DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

OCAS-PER-030, “SRS TBD REVISIONS”

Contract No. 200-2009-28555

SCA-TR-PR2013-0030, Rev. 0 

Prepared by 

Ron Buchanan, PhD, CHP 

SC&A, Inc. 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

July 2013 

Disclaimer

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

2 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No.:

SCA-TR-PR2013-0030

Effective Date: 

Draft – July 1, 2013

Revision No.:

0 – (Draft)

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORT OCAS-PER-030, 

“SRS TBD REVISIONS”

Page 2 of 19

Task Manager:

________________________ Date: ___________

Ron Buchanan, PhD, CHP 

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, CHP

Peer Reviewer(s):

 Hans Behling, PhD, MPH

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/01/2013 Initial issue.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

3 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

TABLE OF CONTENTS

Abbreviations and Acronyms ..........................................................................................................4

1.0 Statement of Purpose ...........................................................................................................5

2.0 Subtask 1: Assess NIOSH’s Identification of the Issues and Their Impact on Dose 

Reconstruction .....................................................................................................................7

2.1 Issuance of OCAS-PER-030....................................................................................7

2.2 SC&A’s Assessment of The Development of OCAS-PER-030..............................8

3.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ...............................9

3.1 SC&A’s Evaluation of Changes in SRS TBD .........................................................9

3.2 SC&A’s Evaluation of NIOSH’s Corrective Action Plan .....................................11

3.2.1 SC&A’s Evaluation of TBD Changes and NIOSH’s Corrective 

Action Plan.................................................................................................12

3.2.2 Conclusions................................................................................................13

4.0 Subtask 3: Evaluate the PER’s Stated Approach for Identifying the Number of 

Dose Reconstructions Requiring Re-evaluation of Dose...................................................14

4.1 NIOSH’s Approach................................................................................................14

4.2 NIOSH’s May 2013 Update...................................................................................14

4.3 SC&A’s Evaluation ...............................................................................................14

5.0 Subtask 4: Conduct Audits of a Sample Set of DRs Affected by OCAS-PER-030 .........16

6.0 References..........................................................................................................................17

Attachment A: SC&A’s Previous Findings Concerning the SRS TBD .......................................18
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

4 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ABBREVIATIONS AND ACRONYMS

ABRWH or

Advisory Board Advisory Board on Radiation and Worker Health

Al aluminum

CFR Code of Federal Regulations

DOL Department of Labor

DR dose reconstruction

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 

2000

HVL half-value layer

L liter

mm millimeter

mrem millirem

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH/OCAS Claims Tracking System

OCAS Office of Compensation Analysis and Support

ORAUT Oak Ridge Associated Universities Team

PEP Program Evaluation Plan

PER Program Evaluation Report

PFG photofluorography

POC Probability of Causation

RU recycled uranium

SC&A S. Cohen and Associates (SC&A, Inc)

SRS Savannah River Site

TBD technical basis document

TIB technical information bulletin

TLND Thermoluminescent Neutron Dosimeter
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

5 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

1.0 STATEMENT OF PURPOSE

To support dose reconstruction (DR), the National Institute for Occupational Safety and Health 

(NIOSH) and the Oak Ridge Associated Universities Team (ORAUT) have assembled a large 

body of guidance documents, technical basis documents (TBD), workbooks, computer codes, 

and tools. In recognition of the fact that all of these supporting elements in DR may be subject to 

revisions, provisions exist for evaluating the effect of such programmatic revisions on the 

outcome of previously completed DRs. Such revisions may be prompted by document revisions 

due to new information, misinterpretation of guidance, changes in policy, and/or programmatic 

improvements.

The process for evaluating potential impacts of programmatic changes on previously completed 

DRs has been proceduralized in OCAS-PR-008, Preparation of Program Evaluation Reports 

and Program Evaluation Plans, Rev. 2 (OCAS 2006). This procedure describes the format and 

methodology to be employed in preparing a Program Evaluation Report (PER) and a Program 

Evaluation Plan (PEP).

A PER provides a critical evaluation of the effect(s) that a given issue/programmatic change may 

have on previously completed DRs. This includes a qualitative and quantitative assessment of 

potential impacts. Most important in this assessment is the potential impacts on the Probability 

of Causation (POC) of previously completed DRs with POCs of <50%.

As needed, a PEP may be issued that serves as formal notification of an impending PER. The 

PEP provides a preliminary description of the issue(s) that will be addressed in the PER, and 

summarizes the likely scope of the effort required to complete the PER.

S. Cohen and Associates (SC&A) was tasked by the Advisory Board to conduct a review of 

OCAS-PER-030, SRS TBD Revisions (OCAS 2007). In conducting a PER review, SC&A is 

committed to perform the following five subtasks, each of which is discussed in this report:

Subtask 1: Assess NIOSH’s evaluation/characterization of the “issue” and its potential impacts 

on DR. Our assessment intends to ensure that the “issue” was fully understood and 

characterized in the PER.

Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where the PER 

involves a technical issue that is supported by document(s) [e.g., white papers, technical 

information bulletins (TIBs), procedures] that have not yet been subjected to a formal 

SC&A review, Subtask 2 will include a review of the scientific basis and/or sources of 

information to ensure the credibility of the corrective action and its consistency with 

current/consensus science. Conversely, if such technical documentation has been 

formalized and previously subjected to a review by SC&A, Subtask 2 will simply provide 

a brief summary/conclusion of this review process. 

Subtask 3: Evaluate the PER’s stated approach for identifying the universe of potentially 

affected DRs, and assess the criteria by which a subset of potentially affected DRs was 

selected for re-evaluation. The second step may have important implications in instances 
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

6 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

where the universe of previously denied DRs is very large and, for reasons of practicality, 

NIOSH’s re-evaluation is confined to a subset of DRs that, based on their scientific 

judgment, have the potential to be significantly affected by the PER. In behalf of 

Subtask 3, SC&A will also evaluate the timeliness for the completion of the PER.

Subtask 4: Conduct audits of DRs affected by the PER under review. Based on information 

contained in the PER (and discussed in Section 5 below), the number of DRs selected for 

audit for a given PER will vary. (It is assumed that the selection of the DRs and the total 

number of DR audits per PER will be made by the Advisory Board.) 

Subtask 5: Prepare a comprehensive written report that contains the results of the above-stated 

subtasks, along with our review conclusions. 
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

7 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

2.0 SUBTASK 1: ASSESS NIOSH’S IDENTIFICATION OF THE ISSUES

AND THEIR IMPACT ON DOSE RECONSTRUCTION

NIOSH has issued a TBD for the Savannah River Site (SRS), along with a number of revisions. 

As stated in OCAS-PER-030, these documents have been utilized to perform DRs for claims 

from the SRS. The TBD has been through several revisions. Although many of the revisions 

only added annotation and attribution or corrected errors that did not affect the DR methods, 

there were a number of substantial changes made that could affect the outcome of a DR. In the

preparation of OCAS-PER-030, the technical changes made in the revisions of the TBD were 

reviewed to determine if any previously completed DRs would result in an increased dose using 

the current methods. The review was limited to identifying any increase in assigned dose, rather 

than any change or an overall increase.

A summary of the SRS TBD (ORAUT-TKBS-0003) revisions are listed below:

 July 15, 2003 – Rev. 00 (ORAUT 2003a)

 August 21, 2003 – Rev. 01 (ORAUT 2003b)

 October 29, 2004 – Rev. 02 (ORAUT 2004)

 April 4, 2005 – Rev. 03 (ORAUT 2005)

In addition, the Occupational Medical Dose Section was revised as a separate document and 

issued on November 30, 2009, Rev. 04 (ORAUT 2009).

2.1 ISSUANCE OF OCAS-PER-030

On December 18, 2007, NIOSH issued OCAS-PER-030 (OCAS 2007), which contained the 

following major sections:

Section 1.0 – This section provides a description of the reason there is a need to consider the 

changes in the revised SRS TBD (Rev. 01 of August 21, 2003) that could potentially increase 

assigned dose to claimants whose claims had previously been processed, with a resulting POC 

<50%, using an earlier version of the SRS TBD (Rev. 00 of July 15, 2003).

Section 2.0 – This section provides a summary of the issues identified by NIOSH from their

evaluation of the changes in the SRS TBD. These were as follows:

 No reduction for 1.5 L – Revision 0 required that urine samples be adjusted 

to a daily rate by assuming 1.4 liter per day standard rate. However, many 

samples were reported as activity per 1.5 liters. Revision 1 indicated that 

samples specified in this way could be considered to be a full day’s excretion. 

Any samples specified as activity per 1.5 liters could have been reduced 

under revision 0 and would not be now. Therefore, claims completed prior to 

revision 1 being issued will have to be reviewed to determine if actual urine 

samples meeting this criterion were reduced.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

8 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

 Revised Environmental Plutonium Intakes – Revision 0 provided a table that 

contained errors in the pre-calculated missed intakes for plutonium exposure.

The values that were miscalculated in revision 0 were corrected in revision 1.

All the values for type M plutonium were too high in revision 0 and the values 

for type S plutonium were too low. Because of this, claims that used the type 

S values from revision 0 will require a new dose estimate. Since the TBD did 

not require the use of these values, it is possible some estimates did not 

include this error. A review of the plutonium intakes will be necessary to 

determine which claims are affected.

 2,500 hours per year Environmental – Some dose estimates include ambient 

external dose. The values in revision 0 assumed a 2000 hour work year. This 

was changed to 2500 hour work year in revision 1. Therefore, claims 

assigned ambient external dose using revision 0 will require a new dose 

estimate.

 Environmental Plutonium and Uranium Headings Transposed – Revision 0 of 

the TBD included a table of the maximum site wide ambient intakes of various 

isotopes. In that table, headings for plutonium and uranium were transposed. 

This was corrected in revision 1. Most dose estimates completed under 

revision 0 were performed with the aid of a computational tool. This tool 

created 7/25/2003 (10 days after revision 0 was issued) contained the 

appropriate values. However, claims completed using revision 0 must be 

reviewed to determine if the appropriate value was used.

Section 3.0 – This section states that there were 54 SRS potentially impacted claims completed 

with a POC <50% prior to the issuance of the Rev. 01 TBD revision. It provides a plan of 

corrective action to resolve the issues created by the revision for any claim that was affected by 

changes in the TBD. This corrective action plan will be further discussed in Section 3 of this 

report.

2.2 SC&A’S ASSESSMENT OF THE DEVELOPMENT OF OCAS-PER-030

SC&A’s review of the applicable SRS TBD revisions and OCAS-PER-030 indicates that NIOSH 

properly outlined the necessary steps to re-evaluate the claims potentially impacted by the 

revisions in the TBD as proceduralized in OCAS-PR-008, Preparation of Program Evaluation 

Reports and Program Evaluation Plans, Rev. 02 (OCAS 2006). 

SC&A provides detailed analyses of our review in the following sections of this report. 
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

9 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

3.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

In instances where the PER involves a technical issue that is supported by documents [e.g., white 

paper(s), TIB(s), and/or procedure(s)] that have not yet been subjected to a formal SC&A 

review, Subtask 2 will assess the scientific basis and/or sources of information to ensure the 

credibility of the corrective action and its consistency with current/consensus science.

Conversely, if such technical documentation has been formalized and previously subjected to a 

review by SC&A, Subtask 2 will simply provide a brief summary/conclusion of this review 

process. 

3.1 SC&A’S EVALUATION OF CHANGES IN SRS TBD 

A complete formal review of all the applicable SRS TBD revisions would be out of the scope 

and time resources of SC&A’s task of evaluating OCAS-PER-030 and would be considered a 

complete SRS profile review. SC&A had performed in the past, or presently performed, the 

following evaluation/review of the SRS profile and related documents:

(1) Occupational Medical X-ray Organ Table – An error in analogues for organ dose 

assignments in Rev. 00 of the TBD (Table 2.04, page 49) and in Rev. 01 of the TBD

(Table 2.3-1, page 50) was corrected in Rev. 02 (Table 2.3-1) and later revisions. This 

change and DR corrections were addressed in OCAS-PER-002 (OCAS 2003). SC&A

reviewed OCAS-PER-002 and found it to adequately address the issue.

(2) SC&A Reviewed the SRS TBD in 2005 – The SRS TBD [ORAUT-TKBS-0003, Rev. 02

(ORAUT 2004)] was reviewed by SC&A in 2005 (SC&A 2005). This review document 

would contain the changes in the TBD that would be relevant to OCAS-PER-030 (which 

emphasized changes in Rev. 01). A short summary of SC&A’s evaluation of the TBD 

(SC&A 2005) is provided in Attachment A of this report.

(3) SC&A’s Current Review of TBD Rev. 03 – In conjunction with SC&A’s evaluation of 

OCAS-PER-030, SC&A recently performed a paragraph-by-paragraph comparison of 

each TBD revision to the former TBD (i.e., SC&A compared Rev. 01 to the contents of 

Rev. 00, etc.) to determine if there were any changes in the later revision that could 

potentially increase the assigned dose. SC&A did not locate any changes that would

potentially increase the assigned dose, except those changes already addressed by OCASPER-030.

(4) Revised Occupational Medical Section Rev. 04 of the TBD (ORAUT 2009) – OCASPER-030, effective December 18, 2007, states on page 2:

Some of the changes in these two revisions represented phased 

implementations... This is the case with photofluorography implemented in 

revision 2... Prior to these revisions, no method existed for these issues and 
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

10 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

claims determined to be affected by them where [sic] held until a method 

could be developed and documented. 

This statement was correct at the time OCAS-PER-030 was issued (if all pending claims 

were processed after the inclusion of the phased implementations). However, it is not 

currently correct concerning occupational medical dose assignments for some claims that 

were performed using the older version of the TBD instead of the revised 2009 edition of 

the occupational medical dose section.

In conjunction with SC&A’s evaluation of OCAS-PER-030, SC&A recently performed a 

paragraph-by-paragraph comparison of the following documents’ occupational medical

dose sections to determine if there were any changes in the later revisions that could 

potentially increase the assigned dose: 

 August 21, 2003, Rev. 01, was compared to July 15, 2003, Rev. 00

 October 29, 2004, Rev. 02, was compared to August 21, 2003, Rev. 01

 April 4, 2005, Rev. 03, was compared to October 29, 2004, Rev. 02

 November 30, 2009, Rev. 04, was compared to April 4, 2005, Rev. 03

From this evaluation, SC&A has the following findings:

Finding #1: Concerns with Phased Implementation

Page 2 of OCAS-PER-030 states:

Although two more revisions have been issued to the Savannah River Site 

TBD, the nature of the modifications made in these revisions do not require a 

review of completed dose reconstructions. The basis for this determination is 

as follows: 

• Some of the changes in these two revisions represented phased 

implementations. In this approach, a TBD is issued with some sections 

either marked “reserved” or a specific issued [sic] is not covered in 

order to allow the completion of claims unaffected by that aspect of 

dose reconstruction. A revision is later issued with the new 

information so that the affected claims can be completed. These types 

of modifications do not require an evaluation of affected claims 

because there was no increase in dose, it is simply the implementation 

of a method where no method existed. This is the case with 

photofluorography implemented in revision 2, type S Ce-144 intakes 

implemented in revision 2 and internal dose from food stuffs 

implemented in revision 3. Prior to these revisions, no method existed 

for these issues and claims determined to be affected by them where 

held until a method could be developed and documented. [Emphasis 

added.]
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

11 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

This raises the following question: What documentation is available to verify that the 

SRS claims that were held waiting for the reserved sections to be completed were (or will 

be) evaluated when the new information became available?

Finding #2: 2009 Revised Occupational Medical Section

SC&A’s comparison of the SRS TBD (Occupational Medical Dose) Rev. 04 to previous 

revisions found that the later edition contains changes that could increase assigned dose 

for some claims compared to data contained in earlier editions of the TBD. Some 

examples are:

 On page 9 of Rev. 04 it states: “Dose reconstructors should assume that 

workers had annual PFG examinations through 1960, unless the worker’s 

X-ray records indicate otherwise.” This could add dose to some claims.

 Table 3-8 (p. 13) of Rev. 04 lists photofluorography (PFG) doses for the 

period 1951–1960, whereas Table B-4 of Rev. 02 (p. 160) and Rev. 03

(p. 162) lists PFG doses for only the period 1951–1957. 

 While most PFG doses listed in Table 3-8 of Rev. 04 decreased in value 

compared to the values listed in Table B-4 of Rev. 02 and Rev. 03, the dose to 

the thyroid increased in the Rev. 04 edition compared to earlier versions. 

 The x-ray machine filtration values changed in Rev. 04, as follows:

o In Revs. 00, 01, 02, and 03, a half-value layer (HVL) of 1.5 mm Al for the 

year 1971 and before, and 2.5 mm Al for years after 1971 was stated.

o In Rev. 04 (pp. 10 and 11), the value changed to 2.5 mm Al for the year of 

1971 and before, and 3.5 mm Al for years after 1971.

The impact on assigned x-ray doses needs to be evaluated, especially to 

areas/organ not in the main primary beam, such as exit skin doses to the chest, 

which depend on the filtration value used in the computations.

Considering that there were significant changes in Rev. 04, it appears that an additional 

PER concerning Rev. 04 of the SRS Occupational Medical Dose site profile would be 

appropriate.

3.2 SC&A’S EVALUATION OF NIOSH’S CORRECTIVE ACTION PLAN

According to Section 3.0 of OCAS-PER-030, at the time OCAS-PER-030 was issued (December 

18, 2007), NIOSH had identified 54 SRS claims that were completed prior to the issuance of 

Rev. 01 of the SRS TBD (August 21, 2003), and which had a POC below 50%. NIOSH will 

review the DR for each of these 54 claims to determine if the evaluation of dose would be 

impacted by the four issues addressed in Section 2.0 above.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

12 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

NIOSH will provide the Department of Labor (DOL) with the list of the 54 claims, as well as a 

determination on each claim as to whether a new dose estimate is required. Documentation for 

each claim not requiring a new DR will provide the basis for that determination. 

3.2.1 SC&A’s Evaluation of TBD Changes and NIOSH’s Corrective Action Plan

SC&A’s evaluation of the impact of the SRS TBD changes on assigned dose, and NIOSH’s 

corrective action plan is as follows:

 No reduction for 1.5 L – SC&A found that the original recommendation in Rev. 00, page 

72, for correcting the 1.5 liter urine sample bioassay results to activity per 1.4 L was not 

necessarily always applicable (or claimant favorable), and concurs with NIOSH’s 

recommendation in Rev. 01, page 73 (and later revisions), to assume a bioassay result

reported as activity per 1.5 L to be a day’s excretion, and that reduction to activity per 

1.4 L is not needed. SC&A concurs with NIOSH’s corrective action plan to review 

potentially impacted claims and correct calculations and resulting dose assignments if 

applicable.

 Revised Environmental Plutonium Intakes – SC&A’s comparison of the Pu-239 Type S 

daily intake rates in Table 4.4.3-1, page 77, of Rev. 00 to those listed in Table 4.4.3-1, 

page 80, of Rev. 01 (and later revisions) indicates that some of the intake rates increased 

in the latter table; therefore, increased dose assignment is possible. SC&A concurs with 

NIOSH’s corrective action plan to review potentially impacted claims and correct intake 

values and resulting dose assignments if applicable.

 2,500 hours per year Environmental – SC&A found that the recommended ambient 

radiation dose levels for various SRS locations as listed in Table C-17 are in units of 

mrem per 2000 hours per year for all revisions of the SRS TBD. Generally, however,

DR protocol recommends the use 2,500 hours per year. Therefore, the recommendation 

on page 64 of Rev. 01 (and later revisions) to multiply the values in Table C-17 by a 

factor of 2,500/2,000 = 1.25 is appropriate, and claimant favorable in most cases. The 

SRS maximum ambient radiation dose level has been selected from Table C-17 and 

multiplied by the 1.25 correction factor and listed on an annual basis in Table 3.4-1, page 

65, of Rev. 01 (and in later revisions). SC&A concurs with NIOSH’s corrective action 

plan to review potentially impacted claims and correct ambient dose level values and 

resulting dose assignments if applicable.

 Environmental Plutonium and Uranium Headings Transposed – SC&A found that the 

headings for plutonium and uranium appear to be transposed in Table C-17 of Rev. 00, 

compared to Table C-17 of Rev. 01 (and later revisions). This could result in insufficient 

intake/dose of plutonium being assigned for DRs using Table C-17 of Rev. 00. SC&A 

concurs with NIOSH’s corrective action plan to review potentially impacted claims and 

correct intakes and resulting dose assignments if applicable.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

13 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

3.2.2 Conclusions

SC&A found that OCAS-PER-030 sufficiently addressed the changes in the SRS TBD and 

recommended proper corrective action as of its effective date of December 18, 2007, if all 

pending claims were processed after the inclusion of the phased implementations. However, a 

review of the 2009 revision of the Occupational Medical Dose Section (Rev. 04) indicates that 

claims impacted by these changes need to be addressed. 
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

14 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

4.0 SUBTASK 3: EVALUATE THE PER’s STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DOSE RECONSTRUCTIONS

REQUIRING RE-EVALUATION OF DOSE

4.1 NIOSH’S APPROACH

Section 3.0 of PER-030 identified the set of criteria used to determine the total population of 

claims that had the potential of being affected by changes in the SRS TBDs. At the time that 

OCAS-PER-030 was issued (December 18, 2007), NIOSH identified 54 SRS claims that were 

completed prior to that date and had a POC below 50%. NIOSH will review the DR for each of 

these 54 claims to determine if the evaluation of dose involved any of the issues outlined in 

Section 3 of this report and would be subject to NIOSH’s corrective action plan.

4.2 NIOSH’S MAY 2013 UPDATE

At the February 5, 2013, Procedures Review Subcommittee meeting, NIOSH received an action 

item to follow up on actions for OCAS-PER-030 (SRS); the following describes the claims 

evaluation outcome (NIOSH 2013):

54 claims were listed as potentially affected. Six were returned to NIOSH for 

other reasons prior to being evaluated so they were never evaluated under PER 

30. The remaining 48 were evaluated and none were found to meet any of the 

criteria. A spreadsheet with the claim numbers can be found in a separate folder 

(PER-030) in the existing “Procedures Subcommittee” folder on the Advisory 

Board drive (K:/ABRWH/AB Document Review drive).

4.3 SC&A’S EVALUATION

SC&A queried the NIOSH/OCAS Claims Tracking System (NOCTS) database using the 

following criteria:

 Worked at SRS

 <50% POC

 The variable “Draft DR sent date” was set at 1/1/2000 to 8/21/2003.

This search indicated that 57 claims met all three criteria; additionally, a manual search 

identified 3 more claims that met these criteria, making a total of 60 claims identified by SC&A. 

The following is a summary of the comparison of SC&A’s query results to NIOSH’s list of 54 

claims:

 54 of the 60 claim numbers identified by SC&A matched those provided by NIOSH. 

SC&A corresponded with NIOSH concerning the status of the 6 claims identified by 

SC&A, but not present on NIOSH’s list. The dispensation of these 6 claims was as 

follows:
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

15 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

o Three of these claims were returned to NIOSH by DOL for reasons other than 

PER-030, and then were reworked using Rev. 01, or a later revision, of the TBD. 

Therefore, none of the claims were affected by PER-030 because a rework using 

Rev. 01, or a later revision, of the TBD occurred prior to the issuance of the PER. 

SC&A used the NOCTS database to verify that this was true for each of these 

three claims.

o The DR for the remaining 3 claims was performed using Rev. 00 of the TBD. 

However, the DR used 2,500-hour per year ambient dose and hypothetical

internal intakes; therefore, the changes recommended in OCAS-PER-030 would 

not apply to these 3 claims. SC&A used the NOCTS database to verify that this 

was true for each of these three claims.

The result of the comparison of the SC&A query and NIOSH’s list of 54 claims indicates that

NIOSH used the correct claims for re-evaluation under OCAS-PER-030.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

16 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

5.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DRs

AFFECTED BY OCAS-PER-030

Selection of DRs to Audit – Because NIOSH has completed the evaluation of the 54 potentially 

impacted claims under OCAS-PER-030 and found none met one or more of the four TBD 

changes/criteria that would affect dose and would, therefore, require new dose reconstructions, it 

is recommended that SC&A sample the 48 applicable claims (54 claims minus 6 claims returned 

to DOL for other reasons) and evaluate some of them to verify that changes in the SRS TBD did 

not impact the dose assignments as per criteria set forth in OCAS-PER-030. This sampling 

would consist of SC&A scanning the 48 claims and selecting the claims that potentially could be 

impacted by OCAS-PER-030 (such as those that had bioassay records, those that have an 

indication of the need for ambient external dose, and/or the need for environmental intakes). 

SC&A would then perform a more detailed evaluation of these selected claims to determine if 

any meet the criteria for re-evaluation as outlined in OCAS-PER-030. SC&A recommends that 

at least 5–15 claims be subjected to this detailed analysis.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

17 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

6.0 REFERENCES

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction under the Energy Employees

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal

Register/Vol.67, No. 85/Thursday, May 2, 2002, p. 22314.

NIOSH 2013. E-mail from NIOSH to SC&A and the Procedures Workgroup, Subject: PER-030 

Claims Evaluation. National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. April 11, 2013.

OCAS 2003. SRS TBD - Error in surrogate organ assignment resulting in an underestimate of 

X-ray dose in SRS dose reconstructions, OCAS-PER-002, Rev. 00, National Institute for 

Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. December 15, 2003.

OCAS 2006. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

OCAS-PR-008, Rev. 02, NIOSH’s Office of Compensation Analysis and Support, Cincinnati, 

Ohio. December 6, 2006.

OCAS 2007. SRS TBD Revisions, OCAS-PER-030, Rev. 00, National Institute for Occupational 

Safety and Health, Office of Compensation Analysis and Support, Cincinnati, Ohio. December 

18, 2007.

ORAUT 2003a. Technical Basis Document for the Savannah River Site, ORAUT-TKBS-0003,

Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. July 15, 2003.

ORAUT 2003b. Technical Basis Document for the Savannah River Site, ORAUT-TKBS-0003, 

Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 21, 2003.

ORAUT 2004. Technical Basis Document for the Savannah River Site, ORAUT-TKBS-0003, 

Rev. 02, Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 29, 2004.

ORAUT 2005. Technical Basis Document for the Savannah River Site, ORAUT-TKBS-0003, 

Rev. 03, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 5, 2005.

ORAUT 2009. Technical Basis Document for the Savannah River Site – Occupational Medical 

Dose, ORAUT-TKBS-0003, Rev. 04, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. November 30, 2009.

SC&A 2005. Review of NIOSH Site Profile for Savannah River Site, SCA-TR-TASK1-003. 

SC&A, Inc., McLean, Virginia, and Saliant, Inc., Jefferson, Maryland. March 21, 2005.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

18 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ATTACHMENT A: SC&A’s PREVIOUS FINDINGS 

CONCERNING THE SRS TBD

On March 21, 2005, SC&A issued a draft report SCA-TR-TASK1-0003 titled, Review of NIOSH 

Site Profile for Savannah River Site (SC&A 2005). This draft report presents SC&A’s 

evaluation of the NIOSH Site Profile for the SRS, Rev. 02 (ORAUT 2004). The following is a 

summary of those findings:

Finding 1: The use of the “high-five” approach as surrogate data for internal 

dose for unmonitored workers and for target organs that do not concentrate the 

radionuclides in question is not necessarily a maximizing approach for making 

dose estimates, contrary to the claim in the TBD. The method is not consistent 

with the 42 CFR 82-recommended methodologies for the calculation of internal 

dose. The completeness of the database from which the intakes were derived is 

questionable.

Finding 2: The method used to reconstruct doses to unmonitored outdoor 

workers due to airborne emissions employs an atmospheric dispersion model, 

assumptions, and a resuspension factor that do not appear to be claimant 

favorable and is not entirely appropriate for this class of problem.

Finding 3: The site profile does not contain guidelines for resolving 

uncertainties related to recycled uranium (RU) in ways that give the benefit of the 

doubt to the claimants. For instance, the TBD does not consider internal dose 

contributions for plutonium, other transuranics, or fission products.

Finding 4: The beta/gamma dosimeter adjustment factors and uncertainties 

applied underestimated the true exposure measured by the dosimeter. Correction 

factors applied to dosimeter results account for on-phantom calibration and do 

not consider uncertainty from field exposure conditions.

Finding 5: The geometric mean and standard deviation that describe the post1971 neutron-to-photon ratio are neither technically defensible nor likely to be 

claimant favorable to a large number of claimants. The TLND recorded neutron 

doses between 1971 and 1995, as well as the pre-1971 neutron doses (derived 

from neutron-to-photon ratios), suffer from a high degree of uncertainty. The use 

of the 95th percentile value for the TLND neutron dose of records is recommended 

for use.

Finding 6: The adequacy of the F- and H-area Tank Farm characterization in 

the TBD is questionable for use as dose reconstruction guidance. This is 

particularly true for early periods of operation, where primary records involving 

key operations and incidents are lacking. Moreover, no references are provided 

for the Tank Farm discussion in the TBD, and there is no analysis indicating how 

the conclusions were reached.
Effective Date:

July 1, 2013

Revision No.:

0 – (Draft)

Document No.

SCA-TR-PR2013-0030

Page No.

19 of 19

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

Finding 7: Solubility, oro-nasal breathing, and ingestion should be carefully 

considered in regard to internal dose reconstruction. SC&A originally developed 

these points for the review in the Bethlehem Steel and Mallinckrodt Chemical 

Works site profile reviews, and they are applicable for all bioassay 

interpretations for EEOICPA.

These findings are not directly applicable to the issues covered in OCAS-PER-030.