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The SOPs provided to the committee (DTRA, 1997) contain a provision for periodic review and updating. The version provided to the committee had not been modified in several years, even though significant changes had occurred in the program. An example of an important change that should have triggered an update of the 1997 SOPs is the routine assessment of beta dose to skin that began in 1998. Documentation of procedures for determining beta dose to skin is important because the number of claims filed for skin cancer under the nonpresumptive regulation has increased dramatically over the last 4 years.
The committee was unable to locate formal documentation detailing when particular procedures were implemented or revised,2 although those changes might have been documented in internal memoranda not reviewed by the committee. Examples include implementation of large-particle inhalation dose coefficients, revision of the upper-bound gamma dose for target-ship boarding parties at Operation CROSSROADS, and the upper-bound analysis for sums of film-badge readings.
QA is not discussed in any detail in the SOPs, nor are many important procedures, such as details on how film-badge uncertainties are calculated. Because of the evolution of the program and the lack of formal documentation of changes in policy available either publicly or in the individual files, it is difficult for a reviewer to evaluate a given dose reconstruction to ensure that up-to-date approved and consistent procedures were used. Some of the case files contained no narrative discussions of the dose assessments.
Dose reconstruction memoranda prepared by the NTPR program supposedly contain references to all methods used. However, references in dose memoranda are often internal NTPR program memoranda.3 A veteran reviewing such a dose report would have no ready access to the referenced documents. Dose reconstructions by different analysts for similar scenarios often referenced different internal memoranda or reports for the same method.
For 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). The reply (Schaeffer, 2002b) stated that the upper bound had been revised, but no specific documentation as to when and why was supplied. Similarly, the committee requested specific information as to how the upper bound for sums of film-badge readings was calculated. In reply, the committee was told that the NTPR program followed recommendations of the NRC (1989) and supplied an unannotated copy of the computer program used to calculate upper bounds. Comments in the program listing clearly indicated that the method recommended by the NRC had been slightly modified. However, no additional documentation justifying the modifications was supplied.
The committee found a number of instances in which the references cited in a dose memorandum were not the appropriate or correct source of the information used to calculate the dose. Often, the cited reference contained only a reference to another document that discussed the procedure.