Summary of Seven Document Reviews 

Approved by the Subcommittee for 

Procedure Reviews

Kathleen Behling, SC&A, Inc.

Advisory Board on Radiation and Worker Health

December 8, 2022
2

SPR-approved documents

 ORAUT-OTIB-0014, rev. 00, “Technical Information Bulletin – Assignment 

of Environmental Internal Doses for Employees Not Exposed to Airborne 

Radionuclides in the Workplace”

 ORAUT-PROC-0002, rev. 00, “Use of Integrated Modules for Bioassay 

Analysis (IMBA)”

 ORAUT-PROC-0077, rev. 00, “Dose Reconstruction Error Tracking and 

Reporting”

 OCAS-PER-003, rev. 0, “Evaluation of the Effect of Adding Ingestion 

Intakes to Bethlehem Steel Cases”

 OCAS-PER-025, rev. 0, “Huntington Pilot Plant TBD Revision”

 DCAS-PER-033, rev. 0, “Reduction Pilot Plant TBD Revision”

 DCAS-PER-038, rev. 0, “Hooker Electrochemical TBD Revisions”
3

ORAUT-OTIB-0014, rev. 00

 Title: “Technical Information Bulletin – Assignment of 

Environmental Internal Doses for Employees Not Exposed to 

Airborne Radionuclides in the Workplace”

 Issued June 22, 2004

 Provides guidance to the dose reconstructor on:

– when to assign environmental internal doses rather than workplace 

exposures to workers

– the methodology for assigning such doses
4

SC&A’s review of OTIB-0014, rev. 00

 Review submitted June 8, 2006

 Review identified one finding

 Finding discussed at the September and November 2007 SPR 

meetings and resolved during April 11, 2012, SPR meeting
5

Issue resolution for OTIB-0014 finding 1

Finding 

date

Finding description NIOSH response Finding resolution

6/8/2006 Particular care must be 

taken when assigning a 

construction worker to a 

given category of 

exposure due to the 

highly diverse nature of 

exposures that some 

construction workers 

experience.

9/25/2007. NIOSH 

agrees. ORAUTOTIB-0052 provides 

additional guidance 

regarding 

construction workers.

11/7/2007. SPR 

transferred finding 

to OTIB-0052.
6

Issue resolution for OTIB-0014 finding 1 

followup

Finding date Finding description NIOSH response Finding resolution

6/8/2006 Particular care must 

be taken when 

assigning a 

construction worker 

to a given category of 

exposure due to the 

highly diverse nature 

of exposures that 

some construction 

workers experience.

12/16/2011. OTIB-0014 provides 

guidance on assigning environmental 

internal doses. Unmonitored CTWs 

are not assigned environmental 

internal doses since they are assumed 

to be more highly exposed and better 

represented by the population of 

monitored CTWs. OTIB-0052, rev. 01, 

section 8.4, requires that internal 

doses for unmonitored CTWs be 

assigned using 50th percentile of 

coworker population with the 

applicable GSD. Therefore, OTIB0014 does not apply to either 

monitored or unmonitored CTWs.

4/11/2012. SPR 

agreed with NIOSH’s 

response and closed 

the finding.
7

Board discussion of ORAUT-OTIB-0014
8

ORAUT-PROC-0002, rev. 00

 Title: “Use of Integrated Modules for Bioassay Analysis (IMBA)”

 Issued August 14, 2003

 Provides guidance to the dose reconstructor on:

– running the IMBA software

– required IMBA documentation and file creation process for the NIOSH 

dose reconstruction (DR) process
9

SC&A’s review of PROC-0002, rev. 00

 Review submitted January 17, 2005

 Review identified three findings

 Finding discussed and resolved during the July 27, 2006, SPR 

meeting
10

Issue resolution for PROC-0002 finding 1

Finding date Finding description NIOSH response Finding resolution

1/17/2005 Procedure lacks clear 

descriptions for location of 

various functional buttons 

related to the IMBA 

program (i.e., “Start 

Calculation” button)

7/27/2006. NIOSH does 

not feel that these 

comments warrant 

revision to the procedure. 

The procedure provides 

sufficient detail so that a 

novice user can operate 

IMBA with a little effort. 

After only brief 

experience, the user has 

no need for the additional 

specificity called for by 

this comment.

7/27/2006. SPR 

agreed with NIOSH’s 

response and closed 

the finding.
11

Issue resolution for PROC-0002 finding 2

Finding date Finding description NIOSH response Finding resolution

1/17/2005 Procedure lacks 

sufficient guidance on 

evaluating results of 

bioassay calculations 

(i.e., modifying fit data).

7/27/2006. NIOSH does 

not feel that these 

comments warrant revision 

to the procedure. The 

procedure only provides 

guidance on general use 

of IMBA. It does not 

provide the dose 

reconstructor with the 

necessary tools and 

experience to reconstruct 

internal dose.

7/27/2006. SPR 

agreed with NIOSH’s 

response and closed 

the finding.
12

Issue resolution for PROC-0002 finding 3

Finding date Finding description NIOSH response Finding resolution

6/8/2006 Procedure is inadequate 

with regard to providing 

IMBA users with more 

guidance requiring 

professional judgments 

(i.e., modifying bioassay 

input assumption to 

establish better fit of 

data).

7/27/2006. NIOSH does 

not feel that these 

comments warrant 

revision to the procedure. 

The procedure only 

provides guidance on 

general use of IMBA. It 

does not provide the dose 

reconstructor with the 

necessary tools and 

experience to reconstruct 

internal dose.

7/27/2006. SPR 

agreed with NIOSH’s 

response and closed 

the finding.
13

Board discussion of ORAUT-PROC-0002
14

ORAUT-PROC-0077, rev. 00

 Title: “Dose Reconstruction Error Tracking and Reporting”

 Issued March 28, 2005

 Provides process for review, disposition, correction, tracking, 

and trending of DR report errors and comments received by 

ORAUT
15

SC&A’s review of PROC-0077, rev. 00

 Review submitted June 8, 2006

 Review identified three findings

 Findings resolved during the August 21, 2008, SPR meeting
16

Issue resolution for PROC-0077 finding 1

Finding date Finding description NIOSH response Finding resolution

6/8/2006 Discuss how this 

procedure fits into the 

overall ORAUT QA 

program.

9/25/2007. This 

procedure serves as 

one part of the overall 

Quality Management 

System (QMS) for the 

ORAU Team Dose 

Reconstruction Project, 

which is modeled on the 

requirements of ISO 

9001:2000E, Quality 

Management SystemsRequirements. 

8/21/2008. SPR 

agreed with NIOSH’s 

response and closed 

the finding.
17

Issue resolution for PROC-0077 finding 2

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The user would benefit 

from a flowchart keyed to 

text sections.

9/25/2007. We will 

consider adding a 

flowchart to the 

procedure the next time 

the procedure is 

modified or during the 

next biennial review. 

8/21/2008. SPR 

agreed with NIOSH’s 

response and closed 

the finding.
18

Issue resolution for PROC-0077 finding 3

Finding date Finding description NIOSH response Finding resolution

6/8/2006 Reference to 

financial incentives 

does not belong in a 

QA procedure.

9/25/2007. The financial 

incentive was not a driver for 

section 4.5 of the procedure. 

The CPAF goals represent 

measurable expectations from 

NIOSH that are based on 

provisions of EEOICPA, which 

ultimately benefit the energy 

employee (EE). NIOSH will 

consider modifying the text of 

section 4.5 the next time the 

procedure is modified or during 

the next biennial review.

8/21/2008. SPR 

agreed with 

NIOSH’s response 

and closed the 

finding.
19

Board discussion of ORAUT-PROC-0077
20

OCAS-PER-003, rev. 0

 Title: “Evaluation of the Effect of Adding Ingestion Intakes to 

Bethlehem Steel Cases”

 Issued January 28, 2005

 Determines the impact of changes to the Bethlehem Steel TBD

 Revision 01 of ORAUT-TKBS-0001 added intakes of uranium 

through the ingestion pathway

 Ingestion intakes will be assessed based on a fixed percentage 

of the inhalation intake

 Increase in dose will vary for each organ
21

SC&A’s review of PER-003, rev. 0

 Review submitted October 29, 2007

 Review identified four findings 

 Findings discussed during December 9, 2008, and 

May 16, 2016, SPR meetings

 Protocol prior to June 23, 2007, did not require case 

reviews
22

Issue resolution for PER-003 finding 1

Finding date Finding description NIOSH response Finding resolution

10/29/2007 Document title is 

misleading. It does not 

deal solely with 

ingestion component, 

but also recalculates 

the probability of 

causation (POC) and 

includes updated 

occupational x-ray 

data.

12/9/2008. Any time claims 

are reworked, they are 

completed in accordance 

with all current guidelines. 

Consequently, the revised 

occupational medical doses 

were included in the 

reworked claims.

12/9/2008. SC&A 

agreed with NIOSH’s 

response. The SPR 

closed the finding.
23

Issue resolution for PER-003 finding 2

Finding date Finding description NIOSH response Finding resolution

10/29/2007 PER does not specify 

which specific intake 

parameters it utilizes 

in determining the 

annual percent 

increase dose. The 

technical basis 

document (TBD) lists 

high-sided and lowsided estimate for 

inhalation.

12/9/2008. Intake 

parameters utilized in 

calculating ingestion are 

based on the high side of 

estimates.

12/9/2008. SC&A 

agreed with NIOSH’s 

response. The SPR 

closed the finding.
24

Issue resolution for PER-003 finding 3

Finding date Finding description NIOSH response Finding resolution

10/29/2007 The method used in 

order to produce a 

more precise POC is 

not clearly explained. 

If this methods stems 

from the IREP User’s 

Guide, this document 

should be referenced. 

Also, additional 

information concerning 

the “average” value 

should be added.

12/9/2008. NIOSH agrees 

that the IREP user’s guide 

should be referenced in the 

TBD.

12/9/2008. SPR 

changed status of 

finding to in 

abeyance awaiting a 

change to the TBD.
25

Issue resolution for PER-003 finding 3 followup

Finding date Finding description NIOSH response Finding resolution

10/29/2007 The method used in 

order to produce a 

more precise POC is 

not clearly explained. 

If this methods stems 

from the IREP User’s 

Guide, this document 

should be referenced. 

5/16/2016. In retrospect, 

NIOSH questioned the 

relevance of making this 

change.

5/16/2016. SC&A 

agreed, since the 

process of calculating 

a POC, as explained, 

is a standard protocol 

and would not have a 

significant impact on 

the TBD. SPR closed 

the finding.
26

Issue resolution for PER-003 finding 4

Finding date Finding description NIOSH response Finding resolution

10/29/2007 Absorption type S 

appears to be the 

most claimant 

favorable for all organs 

except the respiratory 

tract organ (ET1).

12/9/2008. NIOSH provided 

no response.

12/9/2008. SPR kept 

the finding open.
27

Issue resolution for PER-003 finding 4 followup

Finding date Finding description NIOSH response Finding resolution

10/29/2007 Absorption type S 

appears to be the 

most claimant 

favorable for all organs 

except the respiratory 

tract organ (ET1).

5/16/2016. There were no 

cases evaluated in behalf of 

PER-003 that involved ET1.

5/16/2016. SC&A did 

not have a complete 

list of all reworked 

cases but accepts 

NIOSH’s response. 

SPR closed the 

finding.
28

Board discussion of OCAS-PER-003
29

Huntington Pilot Plant PERs

 OCAS-PER-025, rev. 0, “Huntington Pilot Plant TBD 

Revision”

 DCAS-PER-033, rev. 0, “Reduction Pilot Plant TBD 

Revision”

 SC&A reviewed both PERs in its July 18, 2013, report
30

History of Huntington Pilot Plant TBD

 ORAUT-TKBS-0004, “Technical Basis Document: Basis for Development of an Exposure 

Matrix for Huntington Pilot Plant,” rev. 00 (October 2003)

 ORAUT-TKBS-0004, rev. 01 (January 2004)

 OCAS-PER-025 (September 2007) evaluated addition of electron dose in ORAUT- TKBS-0004, rev. 01 

 OCAS-TKBS-0004, “Technical Basis Document for the Huntington Pilot Plant, 

Huntington, West Virginia,” rev. 00 (August 2008), added intakes for total uranium, 

Pu-239, and Np-237

 DCAS-PER-033 (December 2011) evaluated increase in internal dose from OCAS- TKBS-0004, rev. 00

 DCAS-TKBS-0004, “Technical Basis Document for the Huntington Pilot Plant, 

Huntington, West Virginia,” rev. 01 (December 2013), added intakes for Am-241, 

Th-230, and Tc-99

 DCAS-PER-066 (November 2015) evaluated increase in internal dose in OCAS-TKBS- 0004, rev. 01
31

SC&A’s review of Huntington Pilot Plant 

documents

 SC&A’s previous reviews included:

– Attachment 3 to the 8th set of DR audit reports (reviewed May 2008)

– OCAS-TKBS-0004, rev. 00 (focused review under Subcommittee for 

Dose Reconstruction Reviews) (reviewed March 2013)

– OCAS-PER-025, rev. 0 (reviewed July 2013)

– OCAS-TKBS-0004, rev. 00 (reviewed June 2013)

– DCAS-PER-033, rev. 0 (reviewed July 2013)

– DCAS-PER-066, rev. 0 (reviewed October 2016) – the Board approved 

this document review at the August 18, 2022, meeting
32

Huntington Pilot Plant history

 Alternative name: Reduction Pilot Plant

 Covered period: 1951–1963, 1978–1979

 Supplied nickel powder used to make gaseous diffusion barrier 

for Paducah and Portsmouth gaseous diffusion plants

 Sources of feed material were nickel oxide and barrier scrap 

contaminated with uranium and associated radionuclides from 

the uranium enrichment process 
33

OCAS-PER-025, rev. 0

 Title: “Huntington Pilot Plant TBD Revision”

 Issued September 28, 2007

 Determines the impact of revision 01 changes to the 

Huntington Pilot Plant TBD

 Revision added external electron dose

 Revision impacted cases where the external target organ was 

skin, breast, or testes
34

DCAS-PER-033, rev. 0

 Title: “Reduction Pilot Plant TBD Revision”

 Issued December 9, 2011

 Determines the impact of changes introduced in the Huntington 

Pilot Plant TBD, OCAS-TKBS-0004, which superseded 

ORAUT-TKBS-0004

 Revision modified operator inhalation intakes from 

3.83 pCi/day to 44 pCi/day

 Revision decreased dose in other exposure pathways 
35

Subtask 1 review of PER-025, rev. 0, and 

PER-033, rev. 0

 Subtask 1: Assess NIOSH’s evaluation of the issues prompting PERs and 

their potential impact on DR

 SC&A reviewed technical changes to applicable revisions of the TBD

 Confirmed electron doses were added and require assessment of skin, 

breast, and testes doses in ORAUT-TKBS-0004, rev. 01, as addressed 

under PER-025

 Verified OCAS-TKBS-0004, rev. 00, modified inhalation intakes for 

operators, prompting PER-033 to evaluate impact of increased internal 

dose

 No findings under subtask 1
36

Subtask 2 review of PER-025, rev. 0, and 

PER-033, rev. 0

 Subtask 2: Assess NIOSH’s specific methods for corrective 

action

 SC&A reviewed previous versions of TBD

 Confirmed PER-025 corrective actions properly address 

ORAUT-TKBS-0004, rev. 01, modifications

 Confirmed PER-033 corrective actions properly address 

revisions in OCAS-TKBS-0004, rev. 00

 No findings under subtask 2
37

Subtask 3 review of PER-025, rev. 0

 Subtask 3: Evaluate PER’s stated approach for identifying the 

number of DRs requiring reevaluation of dose

 NIOSH identified one case completed for the target organs with 

POC <50% prior to TBD revision

 SC&A searched NOCTS to verify only one case impacted

 SC&A verified NIOSH reworked the one case

 SC&A had no findings under subtask 3 for PER-025
38

Subtask 3 review of PER-033, rev. 0

 Subtask 3: Evaluate PER’s stated approach for identifying the number 

of DRs requiring reevaluation of dose

 NIOSH identified 32 cases:

– POC <50% prior to TBD revision

– employed between 1956–1963 or 1978–1979

 NIOSH’s rework of cases:

– 12 cases resulted in higher POC

– 20 cases resulted in decreased POC

– highest reworked POC did not exceed 50%

 SC&A searched NOCTS to verify 32 cases impacted

 SC&A verified NIOSH reworked the 32 cases

 SC&A had no findings under subtask 3 for PER-033
39

Subtask 4 review of PER-025, rev. 0, and 

PER-033, rev. 0

 Subtask 4: Conduct audits of a sample set of DRs affected 

by PER

 PER-025 evaluated only 1 case; SC&A recommended 

reviewing this case

 PER-033 evaluated 32 cases; SC&A recommended 

selecting cases based on the criteria:

–Internal dose assigned during 1956–1963 and/or 1978–1979

–Shallow dose assigned to the hands and forearms for equipment 

operator or maintenance worker during 1956–1963 and/or 1978–

1979
40

PER-025 subtask 4 case review process

 SC&A submitted its subtask 4 review of PER-025 on 

December 5, 2013

 SC&A presented its review to the SPR at the February 13, 

2014, meeting

 SC&A reviewed the one case impacted by PER-025

 Review evaluated only shallow dose calculations, as 

addressed under PER-025

 SC&A identified one finding
41

PER-025 case background

 EE worked at Huntington Pilot Plant for many years during the 

covered period

 No records of external or internal monitoring available

 EE classified as a production worker

 Diagnosed with a qualifying cancer while employed 
42

Comparison of NIOSH’s reworked doses and 

original doses for PER-025 case

Dose categories Reworked vs. original dose 

percentage

External ~87% decrease

Occupational medical ~96% decrease

Internal ~174% increase

Total ~82% decrease

POC ~89% increase
43

Original shallow dose for PER-025 case 

 DR performed in 2003 

 TBD did not recommend assigning shallow dose

 No shallow dose assigned
44

Reworked shallow dose for PER-025 case 

 Case was reworked for PER-025 and change in employment 

dates

 Rework calculated external and internal doses based on 

production worker category

 However, rework did not include shallow dose
45

Issue resolution for PER-025 subtask 4, 

finding 1

Finding 

date

Finding description NIOSH followup Finding resolution

12/5/2013 Since worker had 

potential for shallow dose 

and case resubmitted for 

DR based on PER-025, 

shallow dose should have 

been assigned. SC&A 

calculated the shallow 

dose, which would have 

added 0.018 rem/yr for 

4 years of employment.

2/13/2014. NIOSH agrees. 

Upon further review, NIOSH 

determined that an error

correction would not impact 

compensability. Therefore, no 

further action is necessary.

2/13/2014. SPR 

closed finding.
46

PER-033 case reviews

 Two cases selected for review

 Subtask 4 review submitted January 15, 2014

 SC&A presented its report to the SPR at the February 13, 

2014, meeting

 Review evaluated shallow dose to the hand/forearm and 

internal dose

 SC&A had no findings
47

PER-033 case 1 background

 EE worked at Huntington Pilot Plant for several years

 EE worked throughout the site

 No records of external or internal monitoring available

 Diagnosed with qualifying cancer many years after termination 

of employment
48

Comparison of NIOSH’s reworked doses and 

original doses for PER-033 case 1

Dose categories Reworked vs. original dose 

percentage

External photon ~69% decrease

External electron ~77% decrease

Occupational medical ~145% increase

Internal ~87% increase

Total ~52% decrease

POC ~42% decrease
49

Original internal and shallow dose calculations for 

PER-033 case 1 

 DR performed in 2004 as an overestimate of dose 

 Internal dose:

– Used internal intake values from table 5 of ORAUT-TKBS-0004, rev. 01

– Calculated doses using the chronic annual dose workbook (CADW) 

– Total internal dose of less than 0.010 rem assigned

 Shallow dose:

– Annual dose of 0.85 rem assigned to hand/forearm, based on OCASTKBS-0004, rev. 00

– Entered in IREP as electrons >15 keV
50

Reworked internal and shallow dose 

calculations for PER-033 case 1 

 Internal dose:

– Used production worker inhalation and ingestion intake values from 

table 5 of OCAS-TKBS-0004, rev. 00

– Calculated doses using CADW for total uranium, Pu-239, Np-237 

– Compared absorption types as specified in table 5

– Resulted in assigning a total internal dose of <0.100 rem

 Shallow dose:

– Annual shallow dose of 0.270 rem assigned, based on nonoperator 

values in table 6 of OCAS-TKBS-0004, rev. 00
51

SC&A’s conclusions about internal and shallow 

dose calculations for PER-033 case 1 

 Concurs that EE should be classified as a nonproduction worker

 Internal dose:

– Verified correct inhalation and ingestion intake values taken from table 5 of 

OCAS-TKBS-0004, rev. 00

– Confirmed the greater dose was assigned considering the potential solubility 

types

– Verified intake values appropriately entered in CADW

 Shallow dose:

– Confirmed correct shallow dose values assigned

– Annual doses correctly entered in IREP

 No findings about the rework of case 1
52

PER-033 case 2 background

 EE worked at Huntington Pilot Plant for many consecutive 

years

 EE worked throughout the site

 No records of external or internal monitoring available

 Diagnosed with qualifying cancer during employment period 
53

Comparison of NIOSH’s reworked doses and 

original doses for PER-033 case 2

Dose categories Reworked vs. original dose 

percentage

External ~75% decrease

Occupational medical ~37% decrease

Internal ~727% increase

Total ~250% increase

POC ~56% increase
54

Original internal dose calculations for 

PER-033 case 2 

 DR performed in 2003 as an overestimate of dose 

 Used internal intake values from table 5 of ORAUT-TKBS0004, rev. 00

 Calculated doses using CADW 

 Total internal dose of >2.0 rem assigned
55

Reworked internal dose calculations for 

PER-033 case 2 

 Used production worker inhalation and ingestion intake values 

from table 5 of OCAS-TKBS-0004, rev. 00

 Calculated doses using CADW for total uranium, Pu-239, 

Np-237 

 Compared absorption types as specified in table 5

 Resulted in assigning a total internal dose of >18.0 rem
56

SC&A’s conclusions about internal calculations 

for PER-033 case 2 

 Concurs that EE should be classified as a production worker 

 Verified correct inhalation and ingestion intake values taken 

from table 5 of OCAS-TKBS-0004, rev. 00

 Confirmed the greater dose was assigned considering the 

potential solubility types

 Verified intake values correctly entered in CADW

 No findings about the rework of case 2
57

Board discussion of OCAS-PER-025 and 

DCAS-PER-033
58

DCAS-PER-038, rev. 0

 Title: “Hooker Electrochemical TBD Revisions”

 Issued July 24, 2012

 Determines the impact of changes to the Hooker 

Electrochemical TBDs
59

Hooker Electrochemical TBD history

 Initial guidance in Battelle-TBD-6001 (appendix AA), June 15, 

2007

 Stand-alone TBD (DCAS-TKBS-0009) issued April 4, 2011

– Uranium intakes increased during the operational years for 

nonoperator intakes 

– Shallow dose rates increased during the residual period for all job 

categories

 Revision 1 to DCAS-TKBS-0009 issued June 16, 2011

– Corrected errors in tables 2, 3, and 6

– Changes caused external doses to operators to decrease during the 

operational period
60

SC&A’s review of PER-038, rev. 0

 Subtask 1–3 review submitted May 20, 2013

 No findings identified

 Review discussed during the November 7, 2013, SPR 

meeting

 Subtask 4 (case review) submitted October 16, 2014 

 No findings identified

 Subtask 4 report discussed at the November 25, 2014, 

SPR meeting 
61

Subtask 1 review of PER-038, rev. 0

 Subtask 1: Assess NIOSH’s evaluation of the issues prompting PERs and 

their potential impact on DR

 SC&A compared changes made in applicable revisions of DCAS-TKBS0009

 Confirmed:

– Uranium intakes increased for nonoperators during operations years in TBD rev. 0

– Shallow dose rates added for all job categories during the residual period in TBD 

rev. 0

– Uranium intakes decreased for operators during operational years in TBD rev. 1

 No doses or intakes were higher in TBD rev. 1

 No findings under subtask 1
62

Subtask 2 review of PER-038, rev. 0 

 Subtask 2: Assess NIOSH’s specific methods for corrective 

action

 SC&A reviewed Battelle-TBD-6001, appendix AA, in 

September 2010

 SC&A reviewed DCAS-TKBS-0009, rev. 1, in March 2013

–Review identified 6 findings 

–Findings resolved under the URAWE Work Group

 Confirmed PER-038 corrective actions properly address 

ORAUT-TKBS-0009, rev. 0 and rev. 1, modifications

 No findings under subtask 2
63

PER-038 subtask 3 population criteria

 Subtask 3: Evaluate PER’s stated approach for identifying the number of DRs 

requiring reevaluation of dose

 NIOSH identified two populations of potentially affected cases:

– Population 1: 

• POC <50%

• DR approved on or prior to April 4, 2011 (issue date of TBD rev. 0)

• Employed at Hooker during the residual period

• Diagnosed with nonqualifying cancer (only shallow dose increased)

• 14 cases identified

– Population 2:

• POC <50%

• DR approved on or prior to April 4, 2011 (issue date of TBD rev. 0)

• Employed at Hooker during operational period

• 39 cases identified
64

PER-038 subtask 3 DR reworks

 NIOSH’s rework of cases:

–53 total cases identified

–33 cases assigned to operator category

–20 cases reevaluated

 Reevaluation results:

–POC <45% for 19 cases

–POC 45–50% for 1 case
65

SC&A’s subtask 3 review of PER-038

 Concurs with selection criteria 

 Determined selection criteria encompass the universe 

of potentially affected DRs 

 Verified none of these DRs exceed a 50% POC

 SC&A had no findings under subtask 3
66

Subtask 4 review of PER-038, rev. 0

 Subtask 4: Conduct audits of a sample set of DRs 

affected by PER

 SC&A recommended that audits be deferred until 

DCAS-TKBS-0009, rev. 1, findings were resolved

 Advisory Board ultimately selected 3 cases for review
67

PER-038 case reviews

 Subtask 4 review of 3 cases submitted October 16, 

2014

 Review evaluated reworked external and internal doses

 NIOSH’s rework documented in a one-page MS Word 

file

 All POCs <50%; therefore, no formal DR revision 

performed or submitted to U.S. Department of Labor
68

PER-038 case 1 background

 EE worked at Hooker for during operational period and portion 

of residual period

 EE worked throughout the site

 No records of external or internal monitoring available

 Diagnosed with qualifying cancer after employment termination 
69

Comparison of NIOSH’s reworked doses and 

original doses for PER-038 case 1

Dose categories Reworked vs. original dose 

percentage

External ~99% decrease

Occupational medical No change

Internal ~77% increase

Total ~39% increase

POC ~39% increase
70

Original external dose calculations for 

PER-038 case 1 

 DR performed in 2008 as an overestimate of dose

 Assumed EE’s job category nonoperator 

 Used external dose values from table AA.3 of Battelle-TBD6001, appendix AA

 Applied applicable exposure-to-organ dose conversion factor 

(DCF) value

 Assigned annual doses as 100% 30–250 keV in IREP

 Total external dose of ~2 rem assigned
71

Reworked external dose calculations for 

PER-038 case 1 

 Assumed EE’s job category as operator

 Used “material” and “contamination” values from table 5 of 

DCAS-TKBS-0009, rev. 1, for operational period

 Used values from table 6 of DCAS-TKBS-0009, rev. 1, for 

residual period

 Applied applicable exposure-to-organ DCF value

 Assigned annual doses as 100% 30–250 keV in IREP

 Total external dose of <0.100 rem calculated
72

Original internal dose calculations for 

PER-038 case 1 

 No bioassay records identified

 Assumed EE directly involved in uranium operations and 

source material was inhaled and ingested

 Used internal intake values for nonoperator from table AA.1 of 

Battelle-TBD-6001, appendix AA

 Calculated doses using IMBA and assuming type S solubility 

 Total internal dose of nearly 8 rem assigned
73

Reworked internal dose calculations for 

PER-038 case 1 

 Used inhalation and ingestion intake values in DCAS-TKBS0009, rev. 1, for operational and residual periods

 Compared solubility types M and S in IMBA, with type S 

resulting in higher dose

 Annual alpha doses entered in IREP as constants 

 Calculated total internal dose of >14 rem
74

SC&A’s conclusions about external and 

internal calculations for PER-038 case 1 

 External dose:

– Confirmed appropriate operator values used from table 5 of TBD rev. 1 for operational 

period

– Confirmed appropriate residual doses selected from table 6 of TBD rev. 1

– Noted: TBD recommends operational period contamination dose distributions of 

80.3% <30 keV, 12.3% 30–250 keV, and 7.5% <250 keV; assuming 100% 30–250 

keV is claimant favorable and resulted in slight increase in POC

 Internal dose:

– Verified correct inhalation and ingestion intake values taken from DCAS-TKBS-0009, 

rev. 1

– Confirmed greater dose was assigned considering solubility types M and S

– Doses entered in IREP with appropriate exposure parameters and dose distribution

 SC&A re-ran IREP and confirmed NIOSH’s POC value

 No findings about the rework of case 1
75

PER-038 case 2 background

 EE worked at Hooker for during operational period and portion 

of residual period

 EE worked in a nonoperator role

 No records of external or internal monitoring available

 Diagnosed with qualifying cancer many years after 

employment termination 
76

Comparison of NIOSH’s reworked doses and 

original doses for PER-038 case 2

Dose categories Reworked vs. original dose 

percentage

External ~87% decrease

Occupational medical Modest decrease

Internal ~1922% increase

Total ~1618% increase

POC ~1010% increase
77

Original external dose calculations for 

PER-038 case 2 

 DR performed in 2008 using claimant-favorable assumptions

 Assumed EE’s job category as nonoperator

 Used external dose values from table AA.3 of Battelle-TBD6001, appendix AA

 Applied applicable exposure-to-organ DCF value

 Assigned annual doses as 100% 30–250 keV in IREP

 Total external dose of <0.100 rem assigned
78

Reworked external dose calculations for 

PER-038 case 2 

 Assumed EE’s job category as operator/laborer

 Used “material” and “contamination” values from table 5 of 

DCAS-TKBS-0009, rev. 1, for operational period

 Used values from table 6 of DCAS-TKBS-0009, rev. 1, for 

residual period

 Applied applicable exposure-to-organ DCF value

 Assigned annual doses as 100% 30–250 keV in IREP

 Total external dose of <0.010 rem calculated
79

Original internal dose calculations for 

PER-038 case 2 

 No bioassay records identified

 Assumed EE directly involved in uranium operations and 

source material was inhaled and ingested

 Used internal intake values for clerical worker from table AA.1 

of Battelle-TBD-6001, appendix AA

 Calculated doses using IMBA and assuming type S solubility 

 Total internal dose of <1.0 rem assigned
80

Reworked internal dose calculations for 

PER-038 case 2 

 Used inhalation and ingestion intake values from DCAS-TKBS0009, rev. 1, for operational and residual periods

 Assumed 3 intake regimes: operational inhalation, operation 

ingestion, and residual inhalation

 Compared solubility types M and S in IMBA, with type S 

resulting in higher dose

 Annual alpha doses entered in IREP as constants 

 Calculated total internal dose of >13 rem
81

SC&A’s conclusions about external and 

internal calculations for PER-038 case 2 

 External dose:

– Confirmed appropriate operator values used from table 5 of TBD rev. 1 for operational 

period

– Confirmed appropriate residual doses selected from table 6 of TBD rev. 1

– Noted: TBD recommends operational period contamination dose distributions of 

80.3% <30 keV, 12.3% 30–250 keV, and 7.5% <250 keV; using 100% 30–250 keV is 

claimant favorable and resulted in slight increase in POC

 Internal dose:

– Verified correct inhalation and ingestion intake values taken from DCAS-TKBS-0009, 

rev. 1

– Confirmed greater dose was assigned considering solubility types M and S

– Doses entered in IREP with appropriate exposure parameters and dose distribution

 SC&A re-ran IREP and confirmed NIOSH’s POC value

 No findings about the rework of case 2
82

PER-038 case 3 background

 EE worked at Hooker briefly during operational period and the 

entire residual period

 EE worked throughout the plant

 No records of external or internal monitoring available

 Diagnosed with qualifying cancers many years after 

employment termination 
83

Comparison of NIOSH’s reworked doses and 

original doses for PER-038 case 3

Dose categories Reworked vs. 

original dose 

percentage for 

cancer 1

Reworked vs. 

original dose 

percentage for 

cancer 2

External ~67% decrease ~100% decrease

Occupational medical No change Modest decrease

Internal No change ~48,800% increase

Total ~63% decrease ~62% decrease

POC (a) (a)

(a) Combined reworked POC decreased 22% versus the combined original POC.
84

Original external dose calculations for 

PER-038 case 3 

 DR performed in 2010 using claimant-favorable assumptions

 Assumed EE’s job category as an operator 

 Used external dose values from table AA.3 of Battelle-TBD6001, appendix AA

 Applied applicable exposure-to-organ DCF values

 Assigned annual doses as 100% 30–250 keV in IREP

 Total external dose of >3.0 rem assigned to cancer 1

 Total external dose of >5.0 rem assigned to cancer 2
85

Reworked external dose calculations for 

PER-038 case 3 

 Assumed EE’s job category as operator/laborer

 Used “material” and “contamination” values from table 5 of DCAS-TKBS- 0009, rev. 1, for operational period

 Operational doses corrected for partial year of exposure

 Used values from table 6 of DCAS-TKBS-0009, rev. 1, for residual period

 Applied applicable exposure-to-organ DCF values

 Assigned annual doses as 100% 30–250 keV in IREP

 Total cancer 1 external dose assigned:

– photon dose of <0.100 rem 

– electron dose of >1.0 rem

 Total external dose of <0.100 rem assigned for cancer 2
86

Original internal dose calculations for 

PER-038 case 3 

 No bioassay records identified

 Assumed EE directly involved in uranium operations and 

source material was inhaled and ingested

 Used internal intake values for operator from table AA.1 of 

Battelle-TBD-6001, appendix AA

 Calculated doses using IMBA and assuming type M solubility 

 Total internal dose of <0.100 rem assigned to cancers 1 and 2
87

Reworked internal dose calculations for 

PER-038 case 3 

 Used inhalation and ingestion intake values from DCAS-TKBS0009, rev. 1, for operational and residual periods

 Assumed 3 intake regimes: operational inhalation, operation 

ingestion, and residual inhalation

 Compared solubility types M and S in IMBA, with type M 

resulting in higher dose for cancer 1 and type S for cancer 2

 Annual alpha doses entered in IREP as constants 

 Calculated total internal dose of <0.100 rem for cancer 1

 Calculated total internal dose of nearly 2.0 rem for cancer 2
88

SC&A’s conclusions about external dose 

calculations for PER-038 case 3 

 Confirmed appropriate operator values used from table 5 of 

TBD rev. 1 for operational period

 Confirmed appropriate residual doses selected from table 6 of 

TBD rev. 1

 SC&A’s calculations matched NIOSH’s assigned doses

 Noted: TBD recommends entering operational period 

contamination doses in IREP as 80.3% <30 keV, 12.3% 30–

250 keV, and 7.5% <250 keV; using 100% 30–250 keV is 

claimant favorable and resulted in slight increase in POC
89

SC&A’s conclusions about internal dose and 

POC calculations for PER-038 case 3 

 Internal dose:

– Verified correct inhalation and ingestion intake values taken from 

DCAS-TKBS-0009, rev. 1

– Confirmed greater dose was assigned considering solubility types M 

and S

– SC&A was able to recalculate doses that matched NIOSH’s assigned 

doses

– Doses entered in IREP with appropriate exposure parameters and 

dose distribution

 SC&A re-ran IREP and confirmed NIOSH’s POC value

 No findings about the rework of case 3
90

Board discussion of DCAS-PER-038