DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

DCAS-PER-055, “TBD-6000 REVISION, 9/12/2014”

Contract No. 211-2014-58081

SCA-TR-PER2015-0097, Revision 0

Prepared by 

John Mauro, PhD, CHP 

Amy Meldrum 

Nicole Briggs 

SC&A, Inc. 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

July 2015 

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.
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S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORT DCAS-PER-055, 

“TBD-6000, REVISION, 9/12/2014”

Document No. 

SCA-TR-PER2015-0097 

Effective Date: 

Draft – July 24, 2015 

Page 2 of 23 

Task Manager:

________________________ 

John Mauro, PhD, CHP

Date: ___________

Supersedes:

N/A

Project Manager:

________________________ 

John Stiver, CHP 

Date: ___________

Reviewer(s):

 John Stiver 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/24/2015 Initial issue

 

 

 

 

 

 

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.
Effective Date:

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

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TABLE OF CONTENTS

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

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

2.0 Subtask 1: Identify the Circumstances that Necessitated the Need for 

DCAS-PER-055...................................................................................................................7

3.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ...............................8

3.1 Changes Incorporated in Revision 01 of TBD-6000 ...............................................8

3.2 Issues Raised Subsequent to the Publication of Revision 1 to TBD-6000 ............10

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

DRs Requiring Re-evaluation............................................................................................11

4.1 SC&A’S Review of the Process Used by NIOSH to Identify the Universe of 

Potentially Impacted Claims..................................................................................12

4.2 SC&A’s Comments on Execution of Selection Criteria........................................14

4.2.1 SC&A’s Comments on NIOSH’s Exclusion Criteria ................................15

4.2.2 SC&A’s Comments on Cases Re-evaluated by NIOSH............................17

5.0 Subtask 4: Review of Cases..............................................................................................18

6.0 References..........................................................................................................................19

Attachment A: Correspondence Pertaining to ORAUT-OTIB-0070............................................21

Attachment B: Correspondence that Provided SC&A with the Universe of Potentially 

Impacted Cases Identified by NIOSH................................................................................22
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ABBREVIATIONS AND ACRONYMS

Advisory Board

or ABRWH Advisory Board on Radiation and Worker Health

AWE Atomic Weapons Employer

DCAS Division of Compensation Analysis and Support

DR Dose Reconstruction

m

2

square meter

m/s meters per second

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

POC Probability of Causation

RF resuspension factor

RU recycled uranium

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

SEC Special Exposure Cohort

TBD Technical Basis Document

TIB Technical Information Bulletin
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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, 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 (OCAS 2006), Revision 2. 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 impact on the Probability of 

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

As needed, a PEP may be issued that serves as a 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.

During a meeting of the Procedures Review Subcommittee held on April 28, 2015, SC&A was 

authorized to review DCAS-PER-055, TBD-6000 Revision (DCAS 2014). 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, 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 
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selected for re-evaluation. The second step may have important implications in instances 

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 Table 1 (and discussed in Section 3.1 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. 
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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: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR DCAS-PER-055

DCAS-PER-055 was issued on September 12, 2014, in response to the issuance of Revision 1 of 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium Metals

(Battelle 2011) (referred to here as Rev. 1 to TBD-6000). Prior to the issuance of Rev. 1 to 

TBD-6000, many DRs were performed based on Rev. 0 of TBD-6000 (Battelle 2006); hence, the 

need for this PER.

As explained in PER-055, there are many appendices to TBD-6000, which provide DR guidance 

for specific Atomic Weapons Employer (AWE) facilities that handled and machined uranium 

metal. These appendices are not addressed as part of PER-055, even though they could be 

affected by changes to TBD-6000. If the appendices to TBD-6000, such as Appendix BB 

dealing with General Steel Industries, require revision, they will be treated under separate PERs. 

As such, only DRs that are based entirely on TBD-6000 and not based on one of the appendices 

to TBD-6000 were revisited under this PER.

While some changes incorporated into Rev. 1 to TBD-6000 increased the assigned doses, others 

resulted in a decrease. All changes introduced in Rev. 1 reflect formal internal reviews by 

ORAUT, NIOSH, and the TBD-6000 Work Group.

However, subsequent to the issuance of Rev. 1 to TBD-6000, new TBD-6000 issues emerged 

due to ongoing reviews of a number of site profiles. These new issues were brought to the 

attention of the TBD-6000 Work Group and resolved. These matters are discussed in greater 

detail later in this review.
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3.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

3.1 CHANGES INCORPORATED IN REVISION 01 OF TBD-6000

On June 17, 2011, Rev. 1 of TBD-6000 was issued, which contained the following changes that 

are briefly summarized in the section of TBD-6000 titled, “Records of Review/Revisions.” 

However, this section is quite brief, stating the following:

Revision initiated to incorporate review comments. Added external beta dose 

from surface contamination. Expanded discussion in Section 3.3.1. Additional 

editorial changes and typographical errors.

A more complete description of the changes is provided in the TBD-6000 issues resolution 

matrix dated October 28, 2009 (SC&A 2009), which reflects the discussions held during the 

TBD-6000 Work Group meeting held on October 14, 2009. The following summarizes the 

issues and the degree to which they have been resolved in Rev. 1 of TBD-6000:

1. Resolution of issues pertaining to the Putzier (1982) effect. NIOSH explained that the 

Putzier effect only occurs during re-casting of uranium, and SC&A agrees. Also, during 

the Work Group meeting, NIOSH agreed to look into this matter further. Section 3.3.1 of 

Rev. 1 of TBD-6000 on Electron Dosimetry, does explore this issue with the following 

discussion:

The derby resulting from the reduction step contained impurities that made it 

unsuitable for reactor fuel. The metal was both purified and altered in shape 

in the remelt process. In this process, the derbies are melted in a vacuum 

furnace and molten uranium metal poured into a graphite mold (Chrisofano 

and Harris 1960). The vacuum casting removes volatile contaminants and 

allows other impurities to float to the surface concentrating impurities near 

the top. Impurities can also be concentrated where the molten uranium metal 

cools rapidly preventing (or minimizing) the time necessary for the impurities 

to separate. This can cause impurities to also concentrate near other surfaces 

of the casting. The separation can be improved by controlling the cooling of 

the cast uranium. If the mold is insulated near the top, a steep temperature 

gradient is formed causing the ingot to solidify from the bottom to the top. 

This allows impurities to separate and migrate to the top of the ingot without 

being trapped in solidifying metal. The “hot-top” that is formed is then cut 

off (cropped) to eliminate the impurities (Fleishman-Hillard 1967).

The implications are that TBD-6000 alerts the dose reconstructor to this potential issue,

but provides little guidance regarding how to address this issue. SC&A therefore remains 

concerned that TBD-6000 does not adequately address this issue with respect to 

providing adequate guidance to the dose reconstructor.
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2. Resolution of issues related to external beta exposures associated with contaminated 

surfaces. Rev. 1 to TBD-6000 adequately addresses this issue.

3. Issues related to the inclusion of Th-232 as one of the radionuclides present in recycled 

uranium (RU). This issue was resolved by NIOSH explaining the origin of Th-232 in 

RU, and there was no need to address this issue in Rev. 1 to TBD-6000; the issue was 

closed.

4. Issues related to investigating data characterizing sources of airborne uranium in addition 

to those cited by Harris and Kingsley (1959), such as Adley et al. (1952) and those 

reported for Simonds Saw and Steel (ORAUT 20051). Rev. 1 to TBD-6000 addresses 

this issue and SC&A recommends that this issue be closed.

5. Issues related to the methods used by NIOSH to derive the accumulation of uranium dust 

on surfaces. NIOSH addressed this issue by drawing from data in Adley et al. 1952 and 

SC&A recommends that this issue be closed.

6. Issues related to the resuspension factor (RF): The issue related to NIOSH’s use of an RF 

of 1E-6/m. This issue was resolved by OTIB-0070 (ORAUT 2012), which deals with 

derivation of exposures during the residual period. This TIB itself went through a 

complex review process, where all issues were resolved. One of the issues dealt with the 

need to adjust the RF for different sets of conditions. Rev. 1 to TBD-6000 does not adopt 

the approved OTIB-0070 protocols. In response to an inquiry regarding this matter made 

by SC&A, SC&A received a response to our inquiry from NIOSH (Jim Neton) on June 1, 

2015 (see Attachment A), which explains that NIOSH concurs that Rev. 1 to TBD-6000 

should have made reference to OTIB-0070 (ORAUT 2012). Hence, this issue should 

remain in abeyance.

7. Issues related to inadvertent ingestion of uranium. This issue was resolved by the 

Procedures Review Subcommittee and was appropriately incorporated into Rev. 1 of 

TBD-6000.

All these issues were resolved in principle during the TBD-6000 Work Group meetings and were 

either closed or placed in abeyance until Rev. 1 to TBD-6000 was issued, and it can be 

confirmed that all issues were, in fact, appropriately addressed. A review of Rev. 1 reveals that,

except for the Putzier effect issue (Issue 1) and the RF issue (Issue 6), all issues have been 

appropriately addressed in Rev. 1. The e-mail SC&A received on June 1, 2015, confirms that 

Issue 6 was, in fact, resolved with the finalization of OTIB-0070 (ORAUT 2012), and Rev. 1 to 

TBD-6000 should have made appropriate reference to OTIB-0070. We still have concerns

regarding Issue 1.

On June 17, 2011, Rev. 1 of TBD-6000 was issued, which contained the following changes 

salient to DR:

 Section 3.3.1 (page 22) discusses issues related to the enhancement of Th-234 at the 

surface of re-cast uranium (and associated elevated beta exposures). Hence, this issue is 

 

1 This TIB was cancelled in April 2011 and the sites that were previously appendices to TBD-6001 are now 

stand-alone documents (see the NIOSH web site at http://www.cdc.gov/niosh/ocas/awedocs.html.
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addressed in Rev. 1 and alerts dose reconstructors to the possibility of encountering this 

phenomenon at some metal-handling facilities. However, additional guidance is needed 

regarding how to address this issue.

 Tables 3.4 and 3.10 explicitly address beta exposures at contact with uranium slabs and 

also at 1 meter above surfaces contaminated with uranium dust and flakes.

 Section 3.4.2 (page 25) discusses data provided in Adley et al. (1952) and Simonds Saw 

and Steel (AEC 1949), and factors those data into the exposure matrices employed in 

Rev. 1 to TBD-6000.

 Section 7.1.5 (page 49) discusses resuspension during periods with no uranium 

operations. The discussion adopts an RF of 1E-6/m, with no mention of updated 

information regarding RFs provided in OTIB-0070 (ORAUT 2012). However, as 

discussed above, NIOSH acknowledges this oversight. As part of Subtask 4 of this PER 

review, it would be appropriate to review cases where OTIB-0070 might apply to some 

cases in order to determine if appropriate RFs were, in fact, used; e.g., situations where 

an RF of 1E-5/m should be used.

 Section 7.1.6 (page 50) describes the procedures to be used to reconstruct ingestion 

doses. Reference is made to OCAS-TIB-009 (OCAS 2004), which describes the methods 

approved for use in reconstructing ingestion intakes due to inadvertent ingestion.

3.2 ISSUES RAISED SUBSEQUENT TO THE PUBLICATION OF REVISION 1 TO 

TBD-6000

Subsequent to the issuance of Rev. 1 to TBD-6000, SC&A reviewed a number of DRs, site 

profiles, and a petition evaluation report that relied on Rev. 1 of Battelle-TBD-6000 to provide 

the bases for completed DRs or possible future DRs (e.g., Joslyn). During those reviews, SC&A 

had an opportunity to look closely at Rev. 1 of TBD-6000 as it was applied to these specific

cases and site profiles. As a result of these reviews (SC&A 2013), SC&A identified the 

following supplementary issues associated with Rev. 1 to TBD-6000:

 The suitability of using a terminal settling velocity of 0.00075 m/s and the time required 

to reach an equilibrium surface concentration

 The attenuation rate for surface contamination

 A comparison of site-specific air concentrations with generic data used in TBD-6000

 Operations not explicitly covered in TBD-6000

SC&A advised the Designated Federal Official, NIOSH, and the TBD-6000 Work Group of 

these additional concerns, and SC&A was directed to perform a focused review of these 

concerns. On May 13, 2013, SC&A issued Supplementary Comments on Revision 1 of BattelleTBD-6000 (SC&A 2013) in response to this directive.

Our review confirmed the adequacy of the dust deposition velocity of 0.00075/m2. However, we 

found that there was considerable uncertainty associated with the deposition duration of 30 days 
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before an effective equilibrium was achieved (i.e., the time period when the deposition rate of 

dust on surfaces was in quasi-equilibrium with the rate at which dust was removed from surfaces 

due to air turbulence and perhaps some anthropomorphic activities). After discussion of this 

issue with the Work Group, an assumed default dust deposition duration of 30 days was found to 

be reasonable. We also compared the generic airborne uranium dust concentrations in TBD6000 (Battelle 2011) to the site-specific time-weighted air exposure values for the Hanford Melt 

Plant Building (Adley et al. 1952), Simonds Saw and Steel (ORAUT 2011), Joslyn (NIOSH 

2012), and Bethlehem Steel (NIOSH 2010). These comparisons demonstrated that the default 

assumptions employed in Rev. 1 to TBD-6000 were largely claimant favorable for a very broad 

range of job descriptions at numerous uranium handling and machining facilities.

We also questioned whether the geometric mean airborne concentrations should be employed as 

the basis for estimating internal doses, as opposed to either the arithmetic mean or upper 95th

percentile. NIOSH demonstrated that, by using the full distribution of airborne dust loadings, 

which assumed a lognormal distribution with a geometric standard deviation of 5, the outcome of 

the calculation of the POC was similar to the POC one would derive if a fixed airborne dust 

loading at the 95th percentile was employed. On this basis, this issue was resolved.

Our final supplementary issue was a concern that the default airborne dust loading used in TBD6000 did not take into consideration transient conditions, such as aggressive sweeping and 

uranium fires. However, after careful review of the underlying research used to derive the 

default dust loading used in TBD-6000, we realized that there was sufficient conservatism 

inherent in these default values to accommodate such transients in a claimant-favorable manner. 

Therefore, the outcome of our supplemental investigations found Rev. 1 to TBD-6000 to be quite 

claimant favorable with respect to this matter.

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

IDENTIFYING THE NUMBER OF DRS REQUIRING 

RE-EVALUATION

NIOSH used the following set of criteria to determine the universe of claims that could have 

potentially been impacted by the revisions to TBD-6000:

1. A text search of all DR reports for previously completed claims for the phrase “6000”

2. Claims that resulted in a POC of less than 50%

Using these criteria, NIOSH identified a total of 809 cases that were potentially affected by the 

revisions to TBD-6000. In DCAS-PER-055 (DCAS 2014), NIOSH lists the following reasons 

for which cases would be removed from the universe of 809 for re-evaluation:

1. Cases that were associated with a site for which a site-specific PER was already 

conducted. The PERs included the revision to TBD-6000.
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2. Cases that were associated with a site for which an appendix to TBD-6000 exists and/or 

were already scheduled for a site-specific PER that would include the revision to TBD6000.

3. Cases whose text search result was not associated with TBD-6000 or cases in which 

TBD-6000 was referenced but not used in the DR.

4. Cases whose DR reports already referenced Rev. 1 of TBD-6000. 

5. Cases whose original DR indicated that using Rev. 1 of TBD-6000 would result in the 

same or lower POC values.

SC&A believes that this basic strategy for identifying the potentially impacted cases, and the 

screening criteria used to determine which cases need to be re-evaluated, are appropriate. In the 

subsections that follow, we describe our approach, and results of our approach, for 

(1) confirming that NIOSH did not miss any potentially impacted cases, and (2) that NIOSH did 

not screen out any cases that require re-evaluation. In order to accomplish this, we requested that 

NIOSH provide us with the database identifying the 809 cases that represent the universe of 

potentially impacted cases and screening information used to identify the 30 cases that were 

determined to require a formal re-evaluation. Appendix B presents the correspondence between 

SC&A and NIOSH where NIOSH provided the requested information.

4.1 SC&A’S REVIEW OF THE PROCESS USED BY NIOSH TO IDENTIFY THE 

UNIVERSE OF POTENTIALLY IMPACTED CLAIMS

The information provided by NIOSH in response to our request is in the form of a large 

spreadsheet with three columns. Because of its size, this spreadsheet is not provided here. The 

first column in the spreadsheet is the case number, the second column is the site at which that 

claimant worked, and the third column is NIOSH’s screening designation for that case. The first 

column of NIOSH’s spreadsheet is the list of the 809 cases captured by NIOSH’s search.

The first step in our review was to confirm that the 809 cases identified by NIOSH do, in fact,

represent the list of cases that, in theory, might be impacted by the revisions to TBD-6000; i.e., 

did NIOSH miss any potentially impacted cases?

The approach we used to try to answer this question was to first identify all of the sites 

represented by the 809 cases. We found that a total of 61 sites are represented by these cases. If 

NIOSH missed any cases, they would likely be among the sites captured by NIOSH’s search. 

We then went through a site elimination process to determine if we could find any cases that 

might have been missed by NIOSH and would have a greater potential for the need to be reevaluated under Rev. 1.

The site elimination process began with the elimination of sites from further consideration for 

any of the following reasons: 

1. The site has an appendix to TBD-6000

2. The site has a pre-existing PER
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3. The site has cases where TBD-6000 is referenced but not used

4. The site has cases where the number ‘6000’ is within the text, but has nothing to do with 

TBD-6000

After this screening process, we were left with the facilities listed in Table 4-1, which, in theory,

could include claimants that require reconsideration. The first step was to conduct a NIOSH/ 

OCAS Claims Tracking System (NOCTS) search for all cases associated with these sites whose 

POC was less than 50%. Then, we eliminated all cases from those facilities that were among

NIOSH’s 809 cases. At this point, we identified 472 cases, and we checked if any of the cases 

refer to TBD-6000. We found 294 cases that did use TBD-6000, but are not on NIOSH’s list of 

809 cases. However, of these, 287 used Rev. 1 of TBD-6000 (Battelle 2011). The remaining 

seven cases referenced Appendix C of TBD-6000 for Dow Chemical Company (Madison Site). 

It is likely that the cases found during this search were not included in NIOSH’s list of 809 cases,

because the DR reports may not have been completed until after NIOSH conducted their search. 

Based on this review, we believe that the 809 cases identified by NIOSH do, in fact, represent 

the universe of cases that might require reconsideration.

SC&A found that the selection criteria used to identify the universe of 809 cases that might 

require a reassessment to be appropriate and comprehensive.
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Table 4-1. Sites Included in the NOCTS Search for Potentially Missed Cases

Work Site Name

AC Spark Plug

Alba Craft

Allied Chemical and Dye Corp.

Allis-Chalmers Co.

B&T Metals

Baker Brothers

Bendix Aviation (Pioneer Division)

Beryllium Production Plant (Brush Luckey Plant)

Brush Beryllium Co. (Cleveland)

C.H. Schnoor & Company

Cincinnati Milling Machine Co.

Colonie Interim Storage Site (National Lead Co.)

Crucible Steel Co.

Heppenstall Co.

Herring-Hall Marvin Safe Co.

Hunter Douglas Aluminum Corp.

Ithaca Gun Co.

Koppers Co. Inc.

Medart Co.

Metallurgical Laboratory

Metals and Controls Corp. 

Norton Co.

Nuclear Metals Inc.

Reed Rolled Thread Co.

Revere Copper and Brass

Southern Research Institute

Spencer Chemical Co. Jawhawks Works

Superior Steel Co.

Sylvania and Corning Nuclear Corp. - Bayside Laboratories

Sylvania and Corning Nuclear Corp. - Hicksville Plant

Torrington Co.

Ventron Corporation

Vulcan Tool Co.

W.E. Pratt Manufacturing Co.

4.2 SC&A’S COMMENTS ON EXECUTION OF SELECTION CRITERIA

Table 4-2 summarizes NIOSH’s screening criteria used to identify the 30 cases out of the 809 

that were selected for re-evaluation.
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Table 4-2. Summary of Potentially Affected Cases as Reported by NIOSH

Number of Claims NIOSH's Evaluation

166 Eliminated due to existence of site-specific PER

356 Eliminated because site has an appendix to TBD-6000

50 Eliminated because TBD-6000 referenced and not used, or listed in error

56 Eliminated because Rev. 1 used in DR

151 Eliminated because using Rev. 1 would result in the same or lower values

30 Re-worked under Rev. 1 of TBD-6000

4.2.1 SC&A’s Comments on NIOSH’s Exclusion Criteria

SC&A agrees with NIOSH’s evaluation and exclusion of cases associated with sites that have 

another PER. All of the PERs mentioned in these cases were issued after the Rev. 1 of TBD6000 went into effect, as shown in Table 4-3. It is therefore assumed that the cases pulled by the 

other PERs would address all open concerns, including the revision of TBD-6000.

Table 4-3. PERs Referenced by NIOSH in the Exclusion of Cases for Re-Evaluation

PER Mentioned Date PER Issued

PER-039 Baker Perkins 1/7/2013

PER-047 Grand Junction 3/26/2014

PER-048 Wah Chang 9/27/2013

PER-050 Bliss and Laughlin 3/14/2014

PER-052 Westinghouse Nuclear Fuels Division 3/24/2014

PER-054 Carborundum 7/25/2014

PER-056 BWXT Technologies Inc. (Virginia) 9/12/2014

SC&A agrees with NIOSH’s evaluation and exclusion of cases associated with sites that have an 

appendix to TBD-6000. If NIOSH finds that any of the appendices to TBD-6000 require 

revision, a PER will be issued for those appendices. This is, in fact, what was done with 

Appendix BB to TBD-6000, which deals with General Steel industries.

SC&A agrees that the cases in which TBD-6000 is referenced but not actually used in the DR

should be eliminated from consideration for re-evaluation. The cases which were captured in the 

text search for the phrase “6000,” but do not deal with TBD-6000, were also correctly excluded 

from further consideration.

SC&A agrees that the cases within the universe of 809 that already used Rev. 1 of TBD-6000 

should be removed from further consideration.

The following presents a series of observations that have no effect on the outcome of the PER 

case selection process, but identify places where cases should have been eliminated for reasons 

other than the reasons cited by NIOSH. This material is provided solely for the purpose of 
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having a complete record describing the basis for eliminating certain cases from further 

consideration.

During SC&A’s review of the cases that NIOSH excluded from consideration because use of 

Rev. 1 would result in “the same or lower values,” it was found that several cases included in this 

category should have been excluded by other criteria used by NIOSH, as summarized below.

Table 4-4. Cases Listed by NIOSH as Having “Lower or the Same Values” under Revision 

1 that Should Have Been Excluded for Other Reasons

Number of cases Reason Case Should Have Been Excluded Earlier in the Process

14 Work site has an appendix to TBD-6000

5 Listed in error; does not reference TBD-6000

1 Referenced TBD-6000, but was not used in DR

42 DR report used Rev. 1

SC&A found six cases from US Steel Co., National Tube Division, and eight cases from Heald 

Machine Company listed by NIOSH in this category. However, appendices to TBD-6000 exist 

for these sites (Appendix CO and Appendix BD, respectively) and should have been eliminated 

for this reason. Four of the cases for Heald Machine Company even referenced Appendix BD in 

their DR report.

SC&A found five cases in which TBD-6000 was not referenced, but the phrase “6000” happened 

to appear elsewhere in an unrelated manner. SC&A also found one case where TBD-6000 was 

referenced but not used in the DR.

It is interesting that 42 cases NIOSH excluded by claiming that the use of Rev. 1 would result in 

“the same or lower values” were, in fact, already evaluated by NIOSH using Rev. 1 to TBD6000.

The remaining 89 cases were eliminated for re-evaluation because use of Rev. 1 would result in 

“the same or lower values.” Specifically, NIOSH indicated that several cases used TBD-6000 in 

such a way that Rev. 1 would likely result in such a small increase in dose that it would not 

affect the compensation decision if the POC was below 49.6%. Our review revealed that no 

cases were actually eliminated based on their POC. We believe that NIOSH simply is informing 

the reader that the POC based on doses derived using Rev. 0 would have to be 49.6% before a 

reversal of the compensation decision would occur if the doses were reconstructed using Rev. 1. 

SC&A did not check whether 49.6% is, in fact, the decision threshold, since the case elimination 

process never had to use this elimination criterion. SC&A agrees with NIOSH’s elimination of 

cases whose POC will likely change very slightly under Rev. 1.
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4.2.2 SC&A’s Comments on Cases Re-evaluated by NIOSH

NIOSH listed 30 cases that were not excluded from consideration and were re-evaluated under 

Rev. 1 of TBD-6000. SC&A examined these 30 cases to check if they were appropriately 

considered.

SC&A found one case that should not have been included in the universe of potentially affected 

cases from the start. A document from 2011 associated with this particular case says that the 

claim was compensated as part of a Special Exposure Cohort (SEC); therefore, re-evaluation of 

the case was not necessary.

Eight of the remaining cases that were re-evaluated involved skin cancers and the use of TBD6000 for external beta dose. Therefore, re-working of these cases under Rev. 1 was likely 

necessary. However, the remaining 21 cases do not exhibit characteristics that make them stand 

out as good candidates for re-evaluation. Many of these cases deal with non-skin cancers, and 

their DRs appear to have been done in a similar manner as cases previously excluded from 

consideration because Rev. 1 would result in “the same or lower values.” Additionally, the cases 

eliminated for this reason all had POCs below 45%. However, NIOSH also states that 29 of the 

re-evaluated cases resulted in POCs that were also below 45%. It is unclear why these non-skin 

cancer cases were re-evaluated by NIOSH under Rev. 1, since the cases were not concerned with 

external beta dose and would likely receive only a slight increase in assigned dose from photons. 

To reiterate, all of these observations have no effect on NIOSH’s decision-making process or its 

conclusions, but are provided to help clarify the record.
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5.0 SUBTASK 4: REVIEW OF CASES

SC&A would like to request the opportunity to audit a sample set of the re-evaluated cases to 

assess whether Rev. 1 of TBD-6000 was implemented correctly. SC&A recommends selection 

of three claims affected by PER-055. We would like to review the case that had a reversal in the 

compensation decision. We would also like to review one case where the dose increased and one 

where the dose decreased, which should include a case were OTIB-0070 was employed.
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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.

AEC (U.S. Atomic Energy Commission). 1949. Simonds Saw & Steel Co. Summary Report of 

Three Surveys (Oct. 27, 1948 – Feb. 15, 1949), 1949. [SRDB ID 11996, pp. 249–254]

Adley, F.E., W.E. Gill, and R.H. Scott, 1952. Study of Atmospheric Contamination in the Melt 

Plant Building, USAEC report HW-233352 (Rev.), April 4, 1952.

Battelle 2006. Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Battelle-TBD-6000, Rev. 0, Battelle, Pacific Northwest Division, Richland, Washington, 

December 13, 2011.

Battelle 2011. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, 

Battelle-TBD-6000, Rev. 1, Battelle, Pacific Northwest Division, Richland, Washington, June 

17, 2011. SRDB Ref ID: 101251.

Christofano, E., and W.B. Harris, 1960. “The Industrial Hygiene of Uranium Refining,” 

Archives of Environmental Health, volume 1, pp. 438–460 (reprinted).

DCAS 2014. TBD-6000 Revision. DCAS-PER-055, Rev. 0. NIOSH’s Division of 

Compensation Analysis and Support, Cincinnati, Ohio. September 12, 2014.

Fleishman-Hillard 1967, “Fuel For the Atomic Age, Completion Report on St. Louis-Area 

Uranium Processing Operations, 1942-1967”. September 30, 1967.

Harris, W.B., and I. Kingsley, 1959. “The Industrial Hygiene of Uranium Fabrication.” A.M.A. 

Archives of Industrial Health, Vol. 19, May 1959. pp 76-101.

NIOSH 2010. Technical Basis Document: Basis for Development of an Exposure Matrix for 

Bethlehem Steel Corporation, Lackawanna, New York, Period of Operation: 1949–1952. 

DCAS-TKBS-0003, Rev. No. 1. National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. November 30, 2010.

NIOSH 2012. SEC Petition Evaluation Report SEC-00200. Joslyn Manufacturing. National 

Institute for Occupational Safety and Health, Cincinnati, Ohio. December 3, 2012.

OCAS 2004. Technical Information Bulletin – Estimation of Ingestion Intakes, OCAS-TIB-009, 

Rev. 0. NIOSH’s Office of Compensation Analysis and Support, Cincinnati, Ohio. April 13, 

2004.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

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

OCAS-PR-008, Rev. 2, NIOSH’s Office of Compensation Analysis and Support, Cincinnati, 

Ohio. December 6, 2006.

ORAUT 2011. Site Profile for Simonds Saw and Steel, ORAUT-TKBS-0032, Rev. 01 PC-1, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. April, 18, 2011.

ORAUT 2012. Dose Reconstruction during Residual Radiation Periods at Atomic Weapons 

Employer Facilities. ORAUT-OTIB-0070, Rev. 1, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio.

Putzier, E.A., 1982. The Past Thirty Years at Rocky Flats Plant, Rocky Flats Plant, Golden,

Colorado. November 1982.

SC&A 2009. “Issue Resolution Matrix for SC&A Findings on TBD-6000,” Revised document 

updated following the October 14, 2009, TBD-6000 Work Group Meeting. SC&A, Inc., Vienna, 

Virginia. October 28, 2009.

SC&A 2013. Supplementary Comments on Revision 1 of Battelle-TBD-6000, Rev. 0. SC&A, 

Inc., Vienna, Virginia. May 13, 2013.
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ATTACHMENT A: CORRESPONDENCE PERTAINING TO 

ORAUT-OTIB-0070

From: Neton, Jim (CDC/NIOSH/DCAS) 

Sent: Monday, June 01, 2015 9:22 AM

To: John Mauro

Subject: RE: PER-055

John,

You raise a good point. I think that TBD-6000 should refer to the guidance in TIB-0070, which 

says that the 1E-06 value needs to be reviewed for facilities that have active operations.

Jim

From: John Mauro

Sent: Friday, May 29, 2015 3:39 PM

To: Neton, Jim (CDC/NIOSH/DCAS)

Subject: PER-055

Jim,

I’m reviewing PER-055 dealing with Revision 1 to TBD-6000. One of the sections of my report 

summarizes the changes made from going from Rev 0 to Rev 1. In preparing this section of my 

report, I am taking advantage of a very thorough issues resolution matrix issued on March 9, 

2009, which shows all that all issues were resolved/placed in abeyance. In reading Rev 1, I 

noticed that section 7.1.5 uses a RF of 1E-6/m and no mention is made of OTIB-0070. However, 

in response to Issue 6 in the issues resolution matrix, reference is made to OTIB-0070, which 

resolved this issue. I am writing seeking clarification on how resuspension during the residual 

period will being handled under Rev 1 to TBD-6000. Will 1E-6/m always be used or will OTIB0070 be used?

John

Can you help me out?

John 
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ATTACHMENT B: CORRESPONDENCE THAT PROVIDED SC&A 

WITH THE UNIVERSE OF POTENTIALLY IMPACTED CASES 

IDENTIFIED BY NIOSH 

From: Allen, David (CDC/NIOSH/DCAS) 

Sent: Tuesday, June 02, 2015 1:50 PM

To: John Mauro

Subject: RE: memo

Hi John,

 Sorry I didn’t get back to you sooner, I was on vacation last week. The text search is 

something I had to get our computer folks to do. It is not a standard NOCTS query. The results 

of the search are in a spreadsheet that that I put in a folder I think you can get to (let me know if 

you can’t). I don’t know what it looks like when you log in but here is the folder hierarchy I’m 

seeing “ABRWH\ABRWH_Board_Meetings\AB Document Review\Procedures 

Subcommittee\PER-055”. I made the “PER-055” folder and put a spreadsheet in there.

On the “Cases” tab all 809 cases are listed. There are 831 lines but 22 cases are duplicated 

because they had employment at more than one of the sites.

Column A is the NIOSH ID

Column B is the site name

Column D is the disposition of the case for this PER

The “Tally” tab is where the numbers come from that appear in the PER (Column I rows 18 

through 25). You can see I categorized the disposition of the claims and then grouped them 

somewhat. Some of the claims with employment at more than one site had different dispositions 

so I had to just make a call as to what category to put them in. It made no difference whether the 

claims was evaluation just how it was tallied in the PER document.

Let me know if you can’t get this spreadsheet or if you have any questions.

Dave
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From: John Mauro

Sent: Thursday, May 28, 2015 4:24 PM

To: Allen, David (CDC/NIOSH/DCAS)

Subject: FW: memo

Dave,

In reading DCAS-PER-055, it was stated that NIOSH identified the population of claims to 

consider based on “a text search of the dose reconstruction reports for all previously completed 

claims” for any mention of ‘6000.’ However, within the custom query page of NOCTS, I am not 

able to search within the text of a specific type of document. It would be very beneficial if 

NIOSH would provide us with a list of the 809 cases they identified as the initial populations of 

claims to consider for PER-055. NIOSH has done this for SC&A in the past for PER-011 and 

PER-014. This would certainly help our review of PER-055.

Thank you,

John