ORAU TEAM

Dose Reconstruction

Project for NIOSH

Oak Ridge Associated Universities I Dade Moeller & Associates I MJW Corporation

Page 1 of 5

Document Title:

Pacific Northwest National Laboratory –

Occupational Medical Dose

Document Number: ORAUT-TKBS-0027-3

Revision: 01

Effective Date: 06/18/2007

Type of Document TBD

Supersedes: Revision 00

Subject Expert(s): Vernon E. Shockley and Ronald L. Kathren

Site Expert(s): N/A

Approval: Signature on File Approval Date: 06/04/2007

Edward D. Scalsky, Document Owner

Concurrence: Signature on File Concurrence Date: 05/28/2007

John M. Byrne, Task 3 Manager

Concurrence: Signature on File Concurrence Date: 05/29/2007

Edward F. Maher, Task 5 Manager

Concurrence: Signature on File Concurrence Date: 05/31/2007

Kate Kimpan, Project Director

Approval: Brant A. Ulsh Signature on File for Approval Date: 06/18/2007

James W. Neton, Associate Director for Science

 New Total Rewrite Revision Page Change

FOR DOCUMENTS MARKED AS A TOTAL REWRITE, REVISION, OR PAGE CHANGE, REPLACE THE PRIOR 

REVISION AND DISCARD / DESTROY ALL COPIES OF THE PRIOR REVISION.
Document No. ORAUT-TKBS-0027-3 Revision No. 01 Effective Date: 06/18/2007 Page 2 of 5

PUBLICATION RECORD

EFFECTIVE 

DATE

REVISION 

NUMBER DESCRIPTION

08/09/2005 00 Original draft technical basis document, Section 3, for Pacific 

Northwest National Laboratory. Draft document to refer dose 

reconstructors to Document No. ORAUT-TKBS-0006-3, Hanford Site 

– Occupational Medical Dose. Incorporates NIOSH review 

comments. First approved issue. Training required: As determine 

by the Task Manager. Initiated by Edward D. Scalsky.

06/18/2007 01 Revised to include Attributions and Annotations section. Constitutes 

a total rewrite of the document. No further changes occurred as a 

result of formal internal or NIOSH review. This revision results in no 

change to the assigned dose and no PER is required. Training 

required: As determined by the Task Manager. Initiated by Edward 

D. Scalsky.
Document No. ORAUT-TKBS-0027-3 Revision No. 01 Effective Date: 06/18/2007 Page 3 of 5

TABLE OF CONTENTS

SECTION TITLE PAGE

6.1 Introduction..................................................................................................................................4

6.2 Attributions and Annotations ........................................................................................................5

References ..........................................................................................................................................5

.

1
Document No. ORAUT-TKBS-0027-3 Revision No. 01 Effective Date: 06/18/2007 Page 4 of 5

1 6.1 INTRODUCTION

2 Technical basis documents and site profile documents are not official determinations made by the 

3 National Institute for Occupational Safety and Health (NIOSH) but are rather general working 

4 documents that provide historic background information and guidance to assist in the preparation of 

5 dose reconstructions at particular sites or categories of sites. They will be revised in the event 

6 additional relevant information is obtained about the affected site(s). These documents may be used 

7 to assist NIOSH staff in the completion of the individual work required for each dose reconstruction.

8 In this document the word “facility” is used as a general term for an area, building, or group of 

9 buildings that served a specific purpose at a site. It does not necessarily connote an “atomic weapons 

10 employer facility” or a “Department of Energy [DOE] facility” as defined in the Energy Employees 

11 Occupational Illness Compensation Program Act [EEOICPA; 42 U.S.C. § 7384l(5) and (12)]. 

12 EEOICPA defines a DOE facility as “any building, structure, or premise, including the grounds upon 

13 which such building, structure, or premise is located ... in which operations are, or have been, 

14 conducted by, or on behalf of, the Department of Energy (except for buildings, structures, premises, 

15 grounds, or operations ... pertaining to the Naval Nuclear Propulsion Program)” [42 U.S.C. § 

16 7384l(12)]. Accordingly, except for the exclusion for the Naval Nuclear Propulsion Program noted 

17 above, any facility that performs or performed DOE operations of any nature whatsoever is a DOE 

18 facility encompassed by EEOICPA.

19 For employees of DOE or its contractors with cancer, the DOE facility definition only determines 

20 eligibility for a dose reconstruction, which is a prerequisite to a compensation decision (except for 

21 members of the Special Exposure Cohort). The compensation decision for cancer claimants is based 

22 on a section of the statute entitled “Exposure in the Performance of Duty.” That provision [42 U.S.C. § 

23 7384n(b)] says that an individual with cancer “shall be determined to have sustained that cancer in the 

24 performance of duty for purposes of the compensation program if, and only if, the cancer ... was at 

25 least as likely as not related to employment at the facility [where the employee worked], as 

determined in accordance with the [probability of causation1

30 As noted above, the statute includes a definition of a DOE facility that excludes “buildings, structures, 

31 premises, grounds, or operations covered by Executive Order No. 12344, dated February 1, 1982 (42

32 U.S.C. 7158 note), pertaining to the Naval Nuclear Propulsion Program” [42 U.S.C. § 7384l(12)].

33 While this definition contains an exclusion with respect to the Naval Nuclear Propulsion Program, the 

34 section of EEOICPA that deals with the compensation decision for covered employees with cancer 

35 [i.e., 42 U.S.C. § 7384n(b), entitled “Exposure in the Performance of Duty”] does not contain such an 

36 exclusion. Therefore, the statute requires NIOSH to include all occupationally derived radiation 

37 exposures at covered facilities in its dose reconstructions for employees at DOE facilities, including 

38 radiation exposures related to the Naval Nuclear Propulsion Program. As a result, all internal and 

39 external dosimetry monitoring results are considered valid for use in dose reconstruction. No efforts 

40 are made to determine the eligibility of any fraction of total measured exposure for inclusion in dose 

41 reconstruction. NIOSH, however, does not consider the following exposures to be occupationally 

42 derived:

26 ] guidelines established under subsection 

27 (c) ...” [42 U.S.C. § 7384n(b)]. Neither the statute nor the probability of causation guidelines (nor the 

28 dose reconstruction regulation) define “performance of duty” for DOE employees with a covered 

29 cancer or restrict the “duty” to nuclear weapons work.

43 • Radiation from naturally occurring radon present in conventional structures

44 • Radiation from diagnostic X-rays received in the treatment of work-related injuries

45

 1 The U.S. Department of Labor is ultimately responsible under the EEOICPA for determining the probability of 

causation (POC).
Document No. ORAUT-TKBS-0027-3 Revision No. 01 Effective Date: 06/18/2007 Page 5 of 5

1 The Medical program at the Pacific Northwest National Laboratory (PNNL) is the same program that 

2 existed at Hanford subsequent to 01/03/1965 when Battelle Memorial Institute (BMI) assumed 

3 responsibility for operation of the Hanford Laboratories and certain Hanford-wide services and 

4 functions as part of the Atomic Energy Commission (AEC) operations at the Hanford site. Since that 

5 is the case, it has been determined that any dose reconstructions that incorporate the dose received 

6 by PNNL employees as a result of required medical X-ray examinations will be determined based on 

7 the programs described in the corresponding Hanford TBD, Hanford Site – Occupational Medical 

8 Dose (ORAUT 2005).

9 6.2 ATTRIBUTIONS AND ANNOTATIONS

10 All information requiring identification was addressed in ORAUT (2005).

11 REFERENCE

12 ORAUT (Oak Ridge Associated Universities Team), 2005, Hanford Site – Occupational Medical Dose,

13 ORAUT-TKBS-0006-3, Rev. 01, Oak Ridge, Tennessee, April 11.