Summary of Five Document Reviews 

Approved by the Subcommittee for 

Procedure Reviews

Kathleen Behling, SC&A, Inc.

Advisory Board on Radiation and Worker Health

April 19, 2023
2

SPR-approved documents

 DCAS-PER-045, rev. 0, “Aliquippa Forge TBD Revision”

 DCAS-PER-076, rev. 0, “Aliquippa Forge TBD”

 DCAS-PER-077, rev. 0, “Simonds Saw and Steel TBD”

 DCAS-PER-043, rev. 0, “Internal Dosimetry Organ, External 

Dosimetry Organ, and IREP Model Selection by ICD-9 Code 

Revision”

 DCAS-PER-059, rev. 0, “Norton Company”
3

DCAS-PER-045

 Title: “Aliquippa Forge TBD Revision”

 Issued April 2012 due to revisions to Aliquippa Forge site 

profile (ORAUT-TKBS-0021)

 Revision resulted from identification of new data and 

incorporating data from revision 01 of ORAUT-OTIB-0070, 

“Dose Reconstruction During Residual Radioactivity Periods at 

Atomic Weapons Employer Facilities”

– increased external dose during most of the residual period

– decreased internal dose for most years but increased for some
4

Aliquippa Forge Facility operational history

 Produced uranium rods from uranium billet 

 Rolling operation started in January 1947 through the Atomic 

Energy Commission (AEC) contract period ending on 

February 28, 1950 

 Residual period was from March 1, 1950, through 

December 31, 1987, and again from January 1, 1989, through 

December 31, 1992
5

SC&A’s review of PER-045

 Review submitted August 20, 2014

 Review identified 8 findings and 2 observations

 All findings and observations were discussed and closed at the 

Subcommittee for Procedure Reviews (SPR) meeting on 

May 16, 2016
6

Subtask 1 review of PER-045 

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

PERs and their potential impact on dose reconstruction (DR).

 SC&A identified two observations:

– Observation 1: NIOSH should rephrase the role of ORAUT-OTIB-0070 

in section 2.0 of DCAS-PER-045.

– Observation 2: Neither rev. 00 nor rev. 01 of the Aliquippa Forge TBD 

(ORAUT-TKBS-0021) was ever reviewed or audited by SC&A.
7

Subtask 2 review of PER-045

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

 SC&A previously reviewed OTIB-0070

 SC&A performed a focused review of Aliquippa Forge TBD, rev. 01, 

pertaining to residual period doses

 SC&A identified 7 findings:

– Finding 1: Failure to account for a previous decontamination and 

decommissioning effort

– Finding 2: Backward extrapolation by means of the NIOSH-derived source 

term depletion factor is inappropriate

– Finding 3: SC&A was unable to match inhalation and ingestion rates in 

table 3

– Finding 4: Failure to acknowledge and use a reported air sample that at 

180 dpm/m3 was ~20-fold higher than NIOSH’s value of 8.94 dpm/m3
8

Subtask 2 review of PER-045, findings 5–7

 Finding 5: NIOSH’s “conversion” of empirically measured air 

concentration 8.94 dpm/m3 that was reduced more than 42-fold to a 

“modeled air concentration” represents a major error as the starting 

point for deriving inhalation and ingestion doses for years 1950 to 

1995. 

 Finding 6: Inappropriate use of the resuspension factor 1×10-6 m-1

for post-AEC work during active operations at the Aliquippa Forge 

facility.

 Finding 7: Use of 1992 survey measurement (350 dpm/100 cm2) 

removable alpha contamination postdates the “interim 

decontamination efforts” conducted from October to 

December 1988.
9

Subtask 3 review of PER-045

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

number of DRs requiring reevaluation of dose

 SC&A had one finding

 Finding 8: NIOSH’s methodology for deriving inhalation and 

ingestion doses does not comply with the use of available data 

and the prioritization of recommended methods defined in 

ORAUT-OTIB-0070, rev. 01
10

Issue resolution for PER-045 findings 1–8

Finding 

date

Finding description NIOSH response Finding 

resolution

8/20/2014 Findings 1–8 as described in 

previous slides.

3/24/2015. SC&A submitted its 

review of NIOSH’s response to the 

PER-045 findings. In summary, 

NIOSH agreed with finding 5, which 

involved incorrectly deriving air 

concentration for 1950. All other 

findings were tied to the faulty 

assumptions used to reconstruct 

that air concentration.

1/23/2015. NIOSH 

provided a response 

to the 8 findings.

5/16/2016. SPR 

closed all findings.
11

Subtask 4 review of PER-045

 ABRWH selected one reworked case for SC&A’s review 

April 2021, based on following criteria:

– assignment of external dose during the residual period

– assignment of internal dose during the residual period

 SC&A reviewed reworked case in December 2021 to determine 

if external and internal doses were correctly assessed in 

accordance with PER-045
12

NIOSH reworked DR for PER-045

 NIOSH’s rework of the case:

– Used applicable DR tools 

– Recalculated all annual doses 

– Re-ran IREP

 Revised DR report not sent to DOL because the compensation 

decision did not change
13

PER-045 case background

 Energy employee (EE) worked at Aliquippa Forge for two brief 

timeframes during the residual period

 EE worked throughout site

 EE was not monitored for radiation exposure

 Diagnosed with qualifying cancers more than two decades 

after employment termination
14

Comparison of NIOSH’s reworked doses and 

original doses for PER-045 case

Dose categories Reworked vs. original dose percentage

External ~ 207% increase

Occupational medical No change 

Internal ~ 80% decrease

Total ~ 39% decrease

POC ~ 158% decrease
15

Original external dose calculations for 

PER-045 case

 Used external exposure values from table 13 of ORAUT-TKBS0021, rev. 00 PC-1 

 Doses prorated for partial years of employment

 Dose conversion factors (DCFs):

– DR report stated DCF values based on thyroid (1.440) as the surrogate 

organ 

– Doses actually calculated using the maximum thymus DCF values 

(1.692)

– This resulted in a slight overestimate of dose

 Assigned dose to all cancer sites ~0.300 rem
16

Reworked external dose calculations for 

PER-045 case

 Used external exposure values from table 5-1 of TBD rev. 01

 No prorating for partial years of employment

 Applied exposure DCF of 1.44 for the thyroid as the surrogate 

organ

 Assigned dose of ~1.100 rem to all cancer sites
17

SC&A’s conclusions on external dose for 

PER-045 case

 Appropriate dose values selected from table 5-1 of TBD rev. 01

 Correct surrogate organ was selected, based on ORAUT-OTIB0005, rev. 05

 Appropriate DCF value was applied

 No partial year prorating applied, as an efficiency and claimantfavorable measure

 Review confirmed doses were accurately entered in IREP 

 As expected, reworked DR external dose increased from that 

calculated in the original DR

 SC&A had no findings about reworked external dose assignment
18

Comparison of internal dose calculations for 

PER-045 case 

Original DR

 Used inhalation and ingestion 

intakes from table 13 of TBD 

rev. 00 PC-1 

 Used IMBA to compare doses 

from uranium absorption 

types M and S, with type S 

resulting in the higher dose

 Assigned dose of ~2.200 rem 

to all cancer sites

Reworked DR

 Used inhalation and ingestion 

exposure values from table 5-1 

of TBD rev. 01 

 Compared solubility types M 

and S, with type S resulting in 

higher dose

 Using CADW, calculated dose 

of ~0.400 rem to all cancer 

sites
19

SC&A’s conclusions on internal dose for 

PER-045 case

 Reviewed NIOSH’s CADW files for the reworked DR and 

confirmed that correct intake values were used, based on data 

in table 5-1 of TBD rev. 01 

 SC&A verified: 

– Type S solubility resulted in the higher dose 

– Dose data appropriately entered in IREP table

– Doses were assessed to the date of cancer diagnoses

 SC&A had no findings about the assessment of internal dose in 

the reworked case
20

Board discussion of DCAS-PER-045
21

DCAS-PER-076, rev. 0

 Title: “Aliquippa Forge TBD”

 Issued February 15, 2017

 Resolution of PER-045 findings/observations resulted in the 

issuance of rev. 02 of Aliquippa Forge TBD on November 16, 

2015, prompting PER-076

 Revision resulted in an increase in external and internal doses 

during the residual period (1950–1995)

 Since SC&A reviewed prior TBDs, SPR determined only 

subtask 4 review was necessary
22

PER-076 subtask 4 review

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

PER

 NIOSH reevaluated 21 cases:

– One case resulted in a POC >52%

– Remaining cases resulted in a POC <45%

 SC&A recommended selecting cases based on the criteria:

– Assignment of external dose during the residual period

– Assignment of internal dose during the residual period
23

PER-076 subtask 4 case review process

 SC&A submitted its subtask 4 review of PER-076 on April 18, 

2018

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

2019, meeting

 One case was reviewed in which the EE was assigned external 

and internal dose during the residual period

 SC&A had no findings
24

PER-076 case background

 EE worked at Aliquippa Forge for two timeframes during the 

residual period

 EE worked primarily in one building at the site

 No records of external or internal monitoring available

 Diagnosed with a qualifying cancer several decades after 

employment termination
25

Comparison of NIOSH’s reworked doses and 

original doses for PER-076 case

Dose categories Reworked vs. original dose percentage

External 548% increase

Internal 325% increase

Total 547% increase

POC 452% increase
26

Original external dose for PER-076 case

 DR performed in 2008

 External doses based on values in table 13 of ORAUT-TKBS0021, rev. 00 PC-1

 Applied applicable OCAS-IG-001 DCF

 Total external dose <1.0 rem

 Annual doses entered in IREP as lognormal distribution with 

geometric standard deviation (GSD) of 1.5
27

Reworked external dose for PER-076 case

 DR performed in 2016

 External doses based on annual values in table 5-1 of ORAUTTKBS-0021, rev. 02

 Applied applicable IG-001 DCF

 Total external dose >4.0 rem

 Significant increase in external dose reflects the use of a 

revised starting air concentration value, which increased by a 

factor of 42 between rev. 01 and rev. 02 of the TBD

 Annual doses entered in IREP as constant values
28

Original internal dose for PER-076 case

 Used Aliquippa Forge TBD, rev. 00 PC-1, table 13: 

– inhalation intakes of 3.40 pCi/d

– ingestion intakes of 0.071 pCi/d during the residual period

 Used IMBA to compare solubility types M and S, with type M 

resulting in higher dose

 Total dose <0.010 rem

 Annual doses entered in IREP as lognormal distributions with 

GSD of 3
29

Reworked internal dose for PER-076 case

 Used Aliquippa Forge TBD, rev. 02, table 5-1, revised annual 

inhalation and ingestion intakes 

 Inhalation values entered in CADW as type M solubility 

absorption 

 Ingestion values entered as f(1) max, which assesses all 

absorption types and assigns the highest dose for the selected 

organ

 Total dose <0.100 rem

 Annual doses entered in IREP as constant values
30

SC&A’s conclusions about external and 

internal dose calculations for PER-076 case

 External dose:

– Verified correct doses were used from table 5-1 of TBD rev. 02

– Confirmed appropriate anterior-posterior (AP) DCF from IG-001 was applied

– SC&A was able to reproduce NIOSH’s doses

– Annual doses entered in IREP as specified in TBD rev. 02

 Internal dose:

– Verified annual inhalation and ingestion intakes from table 5-1 of TBD rev. 02 

correctly entered in CADW

– Confirmed that solubility type M provided greater overall dose

– Confirmed dose values appropriately entered in IREP with a constant 

distribution

 SC&A had no findings about the rework of PER-076 case
31

Board discussion of DCAS-PER-076
32

DCAS-PER-077, rev. 0

 Title: “Simonds Saw and Steel TBD”

 PER issued February 28, 2017

 Determines the impact of rev. 02 changes to the Simonds Saw and Steel 

TBD

 Key TBD revisions:

– Updated operational period external dose and internal intake rates for operational 

workers to assign the 95th percentile and 50th percentile to administrative workers

– Updated residual period external dose and internal intake rate assignments and 

increased exposure time from 2,000 to 2,500 hours per year

 Since SC&A reviewed prior TBDs and the PER reevaluated all cases with 

POCs <50%, SPR determined only subtask 4 review was necessary
33

Simonds Saw and Steel operational history

 Involved in rolling natural uranium and some depleted and 

enriched uranium and thorium rods 

 Rolling operation February 24, 1948, through December 31, 

1957 

 Residual period January 1, 1958, through the present
34

PER-077 subtask 4 review

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

 NIOSH evaluated 105 cases:

– 27 cases resulted in a POC >50%

– 78 cases resulted in a POC <45%

 SC&A recommended selecting cases based on 3 criteria:

1. Operations/production worker employed during some portion of operational 

and residual periods who was not monitored internally and either partially or 

not monitored externally

2. Administrative/office worker who was employed during the operational 

period

3. At least one case with covered employment during the entire year of 1948
35

PER-077 subtask 4 case review process

 SC&A submitted its subtask 4 review of PER-077 on June 11, 

2018

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

2019, meeting

 One case was selected that met criteria 1 and 3 for an 

operational/production worker

 No cases were available for an EE with a job category of 

administrative/office worker
36

PER-077 case background

 EE worked at Simonds Saw and Steel for nearly 3 decades

 EE was an operator for a specific trade

 EE was diagnosed with a qualifying cancer after termination of 

employment
37

Comparison of NIOSH’s reworked doses and 

original doses for PER-077 case

Dose categories Reworked vs. original dose percentage

External 545% increase

Internal 53% increase

Total 506% increase

POC 57% increase
38

Original external dose assumptions for 

PER-077 case

 DR performed in 2005

 EE was not monitored for external exposure

 NIOSH used TBD rev. 00 PC-1 median values and associated GSDs from 

table 18 (operational period) and table 20 (residual period)

 Dose assessed for four exposure scenarios:

– ambient contamination submersion during operations

– uranium billets during operational rolling 

– uranium rods during operational rolling 

– post-operational residual contamination

 Applied applicable IG-001 maximum exposure-to-organ DCFs:

– Assumed isotropic (ISO) geometry for submersion in ambient contamination

– Assumed AP geometry for operational rolling and residual contamination

 NIOSH calculated a total external dose of >10 rem
39

Reworked external dose for PER-077 case

 Reevaluated DR performed 2017

 Assumed EE was an operations/production worker during the 

operational period 

 Assigned the 95th percentile annual doses in table 4-3 of TBD 

rev. 02

 Annual residual dose was assessed using the value of 200 mrem 

per year from table 5-3 of TBD rev. 02

 Total external dose of >69 rem assigned
40

Notable differences between reworked and 

original external dose calculations

Original 2005 DR

 Used median dose rates with associated 

GSDs during operational period

 Assumed 2,000 hours exposure at 

80 mR/hr, input as GSD of 3.5 during 

residual period

 Assumed ISO geometry for submersion 

dose during the operational period

 Used maximum AP exposure-to-organ 

dose DCFs

 Calculated dose for full termination year

Reworked 2017 DR

 Used 95th percentile dose rates input as 

constants during operational period

 Assumed 2,500 hours of exposure at 

80 mR/hr, input as a constant during 

residual period

 Assumed AP geometry for all 4 exposure 

scenarios

 Used midpoint value of AP exposure-to- organ dose DCF

 Prorated dose for partial year of 

termination employment
41

SC&A’s conclusions about external dose for 

PER-077 case

 Confirmed that NIOSH used correct external exposure rates based 

on TBD rev. 02

 Determined that appropriate guidance from TBD rev. 02 was 

followed 

 Verified doses were input in IREP correctly

 SC&A has no findings or observations related to calculation of 

external dose
42

Original internal dose for PER-077 case

 EE was not monitored for internal exposure

 NIOSH used TBD rev. 00 PC-1 intake values, absorption types, and 

associated GSDs from:

– Table 15 for the operational period

– Table 20 for the residual period

 Internal exposure to uranium via inhalation intakes assigned for each year 

of covered employment with no prorating for termination year

 Inhalation exposure to recycled uranium (RU) contaminants (neptunium 

and plutonium) was assumed during operational period

 Since source term relied on air sampling measurements rather than 

bioassay, inhalation and ingestion intakes of Th-232 and Th-228 were 

assessed 

 Total internal dose of ~0.500 rem assigned
43

Reworked internal dose for PER-077 case

 NIOSH used TBD rev. 02 intake values, absorption types, and associated GSDs from 

table 3-13 (operational period) and table 5-1 (residual period)

 EE was considered an operations/production worker; therefore, 95th percentile intake 

values were used

 Dose for termination year was prorated

 Inhalation exposure to RU contaminants was expanded to include Tc-99 as well as 

Np-237 and Pu-239 and was assumed during operational period

 Due to SEC, thorium exposure only assessed for residual period

 Thorium daughter products included Th-232,Th-228, Ac-228, Ra-228, and Ra-224

 Total internal dose of ~0.800 rem assigned
44

SC&A’s conclusions about internal dose for 

PER-077 case

 Using the TBD rev. 02 intake rates from table 3-13 (operational 

period) and table 5-1 (residual period), SC&A was able to recreate 

the assigned internal doses to within 2% of NIOSH’s internal dose 

calculation

 SC&A had no findings or observations about NIOSH’s reworked 

internal dose
45

Board discussion of DCAS-PER-077
46

DCAS-PER-043, rev. 0

 Title: “Internal Dosimetry Organ, External Dosimetry Organ, 

and IREP Model Selection by ICD-9 Code Revision,” which is 

ORAUT-OTIB-0005

 PER issued June 7, 2013

 OTIB-0005 was initially issued March 11, 2003

 NIOSH issued nine revisions of OTIB-0005 prior to issuing 

PER-043
47

OTIB-0005 revisions that may increase organ 

dose and required DCAS-PER-043

 Revision 01 PC-1 added bone cancer model as possible option to International 

Classification of Diseases Ninth Edition (ICD-9) code 238.7.

 Revision 01 PC-2 changed designated internal organ for ICD codes 231.8, 

235.8, and 235.9 from lung to “medical review,” and external organ for prostate 

was changed from testes to bladder.

 Revision 02 modified adenocarcinoma of the lower third of the esophagus and 

required modeling of esophagus and stomach to determine which is higher.

 Revision 03 changed the internal organ for ICD-9 code 155.1 from gallbladder to 

liver/gallbladder. 

 Revision 04 changed target organs for ICD-9 codes 238.0 and 239.2. Internal 

target organ changed from “medical review” to bone surfaces, and external 

target organ changed from red bone marrow to bone surface.

 Revision 05 added code 204.1 for chronic lymphocytic leukemia.
48

SC&A’s review of PER-043, rev. 0

 Subtask 1–3 review submitted August 18, 2014

– SC&A identified 0 findings

 Subtask 1–3 review presented to the SPR at the August 28, 

2014 meeting

 Subtask 4 review submitted December 17, 2014

– SC&A identified 3 findings

 All findings from subtask 4 review were discussed and closed 

at the SPR meeting on February 18, 2015
49

Subtask 1 review of DCAS-PER-043, rev. 0

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

PERs and their potential impact on DR

 To assess subtask 1, SC&A reviewed OTIB-0005, rev. 05, which 

states: 

– Section 2.0: “organs or tissues for which doses must be estimated are those 

that are delineated by the specified ICD-9 code that is received from the U.S. 

Department of Labor (DOL).”

– Section 2.0: “Coding of the cancers is conducted by DOL on the basis of 

ICD-9.”

– Section 4.2: “Due to the complexity of determining the appropriate organs and 

tissues for some ICD-9 code cancers, a medical review by an Oak Ridge 

Associated Universities (ORAU) Team physician is required to determine the 

organs and tissues to use in IMBA for those cancers.”
50

SC&A’s subtask 1 conclusion for PER-043

 Revisions to OTIB-0005 were exclusively introduced by parties 

generally not within the scope of SC&A’s review 

 SC&A assumes that changes and additions to ICD-9 codes 

reflect updates/revisions to the International Classification of 

Diseases and ORAUT’s improved understanding of 

corresponding internal and external target organs

 SC&A accepts the changes and had no findings or 

observations for subtask 1 
51

Subtask 2 review of DCAS-PER-043

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

action

 SC&A subtask 2 assessment:

– Reviewed all revisions stated in PER-043

– Compared these to statements in the text and to entries in table 3-1 of 

OTIB-0005, rev. 05

 SC&A had no findings or observations under subtask 2
52

Subtask 3 review of DCAS-PER-043

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

number of DRs requiring reevaluation of dose

 NIOSH’s criteria to determine population of claims potentially 

affected by DCAS-PER-043 included:

– Cases completed before the issue date of a specific revision, which had the 

potential of increasing the dose

– Cases with a derived POC less than 50% 

– Cases that met one or more changes that were identified in PER-043

 NIOSH identified 36 previously completed cases:

– 2 cases resulted in a revised POC greater than 50% 

– 34 claims resulted in POCs less than 45%
53

Subtask 3 assessment of PER-043

 SC&A was not given access to primary data used to identify 

and quantify those cases that qualified for reevaluation; 

therefore, was not able to verify 36 cases

 SC&A’s evaluation limited to methodology/criteria employed to 

identify cases that were potentially impacted by PER-043

 SC&A concluded that screening criteria used to identify 

potentially impacted claims are scientifically sound

 SC&A had no findings under subtask 3
54

Subtask 4 case selection criteria for PER-043

1. Revision 02 of OTIB-0005: ICD-9 code 150 – Change required the 

need to consider stomach cancer (both target organ and cancer model) 

for esophageal cancer of the lower third portion of the esophagus. Select 

one case from among four affected cases with reworked POC of <50%.

2. Revision 03: ICD-9 code 155.1 – Change specified liver as the 

appropriate internal dose organ for cases that had previously used the 

gallbladder. Select one case from 15 affected claims with reworked 

POCs of <50%.

3. Revision 04: ICD-9 code 232 – Added basal carcinoma to the 

considered cancer models for code 232 when cell type was not 

specified. Select one claim from 16 reworked claims with POC of <50%.

4. ICD-9 code 238 – changed target organs. Select the single claim that 

was reevaluated and resulted in a POC of <50%.
55

Subtask 4 case review of DCAS-PER-043

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

PER

 Based on selection criteria, NIOSH identified 4 cases for 

SC&A’s review

 SC&A’s review resulted in the following:

– Case A: Two findings on the assignment of an incorrect ICD-9 code to 

a metastatic cancer 

– Case B: No findings

– Case C: One finding on NIOSH’s selection of the internal organ that 

required a medical review

– Case D: No findings
56

PER-043 case A background

 EE worked at a DOE covered facility for more than 2 decades

 EE was initially diagnosed with a cancer that was not 

discussed in PER-043 (original DR)

 A second cancer with assigned ICD-9 code 238.0 was 

diagnosed shortly after termination of employment (DR rev. 1)

 OTIB-0005, rev. 04, changed internal target organ for ICD-9 

code from “medical review” to bone surface (DR reworked 

under PER)
57

Comparison of NIOSH’s reworked doses and 

original doses for PER-043 case A

Dose categories Dose reworked under PER vs. DR rev. 1 dose percentage for 

cancer 2

External ~19% increase

Occupational medical ~54% increase

Internal ~838% increase

Total ~489% increase

POC ~330% increase (when combined with cancer 1)
58

SC&A’s review of PER-043 case A

 SC&A concluded that the second cancer should not have been 

assigned ICD-9 code 238.0 but should have been considered a 

metastatic cancer and assigned the same ICD-9 code as the 

primary cancer

 This conclusion resulted in two findings
59

Issue resolution for PER-043 case A finding 1

Finding 

date

Finding description NIOSH response Finding resolution

12/17/2014 Failure to revise ICD-9 

code 238.0 to that of the 

primary cancer, code 209.35. 

Had the ICD-9 code for the 

“metastatic” cancer been 

changed to 209.35, case A 

would not have required 

reevaluation under the stated 

criteria of DCAS-PER-043.

4/28/2015. NIOSH 

agreed. However, after 

lengthy discussions, it 

was determined the 

error was committed by 

DOL, did not impact the 

POC for the case, and 

does not appear to be 

systemic. Therefore, no 

additional remediation 

necessary.

4/28/2015. SPR 

closed the finding.
60

Issue resolution for PER-043 case A finding 2

Finding 

date

Finding description NIOSH response Finding resolution

12/17/2014 As a metastatic cancer for 

which the primary cancer 

was identified, there was 

neither a need to assess the 

dose to the metastatic cancer 

(since it is essentially 

identical to that of the primary 

cancer), nor include such a 

dose for the calculation of the 

POC.

4/28/2015. NIOSH 

agreed. However, after 

lengthy discussions, it 

was determined the 

error was committed by 

DOL, did not impact the 

POC for the case, and 

does not appear to be 

systemic. Therefore, no 

additional remediation 

necessary.

4/28/2015. SPR 

closed the finding.
61

PER-043 case B background

 EE worked at a DOE covered facility for 2 time periods

 EE was diagnosed with a cancer that was assigned ICD-9 

code 150.5

 The original DR calculated doses from external, medical, and 

internal exposures to the distal esophageal tissue

 Under rev. 02 of OTIB-0005, NIOSH recalculated dose using 

the stomach as the internal and external organ

 SC&A’s review did not identify any findings or observations
62

Comparison of NIOSH’s reworked doses 

versus original doses for PER-043 case B

Dose categories Rework vs. original dose percentage

External ~40% decrease

Occupational medical ~23% decrease

Internal ~378% increase

Total ~0.03% decrease

POC ~9% decrease
63

Differences between original and reworked 

external dose calculations for PER-043 case B

Original DR

 Uses esophagus as the 

external organ of interest

 External Dosimetry Data 

Workbook used

 Applied dose from <30 keV to 

account for exposure to 

plutonium

 Total dose assigned of nearly 

3.0 rem

Reworked DR

 Uses stomach of external 

organ of interest

 Updated External Dosimetry 

Data Workbook used

 Assigns all dose as 30–250 

keV (unlikely EE worked in 

plutonium area)

 Total dose assigned <2.0 rem
64

Differences between original and reworked 

internal dose calculations for PER-043 case B

Original DR

 Uses the esophagus as the 

internal organ of interest

 Environmental internal dose 

calculated using CADW

 Total internal dose assigned 

of <0.5 rem 

Reworked DR

 Uses the stomach as the 

internal organ of interest

 OTIB-0018 applied to ensure 

an overestimate of internal 

dose

 Total internal dose assigned 

of >1.5 rem
65

SC&A’s conclusions about external and 

internal doses for PER-043 case B

 SC&A reviewed and compared derived external and internal dose 

estimates calculated in the original DR to reassess external and 

internal dose 

 SC&A concurs with the elimination of external exposures to <30 keV 

photons from plutonium based on case job title information

 Revised internal dose likely overestimated since based on ORAUTOTIB-0018

 SC&A had no findings or observations about NIOSH’s reworked 

internal dose
66

PER-043 case C background

 EE worked at a DOE covered facility

 EE employment spanned a few years

 Diagnosed with cancer assigned ICD code 155.1 after 

employment termination

 OTIB-0005, rev. 03, changed organs used for ICD code 155.1:

– The external organ was changed from bladder to liver

– The internal organ was changed from gallbladder to liver/gallbladder
67

Comparison of NIOSH’s reworked doses and 

original doses for PER-043 case C

Dose categories Rework vs. original dose percentage

External Same

Occupational medical Same

Internal ~1,653% increase

Total ~142% increase

POC ~49% increase
68

Comparison of original and reworked 

external dose calculations for PER-043 case C

Original DR

 Uses bladder as the external 

organ of interest

 Applied DCF of 1 for all 

energy ranges, which was 

claimant favorable

 Total dose assigned of >3.0 

rem 

Reworked DR

 Uses liver of external organ 

of interest

 Dose not changed, since 

original used claimantfavorable DCF

 Same total dose assigned
69

Comparison of original and reworked internal 

dose calculations for PER-043 case C

Original DR

 Uses the gallbladder as the 

internal organ of interest

 Total internal dose assigned 

of <0.5 rem 

Reworked DR

 Uses the liver as the internal 

organ of interest

 Total internal dose assigned 

of >5 rem
70

SC&A’s conclusions on PER-043 case C dose 

calculations

 NIOSH’s choice of surrogate organ for EE’s cancer is 

questionable, since there are three general locations where the 

cancer could arise.

 ORAUT-OTIB-0005, rev. 05, states that, “If the description is 

unclear, a medical review should be conducted to determine 

the appropriate internal organ of interest.”

 EE’s records did not indicate that a medical review was 

performed.

 Based on this information, SC&A identified finding 3.
71

Issue resolution for PER-043 finding 3

Finding 

date

Finding description NIOSH response Finding resolution

12/17/2014 In the absence of a medical 

review that would specify the 

cancer as extrahepatic, 

NIOSH’s selection of the liver 

as the appropriate internal 

organ is inappropriate and 

would obviate the need for 

Case C to be reevaluated.

4/28/2015. NIOSH 

stated that in the PER 

process, if you can do a 

DR with available 

information and 

determine that the POC 

is still below 50%, there 

is no need to stop the 

process and get a 

medical review.

4/28/2015. SPR 

agreed with 

NIOSH’s response 

and closed the 

finding.
72

PER-043 case D background

 EE worked at an AWE covered facility for a brief employment 

period

 Diagnosed with a qualifying cancer identified with ICD-9 code 

232.6

 Prior to rev. 04 of OTIB-0005, a comparison of malignant 

melanoma and non-melanoma squamous cell carcinoma 

was made and the one that produced the higher POC value 

was assigned. Revision 04 added basal cell carcinoma as a 

third option.
73

NIOSH rework of PER-043 case D

 Original DR calculated doses for malignant melanoma

 Rework recalculated doses assuming non-melanoma basal cell 

carcinoma

 Rework determined that malignant melanoma produced the 

higher dose and POC
74

SC&A’s assessment of NIOSH’s rework of 

PER-043 case D

 SC&A confirmed that NIOSH’s rework assuming non-melanoma 

basal cell carcinoma produced a lower POC than malignant 

melanoma used in original DR

 SC&A could not determine if NIOSH performed a rework using nonmelanoma squamous cell carcinoma 

 SC&A independently assessed the non-melanoma skin squamous 

cell IREP model, which yielded the lowest POC value

 SC&A concurs with NIOSH that, for case D, the IREP model 

malignant melanoma yields the highest POC value

 SC&A had no findings or observations about NIOSH’s rework of 

case D
75

Board discussion of DCAS-PER-043
76

DCAS-PER-059

 Title: “Norton Company”

 Issued April 2015 due to revisions to the Norton Company 

template

 Revision included: 

– Modified template to include second SEC class corresponding to a 

portion of residual period (January 1, 1958, to October 10, 1962) 

– Incorporated updated ORAUT-OTIB-0070, rev. 01, guidance, which 

adopted a lower depletion rate of 0.067% per day for residual 

contamination starting October 10, 1962, through 2009
77

Summary of Norton Facility operational 

history

 Worked with thorium and uranium

 Operational period 1945 through 1957

 Residual radiation period 1958 through October 2009 

 No technical basis documents

 DR methodology incorporated into a template
78

SC&A’s review of PER-059

 Subtask 1–3 review submitted May 22, 2017

– SC&A identified 3 findings

 All subtask 1–3 findings were discussed and closed at the SPR 

meeting on October 31, 2018

 Subtask 4 review submitted December 28, 2021

– SC&A identified 0 findings

 Subtask 4 review presented at the May 25, 2022, SPR meeting
79

Subtask 1 review of PER-059

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

PERs and their potential impact on DR

 SC&A regards (1) the addition of SEC-00173 class and 

(2) adoption of a reduced residual period depletion rate as 

justification for revising the Norton Company template and 

reevaluating worker doses as defined in PER-059

 SC&A has no findings or observations under subtask 1
80

Subtask 2 review of DCAS-PER-059

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

 SC&A has reviewed the documents that prompted the issuance of 

PER-059:

– August 29, 2008: SC&A issued its review of ORAUT-OTIB-0070 

– July 7, 2011: SC&A issued a focused review of the Norton Company SEC 

petition evaluation report (ER) for SEC-00173

 SC&A had not reviewed any versions of the Norton template. 

Therefore, its subtask 2 review included assessment of external and 

internal DR methodology

 SC&A identified 3 findings
81

Issue resolution for PER-059 finding 1

Finding 

date

Finding description NIOSH response Finding resolution

5/22/2017 There is insufficient information in 

the Norton template for identifying 

critical data and parameters 

needed to (1) duplicate and (2) 

confirm NIOSH’s model for 

estimating external deep and 

shallow doses starting in residual 

period of 1962.

10/31/2018. SC&A confirmed that 

its 2011 focused review of the 

SEC ER evaluated and approved 

methodology.

11/20/2017. NIOSH 

stated that the 

methodology for 

estimating external 

doses was taken 

from the SEC ER, 

which was reviewed 

by SC&A.

11/20/2017. SPR 

requested that 

SC&A confirm that 

the ER was 

reviewed and the 

methodology 

approved.

10/31/2018. SPR 

closed the finding.
82

Issue resolution for PER-059 finding 2

Finding date Finding description NIOSH response Finding resolution

5/22/2017 Five of the nine “air dust” 

survey references are 

considered “operational” 

thoria and uranium data with 

dates starting in 1958 through 

1964. Operational survey 

data for thoria/uranium after 

1957 are in contradiction with 

the template’s designated 

“operational” period that ends 

in 1957.

11/20/2017. NIOSH 

agreed and stated 

they would change 

the template. They 

also questioned if this 

issue should be a 

finding or observation.

10/31/2018. NIOSH 

confirmed that the 

template had been 

revised.

11/20/2017. SPR 

changed issue to 

observation and 

status was put in 

abeyance.

10/31/2018. SPR 

closed the finding.
83

Issue resolution for PER-059 finding 3

Finding date Finding description NIOSH response Finding resolution

5/22/2017 SC&A was able to derive 

NIOSH’s 1962–1963 air 

concentration and daily intake 

values for thorium; however, 

corresponding values for 

uranium derived by SC&A are 

a factor of 2 lower than values 

derived/assigned for uranium 

air concentration and intakes.

11/20/2017. NIOSH 

agreed that uranium 

intakes were in error 

and stated they would 

change the template.

10/31/2018. NIOSH 

confirmed that the 

template had been 

revised.

11/20/2017. SPR 

placed this finding 

in abeyance until 

the template is 

revised.

10/31/2018. SPR 

closed the finding.
84

Subtask 3 review of PER-059

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

number of DRs requiring reevaluation of dose

 NIOSH identified cases for reevaluation as follows: 

– 54 previously completed claims with POC values ≤50% were identified for 

further evaluation

– Nine of the 54 claims had employment periods prior to 1962 and were 

therefore not impacted by PER-059 

– Two additional claims were removed: one claim had recently been completed 

using the revised template and the other had been returned by DOL and was 

reevaluated by NIOSH as required by PER-059 

– Remaining 43 claims have been reevaluated by NIOSH in accordance with 

the revised Norton Company template and all applicable/approved DR 

protocols

– All 43 revised DRs yielded POC values below 45%
85

SC&A’s conclusion about NIOSH’s case 

selection process for PER-059

 SC&A concurs with NIOSH’s selection criteria for defining the 

43 claims requiring reevaluation of dose

 There were no findings under subtask 3
86

Subtask 4 case selection criteria for PER-059

 SC&A recommended selection of cases based on following 

criteria:

– Assignment of the template-prescribed annual values for external 

doses

– Assignment of internal intake rates for uranium, thorium, and thoron 

– Employment after 1961
87

PER-059 subtask 4 review of 1 reworked case

 ABRWH selected one reworked case for SC&A’s review in 

April 2021, based on the following criteria:

– assignment of external dose during the residual period

– assignment of internal dose during the residual period

 SC&A reviewed the reworked case in December 2021 to 

determine if external and internal doses were correctly 

assessed in accordance with PER-059
88

NIOSH’s reworked DR for PER-059 case

 NIOSH’s rework of the case:

– Used applicable DR tools 

– Recalculated all annual doses 

– Re-ran IREP

 Revised DR report not sent to DOL because the compensation 

decision did not change
89

Case background for PER-059 case

 EE worked at Norton Company for multiple brief periods during 

the residual period

 EE was not monitored for radiation exposure

 Diagnosed with qualifying cancer over two decades after 

employment termination
90

Comparison of NIOSH’s reworked doses and 

original doses for PER-059 case

 Original DR calculated external and internal doses of 

<0.001 rem

 Reworked DR calculated modest external and internal doses
91

Comparison of external dose calculations for 

PER-059 case

Original DR

 Used guidance in template 

available in 2010 for external 

dose during the residual period

 No prorating for partial years of 

employment

 Applied DCF of 1.000

 Derived dose of <0.001 rem

Reworked DR

 Used residual period external 

exposure values from updated 

2011 template

 No prorating for partial years of 

employment. 

 Applied exposure DCF of 1.44 

for the thyroid as the surrogate 

organ

 Assigned dose of ~0.030 rem
92

SC&A’s conclusions on external dose for 

PER-059 case

 Appropriate dose values selected from revised template

 Correct surrogate organ was selected, based on OTIB-0005, rev. 05

 Appropriate DCF value was applied

 No partial-year prorating applied, as an efficiency and claimantfavorable measure

 Review confirmed doses were accurately entered in IREP 

 As expected, reworked DR external dose increased from that 

calculated in the original DR

 SC&A had no findings about reworked external dose
93

Comparison of internal dose calculations for 

PER-059 case

Original DR

 Inhalation and ingestion intakes 

from DR methodology template 

 Used CADW to compare doses 

from U-234 absorption types M 

and S with Th-232 absorption 

types M and S, with Th-232 

type M resulting in the highest 

dose

 Calculated dose of <0.001 rem

Reworked DR

 Used inhalation and ingestion 

exposure values from updated 

template 

 Assumed isotopic mix of U-234, 

Th-232, Th-228, Ac-228, 

Ra-228, Ra-224, and Rn-220 

 Compared solubility types M and 

S, with type M resulting in more 

claimant-favorable dose

 Using CADW, calculated dose of 

<0.020 rem
94

SC&A’s conclusions on internal dose for 

PER-059 case

 Reviewed NIOSH’s CADW files for the reworked DR and 

confirmed that correct intake values were used, based on data 

in updated template 

 SC&A verified: 

– Type M solubility resulted in the higher dose

– Dose data appropriately entered in IREP table

– Doses were assessed to the date of cancer diagnoses

 SC&A had no findings about the assessment of internal dose in 

the reworked case
95

Board discussion of DCAS-PER-059