DISCLAIMER: This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its Working Groups or 

Subcommittees. Documents produced by SC&A, such as memorandum, white paper, draft or working documents are 

not final NIOSH or ABRWH products or positions, unless specifically marked as such. This document prepared by 

SC&A represents its preliminary evaluation on technical issues.

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Memorandum

To: Subcommittee for Procedure Reviews

From: SC&A, Inc.

Date: September 8, 2022 

Subject: SC&A Comments on NIOSH’s Responses to SCA-TR-2019-PR004

On January 29, 2019, SC&A submitted report SCA-TR-2019-PR004, a review of version 3.0 of 

the National Institute for Occupational Safety and Health’s (NIOSH’s) Peek Street Facility (PSF) 

dose reconstruction (DR) template (SC&A, 2019).1 SC&A’s review identified eight findings and 

three observations. On June 14, 2022, NIOSH submitted their responses to SC&A’s review 

(NIOSH, 2022). This memorandum addresses NIOSH’s responses. 

1 SC&A notes that it has not yet been tasked to review version 4.0, the current version of the template.

Finding 1: The assumption of 100% 30–250 kiloelectron volts (keV) for the 

penetrating photon energy distribution is unsupported and inconsistent with 

assumptions used in the Hanford technical basis document.

NIOSH (2022, p. 2) responded, in part: 

Because the bulk of the radioactive material at the PSF was natural and enriched 

uranium, most if not all PSF workers were likely externally exposed to uranium 

during periods of their employment. Table 6-7 in revision 4 of ORAUT-TKBS0006-6, Hanford Site – Occupational External Dose [ORAUT 2010], 

recommends a photon energy distribution assumption of 100% 30–250 keV 

photons for fuel fabrication facilities, which were uranium facilities at Hanford.

SC&A does not disagree with NIOSH’s reasoning. However, as stated in our DR template 

review, “SC&A believes NIOSH should include either the basis or a reference for the basis of 

the penetrating photon energy distribution” (SC&A, 2019, p. 12). 

Finding 2: The assumption of an uncertainty factor of 1.3 is unsupported and 

inconsistent with the cited reference.

NIOSH (2022, p. 2) responded, in part:

NIOSH agrees that revision 04 of ORAUT-TKBS-0006-6 [ORAUT 2010] 

reduced the uncertainty factor for the years of 1947 to 1954 to 1.2. The revised 
SC&A, Inc.

Comments on Responses to SCA-TR-2019-PR004, page 2 September 8, 2022 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

uncertainty value and technical basis document (TBD) reference will be updated

as part of the next revision to the DR Template.

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 

Finding 3: SC&A was unable to verify the neutron-to-photon ratio of 1.2 using the 

cited references.

NIOSH (2022, pp. 3–4) responded, in part:

Instead of using the N:P ratios based on NTA film results that were adjusted with 

an estimated adjustment factor, the PSF evaluation focused on the measured 

neutron data in Table 6-18. In Table 6-18 of ORAUT [2010], the N:P ratios for 

the period before 1961 were based on neutron dose measurements rather than 

NTA film (see Peterson and Smalley [1960] for more details). Those 

measurements were also performed at the front faces to each of Hanford's eight 

production reactors. For the period before 1961 (i.e., before any additional 

shielding was added), the N:P ratios ranged from 0.2:1 to 1.2:1. In addition, N:P 

ratios based on measurements close to the reactor are more representative of the 

potential exposures at the PSF. At the PSF, workers with the potential to receive 

neutron doses from the source material, critical assembly, and/or zero pile were 

likely within 10 m (33 ft) of the neutron radiation source. 

Based on the information at the time of the PSF DR Template development, the 

N:P ratios that were considered representative ranged from 0.06:1 to 1.2:1. Of 

those N:P ratios, the 1.2:1 ratio was selected for the PSF because it resulted in the 

estimates most favorable to the claimants and would ensure that the unmonitored 

PSF neutron doses were not underestimated. 

Since the development of the PSF DR Template, the N:P ratio information in 

the external TBD for Hanford has changed, and Table 6-18 and its N:P ratio 

data are no longer in that TBD. [emphasis added] However, the neutron and 

photon dose measurement data in Peterson and Smalley [1960] on which N:P 

ratios were based are still considered to be applicable to the PSF. Therefore, 

NIOSH believes the 1.2:1 N:P ratio being used for the PSF is still valid. 

SC&A reviewed ORAUT-TKBS-0006-6, revision 03 (ORAUT, 2007) and revision 04 (ORAUT, 

2010), and Peterson and Smalley (1960). While SC&A agrees with NIOSH’s reasoning, the PSF 

DR template SC&A reviewed (version 3.0) does not reflect the basis described in NIOSH’s 

response. As identified in SC&A’s (2019) review, the DR template states the neutron-to-photon 

(N:P) ratio to be used for the PSF was determined from facilities with similar neutron-producing 

activities: 

The technical basis documents for the following reactor and critical assembly 

sites were reviewed to determine an appropriate neutron-to-photon ratio for the 

Peek Street Facility: Hanford, Savannah River Site, Oak Ridge National 

Laboratory, Idaho National Engineering Laboratory, Los Alamos National 
SC&A, Inc.

Comments on Responses to SCA-TR-2019-PR004, page 3 September 8, 2022 

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Laboratory, Argonne National Laboratory East, Brookhaven National Laboratory, 

and the Energy Technology Engineering Center . . . . Based on the information 

provided in these technical basis documents, a neutron-to-photon ratio of 1.2:1 is 

likely claimant-favorable for facilities with critical assemblies and small-scale 

research reactors. It should also be noted that the technical basis documents for 

the following sites did not provide any neutron-to-photon ratios: Idaho National 

Engineering Laboratory, Argonne National Laboratory East, Brookhaven 

National Laboratory, and the Energy Technology Engineering Center. [quoted in 

SC&A, 2019, pp. 14–15] 

SC&A suggests replacing the current DR template wording with the N:P ratio technical basis 

given in NIOSH’s response. 

Finding 4: The dosimeter LOD used in the DR Template is not specified in the 

template, and the value of 0.050 rem assumed based on NIOSH’s calculation is 

not consistent with the Hanford dosimeter information.

NIOSH (2022, p. 4) responded: 

As noted in the response to Finding 2, the “0.050 rem” value in the DR Template 

is a placeholder value and is designed to be updated during the development of 

the dose reconstruction. NIOSH identified that PSF used a Hanford-type 

dosimeter throughout its entire operating period. Therefore, the dosimeter 

information from ORAUT [2010], including limits of detection (LOD), will be 

referenced as defaults as part of the next revision to the DR Template.

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 

Finding 5: SC&A was unable to verify the PSF annual maximum ambient dose 

value using the cited reference.

NIOSH (2022, pp. 4–5) responded: 

NIOSH identified that an incorrect value of 1.550 rem was originally used for the 

1949 ORNL dose when the average maximum annual ambient dose value was 

originally calculated. The 1949 ORNL dose value should have been 1.555 rem. 

Correcting that results in an updated average value of 0.433 rem, versus the 

0.423 rem in the DR Template, which matches SC&A’s calculated value. 

However, NIOSH plans on reevaluating and revising this section with more 

current information in order to provide a more accurate estimate of onsite ambient 

dose as part of the next revision to the DR Template.

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 
SC&A, Inc.

Comments on Responses to SCA-TR-2019-PR004, page 4 September 8, 2022 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Finding 6: The DR Template occupational medical dose basis contains incorrect 

information and outdated references.

NIOSH (2022, p. 5) responded: 

NIOSH will investigate if occupational medical X-rays for the PSF workers were 

performed offsite. The Occupational Medical Dose Section of the DR Template 

will be updated based on the outcome of this investigation and guidance in 

ORAUT-OTIB-0006, Dose Reconstruction from Occupational Medical X-Ray 

Procedures [ORAUT 2019] and ORAUT-OTIB-0079, Guidance on Assigning 

Occupational X-ray Dose Under EEOICPA for X-rays Administered Off Site

[ORAUT 2017].

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 

Finding 7: The fission product information in the DR Template is not consistent 

with current guidance in ORAUT-OTIB-0054, revision 04.

NIOSH (2022, p. 5) responded: 

NIOSH agrees that guidance associated with the current version of ORAUTOTIB-0054, Fission and Activation Product Assignment for Internal Dose-related 

Gross Beta and Gross Gamma Analyses [ORAUT 2015], needs to be incorporated 

into the DR Template. This will be done as part of the next revision to the DR 

Template.

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 

Finding 8: No basis or reference is cited for the recycled uranium activity 

fractions in table 5 of the DR Template.

NIOSH (2022, p. 5) responded: 

NIOSH agrees that the section on the recycled uranium activity fractions should

be updated. NIOSH will revise the DR Template based on guidance in BattelleTBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium 

Metals [NIOSH 2011]. 

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 
SC&A, Inc.

Comments on Responses to SCA-TR-2019-PR004, page 5 September 8, 2022 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Observation 1: SC&A did not locate a PSF-specific tool containing the 

preprogrammed plutonium DCFs.

NIOSH (2022, p. 6) responded: 

Given the limited number of claims for PSF, no site-specific tool has been created 

for PSF. For sites without a site-specific tool, the complex-wide generic “SM 

Calculation Workbook” is used.

The PSF DR template SC&A reviewed (version 3.0) contains the following wording about a sitespecific DR tool: 

(NOTE: For the <30 keV photons energy group, the organ DCFs [dose conversion 

factors] in Table 4.1a of IG-001 [i.e., for the <20 keV Pu photons] should be used 

instead of the App B organ DCFs. Because Table 4.1a does not provide 20 keV 

photon organ DCF values for the esophagus or the ovaries, the <30 keV photon 

DCFs should be used, in accordance with the Table 4.1a recommendations. It 

should also be noted that the Table 4.1a based values for the <30 keV photon 

energy group have been programmed into the tool that was created for the 

PSF.) [emphasis added] [quoted in SC&A, 2019, p. 13] 

SC&A suggests removing the reference to a PSF-specific tool.

Observation 2: The natural uranium PSL in the DR Template is not consistent with 

information in ORAUT 1997 and is not referenced.

NIOSH (2022, p. 6) responded: 

The color coding in the DR Template indicates that claim-specific PSL values are 

a placeholder value to be updated during the dose reconstruction process. This is 

why they do not match what is in “ORAUT 1997” [GE 1997]. Additionally, 

“ORAUT 1997” is not the primary reference for the PSL values that are used in 

the PSF dose reconstructions, as the claim-specific information takes precedence 

over generic programmatic information. 

The “5 μg uranium/day” in the template is actually based on the PSLs for natural 

uranium in urine that were reported in Claims [identifying information redacted]. 

Those [redacted] claims were the only known PSF claims with natural uranium 

urine bioassay data at the time that the DR Template was created. Therefore, 

NIOSH believes that there is value in maintaining the “5 μg uranium/day” in the 

DR Template.

SC&A is not familiar with PSF bioassay data and reporting practices. As such, SC&A would like 

to review the bioassay information and application for the claims cited. 
SC&A, Inc.

Comments on Responses to SCA-TR-2019-PR004, page 6 September 8, 2022 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

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Observation 3: The plutonium composition information is correct. However, the 

reference cited is outdated and needs updating.

NIOSH (2022, p. 6) responded: 

NIOSH agrees that the reference for the plutonium composition information is 

outdated and needs updating. NIOSH will update the reference as part of the next 

revision to the DR Template.

SC&A is requesting that it be tasked with reviewing the PSF DR template when the revisions are 

completed to ensure this finding is appropriately addressed. 
SC&A, Inc.

Comments on Responses to SCA-TR-2019-PR004, page 7 September 8, 2022 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

References

General Electric Company (GE), Knolls Atomic Power Laboratory (KAPL). (1997). Excerpts 

from KAPL radiological history report. Peek Street Facility, Schenectady, NY. SRDB Ref. ID 

34947 [previously referenced as “ORAUT 1997”] 

National Institute for Occupational Safety and Health. (2007). External dose reconstruction 

implementation guideline (OCAS-IG-001, rev. 3). https://www.cdc.gov/niosh/ocas/pdfs/dr/oc-ig001-r3.pdf 

National Institute for Occupational Safety and Health. (2011). Site profiles for Atomic Weapons 

Employers that worked uranium metals (Battelle-TBD-6000, rev. 1). SRDB Ref ID 101251 

National Institute for Occupational Safety and Health. (2022). Responses to SCA-TR-2019-

PR004, revision 0, Dose reconstruction template review for the Peek Street Facility, 

Schenectady, New York [Response paper]. 

Oak Ridge Associated Universities Team (ORAUT). (2007). Hanford Site – Occupational 

external dose (ORAUT-TKBS-0006-6, rev. 03). 

https://www.cdc.gov/niosh/ocas/pdfs/arch/hanford6-r3.pdf 

Oak Ridge Associated Universities Team. (2010). Hanford Site – Occupational external dose

(ORAUT-TKBS-0006-6, rev. 04). https://www.cdc.gov/niosh/ocas/pdfs/tbd/hanford6-r4.pdf 

Oak Ridge Associated Universities Team. (2015). Fission and activation product assignment for 

internal dose-related gross beta and gross gamma analyses (ORAUT-OTIB-0054, rev. 04). 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t54-r4.pdf 

Oak Ridge Associated Universities Team. (2017). Guidance on assigning occupational x-ray 

dose under EEOICPA for x-rays administered off site (ORAUT-OTIB-0079, rev. 02). SRDB 

Ref. ID 166967 

Oak Ridge Associated Universities Team. (2019). Dose reconstruction from occupational 

medical x-ray procedures (ORAUT-OTIB-0006, rev. 06). SRDB Ref. ID 178310 

Peterson, E. G., & Smalley, W. L. (1960). Proposed procedure for reducing reactor front face 

dose rates (HW-66117). General Electric, Hanford Atomic Products Operation, Richland, WA. 

SRDB Ref. ID 15200 

SC&A, Inc. (2019). Dose reconstruction template review for the Peek Street Facility, 

Schenectady, New York (SCA-TR-2019-PR004, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-peekstdrtemp-r0-508.pdf