Office of Compensation Analysis and Support 

Program Evaluation Report

Document Number: OCAS-PER-012 

Effective Date: 8/7/2007 

Revision No. 0

Evaluation of Highly Insoluble Plutonium Compounds Page 1 of 6 

Author: Signature on file Date: _8/6/2007____ Dave Allen, HP Team Leader 

Approval: Signature on file Date: _8/6/2007____ J.W. Neton, Associate Director for Science 

Supersedes: None 

RECORD OF ISSUE/REVISIONS 

ISSUE 

AUTHORIZATION 

DATE 

8/7/2007

EFFECTIVE 

DATE 

8/7/2007 

REV. NO. 

0 

DESCRIPTION 

New document to determine which 

previously completed claims require 

evaluation for the affect of OTIB-0049, 

Highly Insoluble Plutonium Compounds. 

1.0 Description

In the first version of the Rocky Flats Plant (RFP) Internal TBD (Jan 2004), it was noted 

that highly insoluble forms of plutonium were generated during the Rocky Flats fires. In 

response to the need to assess claims with potential exposure to this material, ORAUTOTIB-0049 was developed. ORAUT-OTIB-0049 delineates the methods for assessing 

potential exposure to highly insoluble forms of plutonium, not only from the RFP fires, 

but at other sites in the complex that may have worked with this material. 

2.0 Issue Evaluation

The issuance of ORAUT-OTIB-0049 on February 6, 2007 provided guidance for 

assessing claims with potential exposure to highly insoluble forms of plutonium. 

ORAUT-OTIB-0049 does not propose a new type of material for general modeling 

purposes or propose a new variation of the lung model. Rather, to account for the 

difference in organ doses, the TIB analysis developed empirical “dose adjustment 

factors” from selected cases from RFP and Hanford that exhibited Type Super S behavior 

following intakes of 239Pu mixtures. For intakes calculated from urinary excretion data, a 

bounding analysis is implemented as an intake adjustment factor rather than a defined 

change in ICRP model parameters. 

Due to the increased doses assigned to some workers exposed to Type Super S 

plutonium, previously completed claims that were assigned plutonium doses at sites 
Office of Compensation Analysis and Support

Document Number: OCAS-PER-012 Program Evaluation Plan 

Effective Date: 8/7/2007 Revision No. 0 Page 2 of 6 

where this material is potentially available for exposure need to be reexamined to 

determine the impact (if any) on the dose assessment. 

3.0 Plan for Resolution or Corrective Action

3.1 Determining the total population of claims 

 

The criteria used to determine the population of claims potentially affected by ORAUOTIB-0049 are: 

1. Probability of Causation (PC) less than 50%; 

2. Most recent version of the dose reconstruction approved by OCAS on or prior to 

February 6, 2007 

3. Potential for highly insoluble form of plutonium at the site (see Attachment A); 

and, 

4. Claim currently at DOL (some claims are returned for rework for various reasons) 

 

On July 5, 2007, these criteria were used to generate the list of 4,865 potentially affected 

claims. 

3.2 Determination of claims which will not change due to ORAU-OTIB-0049. 

Each of the 4,865 identified claims would require a new dose reconstruction, unless it can 

be definitively shown that the Probability of Causation (PC) will not increase to 45% or 

greater1 under the maximum possible change in dose. Under ORAUT-OTIB-0049, there 

are two screening criteria that can employed to make this determination. 

Screening Criterion 1 

The effect of OTIB-0049 on changing a compensation decision for previously completed 

dose reconstructions can be evaluated by examining the Probability of Causation (PC) on 

a case by case basis. The use of PC as a screening criterion is based on the fact that the 

dose estimate is mathematically proportional to the Excess Relative Risk (ERR). As 

shown below, the probability of causation is determined directly from the ERR as: 

PC = [ERR/(1+ERR)]*100% 

From this equation, it can be seen that an ERR of 1.0 would result in a PC of 50% and an 

ERR of 0.818 would result in a PC of 45%. It can also be seen that, for a given case, the 

effect on PC of a known increase or decrease in dose can be mathematically determined 

using only the original PC and this equation. 

 

1

 A PC of 45% was selected because any claim that could exceed this value would be required to have 30 

IREP runs with 10,000 iterations per run. 
Office of Compensation Analysis and Support

Document Number: OCAS-PER-012 Program Evaluation Plan 

Effective Date: 8/7/2007 Revision No. 0 Page 3 of 6 

 

For ORAUT-OTIB-0049, the effect on dose to the lung and the LN(TH) is dependent on 

factors which can not be evaluated using screening techniques. Because of this, NIOSH 

will request DOL to return for rework those cases in which the lungs or the thoracic 

lymph nodes were the reconstructed organ. For the remaining organs, the effect of 

ORAUT-OTIB-0049, as shown in table 4-5 of the OTIB, is to increase the dose from the 

inhalation of plutonium by a factor of 4. Although the exact effect can only be 

determined on a case by case basis, it is clear that the maximum amount that the dose 

would increase for any of these cases is a factor of four. 

Using the PC equation above, it can be calculated that, ORAUT-OTIB-0049 can not raise 

the PC to 45% if the original PC was at or below 16.97%. Because of this, a PC at or 

below 16.97% is used as a screening criterion to determine which cases can not increase 

to greater than 45% PC when OTIB-0049 is applied. As noted above, this criterion 

does not apply to cases in which the lung or the LN(TH) are the reconstructed 

organ. It also does not apply to cases that are affected by other technical program 

changes. It should also be noted that this is a conservative analysis in that it applies the 

factor of four to all doses, including external dose and internal dose from other isotopes. 

In a revised dose reconstruction, this increase obviously would not be applied to these 

other doses. Therefore, this screening criterion will conservatively identify a population 

of claims larger than the population that will actually have an increase in PC to greater 

than 45%. 

Screening Criterion 2 

An additional screening criterion can be established to eliminate those cases from further 

consideration in which ORAUT-OTIB-0049 will cause no change in the dose estimate. 

Those would be cases in which no plutonium dose was reconstructed or cases in which 

the intake was not estimated using bioassay data2 and the target organ was not lung or 

LN(TH). 

Screening criteria 1 and 2 identified 3,108 cases of the total affected population of 4,865 

that can be definitively identified as remaining below 45% in light of the changes 

required by ORUAT-OTIB-0049. 

3.3 Consideration of other Program Changes 

Some of the claims that would remain below 45% as a result of ORAU-OTIB-0049 may 

be affected by more than one change in methodology. Since claims in this population 

come from a number of sites, there are a number of changes that could affect them. 

Some of these other changes require a new dose estimate to determine the affect on the 

2

 In ORAUT-OTIB-0049, the only plutonium dose calculations that are affected (other than lung and 

thoracic lymph nodes which are being reworked) are those based on bioassay data. Those plutonium doses 

that were determined using air concentration data are not affected by the new Super S calculation. 
Office of Compensation Analysis and Support

Document Number: OCAS-PER-012 Program Evaluation Plan 

Effective Date: 8/7/2007 Revision No. 0 Page 4 of 6 

claim. It is therefore necessary to review each claim to determine if additional changes 

potentially affect the claim. NIOSH will review each of the 3,108 cases and provide 

DOL with a document indicating what changes the claim was reviewed against and why 

none of changes would raise the Probability of Causation above 45%. For any cases 

where it is not possible to provide this document without a new dose estimate, NIOSH 

will request that DOL return the case for a new Dose Reconstruction. 

3.4 Path Forward

DOL will be provided a list of the entire population of potentially affected claims (4,865 

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

to determine the affect of this change. NIOSH is requesting that DOL return these claims 

to NIOSH for a new Dose Reconstruction. NIOSH will review the remaining 3,108 

claims to determine if any other changes also affect the claim. For each of these claims, 

NIOSH will either request the claim be returned for a new Dose Reconstruction, or 

provide DOL with documentation indicating why the changes will not cause the 

Probability of Causation to increase above 45%. 
Office of Compensation Analysis and Support

Document Number: OCAS-PER-012 Program Evaluation Plan 

Effective Date: 8/7/2007 Revision No. 0 Page 5 of 6 

4.0 References 

1. ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0011-5, 

Technical Basis Document for the Rocky Flats Plant – Occupational Internal 

Dose, Rev 00, January 12, 2004. 

2. ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0049, 

Estimating Doses for Plutonium Strongly Retained in the Lung, Rev 00, February 

6, 2007. 
Office of Compensation Analysis and Support

Document Number: OCAS-PER-012 Program Evaluation Plan 

Effective Date: 8/7/2007 Revision No. 0 Page 6 of 6 

Attachment A 

Sites where Type Super S is to be considered or excluded for this PEP 

Consider Super S Exclude from Super S

Albuquerque Operations Office Allied Chemical (based on SEC) 

Amchitka Armour Research Foundation 

ANL-East Baker-Perkins 

ANL-West Bethlehem Steel 

Area IV Santa Susana Bliss & Laughlin Steel 

Battelle (King and/or W. Jefferson) BONUS Reactor 

Brookhaven Bridgeport Brass 

Clarksville BWXT, Inc. 

Conn. Aircraft Nuclear Eng. Lab Canoga Ave Facility 

General Atomics Clinton Eng. Works 

GE-Evendale (Ohio) Combustion Engineering 

GE-Vallecitos De Soto 

Hanford (PNNL) Downey Facility 

INEEL Extrusion Plant (RMI) 

LANL Fernald (FMPC) 

LBNL Harshaw 

LLNL Heppenstall Company 

Mound Iowa Ordinance Plant 

Nevada Site Office Jessop Steel 

NTS K-25 

NUMEC Kansas City Plant 

Pantex Landis Machine Tool Company 

Peek Street Mallinckrodt 

Rocky Flats Medina 

Salmon Nuclear Oak Ridge Hospital 

SLAC ORISE 

Sandia National Lab (SNL) Paducah 

SNL-Livermore Pinellas 

SPRU (Knolls) Portsmouth 

Savannah River Site Reed Rolled Thread Company 

Tonopah Test Site S-50 

West Valley SAM Laboratories, Columbia University 

Westinghouse Nuclear Fuels Division Seymour Specialty Wire 

W.R. Grace Simonds Saw and Steel 

X-10 (ORNL) Superior Steel 

Torrington Company 

U.S. Steel Corporation 

Vitro Manufacturing 

Weldon Spring 

Westinghouse Atomic Power Devel. Plant 

Y-12