable, SC&A preformed 

a cursory check of the values, assuming NIOSH properly executed the 1.4 adjustment to the 95th

and 50th percentiles. SC&A found the following to be true for each year and percentile:

(CTW dose – Coworker dose)/0.4 = Measured dose

Coworker dose – Measured dose = Missed dose

Measured dose *1.4 + Missed dose = CTW dose

Finding 11: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at Portsmouth

Although our above-cited cursory check of the application of 1.4 adjustment factor is true for the 

values presented in the coworker and CTW coworker models in Tables 8-2 and 8-3, it cannot be

used to prove conclusively that the adjustment was properly implemented, because there are 

many possible combinations of adjustment factors to missed and measured doses that could yield 

the final adjusted values for the CTW coworker dose. Source data are needed to conclusively 

show that the adjustment was correctly applied. Notably, if the adjustment was applied

correctly, more than 70% of the measured coworker doses for the 50th percentile are 0.000 rem,

because the CTW and non-CTW coworker doses are equal.

To calculate CTW coworker photon dose, NIOSH used the Portsmouth Calculation Workbook 

(version 1.21). As part of this Subtask 4 review, SC&A verified that the workbook was properly 

updated to incorporate the guidance from ORAUT-OTIB-0052. Coworker doses from the 95th

and 50th percentile CTW coworker photon dose were both updated to include the guidance from 

ORAUT-OTIB-0052. SC&A confirmed that all CTW coworker percentile values match the 

values listed in Table 8-3 of ORAUT-OTIB-0040.

Observation #1

SC&A questions the applicability of applying a photon dosimetry CF of 1.165 to the entire CTW 

coworker dose. ORAUT-TKBS-0015-6, Table 6-26, recommends multiplying the reported 
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dosimeter dose by a factor of 1.165 before 1981. The CTW dose is actually a combination of 

missed and measured dose. This potentially overestimates dose to the EE.

SC&A found that, although NIOSH did not assign electron coworker dose during 1954, the nonpenetrating 50th percentile coworker dose at that time was zero. This would not add additional 

dose to any of the cancer sites. SC&A concurs that this was correctly omitted from the revised 

DR. SC&A does have a concern that NIOSH omitted unmonitored neutron dose from the 

revised DR. Since no workers at PGDP were monitored for neutron exposure in 1954, NIOSH 

apparently concluded that the EE had no potential for neutron exposure during that year. SC&A 

does not believe that a lack of documented monitoring results alone is sufficient evidence for 

concluding that there was no potential neutron exposure to the EE. However, we understand that 

further investigation is outside the scope of this review.

SC&A was able to verify that most of NIOSH’s assumptions were appropriate and claimant 

favorable and that data were entered into all workbooks correctly. SC&A also verified the IREP 

input, which indicated that the doses were entered with the appropriate dose distribution and 

uncertainty parameters. Although it appears that the rework was done in accordance with 

guidance provided in ORAUT-OTIB-0052, SC&A can only conclusively verify that the 1.4 

adjustment factor was accurately applied to CTW doses if we have a breakdown of missed 

versus measured external dose.
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6.0 REVIEW OF OCAS-PER-014 ISSUES FOR LOS ALAMOS 

NATIONAL LABORATORY

6.1 LOS ALAMOS NATIONAL LABORATORY CASE SELECTION

OCAS-PER-014 identified 49 Los Alamos National Laboratory (LANL) claims as potentially 

impacted by ORAUT-OTIB-0052. Of these claims, only one was sent back to NIOSH for 

revision, NIOSH Case #[redacted]. To date, this case has not been updated to incorporate CTW 

coworker dose. SC&A notes that this claim does not meet all of the criteria cited in 

OCAS-PER-014 to identify claims impacted by ORAUT-OTIB-0052, because no coworker dose 

was assigned. SC&A suspects that the case was not revised for this reason. This case does,

however, represent an instance in which coworker dose was not assigned in the initial DR but 

should be assigned in a revised DR, as noted in SCA-TR-PR2012-0014, Finding #6.

Finding 12: SC&A Questions whether NIOSH Is Planning on Revising the One Returned 

Case for CTW Coworker Dose at Los Alamos National Laboratory

The LANL external coworker model was not issued until after the initial DR’s completion; 

therefore, no coworker dose could be assigned in the initial DR. However, this EE meets all the 

criteria for CTW coworker dose to be assigned.

Because there were no LANL claims revised specifically due to ORAUT-OTIB-0052 and 

OCAS-PER-014, SC&A selected a case that had already been returned to NIOSH at the time of 

OCAS-PER-014 evaluations. Case #[redacted] was selected by SC&A for the review of an

LANL case re-evaluated to incorporate the guidance of ORAUT-OTIB-0052.

6.2 BACKGROUND INFORMATION FOR CASE #[REDACTED]

Case #[redacted] represents an EE who worked at the LANL during the DOL-confirmed time 

from [redacted], through [redacted]. The dosimetry files also indicate the EE was monitored 

for external radiation in [redacted] and [redacted]. The EE’s job functions during the 

employment period were [redacted], [redacted], [redacted]/ [redacted], and [redacted].

The EE was monitored for external photon and electron exposures during employment. Internal 

exposure monitoring was also conducted by means of in-vitro urinalysis bioassays. The EE was 

diagnosed with prostate cancer (ICD Code 185) on November 8, 2001. NIOSH assumed one 

continuous employment period extending from [redacted], through this date.

6.3 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTION

NIOSH performed the original DR of Case #[redacted]in June 2005. The claim was reworked 

in June 2008 to re-evaluate this case based on potential exposure to plutonium for Type Super S 

material. The revised DR also takes into account CTW coworker dose and the updated LANL 

TBDs. Both the original and revised DRs stated that the EE’s radiation dose was overestimated 

using claimant-favorable assumptions. In the original DR, NIOSH calculated a dose of 
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62.79 rem to the prostate. Based on this assigned dose estimate, the DOL determined the POC to 

be 37.18% and the claim was denied.

Using the most current technical guidance documents and considering new CTW coworker dose 

guidance, NIOSH recalculated a dose of 61.386 rem to the prostate in the revised DR. Table 6-1 

provides a comparison of the original and revised external and internal organ dose estimates for 

the prostate. It should be noted that the values cited in Table 6-1 were extracted directly from 

NIOSH’s reworked DR. With the exception of external CTW coworker dose, SC&A has not 

assessed the accuracy or correctness of these doses, since performing such an assessment is 

beyond the scope of this Subtask 4 report.

Table 6-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Prostate in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

External Measured and Missed 36.931 50.308

External Unmonitored 1.650 2.847

Ambient External 7.918 0.000

Medical X-ray 0.038 0.048

Internal 16.192 8.183

Total 62.729 61.386

Using the EE’s DOE records and claimant-favorable assumptions, a prostate dose of 61.386 rem

resulted in a POC of 43.24%, and, on this basis, the revised claim was denied.

6.4 SC&A’S REVIEW OF OCAS-PER-014 ISSUES RELATED TO CASE 

#[REDACTED]

As directed by the Procedures Review Subcommittee, SC&A’s review of Case 

#[redacted]strictly focused on external coworker models for CTWs. Case #[redacted] was 

included in the pool of claims that could potentially be impacted by ORAUT-OTIB-0052; 

however, the case was returned to NIOSH prior to the OCAS-PER-014 evaluation. This case 

met all of the OCAS-PER-014 criteria of (1) original DR was performed prior to August 31, 

2006, (2) the EE worked as a CTW, (3) coworker dose was assigned, and (4) the POC was less 

than 50% but greater than 36.8%, except that the case was already being re-evaluated at the time 

OCAS-PER-014 was issued. This case was selected by SC&A for review because it represented 

a CTW who was not monitored for external exposure at LANL.

The EE was not monitored for external photon exposure during [redacted] and neutron exposure 

during [redacted], [redacted], [redacted], and [redacted]. Because no LANL coworker model 

was published at the time of the original DR, ORAUT-OTIB-0020, Rev. 00, and a compilation 

of completed coworker models were used to assign coworker dose. For the purposes of DR, 

NIOSH assigned the minimum doses at the 50th percentile based on a compilation of coworker 

studies. The DR does not indicate which models were used in this assessment, but does state that 

they come from a wide range of DOE sites and facilities. NIOSH assumed that the EE was 

exposed to 100% 30–250 keV photons and 100% 100 keV–2 MeV neutrons. NIOSH used the 

bladder as a surrogate for the prostate, which is not modeled by ICRP. The total dose for the 

unmonitored years was 0.137 rem from photons and 1.513 rem from neutrons.
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In the reworked DR, NIOSH reviewed the dosimetry files and found that the EE was monitored 

less frequently than the original DR had assumed. Years with no or partial monitoring are listed 

in Table 6-2, along with the number of months that the EE was not monitored and for which 

coworker dose was assigned.

Table 6-2. Summary of Coworker Dose for Case #[Redacted]

Year # of Months Assigned

1963 1

1964 7

1971 1

1974 2

1999 6

2000 12

2001 3

NIOSH adjusted the values from ORAUT-TKBS-0010-6, Table A-2, to account for the number 

of unmonitored months during each year. NIOSH assumed that the EE was exposed to 100% 

30–250 keV photons and 100% 100keV–2MeV neutrons. No other adjustments were made to 

the Table A-2 values. This resulted in a coworker photon dose of 0.385 rem and a neutron dose 

of 2.462 rem.

SC&A does not concur with the coworker DR performed for NIOSH for Case #[redacted]. 

SC&A found the DR did not include any modification to coworker dose for CTWs.

Finding 13: NIOSH Did Not Apply CTW Correction Factor to Coworker Dose

Based on the EE’s DOE files and the CATI report, it is unclear for which time periods the EE 

held each job title. SC&A found employment records located in the DOL initial case file 

indicating that the EE was hired as a [redacted] in [redacted] and as a [redacted] in [redacted]. 

Thus, the DOL files appear to indicate that the EE worked as a [redacted] from [redacted] to 

[redacted]. [Redacted] is a profession considered a construction trade by OCAS-PER-014. 

Therefore, using the guidance of ORAUT-OTIB-0052, a CTW adjustment factor of 1.4 should 

be applied to the measured component of coworker dose for CTW that was not monitored for 

external dose. Not doing so underestimates potential coworker dose during the EE’s years as a 

[redacted] by a factor of 1.4, because LANL coworker dose does not have a missed dose 

component.

Finding 14: NIOSH Did Not Apply Dose Conversion Factor or Dosimeter Correction 

Factors to Coworker Dose

NIOSH did not correct any of the assigned coworker doses for the prostate DCF and did not 

account for dosimeter bias. Section 6 of ORAUT-OTIB-0020, Rev. 01, clearly states that both 

corrections should be applied to coworker dose to reasonably estimate dose to unmonitored 

workers. This would result in a yearly coworker photon dose ranging from 1.617 to 1.140 times 

larger than the dose assigned, and a yearly coworker neutron dose ranging from 2.865 to 2.063 

times larger than the dose assigned.
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Observation #2

OCAS-PER-014 makes the assumption that cases that are returned prior to PER evaluation will 

be updated to include the most recent technical guidance, including that of ORAUT-OTIB-0052. 

Case #[redacted] shows that the most recent guidance is not always incorporated into a DR. 

This raises the question: Were the remaining 83 cases that were returned to NIOSH prior to 

evaluation updated to include this guidance? Further investigation would be needed to determine 

if that was an isolated instance or a larger problem.

SC&A found that this rework was not done in accordance with guidance provided in ORAUTOTIB-0052 and has two findings with NIOSH’s methodology for assessing the EE’s 

unmonitored CTW coworker dose.
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7.0 REVIEW OF OCAS-PER-014 ISSUES FOR THE CASE FOR Y-12 

PLANT

7.1 Y-12 PLANT CASE SELECTION

OCAS-PER-014 identified 159 ORNL Y-12 claims as potentially impacted by ORAUT-OTIB0052. Of these claims, only 10 were sent back to NIOSH for revision. Each of these claims had 

one or more other employment sites also associated with it. From these claims, SC&A selected 

Case #[redacted] at random. Prior to evaluation, SC&A confirmed that this case was revised to 

include coworker dose.

7.2 BACKGROUND INFORMATION FOR CASE #[REDACTED]

Case #[redacted] represents an EE who worked at the Y-12 Plant during [redacted], through 

[redacted], and from [redacted], through [redacted]. This was combined into a single 

employment period by NIOSH. The EE’s job functions during the employment period were

[redacted]/ [redacted] and [redacted].

The EE was monitored for external photon and electron exposures during only some periods of 

employment. The EE was not monitored for internal exposure. The EE was diagnosed with 

adenocarcinoma of the prostate (ICD Code 185) on August 1, 1985.

7.3 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTION

NIOSH performed the original DR of Case #[redacted] in March 2006. The claim was 

reworked in January 2010 to evaluate the potential for additional dose based on new guidance for 

processing claims of CTWs. Both the original and revised DRs stated that the EE’s radiation 

dose was overestimated using efficiency measures. In the original DR, NIOSH calculated a dose 

of 19.005 rem to the prostate. Based on this assigned dose estimate, the DOL determined the 

POC to be 21.59%, and the claim was denied.

Using the most current technical guidance documents and considering updated CTW coworker 

modeling, NIOSH recalculated a prostate dose of 20.876 rem in the revised DR. Table 7-1 

provides a comparison of the original and revised external and internal organ dose estimates for 

the prostate. It should be noted that the values cited in Table 7-1 were extracted directly from 

NIOSH’s reworked DR. With the exception of external coworker dose, SC&A has not assessed 

the accuracy or correctness of these doses, as such an assessment is beyond the scope of this 

report.
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Table 7-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Prostate in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

External Measured/Missed 0.411 0.212

External Coworker 8.237 19.802

Medical X-ray 0.683 0.500

Internal 9.674 0.362

Total 19.005 20.876

Using the EE’s DOE records and claimant-favorable assumptions, NIOSH calculated a prostate 

dose of 20.876 rem, resulting in a POC of 28.76%. On this basis, the revised claim was denied.

7.4 SC&A’S REVIEW OF OCAS-PER-014 ISSUES RELATED TO CASE 

#[REDACTED]

As directed by the Procedures Review Subcommittee, SC&A’s review of Case #[redacted]

strictly focused on external coworker models for CTWs. Case #[redacted] was included in the 

pool of claims that required the DR to be reworked because it met the OCAS-PER-014 criteria of 

(1) original DR was performed prior to August 31, 2006, (2) the EE worked as a CTW, 

(3) coworker dose was assigned, and (4) the POC was less than 50% but greater than 36.8%. 

This case was selected by SC&A because it represented a CTW claimant who was not monitored 

for radionuclide intakes at the Y-12 Plant.

This case is also impacted by the Y-12 Plant Special Exposure Cohort (SEC). Since the prostate 

is not a covered cancer, the EE does not qualify for automatic compensation under the SEC; 

under the SEC, no dose other than medical dose can be reconstructed for the years prior to 1948.

The EE was monitored for external dose only during the year [redacted]. In the original DR,

NIOSH assigned coworker dose for the years [redacted]–[redacted] and [redacted]. A bestestimate organ dose was assigned by multiplying the 95th percentile of the lognormally 

distributed annual photon doses by the applicable triangular distribution of the organ DCF using 

Monte Carlo techniques in accordance with OCAS-IG-001. This resulted in the coworker dose 

of 8.237 rem.

In the reworked DR, NIOSH identified that the job title qualified this EE as a CTW. NIOSH 

assigned 50th percentile gamma CTW dose from ORAUT-OTIB-0064, Table 7-2, to the years 

[redacted]–[redacted] and [redacted]. NIOSH assumed that 100% of the gamma dose was 30–

250 keV photons. No beta coworker dose was included because it would not contribute 

additional dose to the prostate. Since the prostate is not modeled by ICRP, NIOSH assumed the 

bladder to be a reasonable surrogate organ and applied the applicable organ DCF to the modeled 

CTW coworker dose. This resulted in a total CTW coworker dose of 19.802 rem.

NIOSH did not include a workbook in the EE’s case file demonstrating how CTW coworker 

dose was calculated. SC&A was able to replicate the IREP-assigned dose by multiplying the 

ORAUT-OTIB-0064, Table 7-2, CTW coworker doses by the organ DCF for the prostate 

(bladder used as surrogate organ). SC&A requested that NIOSH provide the most recent 

workbook version; however, NIOSH was unable to provide a workbook during the course of this 
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review. SC&A obtained a copy of a recent workbook titled, “Y-12 Calculation Workbook 1.18,” 

Version 1.18. This workbook did not have a tab for the calculation of coworker or CTW 

coworker dose.

Finding 15: Dosimeter Uncertainty Not Applied to CTW Coworker Dose

The Y-12 TBD (ORAUT-TKBS-0014-6) states that the standard error for recorded film badges 

prior to 1980 is 30%; as such, recorded photon results prior to 1980 at Y-12 are multiplied by a 

factor of 1.3 to account for this uncertainty. Coworker dose at Y-12 should be assumed to have

the same standard error because it is based on measured dosimeter results. ORAUT-OTIB-0020, 

Rev. 02, Section 3.0, states that technical considerations, such as dosimeter bias, should be 

incorporated by the dose reconstructor into the coworker dose. This would increase the assigned 

CTW coworker dose by 30%.

SC&A was able to verify that NIOSH’s assumptions were appropriate and claimant favorable. 

SC&A also verified the IREP input, which indicated that the doses were entered with the 

appropriate distribution and uncertainty parameters. SC&A found that the rework was done in 

accordance with guidance provided in ORAUT-OTIB-0052. SC&A did note, however, that 

NIOSH failed to apply the dosimeter uncertainty factor to the CTW dose, as recommended by 

ORAUT-OTIB-0020, Rev 3, and ORAUT-TKBS-0014-6.
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8.0 REVIEW OF OCAS-PER-014 HANFORD ISSUES

8.1 HANFORD CASE SELECTION

OCAS-PER-014 identified 166 Hanford claims as potentially impacted by ORAUT-OTIB-0052. 

Of these claims, only 14 were sent back to NIOSH for revision. Of these 14 returned claims, 

only 3 were revised to include CTW coworker dose. SC&A selected a case at random from 

these three claims.

Case #[redacted] was selected by SC&A for the review of a Hanford case re-evaluated to 

incorporate the guidance of ORAUT-OTIB-0052. This case meets the OCAS-PER-014 criteria 

of (1) original DR was performed prior to August 31, 2006, (2) the EE worked as a CTW, 

(3) coworker dose was assigned, and (4) the POC was less than 50% but greater than 29.0% for a 

Hanford case.

8.2 BACKGROUND INFORMATION FOR CASE #[REDACTED]

Case #[redacted] represents an EE who worked at Hanford during [redacted], through 

[redacted], and also during [redacted], through [redacted]. The EE’s job functions during the 

employment period were [redacted] and [redacted]. According to the CATI report and DOL 

records, the EE worked primarily in the 300 Area.

The EE was not monitored for internal or external exposure while employed at Hanford. The EE 

was diagnosed with carcinoma of the left breast (ICD Code 175) on June 23, 1989. The EE was 

also diagnosed with basal cell carcinoma (skin cancer) on the tip of the nose (ICD Code 173.3) 

on September 12, 1996.

8.3 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTION CASE #[REDACTED]

NIOSH performed the original DR of Case #[redacted] in June 2005. The claim was reworked 

in April 2010 to re-evaluate this case based on new guidance for CTW coworker modeling. The 

original DR was completed using maximizing assumptions, and the revised DR was completed 

with best-estimate assumptions. In the original DR, NIOSH calculated a dose of 9.564 rem to 

the breast and a dose of 8.605 rem to the skin of the nose. Based on this assigned dose estimate, 

the DOL determined the POC to be 42.36%, and the claim was denied.

Using the most current technical guidance documents and considering the new CTW coworker 

modeling recommendations, NIOSH recalculated a breast dose of 4.567 rem and a skin dose of 

4.488 rem in the revised DR. Table 8-1 and Table 8-2 provide a comparison the original and 

revised external and internal organ dose estimates for the breast and skin. It should be noted that 

the values cited in Table 8-1 and Table 8-2 were extracted directly from NIOSH’s reworked DR. 

With the exception of internal and external CTW coworker modeling, SC&A has not assessed 

the accuracy or correctness of these doses, since performing such an assessment is beyond the 

scope of this Subtask 4 report.
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Table 8-1. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Breast in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

External Coworker 2.718 2.586

Ambient External 0.210 0.90

Medical X-ray 0.012 0.150

Internal 6.625 1.742

Total 9.564 4.567

Table 8-2. Comparison of NIOSH-Derived External/Internal Dose Estimates Assigned 

for the Skin of the Nose in the Original and Reworked DRs for Case #[Redacted]

Dose Categories Previous Dose (rem) Revised Dose (rem)

External Coworker 2.718 2.279

Ambient External 0.210 0.144

Medical X-ray 0.008 0.098

Internal 5.670 1.968

Total 8.605 4.488

Using the EE’s DOE records and claimant-favorable assumptions, a breast dose of 4.567 rem and 

a skin dose of 4.488 rem resulted in a POC of 44.74%, and, on this basis, the revised claim was 

denied.

8.4 SC&A’S REVIEW OF OCAS-PER-014 ISSUES RELATED TO CASE 

#[REDACTED]

As directed by the Procedures Review Subcommittee, SC&A’s review of Case #[redacted]

strictly focused on external and internal coworker models for CTWs. Case #[redacted] was 

included in the pool of claims that required the DR to be reworked because it met the OCASPER-014 criteria of (1) original DR was performed prior to August 31, 2006, (2) the EE worked 

as a CTW, (3) coworker dose was assigned, and (4) the POC was less than 50% but greater than 

29.0% for a Hanford case. This case was selected by SC&A because it represented an individual 

who was not monitored for radionuclide intake or external exposure at Hanford.

8.4.1 External Coworker Dose

Even though the EE was not monitored for external exposure, the original DR made the 

claimant-favorable assumption that the EE was likely exposed to external radiation during 

employment. Using the Hanford External Coworker model, NIOSH assigned 95th percentile 

deep/gamma dose to reconstruct the external dose experienced by the EE in [redacted]. No 

coworker dose was assigned to the EE during the 1-month employment during January 1943,

because major radiological work did not begin in the 300 Area until [redacted]. NIOSH did not 

consider potential coworker neutron exposures, because it was thought that neutrons would 

contribute an insignificant amount to dose in comparison to other claimant-favorable 

assumptions. NIOSH assigned an external coworker total dose of 2.718 rem to the breast and 

2.718 rem to the skin.
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After the initial DR, this case was impacted by the Hanford SEC. Since the EE did not work at 

least 250 days at the site, the EE does not qualify for automatic compensation under the SEC. 

Therefore, only a partial DR could be completed for the EE in the reworked DR. In the 

reworked DR, NIOSH identified that the EE’s two job descriptions were both construction trade 

jobs. NIOSH assigned the 50th percentile CTW coworker photon and electron doses from 

ORAUT-TKBS-0006-6, Table B-3, adjusted to account for organ and energy distributions in the 

300 Area. External coworker gamma and electron doses were prorated to account for the 

9 months of employment in [redacted]. NIOSH also prorated neutron dose to 7 months, because 

300 Area neutron work did not begin until [redacted]. Using these adjustments, NIOSH 

assigned external CTW coworker dose as summarized in Table 8-3.

Table 8-3. Summary of External CTW Coworker Dose for Case #[Redacted]

Cancer 

Location

Diagnosis 

Date

Coworker Gamma 

dose (rem)

Coworker Electron 

dose (rem)

Coworker Neutron 

dose (rem)

Breast 6/23/1989 0.920 0.054 1.612

Skin 9/12/1996 0.970 0.153 1.156

OCAS-PER-014 noted that external Hanford coworker dose guidance was documented in 

ORAUT-OTIB-0030. This document was canceled and the external coworker dose guidance 

was incorporated into Attachment B of ORAUT-TKBS-0006-6, Rev. 4, issued on January 7, 

2010. As part of this Subtask 4 report, SC&A reviewed the Hanford guidance, ORAUT-TKBS0006-6, Rev. 4, and found that missed and measured doses are reported as a single value for each 

percentile of coworker dose in Table B-2. ORAUT-TKBS-0006-6, Rev. 4, added an additional 

table (Table B-3) that includes coworker doses for CTWs.

SC&A requested that NIOSH provide separate values for missed and measure coworker dose 

from Table B-2, so that SC&A could independently confirm that the guidance from ORAUTOTIB-0052 was properly implemented and recorded in Table B-3. NIOSH was unable to 

provide these values to SC&A during the course of SC&A’s review of OCAS-PER-014.

Because these separate missed and measured coworker dose data were unavailable, SC&A 

preformed a cursory check of the values assuming NIOSH properly implemented the 1.4 

adjustment to the 99th, 95th, and 50th percentiles. SC&A found the following to be true for each 

year and percentile:

(CTW dose – Coworker dose)/0.4 = Measured dose

Coworker dose – Measured dose = Missed dose

Measured dose *1.4 + Missed dose = CTW dose

Finding 16: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at Hanford 

Although our above-cited cursory check of the application of the 1.4 adjustment factor is 

consistent with the values presented in the coworker and CTW coworker models in Tables B-2 

and B-3, it cannot be used to prove conclusively that the adjustment was properly made at the

site, because there are many possible combinations of adjustment factors to missed and measured 
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dose that could yield the final adjusted values for CTW coworker dose. Source data are needed 

to conclusively show the adjustment was correctly applied.

SC&A reviewed the EE files and found that NIOSH used the workbook titled “HAN B.E. Calc 

Wkbk (Vose) 3.11” to calculate CTW coworker dose to the EE. As part of this review, SC&A 

verified that the workbook was properly updated to incorporate the guidance from ORAUTOTIB-0052. Coworker doses from the 99th, 95th

, and 50th percentile CTW coworker photon dose 

were updated to include the guidance from ORAUT-OTIB-0052. The external coworker data 

and CTW coworker data contained in the workbook match the values listed in ORAUT-TKBS0006-6, Rev. 4, Tables B-2 and B-3. NIOSH correctly manually manipulated the [redacted]

data to prorate dose for a partial year of employment.

Although it appears that the rework of the external components of CTW coworker dose was done 

in accordance with guidance provided in ORAUT-OTIB-0052, SC&A can only conclusive verify 

that the 1.4 adjustment factor was accurately applied to CTW doses if we have a breakdown of 

missed versus measured external dose.

8.4.2 Internal Coworker Dose

The original DR also made the claimant-favorable assumption that the EE was likely exposed to 

internal radiation during the second employment period. No internal dose was assigned to the 

1 month the EE worked during [redacted], because radiological work in the 300 Area of 

Hanford had not yet started. During the [redacted] employment period, NIOSH assumed that 

the EE was likely exposed to each radionuclide likely to result in significant internal dose. 

NIOSH, however, does not identify these radionuclides. NIOSH used ORAUT-OTIB-0002, 

Rev. 01 PC-2, guidance to maximize internal dose estimates to the skin and breast. This resulted 

in a total skin dose of 5.670 rem and a breast dose of 6.625 rem.

In the reworked DR, NIOSH found that the EE was at risk for internal exposure to radioactive 

materials from the EE’s employment during 1944, even though there is no record that the EE 

was monitored at this time. During this year, only the 313, 314, and 303 fuel fabrication 

facilities and the 321 and 3741 research and development facilities were operational in the 

300 Area. Based on this assumption and the duties of a [redacted] and [redacted], NIOSH 

found the largest exposure risk to the EE was U-234. No plutonium or fission product dose 

could be assigned, due to the Hanford SEC. The site profile indicates unmonitored workers in 

the 300 Area fuel fabrication area should be assigned “in accordance with the Process/Job Title 

of Machining/Operator, as presented in Battelle-TBD-6000.” Based on this, NIOSH assigned a 

uranium Type M intake rate of 19,654 pCi/d. This resulted in a dose of 1.742 rem to the breast 

and 1.968 rem to the skin of the nose.

SC&A reviewed the Hanford internal dose documents and found that use of insoluble uranium is 

recommended in the ORAUT-TKBS-0006-5, Rev. 5, for unmonitored workers that worked in 

the 300 Area. SC&A confirmed that the intake rate assigned (19,654 pCi/d) matches the 

Machining/Operator recommendations of TBD-6000. This intake rate was not modified in any 

way. NIOSH modeled U-234 intake in IMBA assuming both Type M and Type S uranium. 

SC&A confirmed that Type M results in the highest dose to both organs modeled.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

SC&A notes that the document that contained internal Hanford Coworker guidance, ORAUTOTIB-0039, was canceled. Hanford internal coworker dose guidance was incorporated into 

Attachment C of ORAUT-TKBS-0006-5, Rev. 3, which was issued on January 7, 2010. The 

current version of this document, Rev. 5, was issued on November 5, 2012. SC&A found no 

mention of ORAUT-OTIB-0052 or its guidance in this document. For the benefit of the reader, 

ORAUT-OTIB-0052, Section 8.4, states:

For Hanford dose reconstructions covered by this TIB, the intake rates in the 

Hanford coworker document should be multiplied by a factor of 2.

No other sites require an internal CTW coworker modification.

Finding 17: No CTW Correction Was Applied to the Unmonitored CTW Internal Dose

NIOSH did not take into account the recommendations of ORAUT-OTIB-0052 when the DR 

was revised. Unmonitored internal dose was assigned without any modification of intake rates to 

account for the EE being a CTW. SC&A notes that the intake assigned is large compared to 

coworker doses from later years that were not based on Battelle-TBD-6000 values. NIOSH 

neither followed the guidance of ORAUT-OTIB-0052 nor discussed its omission in the DR 

report.

Finding 18: There Do Not Appear to Be Any Hanford-Specific Technical Guidance 

Documents Requiring the Implementation of ORAUT-OTIB-0052 for Internal Coworker 

Dose for CTWs

ORAUT-OTIB-0052 directs dose reconstructors to multiply unmonitored coworker intake rates 

by 2 for CTWs who worked at Hanford. SC&A found that this guidance is not reflected in the 

Hanford Internal Dose TBD. Dose reconstructors can make the appropriate adjustments to 

Hanford internal coworker dose without a revision to the document; however, in order to 

properly assign coworker internal dose at Hanford, the dose reconstructor must be familiar with 

ORAUT-OTIB-0052 and its implications on internal CTW coworker dose at Hanford.

Along with reviewing the ORAUT-OTIB-0052 guidance, SC&A analyzed the IMBA input and 

applicable workbooks for Case #[redacted] and found that the data were entered correctly. 

SC&A also verified the IREP input, which indicated that the doses were entered with the 

appropriate distribution and uncertainty parameters. However, SC&A found no evidence that 

NIOSH made any CTW adjustment to the internal dose, as required under ORAUT-OTIB-0052. 

In addition, we question the absence of any Hanford-specific guidance for internal dose to 

CTWs, as cited in ORAUT-OTIB-0052.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

9.0 REVIEW OF OCAS-PER-014 ISSUES FOR THE KANSAS CITY 

PLANT

9.1 KANSAS CITY PLANT CASE SELECTION

OCAS-PER-014 identified 56 KCP claims as potentially impacted by ORAUT-OTIB-0052. Of 

these claims, only five were sent back to NIOSH for revision. Of these five claims, none were 

revised to include CTW coworker dose, because they did not meet the minimum POC criterion. 

SC&A questions why these cases were returned to NIOSH if they did not meet the review 

threshold.

SC&A was unable to find a KCP case that was revised to incorporate CTW coworker 

recommendations. There were no cases “returned prior to evaluation,” and only one case was 

sent back to NIOSH for another PER. However, it was not revised in accordance with ORAUTOTIB-0052, because the EE did not qualify as a CTW.

9.2 KANSAS CITY PLANT DOCUMENTATION EVALUATION

Since no KCP cases were revised to incorporate CTW coworker dose, SC&A was unable to 

evaluate a case impacted by ORAUT-OTIB-0052 guidance. In order to assess the likelihood that 

future cases are evaluated correctly, SC&A reviewed the KCP site profile, ORAUT-TKBS-0031,

and applicable workbooks.

SC&A found that ORAUT-TKBS-0031 has not been revised since the issue of OCAS-PER-014. 

Recorded coworker doses are listed in Table 15 of ORAUT-TKBS-0031, Rev. 00 PC-1. Unlike 

most other sites, coworker doses in Table 15 of ORAUT-TKBS-0031 do not include missed 

dose. However, there is no guidance to dose reconstructors to adjust this dose by a factor of 1.4 

for CTWs.

SC&A requested that NIOSH provide the most recent KCP workbook for review. NIOSH was 

unable to provide this workbook during the course of SC&A’s review of OCAS-PER-014. 

SC&A independently located a recent version of the KCP workbook titled, “KCP Calculation 

workbook,” Version 1.13. This version of the workbook did not have a tab for coworker dose or 

any modifications for coworker dose at KCP.

Finding 19: There Do Not Appear to Be Any KCP Guidance Documents or Workbook for 

Implementing CTW Dose Adjustment Cited in ORAUT-OTIB-0052

ORAUT-TKBS-0031 has not been modified, there has not been a separate KCP-specific TIB 

issued to provide guidance included in ORAUT-OTIB-0052 for CTW dose adjustments, In 

addition, SC&A was unable to confirm whether an updated version of the KCP workbook has 

been issued that contains coworker data.
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

10.0 REVIEW OF OCAS-PER-014 ISSUES FOR PANTEX PLANT

10.1 PANTEX PLANT CASE SELECTION

OCAS-PER-014 identified one Pantex Plant claim as potentially impacted by ORAUT-OTIB0052, Claim #[redacted]. This claim was returned to NIOSH following the release of OCASPER-012, rather than OCAS-PER-014. The claim, however, was not revised. It is unclear to 

SC&A why the claim was not revised, because the OCAS-PER-012 letter indicates that the case 

must be revised “to determine the extent to which th[e] claim is affected.”

10.2 PANTEX PLANT DOCUMENTATION EVALUATION

Because no Pantex cases were revised to incorporate CTW coworker dose, SC&A was unable to 

evaluate a case impacted by ORAUT-OTIB-0052 guidance. In order to assess the likelihood that 

future cases are evaluated correctly, SC&A looked at the 2006 Pantex Plant Occupational 

External Dose TBD (ORAUT-TKBS-0013-6, Rev. 00). SC&A found that this document was 

revised on June 22, 2007 (Rev. 01). This revision occurred after the issue of ORAUT-OTIB0052 but before the issuance of OCAS-PER-014. The revised Occupational External Dose TBD 

makes no reference to the guidance in ORAUT-OTIB-0052.

SC&A found that, although ORAUT-TKBS-0013-6 has been revised since the issue of ORAUTOTIB-0052, it was not revised to include guidance from ORAUT-OTIB-0052. Recorded 

coworker doses are listed in Table 6-17 of ORAUT-TKBS-0013-6, Rev. 01. Unlike for most 

other sites, coworker doses in Table 6-17 of ORAUT-TKBS-0013-6 do not include missed dose. 

However, there is no guidance to dose reconstructors to adjust this dose by a factor of 1.4 for 

CTWs.

SC&A requested that NIOSH provide the most recent Pantex workbook for review. NIOSH was 

unable to provide this workbook during the course of SC&A’s review of OCAS-PER-014. 

SC&A attempted to independently locate a workbook as part of this Task 4 Review for Pantex 

but was unsuccessful.

Finding 20: There Do Not Appear to Be Any Pantex-Specific Guidance Documents or 

Workbook for Implementing CTW Dose Adjustment Cited in ORAUT-OTIB-0052

As indicated above, ORAUT-TKBS-0013-6 has been revised since the issuance of ORAUTOTIB-0052; however, no change was made to implement CTW dose adjustment guidance. In 

addition, SC&A verified that there been not been a separate Pantex-specific TIB issued to 

provide guidance included in ORAUT-OTIB-0052. Lastly, SC&A was unable to confirm 

whether an updated version of the Pantex workbook has been issued that contains coworker data.
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

11.0 REVIEW OF OCAS-PER-014 ISSUES FOR PACIFIC NORTHWEST 

NATIONAL LABORATORY

11.1 PACIFIC NORTHWEST NATIONAL LABORATORY CASE SELECTION

OCAS-PER-014 identified 18 Pacific Northwest National Laboratory (PNNL) claims as 

potentially impacted by ORAUT-OTIB-0052. None of these cases were sent back to NIOSH for 

revision. Of the 18 potentially impacted claims, 8 were returned to NIOSH for another PER, and 

3 claims were returned prior to evaluation. None of these claims were revised to include CTW 

coworker dose from PNNL.

11.2 PACIFIC NORTHWEST NATIONAL LABORATORY DOCUMENTATION 

EVALUATION

Since no PNNL cases were revised to incorporate CTW coworker dose, SC&A was unable to 

evaluate a case impacted by ORAUT-OTIB-0052 guidance. Coworker dose at PNNL is assigned 

using the same guidance as Hanford. Since SC&A previously reviewed this guidance in 

Section 8, no new evaluation was warranted for PNNL CTW coworker dose.
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

12.0 REVIEW OF OCAS-PER-014 ISSUES FOR WELDON SPRINGS 

PLANT

12.1 WELDON SPRINGS PLANT CASE SELECTION

OCAS-PER-014 identified 19 Weldon Spring Plant claims as potentially impacted by ORAUTOTIB-0052. Only one of these claims was sent back to NIOSH for revision, Case #[redacted]. 

Notably, this case does not have an OCAS-PER-014 evaluation letter included in the file. The 

EE in this case does not qualify as a CTW; therefore, no CTW coworker dose was assigned. 

SC&A located one Weldon Spring case (#[redacted]) that was labeled as “return to NIOSH”

NIOSH as a result of OCAS-PER-015; however, this case was also not re-evaluated. This is 

another instance of a case that was returned and not revised, as discussed in Finding 2.

12.2 WELDON SPRINGS PLANT DOCUMENTATION EVALUATION

Because no Weldon Spring Plant cases were revised to incorporate CTW coworker dose, SC&A 

was unable to evaluate a case impacted by ORAUT-OTIB-0052 guidance. In order to assess the 

likelihood that future cases are evaluated correctly, SC&A reviewed the Weldon Spring Plant 

Occupational External Dose TBD (ORAUT-TKBS-0028-6, Rev. 00) and applicable workbooks. 

SC&A found that this document was issued on June 24, 2005.

SC&A found that the latest revision of ORAUT-TKBS-0028-6 (Rev. 01) was on February 6, 

2013. Recorded coworker doses are listed in Table 6-8 of this revised TBD. Unlike for most 

other sites, coworker dose in Table 6-8 of ORAUT-TKBS-0028-6 does not include missed dose. 

There is no guidance to dose reconstructors to adjust this dose by a factor of 1.4 for CTWs. In 

order for CTW coworker dose to be properly assigned, a dose reconstructor must be familiar 

with ORAUT-OTIB-0052.

SC&A requested that NIOSH provide the most recent Weldon Spring workbook for review. 

NIOSH was unable to provide this workbook during the course of SC&A’s review of OCASPER-014. Based on SC&A’s evaluation of the DR Tools folder on the O-drive, we have 

concluded that there has been no workbook developed specific to Weldon Spring Plant.

Finding 21: There Do Not Appear to Be Any Weldon Spring Plant Guidance Documents 

or Workbook for Implementing CTW Dose Adjustment Cited in ORAUT-OTIB-0052

ORAUT-TKBS-0028-6 has not been modified, and there has not been a separate Weldon Springspecific TIB issued to provide guidance included in ORAUT-OTIB-0052 for CTW dose 

adjustments. In addition, SC&A does not believe a Weldon Spring-specific workbook has been

developed.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

13.0 SUMMARY CONCLUSIONS

Under SC&A’s A Protocol to Review NIOSH’s Program Evaluation Reports (PERs) (SCA-TRPR2009-0002), Subtask 4 requires the audit of DR cases reworked as a result of the PER under 

review. Based on guidance in OCAS-PER-014, cases required rework if they met the following 

criteria: (1) original DR was performed prior to August 31, 2006, (2) the EE worked as a CTW, 

(3) coworker dose was assigned, and (4) the POC was less than 50% but greater than 36.8%

(29% for Hanford). Therefore, in order to satisfy Subtask 4, SC&A recommended in SCA-TRPR2012-0014 the selection of 1 case from each of 10 impacted sites addressed in OCAS-PER014.

For each of the six reviewed cases, SC&A provided an overview of the case and a brief 

comparison of external and internal doses assigned in the original and revised DRs. Based on 

directives from the Procedures Review Subcommittee, SC&A’s audit of these cases focused 

strictly on those elements of the DR that were affected by the issuance of ORAUT-OTIB-0052 

and OCAS-PER-014. This included the review of a case from each site affected by ORAUTOTIB-0052 and evaluation of each site’s TBD and applicable workbooks to ensure they were 

properly undated to incorporate ORAUT-OTIB-0052’s CTW coworker recommendations. Cases 

were selected at random from SRS, X-10, Y-12, PGDP, and Hanford from the 52 cases returned 

to NIOSH for re-evaluation. Each case’s CTW coworker DR was reviewed. Additionally,

SC&A evaluated each site’s technical guidance on CTW and workbooks to ensure they were 

consistent with the recommendations of ORAUT-OTIB-0052.

Although every site had at least one case impacted by the PER, SC&A found that several sites 

(i.e., LANL, PNNL, KCP, Weldon Spring Plant, and Pantex Plant) did not have any cases 

revised as a result of being sent back to NIOSH. Because it was acknowledged that not all of the 

10 sites would likely have a case that was returned specifically for OCAS-PER-014, during the 

July 31, 2012, meeting, the Procedures Review Subcommittee agreed to allow SC&A to select 

cases that were returned to NIOSH for other reasons (e.g., another PER) and for which the 

rework included ORAUT-OTIB-0052 guidance.

If no case could be found that was impacted by ORAUT-OTIB-0052 for a particular site, SC&A 

was tasked with verifying that the applicable guidance and workbooks were properly updated. 

SC&A was unable to identify any cases that required rework due to ORAUT-OTIB-0052 (or 

were revised to include guidance) for the KCP, Pantex Plant, PNNL, and Weldon Spring Plant. 

As a result, SC&A reviewed the CTW coworker guidance in each site’s applicable 

documentation (excluding PNNL, as discussed in Section 11.2) to verify that this guidance was 

properly updated to reflect the guidance in ORAUT-OTIB-0052.

During the course of this review, SC&A noted that of the six cases evaluated, the assigned 

coworker dose for three cases decreased from the original DR to the revised DR. This was due 

to the fact that, in the original DR, NIOSH elected to use the 95th percentile coworker model, and 

in the revised case, NIOSH switched to the 50th percentile model. In fact, NIOSH revised the 

selected coworker models from 95th percentile in the original DR to 50th percentile in the 

reworked DR in five of the six cases that were evaluated by SC&A. The 6th case reviewed by 

SC&A used the 50th percentile distribution in both the original and revised DRs. Although 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ORAUT-OTIB-0020 is outside of the scope of this Subtask 4 review, its interpretation has a 

direct impact on the implementation of ORAUT-OTIB-0052. This resulted in Finding 22, which 

is discussed below.

Finding 22: Ambiguity in ORAUT-OTIB-0020 Impacts the Application of ORAUT-OTIB0052

SC&A found that there is ambiguity associated with guidance provided in ORAUT-OTIB-0020, 

Rev. 03, for assigning 95th versus 50th percentile doses for the various CTW job categories. The 

following is cited in ORAUT-OTIB-0020, Rev. 03, page 6:

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. Also note 

that certain construction trades (e.g., pipefitters) might have received higher exposures 

than construction trade workers in general; therefore, they might fall into the category of 

workers who were expected to have been monitored.

Clarity on which trades should be assigned 95th percentile would be beneficial to the DR process, 

especially since this selection will have a significant impact on the assigned dose. Additionally, 

some CTW coworker models (i.e., Hanford and SRS) also have 99th percentile doses. Using the 

currently available guidance, it appears the 99th percentile values would never be selected for use 

in a DR.

SC&A’s Subtask 1–3 review resulted in 6 findings, which are contained in SCA-TR-PR2012-

0014. SC&A’s Subtask 4 review resulted in the identification of 16 findings. These findings are 

summarized below.

 Finding 7: Application of Selection Criteria in Question

 Finding 8: Not All Cases “Returned to NIOSH” Were Re-evaluated

 Finding 9: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at Savannah River Site

 Finding 10: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at X-10, Y-12, and K-25

 Finding 11: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at Portsmouth

 Finding 12: SC&A Questions whether NIOSH Is Planning on Revising the One 

Returned Case for CTW Coworker Dose at Los Alamos National Laboratory
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 Finding 13: NIOSH Did Not Apply CTW Correction Factor to Coworker Dose

 Finding 14: NIOSH Did Not Apply Dose Conversion Factor or Dosimeter Correction 

Factors to Coworker Dose

 Finding 15: Dosimeter Uncertainty Not Applied to CTW Coworker Dose

 Finding 16: SC&A Could Not Conclusively Confirm the CTW Adjustment Factor Was 

Properly Applied to Measured Dose at Hanford 

 Finding 17: No CTW Correction was Applied to the Unmonitored CTW Internal Dose

 Finding 18: There Do Not Appear to Be Any Hanford-Specific Technical Guidance 

Documents Requiring the Implementation of ORAUT-OTIB-0052 for Internal Coworker 

Dose for CTWs

 Finding 19: There Do Not Appear to Be Any KCP Guidance Documents or Workbook 

for Implementing CTW Dose Adjustment Cited in ORAUT-OTIB-0052

 Finding 20: There Do Not Appear to Be Any Pantex-Specific Guidance Documents or 

Workbook for Implementing CTW Dose Adjustment Cited in ORAUT-OTIB-0052

 Finding 21: There Do Not Appear to Be Any Weldon Spring Plant Guidance Documents 

or Workbook for Implementing CTW Dose Adjustment Cited in ORAUT-OTIB-0052

 Finding 22: Ambiguity in ORAUT-OTIB-0020 Impacts the Application of ORAUTOTIB-0052

In Sections 2 through 12 above, SC&A also made two observations. In the first observation, 

SC&A points out that applying a photon dosimetry CF of 1.165 to the entire CTW coworker 

dose, which is a combination of missed and measured dose, results in an overestimate of dose at 

PGDP.

The second observation questions whether all of the 83 cases that were returned to NIOSH prior 

to the PER evaluation, but after the issuance of ORAUT-OTIB-0052, were updated to include 

the most recent technical guidance.
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14.0 REFERENCES

Battelle-TBD-6000. 2006. Site Profiles for Atomic Weapons Employers that Worked Uranium 

and Thorium Metals. Battelle-TBD-6000, PNWD-3738 Rev. 0. Battelle Team Dose 

Reconstruction Project for NIOSH. December 13, 2006.

OCAS-IG-001. 2006. External Dose Reconstruction Implementation Guideline, Rev. 2.

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

Support, Cincinnati, Ohio. August 25, 2006.

OCAS-PER-012. 2007. Evaluation of Highly Insoluble Plutonium Compounds, Rev. 0. Office 

of Compensation Analysis and Support, Program Evaluation Plan, Cincinnati, Ohio. August 7, 

2007.

OCAS-PER-0014. 2007. Construction Trades Workers, Program Evaluation Report, Rev. 0. 

Office of Compensation Analysis and Support, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. November 28, 2007.

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

Estimates for Certain DOE Complex Claims, Rev. 01 PC-2. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. May 7, 2004.

ORAUT-OTIB-0013. 2009. Technical Information Bulletin: Individual Dose Adjustment

Procedure for Y-12 Dose Reconstruction, Rev. 00. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. September 9, 2009.

ORAUT-OTIB-0020. 2004. Use of Coworker Dosimetry Data for External Dose, Rev. 00. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. December 29, 2004.

ORAUT-OTIB-0020. 2005. Use of Coworker Dosimetry Data for External Dose, Rev. 01. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. October 7, 2005.

ORAUT-OTIB-0020. 2008. Use of Coworker Dosimetry Data for External Dose, Rev. 02. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. December 04, 2008.

ORAUT-OTIB-0020. 2011. Use of Coworker Dosimetry Data for External Dose, Rev. 03. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. November 14, 2011.

ORAUT-OTIB-0021. 2006. External Coworker Dosimetry Data for the X-10 Site, Rev. 01. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 7, 2006.

ORAUT-OTIB-0026. 2006. External Coworker Dosimetry Data for the K-25 Site, Rev. 00 

PC-2. Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 15, 2006.

ORAUT-OTIB-0030. 2005. External Coworker Dosimetry Data for the Hanford Site, Rev. 00. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 23, 2005.
Effective Date:

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ORAUT-OTIB-0032. 2006. External Coworker Dosimetry Data for the Savannah River Site, 

Rev. 00 PC-1. Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 7, 2006.

ORAUT-OTIB-0039. 2005. Internal Dosimetry Coworker Data for the Hanford Site, Rev. 00. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 28, 2005.

ORAUT-OTIB-0040. 2006. External Coworker Dosimetry Data for the Portsmouth Gaseous 

Diffusion Plant, Rev. 00 PC-1. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

November 7, 2006.

ORAUT-OTIB-0052. 2011. Parameters to Consider When Processing Claims for Construction 

Trade Workers, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 

17, 2011.

ORAUT-OTIB-0064. 2009. Coworker External Dosimetry Data for the Y-12 National Security 

Complex, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. December 18, 

2009.

ORAUT-TKBS-0006-5. 2010. Hanford Site – Occupational Internal Dose, Rev. 03. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. January 7, 2010.

ORAUT-TKBS-0006-5. 2012. Hanford Site – Occupational Internal Dose, Rev. 5. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. November 5, 2012.

ORAUT-TKBS-0006-6. 2010. Hanford Site – Occupational External Dose, Rev. 4. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. January 7, 2010.

ORAUT-TKBS-0010-6. 2009. Los Alamos National Laboratory – Occupational External Dose,

Rev. 02. Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 12, 2009.

ORAUT-TKBS-0013-6. 2006. Pantex Plant – Occupational External Dose, Rev. 00. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. July 27, 2006.

ORAUT-TKBS-0013-6. 2007. Pantex Plant – Occupational External Dose, Rev. 01. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. June 22, 2007.

ORAUT-TKBS-0014-6. 2009. Y-12 National Security Complex – Occupational External Dose, 

Rev. 02. Oak Ridge Associated Universities Team, Cincinnati, Ohio. December 18, 2009.

ORAUT-TKBS-0015-6. 2007. Portsmouth Gaseous Diffision Plant- Occupational External 

Dose, Rev. 01 PC-1. Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 20, 

2007.

ORAUT-TKBS-0028-6. 2005. Weldon Spring Plant – Occupational External Dosimetry, 

Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 24, 2005.
Effective Date:

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ORAUT-TKBS-0028-6. 2013. Weldon Spring Plant – Occupational External Dosimetry,

Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 6, 2013.

ORAUT-TKBS-0031. 2006. Site Profile for the Kansas City Plant, Rev. 00 PC-1. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. January 6, 2006.

SCA-TR-PR2009-0002. 2009. A Protocol to Review NIOSH’s Program Evaluation Reports 

(PERs), Rev. 1. SC&A, Inc., Vienna, Virginia. December 1, 2009.

SCA-TR-PR2011-0004. 2011. Review of ORAUT-OTIB-0052, Revision 1: Parameters to 

Consider when Processing Claims for Construction Trade Workers, DRAFT – Rev. 0. SC&A, 

Inc., Vienna, Virginia. July 3, 2011. [SRDB Ref ID: 88584]

SCA-TR-PR2012-0014. 2012. A Review of NIOSH’s Program Evaluation Report OCAS-PER014, “Construction Trades Workers,” Rev. 0. SC&A, Inc., Vienna, Virginia. March 16, 2012.