Review of NIOSH’s Program 

Evaluation Report DCAS-PER-093, 

“Texas City Chemicals”

Rose Gogliotti, MS, SC&A, Inc.

Advisory Board on Radiation and Worker Health, 

Subcommittee for Procedure Reviews

February 16, 2023
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DCAS-PER-093 purpose

Address the impacts of issuing revision 01 to the technical basis 

document (TBD) for Texas City Chemicals (TCC), DCAS-TKBS0011, on previously completed cases 
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TCC timeline
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Changes necessitating PER

 Revision 01 of the TBD provides updated residual ingestion 

intake rates that assume the initial residual ingestion intake 

rate is equal to the ingestion intake rate during uranium 

recovery operations

– Ingestion intakes increased from 1955 through 1977

– No other dose or intake values changed between rev. 00 and rev. 01
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PER selection criteria

Employment 

Targeted 

claims

during 

residual 

period

POC 

below 50%
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PER selection criteria: Targeted claims

Targeted 

claims = 

14 total
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NIOSH’s evaluation of impacted claims

 14 claims reevaluated

– 13 claims had new POC <45%

– 1 claim had a POC between 45% and 50%

– None found to increase POC above 50%

 No claims requested back from the U.S. Department of Labor

 SC&A recommended a single case from the 14 impacted cases 

be selected for review

 In September 2022, the SPR agreed with SC&A’s 

recommendation and tasked SC&A to review one case
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Case details

 EE employed at TCC during a portion of the operational and 

residual years

 Short TCC employment length

 EE worked throughout the plant

 No monitoring history

 multiple cancers 

 SC&A’s review identified 4 findings and 1 observation
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Finding 1: Background information

The dates in table 7-11 changed between the issuance of the 

SEC petition evaluation report (SEC ER) and the issuance of 

TBD rev. 00 (renumbered table 11).

Document detail ER rev. 1 TBD rev. 00

Table number in document 7-11 11

Start of residual period doses April 1, 1955 October 1, 1955

Operations period photon dose (rem/day) 0.00060 0.00060

Residual period photon dose (R/day) 0.00016 0.00016
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Finding 1: Impact of issue

 Longer operations period results in larger dose

 Most cases impacted by this change were caught by the PER’s 

broad selection criteria

 If a case was completed before November 2, 2017 (TBD 

rev. 00 issued) with employment that ended between April 1, 

1955, and October 1, 1955, this change would be missed by 

the PER selection criteria

– Unlikely 6 months of external dose would have a significant impact on 

a case

– NIOSH should explore and verify this to be true
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Comparison of original and reworked case

Dose categories Percent change in dose assigned in rework

External <10%

Medical x-ray No change

Internal <10%

Total <10%

Cancer-specific POC 10–25%

Final POC ~10%
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Internal dose

Original:

 Used inhalation and 

ingestion intake values in 

table 7-7 of the TCC SEC 

ER, revision 01 

 CAD used to assign doses

Reworked:

 Used inhalation and 

ingestion intake values in 

tables 7, 8, and 9 of the TCC 

TBD, revision 01

 CAD used to assign doses

– Internal dose increased by 

<10%
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Finding 2: Incorrect inhalation intakes

 Finding 2: Incorrect inhalation intake assigned for some 

radionuclides from April 1, 1954, through September 30, 1955

 SC&A found that NIOSH assigned an intake of 34.9 pCi/day of 

U-238, Th-230, U-234, Ra-226, Pb-210, and Po-210 from 

April,1 1954, through September 30, 1955

 Table 7 of the TBD lists this inhalation intake as 39.4 pCi/day

 This resulted in a reduced intake and dose assigned to target 

organs
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Finding 3: Missing ingestion intakes

 NIOSH did not assign an ingestion intake of 0.021 pCi/day Th232, Ra-228, and Th-228 during the period from April 1, 1954, 

through September 30, 1955, as specified in table 7 of the 

TBD. 

 SC&A believes this would underestimate dose by under 

0.001 rem
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Finding 4: Missing ingestion intakes

 NIOSH did not assign an ingestion intake of 0.307 pCi/d Ra226 during the period from October 1, 1955, through 

December 31, 1955, as specified in table 7 of the TBD. 

 SC&A believes this would underestimate dose by under 

0.001 rem
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Observation 1

 SC&A reviewed the Web CAD output and found that the TCC 

inhalation and ingestion default values are not a selection 

option in the dropdown window. 

 Therefore, when a dose reconstructor wants to assign these 

doses, they must manually enter each of the CAD entries from 

tables 7, 8, and 9 in the TBD. 

 Although SC&A is unaware of anything that requires the site 

values be available in the CAD, prepopulated values reduce 

the likelihood of data entry errors.
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Questions?