J.3_DR_Draft_Mallinckrodt_SEC_11.doc

Covered Employee

Introduction

The Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA), Executive Order No. 13179, and the Radiation Dose Reconstruction Rule

(42 CFR 82)1

EEOICPA established a compensation program to provide a lump sum payment of $150,000 and medical benefits as compensation to covered employees suffering from designated illnesses incurred as a result of their exposure to ionizing radiation, beryllium, or silica while in the performance of duty for the Department of Energy and certain of its vendors, contractors, and subcontractors. This legislation also provided for payment of compensation to certain survivors of these covered employees.

In SEQ CHAPTER \h \r 1Presidential Executive Order No. 13179, the President designated the U.S. Department of Labor to administer this program for claims by current and former employees of nuclear weapons production facilities and their survivors who seek compensation for cancers caused by radiation exposures sustained in the performance of duty. The Executive Order also directed the Department of Health and Human Services to estimate (reconstruct) the radiation doses received by these employees. The Department of Labor uses the reconstructed radiation dose in evaluating whether the employee’s cancer was at least as likely as not related to employment at the facilities covered by EEOICPA. To fulfill the responsibilities assigned to the Department of Health and Human Services, the National Institute for Occupational Safety and Health’s (NIOSH) Division of Compensation Analysis and Support (DCAS) completes dose reconstructions using the methods described in the Radiation Dose Reconstruction Rule (42 CFR 82)1 for the Department of Labor’s use in making compensation decisions.

Option for SEC CLAIMS (If this section is not used, HIGHLIGHT REFERENCE 4 for deletion):

In addition to completing dose reconstructions for claims filed under EEOICPA, NIOSH is also responsible for overseeing the petitioning process for adding classes of employees to the Special Exposure Cohort (SEC). The SEC allows eligible claims to be compensated without the completion of a radiation dose reconstruction or determination of the probability of causation. To qualify for compensation under the SEC, a covered employee must meet the class definition, have worked at the facility for an aggregate of 250 days, and have one of the 22 specified cancers, which include (with some exceptions) the following cancers: bone, renal, leukemia, lung, multiple myeloma, lymphomas, bile ducts, brain, breast (male and female), colon, esophagus, gall bladder, liver, ovary, pancreas, pharynx, salivary glands, small intestine, stomach, thyroid, and urinary bladder. For claims in which the energy employee worked at the facility but did not meet the above SEC criteria for compensation, a partial dose reconstruction will be completed. The petitioning process is described in the SEC Rule (42 CFR 83).4 The Purpose of Radiation Dose Reconstruction

A radiation dose reconstruction is used to estimate the radiation dose received by the specific organ(s) in which a worker developed cancer, particularly when radiation monitoring data are unavailable, incomplete, or of poor quality. Even in instances when radiation dosimetry data are available, they rarely specify dose to an organ and often are based on monitoring procedures that do not meet modern standards.

The basic principle of dose reconstruction is to characterize the occupational radiation environment to which a worker was exposed using available worker and/or workplace monitoring information. In cases where radiation exposures in the workplace environment cannot be fully characterized based on available data, default values based on reasonable scientific assumptions are used as substitutes.

EEOICPA recognized that the process of estimating radiation doses would require dealing with uncertainties and limited data and thus required that the government establish methods for arriving at reasonable estimates of radiation dose received by an individual who was not monitored or inadequately monitored for exposures to radiation, or for whom exposure records are missing or incomplete. To the extent that the science and data involve uncertainties, these uncertainties are typically handled to the advantage, rather than to the detriment, of the claimant. NIOSH has used the best available science to develop the methods and guidelines for dose reconstruction. These methods have been reviewed and commented upon by the public, including experts in the field of dose reconstruction, and the Presidentially-appointed Advisory Board on Radiation and Worker Health.

How Radiation Doses Are Reconstructed

NIOSH reconstructs radiation doses by evaluating all available, appropriate data relevant to the employee’s radiation exposure. Some examples of data that may be included in the dose reconstruction include, but are not limited to, internal dosimetry (such as results from urinalysis), external dosimetry data (such as film badge readings), workplace monitoring data (such as air sample results), workplace characterization data (such as type and amount of radioactive material processed), and descriptions of the type of work performed at the work location.3 Although the specific methods used for each dose reconstruction may vary, after a claim has been referred by the Department of Labor to NIOSH for a dose reconstruction, NIOSH typically requests the worker’s personal radiation monitoring information from the Department of Energy. Upon receipt of the requested information, at least one voluntary informational interview with the claimant and/or survivors is conducted and a copy of the interview report is sent for review. After all of the necessary and available information is gathered, a dose is estimated, using the methods in the Radiation Dose Reconstruction Rule. After a NIOSH health physicist reviews the information, methods, and results, the claimant receives a draft copy of the dose reconstruction report followed by a concluding interview, during which the claimant can add any additional relevant information that may affect the dose reconstruction. If the claimant certifies that he/she has completed providing information and that the record for dose reconstruction should be closed, a final dose reconstruction report is sent to the claimant, the Department of Labor, and the Department of Energy.

As applied in the EEOICPA, dose reconstructions must rely on information that can be developed on a timely basis and on carefully stated assumptions. Therefore, the guiding principle in conducting these dose reconstructions is to ensure that the assumptions used are fair, consistent, and well-grounded in the best available science, while ensuring that uncertainties in the science and data are handled to the advantage, rather than to the detriment, of the claim when feasible. When dose information is not available, is very limited, or the dose of record is very low, NIOSH may use the highest reasonably possible radiation dose, based on reliable science, documented experience, and relevant data, to complete a claimant’s dose reconstruction. In other instances, NIOSH may not need to complete fully a dose reconstruction because a partial dose reconstruction results in an estimated dose which produces a probability of causation of 50% or greater.

How Radiation Dose Reconstructions Are Used in Final Compensation Determinations

The results of an employee’s dose reconstruction are used by the Department of Labor to determine the probability that a worker’s cancer was “at least as likely as not” due to his/her occupational exposure to ionizing radiation during employment at a covered facility. Criteria and guidelines for making this determination are established by EEOICPA and the Probability of Causation Guidelines (42 CFR 81).2 The dose reconstruction is not the final determination of a claim, but rather an interim product that is used by the Department of Labor in making its final decision. Final determinations are made by the Department of Labor based on standards determined by EEOICPA and its implementing regulations.

Dose Reconstruction Overview

NOTE TO DOSE RECONSTRUCTORS: In the dose reconstruction below, please DELETE ALL THE NOTES TO THE DR (like this one, and usually in yellow) prior to sending in the draft DR. This includes the Reference Section.

NOTE TO DOSE RECONSTRUCTORS for information downtown site in TKBS-0005 Rev. 03: Scope of covered period (1942 through 1962, and remediation in 1995) and SEC -pages 11-12 and Tables 1-1 and 1-2; Internal dose 1949-58 - Section 6; External dose 1949-58 - Section 7; X-rays should not be included - Section 7.4.1; Exposure for 1959-62- Sections 8.0 and 8.5, and Tables A-40 and A-41; Section 8.5 describes the use of Table A-40 and the resulting dose is assigned as a constant distribution per Section 8.4.3; Section 8.5 describes the use of Table A-41 (organ DCFs already applied per footnote) and per 8.4.4 dose is assigned as a triangular distribution.

NOTE TO DOSE RECONSTRUCTORS FOR SEC CLAIMS: The Overview and Summary sections should NOT refer to the dose reconstruction as being an overestimate because we are reconstructing only part of the dose even though the parts we do reconstruct may be overestimates.

<Overview Option A: For Overestimate, Non-Compensable (CANNOT BE USED FOR SEC)> The Division of Compensation Analysis and Support has performed a dose reconstruction for FirstName M. LastName in accordance with the applicable requirements of the Energy Employees Occupational Illness Compensation Program Act. Information provided by the Department of Labor (DOL) indicates that Mr. Lastname worked at the Mallinckrodt Chemical Company (Destrehan Street Plant), <Option> and the <LIST OTHER SITE NAMES HERE> and that he was diagnosed with cancer, as shown in the tables below.

<Diagnosis dates prefixes c1, c2, etc., are only for ease of global replacement of dates. DO NOT LEAVE THEM IN TABLES.>

The Mallinckrodt Chemical Company is covered under the Energy Employees Occupational Illness Compensation Program Act for 1942 through 1962, and for remediation in 1995.10 This dose reconstruction was performed for the period Date 1 through Date 2. The listed employment after 1962 (with the exception of 1995, if applicable) at Mallinckrodt was not considered because it is not covered under the Energy Employees Occupational Illness Compensation Program Act.1 Mr. Lastname’s radiation exposure was received during employment as a/an <jobtitle> according to records obtained from the Department of Labor and/or information provided in the interview process. To process this claim, the radiation dose assigned was overestimated using efficiency measures. Claimant-favorable assumptions related to radiation exposure and intakes were applied, based on current science, documented experience, and relevant data. Mr. Lastname’s dose reconstructed under the Energy Employees Occupational Illness Compensation Program Act of 2000 was to the <organ>. The dose was calculated to the organ9 associated with the specified cancer. Throughout the report where the cancer is mentioned, it should be noted that the dose is always assigned to the associated organ.9 <For secondary cancers> This is a secondary cancer with an unknown primary site. According to 42 CFR 81.23, if a primary site is not known, then the potential primary sites should be evaluated. Potential primary sites for this cancer type are the lung, esophagus, stomach, upper large intestine, prostate, and pancreas.9 The reconstructed dose to the <organ> was calculated to be as shown in the table below. <For respiratory-tract cancers, include a separate column for radon dose (in WLMs, if applicable, etc.).>

Even under these assumptions, NIOSH has determined that further research and analysis will not produce a level of radiation dose resulting in a probability of causation of 50% or greater.

In accordance with 42 CFR § 82.10(k),1 NIOSH has determined that sufficient research and analysis have been conducted to consider this dose reconstruction complete. Per the requirements of 42 CFR § 82.10(j),1 only the dose incurred up to the point of cancer diagnosis was included in this dose reconstruction.

If the facts surrounding this dose reconstruction change (e.g., the date of diagnosis is modified, an additional covered cancer is diagnosed, or additional covered employment is identified), the efficiency measures used to reconstruct the dose may not be applicable. In this case, if the facts were to change, the dose reconstructed for the <Cancer Type> could be lower than that reported using the efficiency process.

<Overview Option B: Partial Dose Reconstruction/Underestimate, Compensable> The Division of Compensation Analysis and Support has performed a dose reconstruction for FirstName M. LastName in accordance with the applicable requirements of the Energy Employees Occupational Illness Compensation Program Act. The Department of Labor (DOL) has indicated that Mr. Lastname worked at the Mallinckrodt Chemical Company (Destrehan Street Plant), <Option> and the <LIST OTHER SITE NAMES HERE> and was diagnosed with cancer, as shown in the tables below.

<Diagnosis dates prefixes c1, c2, etc., are only for ease of global replacement of dates. DO NOT LEAVE THEM IN TABLES.>

The Mallinckrodt Chemical Company is covered under the Energy Employees Occupational Illness Compensation Program Act for 1942 through 1962, and for remediation in 1995.10 This dose reconstruction was performed for the period Date 1 through Date 2. The listed employment after 1962 (with the exception of 1995, if applicable) at Mallinckrodt was not considered because it is not covered under the Energy Employees Occupational Illness Compensation Program Act.1

According to dosimetry records obtained from the Department of Energy, the majority of Mr. Lastname’s radiation exposure was received during employment as a/an <jobtitle>. Mr. Lastname’s <internal / external> dose reconstructed under the Energy Employees Occupational Illness Compensation Program Act of 2000 was to the <organ>. The dose was calculated to the organ9 associated with the specified cancer. Throughout the report where the cancer is mentioned, it should be noted that the dose is always assigned to the associated organ.9 <For secondary cancers> This is a secondary cancer with an unknown primary site. According to 42 CFR 81.23, if a primary site is not known, then the potential primary sites should be evaluated. Potential primary sites for this cancer type are the lung, esophagus, stomach, upper large intestine, prostate, and pancreas.9 The reconstructed dose to the <organ> was calculated to be as shown in the table below. <For respiratory-tract cancers, include a separate column for radon dose (in WLMs, if applicable, etc.).>

To expedite this claim, only a portion of the <internal / external> dose has been included in this dose reconstruction. Per the provisions in 42 CFR § 82.10(k)(l),1 it was determined that the reported <internal / external> dose was of sufficient magnitude to consider the dose reconstruction complete. That is, the assigned <internal / external> dose produces a probability of causation of 50% or greater. Thus, the <Cancer Type> dose reported is an underestimate of Mr. Lastname’s total occupational radiation dose. Per the requirements of 42 CFR § 82.10(j),1 only the dose incurred up to the point of cancer diagnosis was included in this dose reconstruction. The results of this dose reconstruction will be used by the Department of Labor to determine eligibility for compensation.

<Overview Option C: For SEC Non-Compensable> The Division of Compensation Analysis and Support has performed a dose reconstruction for FirstName M. LastName in accordance with the applicable requirements of the Energy Employees Occupational Illness Compensation Program Act. Information provided by the Department of Labor (DOL) indicates that Mr. Lastname worked as a/an <jobtitle> at the Mallinckrodt Chemical Company (Destrehan Street Plant), <Option> and the <LIST OTHER SITE NAMES HERE> and that he was diagnosed with cancer, as shown in the tables below.

Weldon Spring Plant

<Diagnosis dates prefixes c1, c2, etc., are only for ease of global replacement of dates. DO NOT LEAVE THEM IN TABLES.>

The Mallinckrodt Chemical Company is covered under the Energy Employees Occupational Illness Compensation Program Act for 1942 through 1962, and for remediation in 1995.10 This dose reconstruction was performed for the period Date 1 through Date 2. The listed employment after 1962 (with the exception of 1995, if applicable) at Mallinckrodt was not considered because it is not covered under the Energy Employees Occupational Illness Compensation Program Act.1 <Option for WSP employment> The Weldon Spring Plant is covered under the EEOICPA from 1955–1966 (operational period) and October 1, 1985, to 2002 (remediation period).18 This dose reconstruction was performed for Mr. Lastname’s entire employment period at both sites.

Mr. Lastname’s dose reconstructed under the Energy Employees Occupational Illness Compensation Program Act of 2000 was to the <organ>. The dose was calculated to the organ9 associated with the specified cancer. Throughout the report where the cancer is mentioned, it should be noted that the dose is always assigned to the associated organ.9 <For secondary cancers> This is a secondary cancer with an unknown primary site. According to 42 CFR 81.23, if a primary site is not known, then the potential primary sites should be evaluated. Potential primary sites for this cancer type are the lung, esophagus, stomach, upper large intestine, prostate, and pancreas.9 The reconstructed dose to the <organ> was calculated to be as shown in the table below. (For respiratory-tract cancers, include a separate column for radon dose (in WLMs, if applicable, etc.).

Mr. Lastname’s occupational radiation dose was reconstructed based on current science, documented experience, and relevant data. Under these assumptions, NIOSH has determined that further research and analysis will not produce a level of radiation dose resulting in a probability of causation of 50% or greater. Per the requirements of 42 CFR § 82.10(j),1 only the dose incurred up to the point of cancer diagnosis was included in this assessment. In accordance with 42 CFR § 82.10(k),1 NIOSH has determined that sufficient research and analysis have been conducted to consider this dose reconstruction complete.

Dose Reconstruction Revision Overview

<REVISION TEXT: ADJUST BASED ON WHAT WAS REVISED. IN ADDITION, TEXT SHOULD BE ADDED TO EACH SECTION AFFECTED. TEXT HERE SHOULD JUST BE A SUMMARY OF WHAT WAS CHANGED.> This dose reconstruction was revised for the following reasons:

· Revision to the organ used to calculate internal/external dose, as discussed in the Internal and External Dose section<s> of this report.

· Revision to the Technical Basis Document for the Mallinckrodt Chemical Company.10 This is discussed in the<Delete those not appropriate.> Dosimeter Dose, Missed Dose, Occupational Medical Dose, and Internal Dose section<s> of this report.

· Addition of the Technical Information Bulletin: Guidance on Assigning Occupational X-Ray Dose under EEOICPA for X-Rays Administered Off Site.7 This is discussed in the Occupational Medical Dose section of this report.

· Additional information provided in the telephone interview, as discussed in the Dose from Radiological Incidents section of this report.

· Change in employment and/or cancer information, as discussed in the Dose Reconstruction Overview section of this report.

· Use of more realistic efficiency/best estimate methods instead of gross overestimates. This is discussed in the <Delete those not appropriate.> Dosimeter Dose, Missed Dose, Occupational Medical Dose, and Internal Dose section<s> of this report.

These modifications have resulted in the following changes in dose (measured in rem).

<NOTE: MAKE SURE THE NUMBERS ENTERED IN THE PREVIOUS DOSE COLUMN ARE FROM THE LAST REPORT SUBMITTED TO THE CLAIMANT, NOT THE LAST REPORT SUBMITTED TO DCAS.>

(includes dosimeter, missed,* and unmonitored)

CANCER 6

c6-mm/dd/yyyy

*In the previous revision, the missed dose may have been reported at the 95% level. However, current reporting practices are to report the missed dose at the mean.

Information Used

<Option A: NON-SEC Claims or if dosimetry records exist and are used)> During this dose reconstruction, the primary data source was the dosimetry records obtained from the Department of Energy (DOE). In addition, specific parameters to the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site10 <Option for WSP employment> and the Technical Basis Document for the Weldon Spring Plant – Occupational External Dosimetry15 were applied to the dosimetry records in order to assign organ dose in accordance with the Internal Dose Reconstruction Implementation Guideline,6 the External Dose Reconstruction Implementation Guideline (Revision 3),5 and the Technical Information Bulletin: Internal Dose Reconstruction.12

<Option B: SEC claims> A class of employees from Mr. Lastname’s place of employment, the Mallinckrodt Chemical Company, has been added to the Special Exposure Cohort (SEC). DOL has determined Mr. Lastname’s claim did not meet the criteria for automatic compensation under the SEC for at least one cancer. Therefore, NIOSH was required to conduct a partial dose reconstruction for this claim. As a result of the SEC class for the Mallinckrodt Chemical Company, NIOSH has determined, and the Secretary of Health and Human Services has concurred, that maximum exposure cannot be determined for all doses through 1948, and for doses due to pitchblende raffinate (thorium-230, actinium-227, and protactinium-231) through 1958. Doses at the Mallinckrodt Chemical Company, within the Uranium Division, cannot be completely reconstructed from 1942 through 1958, inclusive, for the energy employee.10 <Option for Lung Cancers> For lung cancer claims, smoking history is necessary to determine the probability of causation.2 The covered employee was reported to have never smoked <OR> be a former smoker <OR> be a current smoker (#–# cigarettes per day) at the time of cancer diagnosis by the NIOSH Referral Summary.

<Option for Skin Cancers> For skin cancer claims, ethnicity is necessary to determine the probability of causation.2 The covered employee was reported to be “white, non-Hispanic” <OR> “white, Hispanic” <OR> “black” <OR> “Asian or Native Hawaiian or other Pacific Islander”<OR> “American Indian or Alaska Native” according to the NIOSH Referral Summary.

<CATI Option: Available> In addition to the above information, the record of the computer assisted telephone interview was reviewed carefully by the dose reconstructor. The information provided was considered in the dose estimation process. Additional information on the evaluation of the interview is provided in subsequent sections of this report, as applicable.

<CATI Option: Unavailable> In conjunction with the above information, a voluntary computer assisted telephone interview is part of the dose reconstruction process. It should be noted, however, that NIOSH was unsuccessful in its attempts to gather further information by means of an interview. Therefore, no additional information affecting the dose reconstruction was identified.

Dose Estimate

External Dose External dose is received from radiation originating outside the body and is typically measured by dosimetry worn on the body. Radiation dose measured on a film badge or a thermoluminescent dosimeter (TLD) may have been delivered quickly (acute exposure) or slowly over the period of time that the employee was exposed (chronic exposure). [OPTION A] External dose records received from the Department of Energy were reviewed and found to be sufficient for the external dose reconstruction. [OPTION B] Information provided by the Department of Energy indicates Mr. Lastname was not monitored for external radiation exposure, or that radiation monitoring records for Mr. Lastname do not exist. [OPTION C] External dose records provided by the Department of Energy were reviewed and found to be sufficient for the external dose reconstruction, except for [LIST PERIODS]. Records for the aforementioned periods did not exist. <OR> Records for the aforementioned periods show Mr. Lastname was not monitored.

<Add paragraph on work location and potential exposures (i.e., photon, neutron, and/or electron). Discuss how any gaps in the dosimetry data were addressed.> Mr. Lastname worked as a/an job title, primarily in the XXXX facility/facilities (SUPPLEMENT TEXT IN PRECEDING SENTENCE WITH DATES/TIME FRAMES AS APPROPRIATE), according to records received from the Department of Labor and/or information provided in the interview process. Mr. Lastname’s primary exposure would have been to photons and electrons, with some potential for neutrons. <OPTIONAL ELECTRON WORDING> Electron radiation would not have penetrated to the <organ> and therefore has not been considered in this dose reconstruction.

<External Dose Option 3: SEC claims and no external monitoring data> Because no radiation exposure monitoring data were available for Mr. Lastname, <doses were based on surrogate data from workers with similar job titles.> <OR> <and no estimation techniques can be employed to derive a radiation dose for his <Cancer Type>, no external dose has been assigned.> External doses were assigned for <specify time frame dose was assigned> using claimant-favorable assumptions based on information provided in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri.10 Max (Photon/Neutron) – Exposure (1968 to 1969)

*Not applicable

NEUTRON OPTIONS

<OPTION to include neutron dose based on work areas, unless there is an indication that there was no potential for neutron exposure.> Neutron doses at the Mallinckrodt Chemical Company are based on the application of a neutron-to-photon ratio to the photon dose.10 Neutron doses were included in this dose reconstruction based on information presented in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri.10 and information in Mr. Lastname’s radiation monitoring records which indicates duties that might have required work in areas where there was a potential for exposure to neutron radiation.

<Unmonitored Neutron Option (choose ratio used)> Unmonitored neutron doses were calculated based on information provided in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri.10 The 95th percentile/geometric mean neutron-to-photon ratio was applied to the measured and missed <OR> surrogate photon doses to determine the unmonitored neutron dose.

<OPTION (strong indication NOT to include neutron dose>

Though Mr. Lastname worked in the XXXX facility/facilities, based on his job title and information in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri,10 <Option for WSP employment> and the Technical Basis Document for the Weldon Spring Plant – Occupational External Dosimetry,15 his duties would not have required him to work in areas where there was a potential for exposure to neutron radiation. Therefore, neutron doses were not included in this dose reconstruction.

Option 1: If surrogate is NOT needed The external dose to the <organ> was calculated using the model for that organ.9 Option 2: If surrogate organ was used The external dose to the <organ> was determined by using the dose calculated for the <modeled organ>.9 <Optional Text for Remainder Organ> The “remainder organ” is a non-specific organ created by the ICRP, which incorporates all those tissues that do not have their own dedicated ICRP organ models, or are not themselves organs (i.e., ligaments, tendons, etc.).

For the purpose of estimating probability of causation, all photon and electron doses are assumed to be acute and all neutron doses are assumed to be chronic.5 Dosimetry results of Mr. Lastname that were less than half the stated limit of detection (LOD) listed in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri10 <Option for WSP employment> and the Technical Basis Document for the Weldon Spring Plant – Occupational External Dosimetry15 have been treated as missed dose in accordance with the External Dose Reconstruction Implementation Guideline.5 NOTE: For SEC claims and partial dose estimates, the Radiation Type, Dosimeter Dose, and missed dose sections should be DELETED if they are NOT APPLICABLE.

Radiation Type, Energy, and Exposure Geometry

Remove the DCF verbiage if doses are assigned from Table A-41 and/or A-42 when no additional DCF applied from the tool. For the assignment of measured and missed dose, organ dose conversion factors (DCFs) of 1.251 for photons and 1.000 for neutrons was/were applied. In accordance with information provided in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri,10 <Option for WSP employment> and the Technical Basis Document for the Weldon Spring Plant – Occupational External Dosimetry,15 a photon energy range of 100% 30–250 keV was applied. A neutron energy range of 0.1 – 2 MeV was used.10 <Option to include> In addition, a geometry-based correction factor of 2.1 for dose to the lower torso was applied to the photon and neutron doses.11

<SHALLOW DOSE> Additionally, shallow dose was assigned as electrons with an energy range of 100% >15 keV.

<Option: Best Estimate (Monte Carlo, Vose) DO NOT USE for OTIB_0017> The organ DCF is the mode of the distribution listed in the External Dose Reconstruction Implementation Guideline5 that has been applied to the recorded and missed doses according to the methodology described in the Technical Information Bulletin: Monte Carlo Methods for Dose Uncertainty Calculations.14 The geometric mean of the neutron-to-photon ratio was applied to neutron doses.10,14 Dosimeter Dose

Individual dosimeter results were used to reconstruct Mr. Lastname’s dose. Corrections to the reported doses were applied as described above.

<OTIB-0017 Option for Skin Cancer> Corrections to the reported shallow doses were applied in accordance with the Technical Information Bulletin: Interpretation of Dosimetry Data for Assignment of Shallow Dose.8 The electron dose was assumed to be the difference between the reported deep and shallow doses from Mr. Lastname’s Radiological Exposure Individual Dosimeter History document. A dose conversion factor of 1.000 was used for all dosimeter doses applied in this dose reconstruction.8 <Option 1: No Attenuation.> A reduction of the electron dose due to attenuation from clothing was not applied because the skin cancers evaluated in this dose reconstruction were diagnosed in locations in which the skin would not normally be covered. <Option 2: Minimizing Attenuation from clothing.> A 60% reduction of the electron dose due to attenuation from clothing was applied. The 60% value was derived from an analysis of uranium attenuation factors for clothing8 and is the lowest value that could reasonably be considered applicable to Mr. Lastname based on his work description. <Option 3: Best Estimate Attenuation from clothing.> For the skin of the <location>, the calculated electron doses were multiplied by 0.855, which represents the midpoint of the uranium attenuation factors reported for two pairs of coveralls, including the paper liner (0.80) and one Dacron/cotton lab coat (0.91).8 Because the specific clothing worn by Mr. Lastname could not be determined, the approach adopted is considered reasonable. <Modify or eliminate sections of the above paragraph as necessary.> <OTIB-0017 Option for Breast Cancer> Corrections to the reported shallow doses were applied in accordance with the Technical Information Bulletin: Interpretation of Dosimetry Data for Assignment of Shallow Dose.8 The low energy dose was assumed to be the difference between the reported deep and shallow doses from Mr. Lastname’s Radiological Exposure Individual Dosimeter History document. <Option 1: <30 keV photon for Non-comp for max PC.> As noted earlier, the shallow dose was applied in this dose reconstruction as <30 keV photons (which are more claimant-favorable than electrons) as the non-penetrating dose component.8 A dose conversion factor of 0.796 was used for the <30 keV photon doses applied to the breast in this dose reconstruction <Option 2A: Non-comp. electrons> A claimant-favorable factor of 0.3 was applied to the electron skin dose to account for attenuation by clothing and the different depth of the sensitive cells of the breast tissue.8 <Option 2B: Comp. electrons> Electron skin dose was not assigned, so no adjustments were needed to account for attenuation by clothing and the different depth of the sensitive cells of the breast tissue.8

<OTIB-0017: Option for Testes, Penis, and Lip Cancer> Corrections to the reported shallow doses were applied in accordance with the Technical Information Bulletin: Interpretation of Dosimetry Data for Assignment of Shallow Dose.8 The low energy dose was assumed to be the difference between the reported deep and shallow doses from Mr. Lastname’s Radiological Exposure Individual Dosimeter History document. A dose conversion factor of 1.000 was used for all dosimeter doses applied in this dose reconstruction.8 <Option 1: <30 keV photon for Non-comp for max PC.> As noted earlier, the shallow dose was applied in this dose reconstruction as <30 keV photons (which are more claimant-favorable than electrons) as the non-penetrating dose component.8 <Option 2A: Non-comp. electrons for testes and penis> A claimant-favorable factor of 0.3 was applied to the electron skin dose to account for attenuation by clothing and the different depth of the sensitive cells of the tissue.8 <Option 2B: Comp. electrons for testes and penis> Electron skin dose was not assigned, so no adjustments were needed to account for attenuation by clothing and the different depth of the sensitive cells of the tissue.8 <Option 2C: Non-comp. electrons for lip> A claimant-favorable factor of 3.6 was applied to the electron skin dose to account for the different depth of the sensitive cells of the tissue.8 <Option 2D: Comp. electrons for lip> No adjustment factor was applied to the electron skin dose to account for the different depth of the sensitive cells of the tissue.8 The total dosimeter dose assigned for Mr. Lastname is shown in the following table.

<Revision text when neutron-to-photon ratio of 0.23:1 was used instead of 0.20:1> The neutron dose assignment increased due to the application of the 95th percentile of the neutron-to-photon ratio rather than the geometric mean.

<External Dose Option: Partial, underestimate> External dose records received from the Department of Energy were reviewed and found to be sufficient for the external dose reconstruction. However, in accordance with the provisions of 42 CFR § 82.10(k)(1),1 it was determined that the estimation of dose described elsewhere in this report was sufficient to consider the dose reconstruction complete. Because of this, external dose was not reconstructed.

<External Dose Option: Partial, underestimate: records not sufficient> Records received from the Department of Energy were reviewed and did not include monitoring records for Mr. Lastname. However, in accordance with the provisions of 42 CFR § 82.10(k)(1),1 it was determined that the estimation of dose described elsewhere in this report was sufficient to consider the dose reconstruction complete. Because of this, external dose was not reconstructed.

<Revision text when previous assessment did not include external doses prior to 1949> Previously, external doses were not assigned, since Mr. Lastname’s employment was prior to 1949. However, based on changes to the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri,10 and because Mr. Lastname had external monitoring records for his employment in <specify applicable years>, external doses were assigned in this dose reconstruction, resulting in an increased dose. NOTE TO DRS: Neutrons are not assigned prior to 1949.

<Revision text when previous assessment did not apply LOD/2 approach> In the revised dose reconstruction, recorded external dosimeter results for Mr. Lastname that were less than half the limit of detection have been treated as missed dose in accordance with the External Dose Reconstruction Implementation Guideline.5 This resulted in a decrease in the assigned measured dose and an increase in the assigned number of zeros used to calculate missed dose.

<Revised dose LOD/2 – Monte Carlo Option> This change affects the total photon dose and the number of zeros assigned for missed dose.

The change in the number of zeros causes a change in the total error used in the Monte Carlo calculations which affects the dose distribution types.14 These differences had a net effect of slightly decreasing the external dose total and slightly increasing the missed dose.

Unmonitored External Dose

During the extended periods that Mr. Lastname was on site and not monitored <and/or> dosimetry results were unavailable (i.e., indicate the year applied), external doses were assigned based on surrogate data from workers with similar job titles, as discussed in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri.10 <Discuss and/or reference tables used, basis for assignment (low, moderate, high category) <Example Option to include:> Although Mr. Lastname’s potential for radiation exposure was low, photon and electron radiation has been assigned using information described in Tables A-41 and A-42 «specify here assuming a <low, moderate, high> category» of the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri.10 These doses were applied to ensure that a claimant-favorable external dose was assigned. Specify if doses were prorated to actual employment or full years of exposure assumed.

The assigned unmonitored doses are shown in the table below.

<Option to include if dose has decreased due to prorating> Previously, full years of exposure were assumed in the assignment of external doses. External doses were prorated to Mr. Lastname’s actual employment in this dose reconstruction, resulting in a reduction of dose.

<OR, if Compensable without external unmonitored dose> In accordance with the provisions of 42 CFR §82.10(k)(1),1 it was determined that the estimation of other sources of dose was sufficient to consider the dose reconstruction complete. Because of this, the external coworker dose was not reconstructed.

Missed Dose

In accordance with the NIOSH External Dose Reconstruction Implementation Guideline,5 a potential missed dose was assigned to each zero dosimeter reading to provide a claimant-favorable estimate of the potential external doses received by Mr. Lastname. A missed dose represents the dose that could have been received but may not have been recorded due to the dosimeter detection limits or site reporting practices.

[DELETE THIS PARAGRAPH FOR OTIB-0017 CANCERS]

Throughout his employment at the Mallinckrodt Chemical Company,10 <Option for WSP employment> and the Weldon Spring Plant,15 Mr. Lastname was typically on a <weekly/biweekly/monthly/varying> dosimeter change-out schedule. The total number of zero dosimeter readings assigned was 0 for photons. This number was selected to ensure that all possible instances of a zero badge reading were accounted for in this dose reconstruction. Neutron missed dose is based on the application of a neutron-to-photon ratio to the photon missed dose. Based on information provided in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri10 <Option for WSP employment> and the Technical Basis Document for the Weldon Spring Plant – Occupational External Dosimetry15 and per the requirements of the External Dose Reconstruction Implementation Guideline,5 missed dose was assigned based on the dosimeter’s limit of detection.

<For OTIB-0017 Cancers (Skin and BTPL)> In the determination of the non-penetrating dose, for any badge cycle with a combination of zeros in any of the non-penetrating and penetrating doses, a single missed dose was assigned for each cycle according to the information provided in the Technical Information Bulletin: Interpretation of Dosimetry Data for Assignment of Shallow Dose.8

Based on information provided in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri10 <Option for WSP employment> and the Technical Basis Document for the Weldon Spring Plant – Occupational External Dosimetry15 and per the requirements of the External Dose Reconstruction Implementation Guideline,5 missed dose was assigned based on the dosimeter’s limit of detection.

<For All Cancers> Per the requirements of the External Dose Reconstruction Implementation Guideline,5 this results in a potential missed dose for Mr. Lastname as shown in the following table.

<Revision to Missed dose> The missed dose in this revision decreased from the previously assigned missed dose based on changes in the application of the DCF or uncertainty multiplier (as described above) and a decrease in the estimated number of zeros (changes from an overestimating approach to a claimant-favorable approach/best estimate approach). <ADJUST TEXT TO ACCURATELY DESCRIBE WHAT CHANGED> <Missed Dose Option 1: Underestimate> Potential missed doses were not evaluated for this dose reconstruction. While the omission of this dose results in an underestimate of Mr. Lastname’s total occupational dose, this additional dose is considered unnecessary for determination of this claim, per the provisions in 42 CFR § 82.10(k)(l).1

Occupational Medical Dose

NOTE TO DR: Do not include X-rays for downtown site (Destrehan Street Plant) per TBD Section 7.4.1, but include X-rays for SLAPS per Section 9.0 and WSP X-rays per TBD guidance.

<Medical X-Ray Option 1: Underestimate for SLAPS or WSP> Doses from occupational X-rays were not estimated or included in this dose reconstruction. While the omission of this dose results in an underestimate of Mr. Lastname’s total occupational dose, this additional dose is considered unnecessary for determination of this claim, per the provisions in 42 CFR § 82.10(k)(l).1

<Medical X-Ray Option 2> In addition to the estimated dose received from site operations, the dose Mr. Lastname received from diagnostic X-ray procedures <possibly> [DELETE “POSSIBLY” IF BEST ESTIMATE] required as a condition of employment was also evaluated/included in the overall dose to the <organ>, as modeled by the <organ>. The total occupational medical dose was evaluated/assigned based on information in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri,10 <Option for WSP employment> the Technical Basis Document for the Weldon Spring Plant – Occupational Medical Dose,16 the Technical Information Bulletin: Guidance on Assigning Occupational X-Ray Dose under EEOICPA for X-Rays Administered Off Site,7 and the X-ray types and frequencies present in Mr. Lastname’s radiographic records <SLAPS only> that were appropriate for assignment. <OR> <SLAPS or Mallinckrodt> No medical X-rays were found that were appropriate for assignment.> <Medical X-Ray Option 3> Based on the most current information in the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri10 and the Technical Information Bulletin: Guidance on Assigning Occupational X-Ray Dose under EEOICPA for X-Rays Administered Off Site,7 dose from medical X-ray examinations were not included in this dose reconstruction.

<If Applicable> The assigned occupational medical X-rays are shown in the following table.

<Revision to X-Ray Dose> Previously, annual lateral and posterior-anterior chest X-rays were assumed to occur. The X-ray dose was revised from the overestimating assumption of annual X-rays to only X-rays recorded in Mr. Lastname’s DOE record, that were appropriate for assignment. <OR> The X-ray dose was revised from the previous version due to the implementation of the Technical Information Bulletin: Guidance on Assigning Occupational X-Ray Dose under EEOICPA for X-Rays Administered Off Site7 and revisions to the Technical Basis Document: Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri.10 This resulted in a decrease of the total occupational medical dose assigned.

<OR, if Compensable without X-Rays> In accordance with the provisions of 42 CFR §82.10(k)(1),1 it was determined that the estimation of other sources of dose was sufficient to consider the dose reconstruction complete. Because of this, the occupational medical dose was not reconstructed.

On-Site Ambient Dose<Option for WSP employment>

Because Mr. Lastname was monitored for ionizing radiation doses during his employment at the Mallinckrodt Chemical Company (Destrehan Street Plant) and the Weldon Spring Plant from <LIST PERIODS>19XX–19XX, 19XX, and because missed doses were assigned from <LIST PERIODS>19XX–19XX, 19XX, as discussed above, on-site ambient doses were not assessed as part of this dose reconstruction in accordance with the procedure, Occupational On-Site Ambient Dose Reconstruction for DOE Sites.19 However, because no monitoring records were available in <LIST PERIODS>19XX–19XX, 19XX for Mr.