Effective Date:

5/20/2014

Revision No.1 (Draft) Document No. SCA-TR-SP2013-0040 Page No. 1 of 4

ISSUES RESOLUTION MATRIX FOR PACIFIC PROVING GROUND SITE PROFILE

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White 

Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 USC §552a and has been cleared for distribution. 

Finding

Number

Report 

Section Finding Description NIOSH Response

1 4

NIOSH needs to update ORAUT-TKBS-0052, 

Rev. 00, with regard to the 250-workday 

requirement for SEC Class inclusion. Revision 

00 of ORAUT-TKBS-0052, Summary Site 

Profile for the Pacific Proving Grounds, was 

issued on August 30, 2006. At that time, SEC 

status for presumptive cancer claimants required 

employment with at least 250 workdays. The 

250-workday requirement for PPG workers was 

subsequently amended by the Department of 

Labor (DOL) in EEOICPA Bulletin No. 06-15 

issued on September 27, 2006, and EEOICPA 

Bulletin No. 07-05 issued on January 11, 2007. 

Additionally, there may be a need for further 

discussions pertaining to the surrogate use of 

film badge dosimetry for PPG employment

period(s) as recommended in DOL’s EEOICPA 

Bulletin No. 07-05.

NIOSH agrees than an update is needed to ORAUT-TKBS0052, Rev. 00, with regard to the 250-workday requirement for 

SEC Class inclusion. The next revision of ORAUT-TKBS0052 will include provisions of EEOICPA Bulletin No. 06-15 

issued on September 27, 2006, and EEOICPA Bulletin No. 07-

05 issued on January 11, 2007 which state, inter alia, that:

“For any 24-hour period that the employee was present (either 

worked or lived) on the PPG or on ships (evacuated prior to a

nuclear weapon testing), the CE would credit the employee 

with the equivalent of three (8-hour) work days. If there is 

evidence the employee was present at the PPG or on ships for 

24 hours in a day for 83 days, the employee would have the 

equivalent of 250 work days and would meet the 250 work day 

requirement.”

Observation

1 5

There is a need for more definitive guidance 

pertaining to the assignment of occupational 

medical dose in behalf of claimants with no 

formal affiliation with a DOE or AWE facility.

The next revision of ORAUT-TKBS-0052 will include 

provisions from ORAUT-OTIB-0079 which states the NIOSH 

interpretation is that the EEOICPA defines covered radiation as 

the radiation received by a covered employee at a covered 

facility during a covered period. Section 2.0 of ORAUTOTIB-0079 also states that “For most cases in which energy 

employee medical records are not provided, dose 

reconstructors should assume that any occupational medical Xray exposure occurred at the covered facility where the energy 

employee worked.” Therefore, if a covered employee cannot 

be affiliated with a covered facility and there are no records of 

X-rays being administered at a covered facility, then 

occupational medical exposures should not be assigned.

In addition, the next revision of ORAUT-TKBS-0052 will 

delete reference to the guidance found in ORAUT-PROC-0061

for covered employees “hired on location.”

2 6

Section 4.0 “Occupational Environmental 

Dose” completely ignores occupational 

environmental doses for PPG locations from 

fallout. (Note: For PPG locations, occupational 

external environmental dose is for all practical 

purposes an integral part of the occupational 

external (as well as internal) dose and should be 

assessed as such in Section 6.0 of the PPG Site 

Profile.)

NIOSH agrees with the finding and Section 4 of the next 

revision of ORAUT-TKBS-0052 will be revised to instruct 

dose reconstructors that external dose should be assessed in 

Section 6.0 of the PPG Site Profile. Under the current SEC, in 

the absence of bioassay data, internal doses cannot be 

reconstructed.
Effective Date:

5/20/2014

Revision No.1 (Draft) Document No. SCA-TR-SP2013-0040 Page No. 2 of 4

ISSUES RESOLUTION MATRIX FOR PACIFIC PROVING GROUND SITE PROFILE

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White 

Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 USC §552a and has been cleared for distribution. 

Finding 

Number

Report 

Section Finding Description NIOSH Response

3 7.4.2

Available DOE records for a claimant may not 

only be incomplete/inaccurate, but more 

importantly may not include unmonitored 

exposures associated with cohort badging, 

exposure to fallout, etc.

NIOSH understands there are serious deficiencies related to 

film badge dosimetry data and procedural practices identified 

by the NRC (1989), SAIC (1989 – 2006), and Perkins and 

Hammond (1980). In light of these deficiencies, NIOSH finds 

it intractable to achieve more accurate dose assessments than 

those provided by the DNA and reduced in Attachment A of 

ORAUT-TKBS-0052, with realistic uncertainty ranges; too 

many data have been lost or never captured to make such an 

effort feasible. However, the next revision ORAUT-TKBS0052 will include revisions to the Attachment A to provide 

95% doses as appropriate (see response to Findings 8 and 9 

below). For cases where occupation on the various islands is 

documented in the dosimetry records and their stay times are 

known, either by personal or cohort film badges or reentry 

logs, additional dose can be calculated in accordance with the 

information provided in Figures 7-6 through 7-10 and added to 

doses assigned using Attachment A to account for unmonitored 

exposure to fallout. It should be noted that during Operation 

Castle in the first half of 1954, 85% to 90% of all personnel 

were issued operational film badges. In addition, all personnel 

involved in reentry activities were also issued mission badges 

that were read at the end of each mission. (Castle Series, 1954, 

DNA 6035F). For Operation Wigwam on May 15, 1955, and 

all subsequent tests at PPG, 100% of all personnel were issued 

operational film badges. In addition, all personnel involved in 

reentry activities were also issued mission badges that were 

read at the end of each mission. (Wigwam, DNA 6000F, 1981)

4 7.4.2

ORAUT-TKBS-0052 does not provide a 

definition for unmonitored dose as it applies to 

PPG participants or any specific guidance.

The next revision of ORAUT-TKBS-0052 will revise this 

statement to read as follows: “Covered employees that 

participated in the various PPG operations and were not 

badged can be assigned coworker dose as outlined in 

Attachment A.”

5 7.4.2

Average photon energies associated with fallout 

are well above >250 keV. Depending on what 

exposure geometry is assumed, a default photon 

energy of 30–250 keV may not be claimant 

favorable

Although ISO or ROT geometries might be more realistic, the 

general approach taken with all EEOICPA claims is to apply 

the DCF yielding the highest POC. Except for the lung, 

esophagus, red bone marrow, and bone surfaces (as discussed 

in IG-001, Section 4.4) the highest DCF is typically associated 

with the 30-250 keV photon energy range and the AP 

geometry. In addition, as described in Table 5A of the NIOSH 

–IREP Technical Documentation (2002), the radiation 

effectiveness factor (REF) is significantly higher for photons in 

the 30-250 keV range when compared to the > 250 keV range. 

These two factors lead to the recommendation given in Section 

6.0.
Effective Date:

5/20/2014

Revision No.1 (Draft) Document No. SCA-TR-SP2013-0040 Page No. 3 of 4

ISSUES RESOLUTION MATRIX FOR PACIFIC PROVING GROUND SITE PROFILE

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White 

Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 USC §552a and has been cleared for distribution. 

Finding 

Number

Report 

Section Finding Description NIOSH Response

6 7.4.2

Since claims involving skin cancer usually 

specify the location(s) on the body, the critical 

variable of distance above the source plane 

defined by Barss and Weitz (2006) should be 

included in the assignment of beta-to-gamma 

dose ratios for PPG claimants.

Figure C-1 in Attachment C of the NTS external TBD provides 

the information given in Table 7-4 of the SC&A report. In 

addition, with respect to the ratios in Table C-1 of the NTS 

document, Attachment C recommends: “These values can be 

modified with appropriate factors for shielding and distance 

(Barss and Weitz 2006).” Guidance on the assignment of betato-gamma ratios from Barss and Weitz (2006) will be added to 

the next revision of ORAUT-TKBS-0052 for clarity. The

guidance will include, from Barss and Weitz 2006, Table 1, 

Beta-to-gamma dose Ratios for Pacific Test Sites, Table 3, 

Beta-to gamma Ratios for eye Exposures, and Table 7, 

Standard Distances from Source Plane for Various Anatomical 

Locations.

7 7.4.2

NIOSH’s guidance for the assignment of missed 

dose is based on assumptions that are not 

supported by facts and in the face of uncertainty 

are clearly not claimant favorable.

The next revision of ORAUT-TKBS-0052 will revise the 

missed dose guidance as follows: “Assign missed dose based 

on the number of exchanges found in the dosimetry records. 

Also, compare the total of the recorded dose plus the missed 

dose to the 50% dose in Attachment A and assign the larger 

dose. In addition, for cases where occupation on the various 

islands is documented in the dosimetry records and their stay 

times are known, additional dose can be calculated in 

accordance with the information provided in DNA’s 1983 

report entitled Operation Greenhouse 1951 related to 

calculating dose based on island occupation times and added to 

doses assigned as described above to account for potentially 

unmonitored exposure to fallout.” It should be noted that in 

most cases where an individual's dose was assigned based on 

cohort badging, logs were maintained in the individual's 

dosimetry records which documented the location and stay 

times associated with reentry activities. These logs can be 

used to estimate potential dose received during these reentry 

activities.

8 7.4.2

Independent of other concerns/limitations that 

characterize the DNA dose distribution data

(e.g., their accuracy, completeness, etc.), use of 

the 50th percentile dose as a coworker dose is 

not justified for PPG participants for Operations 

up to and inclusive of Operation CASTLE and 

for the subsequent Operations where dosimeter 

damage was an issue.

Owing to the large uncertainties in the operation-specific dose 

reported by DNA, the next revision of ORAUT-TKBS-0052, 

Attachment A will be revised to replace the 50th percentile 

doses with the 95th percentile doses to be used for coworker 

doses, as appropriate.

9 7.4.2

Operation-specific dose distributions defined by 

DNA must be adjusted to account for the MDA 

value of film dosimeters regardless of what 

percentile value is employed.

The next revision of ORAUT-TKBS-0052, Attachment A will 

be revised to ensure the coworker dose approach follows the 

guidance in ORAUT-OTIB-0020 with respect to the treatment 

and inclusion of potential missed dose.
Effective Date:

5/20/2014

Revision No.1 (Draft) Document No. SCA-TR-SP2013-0040 Page No. 4 of 4

ISSUES RESOLUTION MATRIX FOR PACIFIC PROVING GROUND SITE PROFILE

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White 

Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 USC §552a and has been cleared for distribution.