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: Advisory Board on Radiation and Worker Health, Work Group on TBD-6000 

FROM: Robert Anigstein and John Mauro, SC&A 

DATE: December 9, 2016 

SUBJECT: Reply to NIOSH Response Paper Regarding Appendix BB, Revision 2 

On November 8, 2016, David Allen (NIOSH/DCAS) issued a paper (Allen 2016b) in response to the 

SC&A review (Anigstein and Mauro 2016) of Appendix BB, Revision 2 (Allen 2016a). In an email 

message on December 6, 2016, Ted Katz, Designated Federal Officer to the Advisory Board on 

Radiation and Worker Health (ABRWH), agreed that SC&A should review this report (Katz 2016). 

The SC&A review (Anigstein and Mauro 2014) of Appendix BB, Revision 1 (Allen 2014), produced 

nine findings. In a subsequent memo, Anigstein and Mauro (2015) identified a tenth finding. In our most 

recent memo, Anigstein and Mauro (2016) agreed that Allen (2016a) resolved Findings 2–8. 

Finding 1: Neutron Dose Rates 

The original Finding 1 in the SC&A review of Appendix BB, Revision 1, addressed the use of neutron 

dose rates based on effective doses, for which no dose conversion factors (DCFs) are provided in 

OCAS-IG-001 (OCAS 2007). In Revision 2, Allen (2016a) substituted neutron dose rates based on 

ambient dose equivalents (H*[10]), for which DCFs are provided. However, as we stated in our previous 

memo, Allen’s method of calculating organ dose equivalents by applying DCFs for the 0.1–2 MeV 

energy range to these neutron dose rates was not claimant favorable. Using the single example of doses 

to the lung, we calculated the organ doses by taking the sum of the products of the neutron H*(10) dose 

rates in each energy range listed by OCAS, multiplied by the DCF for that energy range. The results 

demonstrated that Allen’s method understated the doses to the lungs by 20%–45% for the three neutron 

exposure scenarios: betatron operators radiographing and handling uranium, betatron operators 

radiographing steel, and the layout man exposed to stray radiation from the betatron. 

In his response paper, Allen (2016b) proposed substituting DCFs for the 2–20 MeV energy range and 

showed that, in the case of doses to the lungs, the results were claimant favorable for the three neutron 

exposure scenarios described above. However, this conclusion is not valid for some of the 13 organs or 

tissues for which neutron DCFs are listed by OCAS (2007). Table 1 lists the dose rates to each of these 

organs or tissues, calculated by taking the sum of the products of the neutron H*(10) dose rates in each 

energy range listed by OCAS multiplied by the DCF for the given organ for that energy range. The 

resulting dose rates are compared to the dose rates calculated by multiplying the total neutron H*(10) 

dose rates by the 2–20 MeV DCFs for the respective organs. As shown in the table, the latter methods 

results in organ dose equivalents that are 4%–19% lower for 4 of the 13 organs. 
Reply to NIOSH Response Paper re App. BB, Rev. 2 2 SC&A – December 9, 2016

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.

Table 1. Neutron Dose Rates to Various Organs, Using DCFs for Various Energy Ranges 

(mrem/shift)

Betatron operator Layout man

Organ or tissue Uranium radiography Steel radiography Steel radiography

All Ea 0–10

keVb Δ1c 2–20MeVd Δ2e All E 0–10keV Δ1

2–20

MeV Δ2 All E 0–10keV Δ1

2–20

MeV Δ2

Bladder 3.044 6.106 101% 2.713 -11% 1.040 2.256 117% 1.002 -4% 1.824 4.838 165% 2.150 18%

Red bone marrow 1.395 2.706 94% 1.765 27% 0.484 1.000 106% 0.652 35% 0.887 2.144 142% 1.398 58%

Bone surface 1.550 2.873 85% 1.656 7% 0.539 1.062 97% 0.612 14% 0.992 2.276 129% 1.312 32%

Female breast 2.977 3.738 26% 2.748 -8% 1.077 1.381 28% 1.015 -6% 2.210 2.962 34% 2.177 -1%

Colon 2.138 4.666 118% 2.243 5% 0.724 1.724 138% 0.829 14% 1.233 3.697 200% 1.777 44%

Esophagus 1.740 3.653 110% 2.131 23% 0.596 1.349 126% 0.787 32% 1.052 2.894 175% 1.689 61%

Lungs 1.942 3.532 82% 2.328 20% 0.679 1.305 92% 0.860 27% 1.278 2.798 119% 1.845 44%

Ovaries 1.978 4.430 124% 2.215 12% 0.668 1.636 145% 0.818 23% 1.127 3.509 211% 1.755 56%

Testes 3.699 5.360 45% 2.999 -19% 1.315 1.980 51% 1.108 -16% 2.579 4.246 65% 2.376 -8%

Liver 2.408 4.726 96% 2.428 1% 0.828 1.746 111% 0.897 8% 1.484 3.745 152% 1.924 30%

Remainder 1.891 3.534 87% 2.185 16% 0.658 1.306 99% 0.807 23% 1.215 2.800 130% 1.731 42%

Skin 2.184 2.530 16% 2.277 4% 0.799 0.935 17% 0.841 5% 1.671 2.005 20% 1.804 8%

Thyroid 3.054 5.953 95% 2.690 -12% 1.047 2.199 110% 0.994 -5% 1.861 4.716 153% 2.131 15%

a Sum of products of neutron doses spanning all neutron energy ranges listed by OCAS (2007), multiplied by effective DCFs 

for H*(10) from neutrons incident in AP orientation

b Sum of neutron doses spanning all neutron energy ranges, multiplied by the effective DCF for H*(10) from 0–10 keV 

neutrons incident in AP orientation

c Δ1 = 0–10 keV ÷ All E − 1

d Sum of neutron doses spanning all neutron energy ranges, multiplied by the effective DCF for H*(10) from 2–20 MeV 

neutrons incident in AP orientation

e Δ2 = 2–20 MeV ÷ All E − 1

We still recommend that NIOSH use the DCFs specific to each energy range in calculating neutron 

doses to the various organs and tissues. However, should that be too cumbersome, we recommend using 

DCFs for the 0–10 keV energy range. As shown in Table 1, these factors result in neutron dose 

equivalents to each organ that are 16%–211% higher than the doses calculated by applying the energyspecific DCFs. As Allen (2016b) observed, neutron doses make relatively small contributions to the total 

dose in the scenarios described by Allen (2016a). Consequently, using these claimant-favorable DCFs 

would be acceptable for estimating neutron doses to GSI workers. 

Finding 10: External Exposure of Betatron Operator 

The original Finding 10, identified by Anigstein and Mauro (2015), addressed the use of dose rates from 

the hypothetical residual radiation from the betatron after shutdown based on effective doses, for which 

no DCFs are provided by OCAS (2007). In Revision 2, Allen (2016a) substituted air kerma rates, for 

which DCFs are provided, and listed the units as rad/y. However, he did not identify the dosimetric 

quantity as air kerma, leading to possible ambiguity as to which DCFs should be applied for calculating 

organ dose equivalents. Furthermore, as we stated in our most recent memo, since the residual radiation 

is hypothesized to have an energy of 30 keV, the maximum rather than the average DCF that 

corresponds to E < 30 keV should be used for dose reconstructions. 
Reply to NIOSH Response Paper re App. BB, Rev. 2 3 SC&A – December 9, 2016

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.

In his response paper, Allen (2016b) agreed to textual changes to be incorporated in the next revision to 

Appendix BB that fully address our concerns. Consequently, we recommend that Issue 10 be closed.

References

Allen, D. 2014. “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals: Appendix 

BB – General Steel Industries,” Battelle-TBD-6000, Appendix BB, Revision No. 1. Division of 

Compensation Analysis and Support, National Institute for Occupational Safety and Health, Cincinnati, 

Ohio. June 6, 2014. http://www.cdc.gov/niosh/ocas/pdfs/arch/b-6000-apbb-r1.pdf

Allen, D. 2016a. “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals: Appendix 

BB – General Steel Industries,” Battelle-TBD-6000, Appendix BB, Revision No. 02. Division of 

Compensation Analysis and Support, National Institute for Occupational Safety and Health, Cincinnati, 

Ohio. May 26, 2016. http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r2.pdf

Allen, D. 2016b. “NIOSH Response to Sanford Cohen & Associates Review of Battelle-TBD-6000 

Appendix BB (General Steel Industries, Rev. 2) Response Paper.” Division of Compensation Analysis 

and Support, National Institute for Occupational Safety and Health, Cincinnati, Ohio. November 4, 

2016. http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsibbr2.pdf

Anigstein, R., and J. Mauro. 2014. “Review of ‘Site Profiles for Atomic Weapons Employers that 

Worked Uranium Metals Appendix BB – General Steel Industries,’ Revision 1.” Memorandum to 

Advisory Board on Radiation and Worker Health, Work Group on TBD-6000, SC&A, Inc., Vienna, 

Virginia. December 10, 2014. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiapbbr1-

121014.pdf

Anigstein, R., and J. Mauro. 2015. “Review of ‘Responses to Sanford Cohen & Associates Review of 

Battelle-TBD-6000 Appendix BB (General Steel Industries, Rev. 1),’ Response Paper.” Memorandum 

to Advisory Board on Radiation and Worker Health, Work Group on TBD-6000, SC&A, Inc., Vienna, 

Virginia. January 26, 2015. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiapbbr1-

012615.pdf

Anigstein, R., and J. Mauro. 2016. “Review of ‘Site Profiles for Atomic Weapons Employers that 

Worked Uranium Metals Appendix BB – General Steel Industries,’ Revision 2.” Memorandum to 

Advisory Board on Radiation and Worker Health, Work Group on TBD-6000, SC&A, Inc., Vienna, 

Virginia. September 6, 2016. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsispr2-090616.pdf

Katz, T. 2016. “RE: TBD-6000 WG,” December 6, 2016, personal email to Robert Anigstein, SC&A, 

Inc., and Paul Ziemer, ABRWH. Copies to other members of the ABRWH Work Group on TBD-6000; 

James Neton and David Allen, NIOSH/DCAS; and John Mauro and John Stiver, SC&A. 

Office of Compensation Analysis and Support (OCAS). 2007. “External Dose Reconstruction 

Implementation Guideline,” OCAS-IG-001, Revision No. 3. Office of Compensation Analysis and 

Support, National Institute for Occupational Safety and Health, Cincinnati, Ohio. November 21, 2007. 

www.cdc.gov/niosh/ocas/pdfs/dr/oc-ig-001-r3.pdf