DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

OCAS-PER-012, “EVALUATION OF HIGHLY INSOLUBLE PLUTONIUM 

COMPOUNDS”

Contract No. 200-2004-03805

SCA-TR-PR2010-0001, Rev. 0 

Prepared by 

SC&A, Inc. 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

March 2010 

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.
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S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No. 

SCA-TR-PR2010-0001

Effective Date: 

Draft – March 18, 2010

A PRELIMINARY REVIEW OF NIOSH’S 

PROGRAM EVALUATION REPORT

OCAS-PER-012, “EVALUATION OF 

HIGHLY INSOLUBLE PLUTONIUM 

COMPOUNDS”

Page 2 of 16

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD, MPH

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Mauro, PhD, CHP
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TABLE OF CONTENTS

1.0 Statement of Purpose ...........................................................................................................4

2.0 Subtask 1: Identify the Circumstances that Necessitated the Need for 

OCAS-PER-012...................................................................................................................6

2.1 Development of ORAUT-OTIB-0049.....................................................................6

2.2 Issuance of ORAUT-OTIB-0049.............................................................................7

2.3 Issuance of OCAS-PEP-012 ....................................................................................7

2.4 Issuance of PER-012................................................................................................8

2.5 SC&A’s Comments Pertaining to the Development of PER-0012 and 

Supporting Documents.............................................................................................8

3.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ...............................9

3.1 A Technical Overview of OTIB-0049 .....................................................................9

3.1.1 Review of Section 4.1.3.4.2 Unmonitored Individual (Coworker 

Model)........................................................................................................10

3.1.2 Review of Section 4.1.4 Doses Based on Fecal Bioassay Data.................11

3.1.3 Technical Basis for < 2 Months Fecal Data...............................................11

3.1.4 Technical Basis for > 2 Months Fecal Data...............................................11

3.2 SC&A Comments Pertaining to the Use of Fecal Data for Dose Reevaluation...............................................................................................................12

4.0 Subtask 3: Evaluate the PER’s Stated Approach for Identifying the Number of 

DRs Requiring Re-evaluation of Dose ..............................................................................13

5.0 Subtask 4: Conduct Audits of a Sample Set of DRs Affected by OCAS-PER-012 .........15

6.0 References..........................................................................................................................16
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1.0 STATEMENT OF PURPOSE

To support dose reconstruction (DR), the National Institute for Occupational Safety and Health 

(NIOSH) and the Oak Ridge Associated Universities Team (ORAUT) have assembled a large 

body of guidance documents, workbooks, computer codes, and tools. In recognition of the fact 

that all of these supporting elements in dose reconstruction may be subject to revisions, 

provisions exist for evaluating the effect of such programmatic revisions on the outcome of 

previously completed DRs. Such revisions may be prompted by document revisions due to new 

information, misinterpretation of guidance, changes in policy, and/or programmatic 

improvements.

The process for evaluating potential impacts of programmatic changes on previously completed 

DRs has been proceduralized in OCAS-PR-008, Preparation of Program Evaluation Reports 

and Program Evaluation Plans (OCAS 2006), Revision 2, dated December 6, 2006. This 

procedure describes the format and methodology to be employed in preparing a Program 

Evaluation Report (PER) and a Program Evaluation Plan (PEP).

A PER provides a critical evaluation of the effect(s) that a given issue/programmatic change may 

have on previously completed DRs. This includes a qualitative and quantitative assessment of 

potential impacts. Most important in this assessment is the potential impacts on the Probability 

of Causation (POC) of previously completed DRs with POCs of <50%.

As needed, a PEP may be issued that serves as a formal notification of an impending PER. The 

PEP provides a preliminary description of the issue(s) that will be addressed in the PER, and 

summarizes the likely scope of the effort required to complete the PER.

During an Advisory Board meeting on October 22, 2009, SC&A was tasked by the Board to 

conduct a review of OCAS-PER-012, Evaluation of Highly Insoluble Plutonium Compounds

(OCAS 2007a). In conducting a PER review, SC&A is committed to perform the following five 

subtasks, each of which is discussed in this report:

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

on 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, 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. 
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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. Based on information 

contained in Table 1 (and discussed in Section 3.1 below), the number of DRs selected 

for audit for a given PER will vary. (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.) 

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

subtasks, along with our review conclusions. 
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2.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR OCAS-PER-012

On January 12, 2004, NIOSH issued the technical basis document (TBD) entitled, Technical 

Basis Document for the Rocky Flats Plant – Occupational Internal Dose, ORAUT-TKBS-0011-

5 (ORAUT 2004). Section 5.2.1.2 of the TBD provided a brief discussion of plutonium 

solubility and particle size that included the following statements: 

Most plutonium in metalworking operations and involved in fires is insoluble (i.e., 

type S). . . . 

The plutonium fire on October 15, 1965, in Buildings 776 and 777, is a special

case. The plutonium, which was strongly retained in the lungs of exposed 

workers with relatively low transfer to the urine, exhibited highly insoluble (super 

type S) characteristics.

. . . A claimant-favorable approach is to assume insoluble plutonium if the 

qualifying cancer is of the respiratory system and to assume soluble plutonium for 

all other cases.

In general, particle size and distributions are not available for work areas or 

incidents at RFP. Therefore, dose reconstructions should use the default value of 

5-μm activity median aerodynamic diameter (AMAD). 

One exception is the plutonium fire on October 15, 1965, in Buildings 776 and 

777, for which Mann and Kirchner (1967) measured a mass median diameter of 

0.3 μm (1-μm AMAD) with a geometric deviation of 1.83. An approach that is 

favorable to claimants is to assume 1-μm AMAD for all plutonium fires unless the 

qualifying cancer involves the tissues of the extrathoracic regions. [Emphasis 

added.]

2.1 DEVELOPMENT OF ORAUT-OTIB-0049

While ORAUT-TKBS-0011-5 of the RFP’s Site Profile acknowledged the unique characteristics 

of plutonium particulates associated with fires by referring to its “. . highly insoluble (super type 

S) characteristics” (and smaller particle size), there was no special guidance provided in the 

TBD that would account for the reduced solubility and resultant higher doses.

NIOSH’s failure to account for the high level of insolubility of Type Super S plutonium in DR, 

however, can be understood when viewed in context with the existing regulatory framework that 

governs the Energy Employees Occupational Illness Compensation Program Act (EEOICPA). 

Under 42 CFR 82, Section § 82.18(b) states the following:

NIOSH will calculate the dose to the organ or tissue of concern using the 

appropriate current metabolic models published by ICRP. [Emphasis added.]
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For the inhalation of plutonium, current International Commission on Radiological Protection 

(ICRP) models include ICRP Publication 66 (ICRP 1993) and ICRP Publication 67 (ICRP 1994). 

Both of these ICRP publications are correctly identified/referenced for use in OCAS-IG-002

(OCAS 2002). Important to note is that both ICRP publications limit their biokinetic models to 

three solubility classes (i.e., Types F, M, and S) that do not include the highly insoluble or Type 

Super S form. 

From a regulatory view point, NIOSH was, therefore, compliant in deriving doses based on 

Type S plutonium, since current ICRP models do not include Type Super S as a distinct 

solubility class. Nevertheless, NIOSH’s acknowledgement of the existence of highly insoluble 

plutonium prompted further discussions and the decision to investigate the potential impacts of 

Type Super S plutonium on organ doses to exposed workers at RFP, as well as other facilities.

2.2 ISSUANCE OF ORAUT-OTIB-0049

On February 6, 2007, NIOSH issued ORAUT-OTIB-0049, Rev. 00, Estimating Doses for 

Plutonium Strongly Retained in the Lung (ORAUT 2007). This document provided guidance for 

reassessing organ doses for highly insoluble plutonium designated as Type Super S that have 

been shown to be retained in the lung longer than predicted by the ICRP Task Group Lung 

Model for Type S. Revision 00 was amended on December 18, 2007, to include guidance for 

dose reassessment based on coworker-derived intakes; and Revision 01 was further amended on 

September 26, 2008 (ORAUT 2008), to provide guidance for dose reassessment in instances 

where the original DR was based on fecal data.

2.3 ISSUANCE OF OCAS-PEP-012

With the issuance of ORAUT-OTIB-0049 and the realization of increased doses that needed to 

be assigned to workers exposed to Type Super S plutonium, NIOSH issued a Program 

Evaluation Plan (OCAS-PEP-012) on March 29, 2007 (OCAS 2007b).

Section 3.0 of PEP-012 describes the methodology/criteria for identifying the universe of claims 

potentially affected by ORAUT-OTIB-0049 and screening these claims on the basis of their 

original POC (i.e., <50% but >20% for claims with target organs other than lung or LNTH. The 

threshold POC level of >20% is based on the fact that the Pu Type Super S correction factor of 4 

will not result in a revised POC >50% for an original POC of <20%.)

Based on the PEP’s stated inclusion criteria, the universe of potentially affected cases totaled 

3,451. This number was reduced to 2,725 cases, when cases with <20% POC were eliminated. 

PEP-012 concluded with the following statement: 

After the potential affected claims have been evaluated, a Program Evaluation 

Report (PER) will be written to summarize the results. As part of the report, 

claims that were not evaluated further due to the POC cut point will be reviewed 

to determine if they are also affected by another PER. The PER will contain 

additional analysis for these cases including additional evaluations if necessary.
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2.4 ISSUANCE OF PER-012

On August 6, 2007 (or about four months after PEP-012 had been issued), NIOSH issued PER012 (OCAS 2007a). Section 3.1 of PER-012 identified four selection criteria, which were more 

conservative and differed from those cited in PEP-012 for identifying the universe of potentially 

affected claims. As a result, a new total of 4,865 cases were identified that had the potential for 

being affected by OTIB-0049.

The universe of 4,865 potentially affected cases was reduced to 1,757 claims that would require 

a reassessment of dose based on ORAUT-OTIB-0049 guidance. The elimination of 3,108 cases 

from the universe of 4,865 cases reflects the application of two screening criteria that are 

discussed in greater detail under Subtask 3.

2.5 SC&A’S COMMENTS PERTAINING TO THE DEVELOPMENT OF PER-0012 

AND SUPPORTING DOCUMENTS

Our review of ORAUT-OTIB-0049, OCAS-PEP-012, and OCAS-PER-012 indicates that 

NIOSH properly characterized the significance of highly insoluble plutonium and complied with 

the process for evaluating potential impacts of programmatic changes on previously completed 

dose reconstructions, as proceduralized in OCAS-PR-008, Preparation of Program Evaluation 

Reports and Program Evaluation Plans, Rev. 2 (OCAS 2006).
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3.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

In instances where the PER involves a technical issue that is supported by documents [e.g., white 

paper(s), technical information bulletin(s), and/or procedure(s)] that have not yet been subjected 

to a formal SC&A review, Subtask 2 will assess the scientific basis and/or sources of information 

to ensure the credibility of the corrective action and its consistency with current/consensus 

science.

However, in behalf of PER-012, such technical documentation was previously formalized by 

means of ORAUT-OTIB-0049, Rev. 00, dated February 6, 2007. SC&A issued a critical review 

of this document in a draft report dated October 29, 2007 (SC&A 2007). Our review of 

ORAUT-OTIB-0049, Rev. 00, concluded with the following statements:

SC&A examined OTIB-0049 in terms of its conceptual approach, including the 

overall technical approach used, scientific validity, and sufficient degree of 

conservatism. SC&A is in agreement with the NIOSH approach for estimating 

annual dose from intakes of Pu-239 that are retained in the lung longer than 

predicted by the normal absorption Type S model, based on the applicability of 

empirically derived adjustment factors for the lung, systemic organs, GI tract 

organ and tissues, and extra-thoracic regions.

In light of the existence of OTIB-0049 and corresponding conclusions reached by SC&A, 

Subtask 2 for PER-012 is reduced to a brief summary of key technical elements that define 

OTIB-0049, which in turn will prepare the reader for Subtasks 3 and 4 that follow. 

3.1 A TECHNICAL OVERVIEW OF OTIB-0049

Empirical human data have shown that high-fired plutonium oxides exhibit a longer retention in 

the lung than currently predicted by the ICRP 66 Human Respiratory Track Model for solubility 

class Type S. Based on the method by which individuals were monitored, the reduced solubility 

and enhanced retention of PuO2 in the lung may significantly impact estimates of tissue/organ 

doses of the exposed worker.

Due to the fact that the ICRP model at present does not address the dosimetric impacts of 

Type Super S plutonium oxides, NIOSH selected human empirical data representing 10 cases 

that were called the “design cases.” Data for the design cases were fitted by means of the IMBA 

computer code to lung data using the default ICRP Type S model. Annual dose adjustment 

factors were principally derived from the ratios of observed plutonium lung retentions projected 

annually for the actual cases to those projected for the ICRP 66 default Type S model for the two 

cases that yielded the maximum ratios.

A summary of dose adjustment factors is provided in Table 8 of ORAUT-OTIB-0049, which is 

reproduced herein as Table 1. Inspection of Table 1 shows that adjustment factors are provided 

for four groupings of target tissues/organs and are based on the type of monitoring data that were 
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used in the original dose reconstruction. Included are lung counting, air monitoring, and 

urinalysis.

Not included in Rev. 00 of ORAUT-OTIB-0049 were dose adjustment factors for original dose 

reconstructions that were based on fecal bioassay data. Also not included in Rev. 00 was any 

mention/guidance pertaining to the “unmonitored worker,” whose previous DR had been based 

on coworker urinalysis data. Due to the fact that these amendments to OTIB-0049 were not 

previously reviewed by SC&A, a technical review of these amendments is provided below.

Table 1. Summary of Type SS Adjustment Factors

Lung counts Air concentrations Urinalysis 

Lungs Table D

(normalized to last chest count) 

Table D Factor of 4 followed by Table D 

adjustment 

Extra-thoracic None None Factor of 4 

GI tract No adjustment None Factor of 4 

Systemic organs None None Prior to last urine sample: none 

Post last urine sample: factor of 4 

3.1.1 Review of Section 4.1.3.4.2 Unmonitored Individual (Coworker Model)

Section 4.1.3.4.2 specifies guidance in behalf of a worker who may have potentially been 

exposed to Type Super S plutonium, but was unmonitored at a facility for which a coworker 

model has been developed by means of urinalysis data.

In order to account for the fact that the existing coworker model assumed Type S plutonium for 

converting urine data into inhalation quantity, the intake adjustment factor of “4” is applied to 

the unmonitored exposure that may have involved Type Super S plutonium. The generic 

adjustment factor of “4” for the coworker model/unmonitored worker was derived in 

Attachment C of OTIB-0049 and accounts for the higher retention rate in the lung and, 

therefore, the lower urine excretion rate for Type SS plutonium when compared to Type S.

Important to note, however, is that the application of the adjustment factor is restricted to those 

years that post-date the period of time that defines the coworker intake model.

Regarding the guidance provided for the revision of dose to the unmonitored worker by means of 

a coworker model that was based on urinalysis data, SC&A concludes the following:

 The adjustment factor of 4 is technically defensible, since it is based on conservative 

selection of empirical human data as cited in Appendix C of OTIB-0049.

 The adjustment factor of 4 for use in a coworker model is consistent with its general use 

as the adjustment factor when urinalysis data were used in the original dose 

reconstruction.
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 The restrictive use of the adjustment factor for only those years that post-date the period 

for which coworker data are available is technically defensible, conservative, and 

consistent with the guidance prescribed for the monitored worker.

3.1.2 Review of Section 4.1.4 Doses Based on Fecal Bioassay Data

This new section in Rev. 01 provides guidance for the re-evaluation of organ/tissue doses that 

had previously been derived for Type S plutonium from fecal data. Potential revision to 

organ/tissue dose is based on two timeframes. In brief, for fecal sample data obtained less than 2 

months after an acute exposure or the cessation of chronic exposure, a dose adjustment is 

required for the lung and LNTH that involves data contained in Table D of OTIB-0049. (All 

other organs/tissues do not require re-evaluation.)

For fecal sampling data that were taken more than 2 months following an acute or prolonged 

chronic exposure, NIOSH provides the following guidance: 

Fecal samples . . . should be modeled as if they were urine samples 

(Section 4.1.3). For example, if the 24-hour fecal sample contained 1 dpm it 

should be modeled as if it were a 24-hour urine sample that contained 1 dpm.

Once the dose to the organ/tissue of interest is calculated, it is adjusted upward 

by a factor of 3.

The technical bases that support this guidance are presented in Attachment E of OTIB-0049 and 

are briefly summarized below.

3.1.3 Technical Basis for < 2 Months Fecal Data

Based on kinetics defined by the ICRP lung model, plutonium activity in fecal samples collected 

less than 2 months following either an acute or a chronic exposure principally reflects the 

mechanical clearing of plutonium from compartments of the respiratory system.

Because mechanical clearance rates are largely unaffected by solubility, Type S and Type Super 

S plutonium can be assumed to have nearly identical transfer rates to the GI tract/feces within the 

first 2 months, as shown in Figures E-1 and E-2 of OTIB-0049, Attachment E. Thus, the fecal 

data may be converted to an air inhalation intake(s) (either acute or chronic) by means of IMBA 

that assumes Type S plutonium. Once the inhalation intake has been determined, a dose 

adjustment that accounts for the lower solubility for Type SS is required only for the lung and 

LNTH, as specified for air sampling data in Section 4.1.1 of OTIB-0049 and noted in Table 1 

above.

3.1.4 Technical Basis for > 2 Months Fecal Data

For time periods greater than 2 months following inhalation exposure, Attachment E states that 

no model currently exists for interpreting fecal data. However, a bounding interpretation may be 

derived from a comparison of fecal excretion fractions to urine excretion fractions following an 

intravenous (IV) injection of plutonium.
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Attachment E of OTIB-0049 provides Figures E-3 and E-4, which show that after 2 months 

following an IV injection of plutonium, the activity levels in a 24-hour urine sample are between 

2 and 3 times higher than that of a 24-hour fecal sample. By means of this relationship, guidance 

provided in Attachment E states the following:

. . . An upper estimate of an intake calculated from a fecal sample following an

inhalation intake of Type SS plutonium is therefore taken to be 3 times the intake 

estimated assuming that the fecal sample was a urine sample and applying the 

methodology in this OTIB for a urine sample. [Emphasis added.]

The above-stated guidance can be illustrated by the following example. If a given 24-hour fecal 

sample contained 1 dpm of plutonium, the dose reconstructor may assume that a 24-hour urine 

sample would have contained 3 dpm of plutonium. Using the 3 dpm per 24-hour urine excretion, 

an organ dose would be calculated for plutonium Type S. Estimate of Type SS dose would now 

follow the additional guidance provided in Section 4.1.3, “Dose Based on Urinalysis Data,” of 

OTIB-0049. Thus, if the target organ was either the lung or LNTH, yearly doses would first 

require the proper dose adjustment factors specified in Table D-1 of Attachment D and the 

intake adjustment factor of 4 in order to obtain a final yearly Type SS dose to the lung (or 

LNTH).

3.2 SC&A COMMENTS PERTAINING TO THE USE OF FECAL DATA FOR DOSE 

RE-EVALUATION

SC&A critically reviewed Attachment E of OTIB-0049, which provides the technical bases for 

guidance in the re-evaluation of doses derived from fecal bioassay data, as stated in 

Section 4.1.4. Separate guidance is provided for bioassay data that are less than or greater than 

2 months duration following an exposure to Type SS plutonium.

SC&A concludes that the protocols for both timeframes are (1) based on reasonable scientific 

principles/assumptions, (2) consistent with other protocols defined in OTIB-0049, and (3) likely 

to yield organ tissues that are claimant favorable.
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4.0 SUBTASK 3: EVALUATE THE PER’s STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DRs REQUIRING 

RE-EVALUATION OF DOSE

Section 3.0 of PER-012 identified the set of criteria used to determine the total population of 

claims that had the potential of being “affected” by ORAUT-OTIB-0049. Here, the word 

“affected” refers to all claims/DRs that (1) had been completed on or before February 6, 2007 

(i.e., the date of issue for OTIB-0049), (2) involved facilities with potential exposure to Type SS 

plutonium, and (3) resulted in a POC of less than 50%. Based on these criteria, NIOSH 

identified a total of 4,865 of potential cases.

In principle, each of the 4,865 cases thus identified would require a re-evaluation of dose, unless 

it could be shown that the application of OTIB-0049 could not advance the POC to 45% or 

greater. NIOSH selected the lower value of 45% POC for reasons of conservatism and 

efficiency, since any claim with a revised POC greater than 45% is required to have 30 IREP 

runs, each with 10,000 iterations.

Imbedded in OTIB-0049, however, are two screening criteria, which significantly reduced the 

number of claims required to be re-evaluated. The first screening criterion that can be applied to 

the 4,865 potential claims is defined by a threshold POC value. With the exception of the lung 

and LNTH, Table 1 above shows that the application of OTIB-0049 can, under the most 

conservative assumption (i.e., when the organ dose/POC was exclusively based on the internal 

exposure to Type SS plutonium), be increased by a factor of 4. 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

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 16.97%.

A second screening criterion applied to the 4,865 total claims identified those claims for which 

either no plutonium dose (independent of solubility class) was assigned, or a plutonium intake 

was based on air monitoring data, but did not involve the lung or LNTH as target organs.

When combined, the two screening criteria eliminated 3,108 cases from further consideration/ 

dose re-evaluation from among the initial 4,865 total cases.

In Section 3.4, “Path Forward,” of OCAS-PER-012, NIOSH concluded with the following 

statement:

NIOSH has determined that 1,757 of these claims required a new dose estimate to 

determine the effect of this change. NIOSH is requesting that DOL return these 

claims to NIOSH for a new Dose Reconstruction. [Emphasis added.]
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

SC&A’s Comments Regarding NIOSH’s Approach

SC&A was not given access to the primary data used by NIOSH to identify and quantify those 

claims that will require re-evaluation of dose. SC&A is, therefore, not able to verify the 

accuracy of the above-cited number of 1,757 claims that will require dose re-evaluation. At a 

minimum, however, SC&A assumes that the number 1,757 is a typographic error that was 

meant to be 1,577 claims (4,685 – 3,108 = 1,577). 

Our review was, therefore, limited to the methodology used by NIOSH to identify and quantify 

those claims that are potentially affected by OTIB-0049. SC&A concludes that the selection and 

screening criteria of claims described in Section 3.0 of OCAS-PER-012 are scientifically sound, 

inclusive of all potential variables affecting original DR, and maximally conservative. The high 

degree of conservatism is principally driven by the 16.97% POC screening criterion and the 

bounding assumption that this value could potentially reflect an organ dose that was 100% 

assigned to a plutonium intake.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

5.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DRs

AFFECTED BY OCAS-PER-012

Selection of DRs

Among the DRs that may require audit from among the 1,577 claims that have been re-evaluated 

in accordance with ORAUT-OTIB-0049 are DRs that include the following:

 The number of target organs/tissues that may be impacted by PER-012

 The method/data that were employed in the original DR

 The time period, work location, and job function(s) that characterize the DR of a claim

A review of PER-012 indicates the need for dose re-evaluation for four groupings of target 

tissues that include (1) lungs and thoracic lymph nodes (LNTH), (2) extrathoracic tissues of the 

respiratory tract, (3) tissues of the gastro-intestinal tract, and (4) other systemic organs.

The need for and the method for the re-evaluation of dose in behalf of these four groupings, 

however, is further dictated by the monitoring methods/data that were used in the original DR, 

which may have employed one of four possible options: (1) air sampling data, (2) urinalysis, 

(3) in-vivo lung counting, and (4) fecal analysis (see Table 1 above). Important to note is that for 

each of the four target organs/tissues, the prescribed method for dose re-evaluation differs. Thus, 

it would appear that for OCAS-PER-012, a minimum of 10 DRs are needed to assess at least 1

claim for each of the 10 permutations for dose re-evaluation, as shown in Table 2 below. 

However, this number could be reduced if there are no claims among the 1,577 cases of affected 

DRs that represent 1 or more of the 10 permutations.

Table 2. Potential Categories of DRs

Target Organ Urinalysis Lung Counts Fecal Sample Air Sampling

Lung/LNTH Yes Yes Yes1 Yes

Extrathoracic Yes No Yes2 No

GI Tract Yes No Yes2 No

Systemic Organs Yes No Yes2 No

 1 Re-evaluation is required regardless of time interval between exposure and fecal sampling.

 2 Re-evaluation is required only if time intervals are >2 months between end of exposure and fecal sampling.

Selections of DRs for audit will require NIOSH to provide the Subcommittee with a distribution 

of the 1,577 claims based on the 10 categories cited in Table 2 above. It is assumed that the 

Subcommittee will identify its final choice of DRs for audit by SC&A.
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.

6.0 REFERENCES

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction under the Energy Employees

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal

Register/Vol.67, No. 85/Thursday, May 2, 2002, p. 22314.

ICRP (International Commission on Radiological Protection) 1993. “Human Respiratory Tract 

Model for Radiological Protection,” ICRP Publication 66, Annals of ICRP 24/1-2, Oxford: 

Pergamon Press.

ICRP (International Commission on Radiological Protection) 1994. “Age-dependent Doses to 

Members of the Public from Intake of Radionuclides: Part 2 Ingestion Dose Coefficients,” ICRP 

Publication 67, Annals of the ICRP 23/3-4, Oxford: Pergamon Press.

Mann, J. R., and R. A. Kirchner, 1967, “Evaluation of Lung Burden Following Acute Inhalation

Exposure to Highly Insoluble PuO2,” Health Physics, Volume 13, pp. 877–882.

OCAS 2002. Internal Dose Guidelines, OCAS-IG-002 Revision 00, NIOSH’s Office of 

Compensation Analysis and Support, Cincinnati, Ohio. August 2002.

OCAS 2006. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

OCAS-PR-008, Revision 2, NIOSH’s Office of Compensation Analysis and Support, 

Cincinnati, Ohio. December 6, 2006

OCAS 2007a. Evaluation of Highly Insoluble Plutonium Compounds, OCAS-PER-012, 

Revision 0, NIOSH’s Office of Compensation Analysis and Support, Cincinnati, Ohio. August 

6, 2007.

OCAS 2007b. Program Evaluation Plan: Evaluation of Highly Insoluble Plutonium 

Compounds, OCAS-PEP-012, Revision 0, NIOSH’s Office of Compensation Analysis and 

Support, Cincinnati, Ohio. March 29, 2007.

ORAUT 2004. Technical Basis Document for the Rocky Flats Plant – Occupational Internal 

Dose, ORAUT-TKBS-0011-5, Rev. 00, Oak Ridge Associated University Team: Cincinnati, 

Ohio. January 12, 2004.

ORAUT 2007. Estimating Doses for Plutonium Strongly Retained in the Lung, ORAUT-OTIB0049, Revision 00, Oak Ridge Associated University Team: Cincinnati, Ohio. February 6, 2007.

ORAUT 2008. Estimating Doses for Plutonium Strongly Retained in the Lung, ORAUT-OTIB0049, Revision 01, PC-1 Oak Ridge Associated University Team: Cincinnati, Ohio. September 

26, 2008.

SC&A 2007. Review of the Third Set of Procedures (45 procedure reviews), SCA-TR-TASK3-

0003, S. Cohen & Associates, Vienna, Virginia, and Saliant Inc., Jefferson, Maryland. October 

29, 2007.