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VI. Findings Related to Other Issues
Pages 231-256

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From page 231...
... Many of the methods used to estimate doses are not discussed at all, nor are the methods that are used to estimate upper bounds. Details of the reconstruction methods are neither discussed nor referenced in the SOPs.i iSome procedures are reported in unit dose reports, specialized reports (for example, Banks et al., 1959; Barss, 2000; Egbert et al., 1985; Barrett et al., 1986; Goetz et al., 1991)
From page 232...
... Dose reconstructions by different analysts for similar scenarios often referenced different internal memoranda or reports for the same method. 2For example, in a letter to DTRA, the committee requested documentation regarding the use of a lower upper-bound estimate of external dose for participants who boarded target ships during Operation CROSSROADS than given in the unit dose report (Weitz et al., 1982)
From page 233...
... In case #88, the dose memorandum and a letter in the file from the NTPR program to the veteran give the dose as 1.0 rem, but the SAIC database lists the total external dose as 1.8 rem, with no upper bound; according to the referenced exposure scenario, if the veteran is given the benefit of the doubt and is assumed to have been in an armored personnel carrier rather than a tank during a maneuver, his dose would have been 1.7 rem with an upper bound of 2.7 rem. Published reports of the NTPR program did not indicate that they had been subjected to peer review.
From page 234...
... , it is assumed that the entire whole body external gamma dose was deposited in the basal cell layer for upper bounding." That statement illustrates a misunderstanding or misuse of the quantity "dose." The committee is of the opinion that those inexact statements would have been identified in a peer review. 5Examples include calculations for combining film-badge data, applying unit dose reconstructions, assessing internal dose, and assigning uncertainty or upper bounds.
From page 235...
... program, or that contain copies of all internal NTPR program procedures memoranda referenced in dose reports. Although the NTPR program (Schaeffer, 2002e)
From page 236...
... VI.B COMMUNICATION WITH ATOMIC VETERANS As discussed in Section III.B, communication with an atomic veteran concerning compensation decisions is the primary responsibility of the VA Regional Office (VARO) , which receives dose reports and other correspondence from DTRA.
From page 237...
... VI FINDINGS RELATED TO OTHER ISSUES 237 Over the years, as represented in our sample cases, written communications with veterans or their families were courteous, and doses were reported accurately. When much time had elapsed between letters, which was often the case, suitable apologies were expressed.
From page 238...
... includes the following statement, which is found in a number of such letters in the early to middle 1980s: "An important finding to date is that radiation exposures to the participants were generally quite low." The letter also refers to "the consensus of the medical community" that "the risk of any adverse health effect from exposures such as experienced by nearly all test participants is very, very slight." It is not clear what "consensus" the letter intended to identify. About a year later, a letter from the NTPR program to another veteran (case #58)
From page 239...
... After what seems to have been a series of further contacts, a 1992 letter included then-common language that "radiation exposures to the participants were generally quite low" and that "the consensus of the medical and scientific community is that the risk of any adverse health effect from exposures such as experienced by nearly all test participants is very, very slight." DTRA completed the latest dose report on this veteran on June 20, 2000. The long period of several dose assessments often resulted in letters concerning revised dose reconstructions that could as easily have undermined a veteran's confidence in the process as reinforced it.
From page 240...
... This section discusses the general requirements of a screening method and the low-level internal dose screen developed in the NTPR program. Particular attention is paid to concerns that the atomic veterans have expressed about use of the internal dose screen in dose reconstructions, especially when a veteran files a claim for compensation for a radiation-related disease.
From page 241...
... VI.C.3 Assumptions Used in Internal Dose Screen The methods used to estimate inhalation doses to participant groups for purposes of screening are the same as those described in Section IV.C.2. That is, the same four basic exposure scenarios and the same methods of estimating inhalation dose in each scenario were used in screening.
From page 242...
... Although the NTPR program recognized that selection of the particular organ and value of the dose criterion to be used in screening is arbitrary, bone was selected because of its importance as a site of deposition of many radionuclides, including long-lived alpha emitters, such as plutonium, and the dose criterion was set at 1% of the dose limit for bone in standards for occupational exposure that had been recommended by the National Council on Radiation Protection and Measurements (NCRP, 1971~. VI.C.4 Use of Internal Dose Screen in Dose Reconstructions for Participant Groups In the low-level internal dose screen, the dose criterion of 0.15 rem to bone and the model to estimate inhalation dose in an assumed scenario for a participant group have been used in a dose reconstruction for that group in the following way (Barrett et al., 1986~.
From page 243...
... VI.C.5 Discussion of Low-Level Internal Dose Screen The committee is aware that the atomic veterans have expressed concerns over use of the low-level internal dose screen in dose reconstructions. The essence of the veterans' concerns appears to be that the screening method is a means to avoid having to estimate inhalation doses and that when the screen was used, significant inhalation doses to participants were not taken into account in dose reconstructions.
From page 244...
... With regard to the last point, the veterans have expressed concern, for example, that some participant groups were assumed to be exposed only to suspended neutron-induced activity in soil in the absence of a fallout field, which results in very low inhalation doses relative to external doses, in cases where fallout from prior shots also was present, thus greatly increasing potential doses from inhalation of resuspended plutonium and longer-lived fission products relative to external doses. The committee has carefully considered the veterans' concerns about the low-level internal dose screen.
From page 245...
... . Based on its review of the 99 randomly selected dose reconstructions for individual veterans, the committee has inferred that the low-level internal dose screen, meaning the screening codes assigned to participant groups at the NTS or in the Pacific (Barrett et al., 1986; Goetz et al., 1991)
From page 246...
... In judging the adequacy of an assessment of inhalation dose in the dose reconstruction for an individual veteran, the most relevant questions concern whether the assumed exposure scenario for that person is reasonable, according to knowledge of his activities and the radiation environment in which those activities took place, and whether the models, parameter values, and other assumptions used to estimate inhalation dose in the assumed scenario provide credible upper-bound estimates. If credible upper-bound estimates of inhalation dose have been obtained for a veteran, it is of secondary concern whether the documentation of the dose reconstruction or the letter sent to the veteran summarizing the results includes statements or reported doses that indicate that the low-level internal dose screen may have been used to estimate inhalation dose or may have influenced the calculation.
From page 247...
... It is the committee's understanding that data on the amounts of plutonium in urine samples provided by atomic veterans that have been collected so far have not been used in assessing internal dose in any dose reconstructions. The committee found no evidence to the contrary in its review of dose reconstructions for individual veterans.
From page 248...
... The committee was concerned about what is done within the NTPR program to re-evaluate dose reconstructions when a claim for compensation was denied but it is thought that later changes in laws, regulations, or methods of reconstructing doses or estimating probability of causation might have affected the outcome if they had been in place at the time of the claim. For example, suppose that a veteran filed a claim for compensation for kidney cancer before this form of cancer was declared to be presumptive in 38 CFR 3.309 (see Section I.B.4)
From page 249...
... In response to a verbal inquiry on the issue of retroactive recalculations of dose and re-evaluations of prior compensation decisions in cases in which claims had been denied, the committee was informed that VA generally does not take the initiative to reopen cases when a change in law, regulations, or methods of reconstructing doses or estimating probability of causation of a radiation-related disease could have affected the compensation decision. Nor does VA or the NTPR program inform individual claimants about changes that could have affected their denied claims.
From page 250...
... Nonetheless, veterans might view the NTPR program more favorably if, for example, individual veterans were informed when changes in methods of estimating doses are made that might result in increases in their previously assigned doses or when policies affecting evaluations of claims are changed and were reminded that they can request a revised dose reconstruction. For example, after recent changes in the methods of calculating beta dose to the skin and evaluating claims for compensation for skin cancer, individual veterans with a previously denied claim for skin cancer, and the community of atomic veterans as a whole, could have been informed that doses to the skin are now being calculated in a different way and, furthermore, that more claims for skin cancer are being granted on the basis of a re-evaluation (lowering)
From page 251...
... , dose reconstructions should provide credible upper bounds of possible doses to participants, taking into account uncertainties in estimating dose that are an inherent part of any dose reconstruction. Indeed, it is the policy of the NTPR program to provide "high-sided" estimates of dose.
From page 252...
... The committee's investigation indicated that the proportion of successful claims for nonpresumptive diseases has been around 1% or less, excluding awards for skin cancer since 1998.15 Therefore, statements that the number of successful claims for nonpresumptive diseases other than skin cancers since the regulations in 38 CFR 3.311 were promulgated is on the order of 50, as previously reported and as believed by the 14The rate of success of claims for nonpresumptive diseases cannot be estimated more precisely because VA does not maintain a database that gives the breakdown of successful and unsuccessful claims for presumptive and nonpresumptive diseases separately. 15Few, if any, claims for skin cancer were granted before 1998, but the number of claims granted since 1998 is such that the current rate of granting claims for all nonpresumptive diseases may be nearly 10%.
From page 253...
... Second, difficulties in estimating inhalation doses notwithstanding, inhalation doses received by many participants almost certainly were low, judging by known conditions of exposure, and often were much lower than external doses that were monitored with film badges or field instruments. Similarly, the committee believes that external doses to most participants were sufficiently low that a re-evaluation of external doses based on the committee's findings about deficiencies in methods of estimating credible upper bounds probably would not result in estimates that exceed the screening doses used in evaluating claims.
From page 254...
... probably is a reasonable upper bound, but consideration of the accumulation of deposited fallout throughout the period of atomic testing, fractionation of radionuclides, and uncertainty in inhalation dose coefficients could result in increases of more than a factor of 10 in credible upper bounds of inhalation dose compared with estimates obtained in dose reconstructions. Depending on the organ or tissue in which a veteran's cancer occurred, it is possible that credible upper bounds of the total dose from external and internal exposure could qualify the veteran for compensation in these cases.
From page 255...
... . Thus, if methods of dose reconstruction used by the NTPR program are changed to be consistent with the committee's findings, the effect on future claims for compensation for nonpresumptive diseases is not likely to be substantial.
From page 256...
... 256 DOSE RECONSTRUCTION PROGRAM OF THE DTRA ing, and if adequate proof of participation is not available, claims are evaluated under the nonpresumptive regulation and a dose reconstruction is required. The committee does not know how often claims for compensation for presumptive diseases have had to be evaluated under the nonpresumptive regulation, but the number of such cases could increase in the future, given the expansion of the list of presumptive diseases, thus increasing the importance of changes in methods of dose reconstruction.


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