Summary of Seven Document 

Reviews Approved by the 

Subcommittee for Procedure Reviews

Kathleen Behling, SC&A, Inc.

Advisory Board on Radiation and Worker Health, 

Subcommittee for Procedure Reviews

April 27, 2022
2

SCPR-approved documents

 ORAUT-OTIB-0066, rev. 01, “Calculation of Dose from Intakes of 

Special Tritium Compounds”

 ORAUT-RPRT-0086, rev. 00, “Internal Dosimetry Coworker Data 

Completeness Test”

 DCAS-PER-057, rev. 0, “General Steel Industries”

 DCAS-PER-080, rev. 0, “General Steel Industries”

 DCAS-PER-063, rev. 0, “Aluminum Company of America –

Pennsylvania (ALCOA-PN)

 DCAS-PER-065, rev. 0, “Anaconda”

 DCAS-PER-064, rev. 0, “DuPont Deep Water Works”
3

ORAUT-OTIB-0066, rev. 01

 Title: “Calculation of Dose from Intakes of Special Tritium 

Compounds”

 Provides guidance for the calculation of best estimate of organ 

doses for intakes of tritium bound to organically bound tritium (OBT) 

and stable metal tritide (SMT)

 Revision 00 issued April 26, 2007

 SC&A submitted its review of rev. 00 on November 25, 2008, and 

identified four findings

 Presented to the SCPR at the March 24, 2009, meeting

 Revision 01 issued October 15, 2020
4

Issue resolution for OTIB-0066, rev. 00, 

finding 1

Finding date Finding description NIOSH response Finding resolution

11/25/2008 The recommendation 

given in OTIB-0066 to 

assess dose to intake 

of OBT using 

methodology in 

ORAUT-OTIB-0011 is 

not claimant 

favorable.

1/23/2009. NIOSH agrees. The 1.4 

factor referenced in OTIB-0011 is 

correct for type 1 calculations on 

urinary excretion during a chronic 

intake, but the adjustment is larger 

for types 2 and 3 calculations. 

OTIB-0011 will be revised.

10/21/2020. The recommendation 

to use OTIB-0011 to calculate 

doses from intakes of OBT has 

been removed in OTIB-0066, 

rev. 01, which now specifies that 

IMBA must be used for such 

assessments.

4/28/2021. SC&A 

performed a focused 

review of OTIB-0066, 

rev. 01, confirmed that 

appropriate changes 

were incorporated into 

rev. 01, and 

recommended closing 

the finding.

11/3/2021. The SCPR 

agreed to close finding.
5

Issue resolution for OTIB-0066, rev. 00, 

finding 2

Finding date Finding description NIOSH response Finding resolution

11/25/2008 Bounding techniques 

proposed in OTIB-0066 

cannot be effectively 

developed and applied 

without understanding the 

special tritium compounds 

handled, material 

quantities, locations and 

time periods of potential 

exposure, and physical 

behaviors of tritium 

compounds in the 

environment.

1/23/2009. This finding is not 

within the scope of OTIB-0066 

and should be addressed in 

the site profile.

3/24/2009. SC&A 

agreed with NIOSH 

response and 

recommending closing 

the finding. The SCPR 

closed the finding 

based on NIOSH’s 

response and SC&A’s 

recommendation.
6

Issue resolution for OTIB-0066, rev. 00, 

finding 3

Finding 

date

Finding description NIOSH response Finding resolution

11/25/2008 OTIB-0066 does not 

ensure that resultant 

doses are based on 

adequate monitoring 

data. The method of 

choice for personnel 

monitoring is 

particulate air 

monitoring; however, 

there are multiple 

issues with the use 

of these data.

1/23/2009. NIOSH agrees that air 

monitoring data are useful for evaluating 

SMT intakes. In the absence of such 

data, urine bioassay can be used to 

bound the SMT intake to the respiratory 

tract and systemic organs. NIOSH will 

add discussion of the practical 

interpretation and shortfalls of urinalysis 

results following an intake of SMT.

10/21/2020. A paragraph was added to 

the Purpose section of rev. 01 that 

discusses the limitations associated 

with the use of urine sampling for 

quantifying SMT intakes.

4/28/2021. SC&A 

performed a focused 

review of OTIB-0066, 

rev. 01, confirmed that 

appropriate changes 

were incorporated into 

rev. 01, and 

recommended closing 

the finding.

11/3/2021. The SCPR 

agreed to close finding
7

Issue resolution for OTIB-0066, rev. 00, 

finding 4

Finding 

date

Finding description NIOSH response Finding resolution

11/25/2008 The procedure 

provides no guidance 

on how to distinguish 

between intakes of 

special tritium 

compounds, 

elemental tritium, 

and/or tritiated water 

that occur 

simultaneously or 

overlap.

1/23/2009. It is not possible 

to identify the compound 

responsible, including 

excretion resulting from 

intakes. Most claimantfavorable models are 

consistent with the source 

terms.

3/24/2009. SC&A 

agreed with NIOSH’s 

response and 

recommended closure. 

11/3/2021. The SCPR 

agreed to close 

finding.
8

Board discussion of ORAUT-OTIB-0066
9

ORAUT-RPRT-0086, rev. 00

 Title: “Internal Dosimetry Coworker Data Completeness Test”

 Evaluates the completeness of internal dosimetry data by 

providing a method to calculate the proportion of missing data 

for a given set of coworkers

 Revision 00 issued September 18, 2017

 SC&A submitted its review of rev. 00 on January 12, 2018, and 

identified three observations

 Presented review and discussed observations at SCPR 

meeting February 13, 2019
10

Issue resolution for RPRT-0086, rev. 00, 

observation 1

Observation 

date

Observation 

description

NIOSH response Observation resolution

1/12/2018 Some RPRT-0086 

parameters are variable, 

and selection of their 

values will determine the 

required sample sizes 

and may affect the 

outcome of analyses. 

These include: 

Parameter 1: Producer’s 

risk α; Parameter 2: 

Consumer’s risk β; 

Parameter 3: Acceptable 

error rate; Parameter 4: 

Unacceptable error rate.

2/13/2019. NIOSH 

indicated that they will note 

this observation, but it does 

not change the 

methodology used in the 

procedure. When the report 

is revised, NIOSH will add 

appropriate wording.

2/13/2019. The SCPR 

accepted NIOSH’s 

response and closed the 

observation.
11

Issue resolution for RPRT-0086, rev. 00, 

observation 2

Observation 

date

Observation 

description

NIOSH response Observation resolution

1/12/2018 “Original dataset” is used 

throughout document to 

refer to the computerreadable dataset in 

electronic form that has 

been transcribed from 

the hardcopy records. 

The term “original” 

generally refers to origin 

or first. A different term 

for the electronic dataset 

would be less confusing 

when reading RPRT0086.

2/13/2019. NIOSH 

indicated that they will note 

this observation, but it does 

not change the 

methodology used in the 

procedure. When the report 

is revised, NIOSH will add 

appropriate wording.

2/13/2019. The SCPR 

accepted NIOSH’s 

response and closed the 

observation.
12

Issue resolution for RPRT-0086, rev. 00, 

observation 3

Observation 

date

Observation 

description

NIOSH response Observation resolution

1/12/2018 The last paragraph on 

page 11 states:

“This process is 

illustrated in Figure 5-3, 

where, for example, the 

critical values for n = 25 

are those shown in 

Figure 5-2.”

According to the caption 

for Figure 5-2, n = 24, 

not 25.

2/13/2019. NIOSH agreed 

that this is a typo, but it 

does not change the 

methodology used in the 

procedure. When the report 

is revised, NIOSH will 

correct this error.

2/13/2019. The SCPR 

accepted NIOSH’s 

response and closed the 

observation.
13

Board discussion of ORAUT-RPRT-0086
14

DCAS-PER-057, rev. 0

 Title: “General Steel Industries” (GSI)

 Issued March 11, 2015

 Determines the effect of rev. 01 of the GSI appendix BB to 

Battelle-TBD-6000

 Extensive changes to dose estimate for each year of the 

operational and residual periods
15

SC&A’s review of PER-057, rev. 0

 GSI appendix BB to TBD-6000, rev. 01, dated June 4, 2014, was 

reviewed separately

 PER-057 review consisted of only subtask 4 protocol for evaluation 

of a sample set of impacted cases

 SC&A reviewed five cases based on selection criteria that included 

employment period, job category, and cancer type

 SC&A submitted its subtask 4 report December 12, 2016

 SC&A’s subtask 4 report identified four findings and seven 

observations 

 SC&A presented review to the SCPR at the January 10, 2017, 

meeting
16

Issue resolution for PER-057 subtask 4, 

finding 1

Finding date Finding description NIOSH response Finding resolution

12/12/2016 NIOSH incorrectly assigned 

the energy employee (EE) 

in one selected case to an 

Administrative category, 

which is inappropriate 

based on information 

provided in the CATI. To 

determine if this was a 

systemic issue, SC&A 

reviewed all GSI cases that 

were assigned in the 

Administrative category and 

concluded this was not 

widespread.

1/10/2017. After 

reviewing the CATI report 

for the EE, NIOSH 

agreed that the worker 

should not have been 

classified under the 

Administrative category. 

However, since the EE 

was not employed at the 

site, there is not much 

that can be done to 

correct the error. 

1/10/2017. The SCPR 

closed the finding, since 

it appears that the 

incorrect job category 

selection was a unique 

situation.
17

Issue resolution for PER-057 subtask 4, 

finding 2

Finding 

date

Finding description NIOSH response Finding resolution

12/12/2016 Using CADW, NIOSH 

prorated intakes to 

account for partial years 

of employment. This 

approach for calculating 

internal doses is 

considered an efficiency 

measure that could have 

affected the 

compensation decision. 

SC&A recommends 

NIOSH use IMBA in 

these cases.

1/10/2017. NIOSH indicated that 

for best estimate cases, typically 

IMBA is used to calculate dose. 

NIOSH did recalculate the 

internal dose using IMBA and reran IREP. This resulted in a 

modest change in the POC, 

which had no impact on the case. 

NIOSH also indicated that CADW 

has been modified to allow for 

partial-year intakes. At the 

SCPR’s request, NIOSH 

submitted a formal response 

documenting this issue.

2/13/2019. Based on 

the response provided 

by NIOSH, the SCPR 

closed the finding.
18

Issue resolution for PER-057 subtask 4, 

finding 3

Finding date Finding description NIOSH response Finding resolution

12/12/2016 NIOSH used an 

incorrect end date in 

calculating intakes of 

uranium. An additional 

year of intake was 

included after the EE’s 

date of employment. 

This error represents a 

quality assurance 

issue.

1/10/2017. NIOSH 

acknowledged that there 

was an error in the end 

date but indicated that it 

did not impact the case.

1/10/2017. The SCPR 

closed the finding.
19

Issue resolution for PER-057 subtask 4, 

finding 4

Finding date Finding description NIOSH response Finding resolution

12/12/2016 NIOSH needs to 

perform further 

research to determine 

if the EE in the 

selected case should 

be reclassified as a 

Plant Worker rather 

than Administrative.

1/10/2017. NIOSH 

indicated that all of the 

GSI cases that were 

assigned under the 

Administrative category 

were re-reviewed to 

ensure that this 

classification was 

appropriate.

1/10/2017. The SCPR 

closed the finding.
20

Issue resolution for PER-057 subtask 4, 

observation 1

Observation 

date

Observation 

description

NIOSH response Observation 

resolution

12/12/2016 NIOSH used a fixed 

value of the exposureto-organ dose 

conversion factor 

(DCF) for assigning 

doses to 

Administrative 

personnel, which is 

inconsistent with the 

instructions in OCASIG-001.

1/29/2021. The GSI 

appendix, tools, and 

some techniques were 

revised, and NIOSH 

issued DCAS-PER-080. 

SC&A was tasked to 

review PER-080 and, 

based on that review, 

determined the 

observation was 

resolved. 

2/18/2021. The SCPR 

closed the 

observation.
21

Issue resolution for PER-057 subtask 4, 

observation 2

Observation 

date

Observation 

description

NIOSH response Observation 

resolution

12/12/2016 External photon doses 

during the residual 

period should be 

entered in IREP as 

chronic exposure 

rates.

1/10/2017. NIOSH 

selects acute versus 

chronic dose based on 

dose rate efficiency 

factors and typically 

selects the exposure 

mode that gives the 

highest POC.

2/18/2021. Based on 

NIOSH’s explanation, 

the SCPR closed the 

observation.
22

Issue resolution for PER-057 subtask 4, 

observation 3

Observation 

date

Observation 

description

NIOSH response Observation 

resolution

12/12/2016 NIOSH derived 

distributions of organ 

doses to operators 

during 1952–1961 by 

incorrectly assuming 

that exposure rates 

and DCFs were totally 

correlated.

1/29/2021. The GSI 

appendix, tools, and 

some techniques were 

revised, and NIOSH 

issued DCAS-PER-080. 

SC&A was tasked to 

review PER-080 and, 

based on that review, 

determined the 

observation was 

resolved. 

2/18/2021. The SCPR 

closed the 

observation.
23

Issue resolution for PER-057 subtask 4, 

observation 4

Observation 

date

Observation 

description

NIOSH response Observation 

resolution

12/12/2016 Appendix BB, 

revision 1, cannot be 

used to assign 

neutron doses.

1/29/2021. The GSI 

appendix, tools, and 

some techniques were 

revised, and NIOSH 

issued DCAS-PER-080. 

SC&A was tasked to 

review PER-080 and, 

based on that review, 

determined the 

observation was 

resolved. 

2/18/2021. The SCPR 

closed the 

observation.
24

Issue resolution for PER-057 subtask 4, 

observation 5

Observation 

date

Observation 

description

NIOSH response Observation resolution

12/12/2016 Beta doses to the skin 

during 1964–1966 

should be entered in 

IREP as chronic 

exposures.

1/29/2021. NIOSH agrees 

that a chronic exposure 

rate is more accurate, but 

they typically assign acute,

because it is more claimant 

favorable. Guidance 

document does not specify. 

If the case is a best 

estimate, NIOSH may use 

the more accurate chronic 

exposure.

2/18/2021. Based on 

NIOSH’s explanation, the 

SCPR closed the 

observation.
25

Issue resolution for PER-057 subtask 4, 

observation 6

Observation 

date

Observation description NIOSH response Observation resolution

12/12/2016 NIOSH used efficiency 

measures, i.e., CADW, to 

estimate internal doses to 

the kidneys.

2/18/2021. Observation 6 is 

similar to finding 2, which 

was closed based on a 

NIOSH memo. SC&A was 

tasked to look at the 

finding 2 memo and provide 

response at the next 

meeting.

11/3/2021. SC&A presented 

its 8/17/2021 memo, which 

indicated the observation 

was resolved since NIOSH 

agreed to use IMBA for best 

estimate cases.

11/3/2021. Based on 

NIOSH’s response and 

SC&A’s memo, the 

SCPR closed the 

observation.
26

Issue resolution for PER-057 subtask 4, 

observation 7

Observation 

date

Observation 

description

NIOSH response Observation 

resolution

12/12/2016 NIOSH assigned 

medical x-ray 

exposures to a worker 

who stated that 

medical x-rays were 

not required as a 

condition of 

employment.

1/29/2021. The GSI 

appendix, tools, and 

some techniques were 

revised, and NIOSH 

issued DCAS-PER-080. 

SC&A was tasked to 

review PER-080 and, 

based on that review, 

determined the 

observation was 

resolved. 

2/18/2021. The SCPR 

closed the 

observation.
27

Board discussion of DCAS-PER-057
28

DCAS-PER-080, rev. 0

 Title: “General Steel Industries”

 Issued August 30, 2017

 Determines the effect of revisions 02 and 03 of the GSI 

appendix BB to Battelle-TBD-6000

 1966 operational period inhalation intakes increased and at 

least one prescribed external organ or skin dose for 

radiographers increased in each operational year 
29

SC&A’s review of PER-080, rev. 0

 GSI (appendix BB to TBD-6000), rev. 02, dated May 26, 2016, and 

rev. 03, dated February 9, 2017, were reviewed separately

 PER-080 review consisted of only evaluating a sample set of 

impacted cases 

 SC&A reviewed five cases based on selection criteria that included 

periods of employment, job categories, and types of cancer

 SC&A submitted its subtask 4 report July 19, 2018

 SC&A’s subtask 4 report identified one observation 

 SC&A presented case review to SCPR at the February 13, 2019, 

meeting
30

Issue resolution for PER-080 subtask 4, 

observation 1

Observation 

date

Observation description NIOSH response Observation 

resolution

12/12/2016 Using CADW, NIOSH 

prorated intakes to 

account for partial years of 

employment. This 

approach for calculating 

internal doses is 

considered an efficiency 

measure that could have 

affected the compensation 

decision of cases with 

POCs close to 50%. SC&A 

recommends NIOSH use 

IMBA in these cases.

2/13/2019. NIOSH indicated 

that their prior statement that 

CADW would assess doses 

based on daily intakes was 

incorrect. CADW was actually 

modified to incorporate the 

prorating approach for partialyear intakes. To resolve this 

issue, the dose reconstructors 

have been instructed to use 

IMBA for any case with a POC 

between 45% and 52%.

2/13/2019. Based on 

the response provided 

by NIOSH, the SCPR 

closed the observation.
31

Board discussion of DCAS-PER-080
32

DCAS-PER-063, rev. 0

 Title: “Aluminum Company of America – Pennsylvania (ALCOA-PN)”

 Issued June 15, 2015

 Determines the effect of rev. 1 of appendix R to Battelle-TBD-6000

 Revision 1 changes:

– incorporated TBD-6000 revisions

– eliminated job categories (Operator, General Laborer, Supervisor, and Clerk) 

and assumes job title of Operator

– included ORAUT-OTIB-0070 depletion factors during residual period

 Inhalation, ingestion, and external doses increased during 

operational period and some residual period doses increased 

through 1980
33

SC&A’s review of PER-063, rev. 0

 SC&A submitted its review of PER-063 July 17, 2017

 No findings identified in the PER-063 review

 Presented review to TBD-6000 work group September 25, 2017

 Under subtask 4 protocol, SC&A reviewed one case where the EE 

was assigned internal and external doses during the operational 

and residual periods

 SC&A submitted its subtask 4 report September 2, 2021

 No findings identified in the review of one reworked case

 SC&A presented case review to SCPR November 3, 2021
34

ALCOA-PN facility history

 ALCOA used a unique welding process to “can” and seal 

uranium slugs produced by other facilities

 Work proceeded under 15 purchase orders, resulting in the 

canning of approximately 100,000 slugs

 The facility was listed as an Atomic Weapons Employer (AWE) 

from 1943 through 1945

 Residual phase consists of the time period from 1946 through 

1991
35

SC&A’s assessment of NIOSH’s method for 

corrective actions in PER-063 

 SC&A previously reviewed revisions to TBD-6000 and OTIB-0070

 PER-063 review compared original and revised TBD-6000, 

appendix R, as follows:

– Operational period external whole body, hands and forearm, and other skin 

dose rates

– Operational period inhalation and ingestion intakes

– Residual period derived floor contamination levels

– Residual period photon and beta dose rates

– Residual period source depletion rate

– Annual residual period external and internal doses based on source depletion 

factors
36

SC&A’s conclusions on NIOSH’s method for 

corrective actions in PER-063

 Confirmed that appropriate parameters from revised TBD-6000 

and OTIB-0070 were applied

 SC&A able to match all rev. 1 operational dose rate and intake 

values

 Verified floor contamination levels and source depletion rates 

were correctly calculated

 Able to match rev. 1 residual dose rates and internal intakes
37

SC&A’s evaluation of PER-063 approach to 

identify potentially affected dose reconstructions

 Initial identification of potentially affected cases performed by 

searching all ALCOA-PN cases with POCs less than 50%

 44 total cases identified

– Two claims eliminated since they were completed using rev. 1

– Five claims completed using a complex-wide overestimating method, 

resulting in higher doses than rev. 1

– Two claims were returned to NIOSH and reworked using rev. 1

 New dose estimates calculated for remaining 35 cases

 SC&A agrees with selection strategy and screening criteria
38

SC&A’s recommendation for review of sample 

set of cases impacted by PER-063

 Under subtask 4 protocol, SC&A reviews a sample set of 

reevaluated cases to assess if appendix R, rev. 1, was 

implemented correctly

 Selection criteria:

– EE assigned external exposure during the operational period

– EE assigned internal exposure during the operational period

– EE assigned external exposure during the residual period

– EE assigned internal exposure during the residual period
39

Selection of PER-063 case review

 NIOSH identified one case that met all selection criteria

 NIOSH reworked the case 

– using applicable DR tools

– recalculated all annual doses

– re-ran Interactive RadioEpidemiological Program (IREP) 30 times at 

10,000 iterations per run

 Rework of the case resulted in a POC between 45% and 50%

 Formal revised DR report not sent to Department of Labor 

(DOL) because the compensation decision did not change
40

PER-063 case background

 EE worked at ALCOA-PN for ~3 decades

 Worked throughout the facility

 Not monitored for radiation exposure

 Diagnosed with qualifying cancer ~20 years after termination of 

employment
41

Comparison of NIOSH’s reworked doses and 

original doses for PER-063 case

Dose categories Reworked vs. original dose percentage

External 1858% increase

Occupational medical No change

Internal 1% decrease

Total 1055% increase

POC 906% increase
42

Original external dose calculations for 

PER-063 case

 Assumed “Plant Floor High” job category

 Used whole-body dose rates from table R.3 of appendix R, 

rev. 0, for operational and residual periods

 Applied DCF of 1.244 associated with bladder as surrogate 

organ

 Assigned dose to cancer site ~0.500 rem
43

Reworked external dose calculations for 

PER-063 case

 Used whole-body dose rates from table R.2 of appendix R, 

rev. 1, for operational and residual periods

 Applied DCF of 1.244 associated with bladder as surrogate 

organ

 Assigned dose to cancer site greater than 9.000 rem
44

Original occupational medical dose for 

PER-063 case

 Assumed pre-employment and annual chest x-rays during 

operational period

 Used dose for urinary bladder, as surrogate organ, from 

ORAUT-OTIB-0006, rev. 03 PC-1

 Assigned dose to cancer site less than 0.100 rem
45

Reworked occupational medical dose for 

PER-063 case

 Also assumed pre-employment and annual chest x-rays during 

operational period

 Used dose for urinary bladder, as surrogate organ, from 

ORAUT-OTIB-0006, rev. 06

 Assigned same dose to cancer site less than 0.100 rem
46

Original internal dose calculations for 

PER-063 case

 Assumed “Plant Floor High” job category

 Inhalation and ingestion of uranium material intake rate values 

for operational and residual periods from tables R.1 and R.2 of 

appendix R, rev. 0

 Used Integrated Modules for Bioassay Analysis (IMBA) 

program to calculate the inhaled and ingested dose from 

uranium

 Compared types M and S uranium, with type M resulting in 

higher dose

 Assigned dose to cancer site ~0.300 rem
47

Reworked internal dose calculations for 

PER-063 case

 Inhalation and ingestion of uranium material intake rate values 

for operational and residual periods from table R.1 of 

appendix R, rev. 1

 Used IMBA to calculate the inhaled and ingested dose from 

uranium

 Compared types M and S uranium, with type M resulting in 

higher dose

 Assigned dose to cancer site ~0.300 rem
48

SC&A’s conclusions on PER-063 case 

 External dose:

– Correct doses selected from applicable tables with exception of one year, 

where NIOSH assigned slightly higher dose than listed in table R.2

– Appropriate surrogate organ selected and associated DCF value applied

 Occupational medical dose:

– Doses calculated for appropriate years of employment

– Correct doses assigned from applicable table

 Internal dose:

– Correct intake values selected except for one year, where NIOSH assigned 

slightly lower dose than identified in table R.1

– Verified type M solubility results in higher dose

 Re-ran IREP 30 times at 10,000 iterations and confirmed POC less 

than 50%
49

Board discussion of DCAS-PER-063
50

DCAS-PER-065, rev. 0

 Title: “Anaconda”

 Issued November 30, 2015

 Determines the effect of rev. 1 of appendix G to TBD-6000

 Revision 1 incorporated changes to TBD-6000 and made dose 

estimates more consistent with existing techniques

 External doses increased for all job categories and all years of 

operation

 Although not explicitly stated, revision also incorporated OTIB-0070 

(periods between extrusion operations) and OTIB-0006 

(occupational medical dose) revisions
51

SC&A’s review of PER-065, rev. 0

 SC&A submitted its review of PER-065 June 15, 2016, which 

included an evaluation of the dose reconstruction (DR) methods

 No findings identified in the PER-065 review

 Presented review to TBD-6000 work group September 25, 2017

 SC&A reviewed one case where EE was assigned external dose as 

an operator during the operational period and was assigned 

occupational medical dose

 SC&A submitted its subtask 4 report August 25, 2021

 No findings identified in the review of one reworked case

 Presented case review to SCPR November 3, 2021
52

Anaconda facility history

 Conducted 1956 pilot project where uranium billets were 

extruded to evaluate uranium extrusion procedures to 

manufacture uranium fuel

 50 billets were extruded in March 1957

 Extrusion activities also took place in October 1959
53

SC&A’s review of Anaconda DR methods

 Compared original and revised versions of TBD-6000, 

appendix G to ensure:

– Revised appendix completely and accurately describes the AWE and 

post-AWE activities

– Revision reflects all the site-specific information and data applicable to 

performing DRs

– Revision uses the most recent generic guidance applicable to DRs at 

Anaconda (i.e., TBD-6000, OTIB-0070, and OTIB-0006)

– Appendix makes use of all applicable information, data, and guidance 

in a scientifically sound and claimant-favorable manner
54

SC&A’s conclusions on Anaconda DR methods

 Site profile accurately extracted and interpreted referenced 

data source information

 Evaluation of non-referenced data sources corroborated 

information from cited data sources

 SC&A agrees with NIOSH’s assumptions and derivation of 

external and internal doses

 SC&A found one minor inconsistency in the appendix where 

the URL for the cited DOL website was incorrect
55

SC&A’s evaluation of PER-065 approach to 

identify potentially affected DRs

 Initial identification of potentially affected cases performed by 

searching for all Anaconda cases with POCs less than 50%

 Ten cases were identified and new dose estimates calculated

 SC&A agrees with selection strategy
56

SC&A’s recommendation for review of a 

sample set of cases impacted by PER-065

 Under the subtask 4 protocol, SC&A reviews a sample set of 

reevaluated cases to assess if appendix G, rev. 1, was 

implemented correctly

 Selection criteria:

– assignment of external dose for the Operator and Laborer job category

– employment during the period 1956–1959

– occupational medical x-ray examinations with dose calculated using 

ORAUT-OTIB-0006, rev. 04, or later
57

Selection of PER-065 case review

 NIOSH identified one case that met all selection criteria

 NIOSH reworked the case 

– using applicable DR tools

– recalculated all annual doses

– re-ran IREP

 Rework of the case resulted in a POC less than 50%

 Formal revised DR report not sent to DOL because the 

compensation decision did not change
58

SC&A’s review of reworked DR impacted by 

PER-065

 SC&A’ review was generally limited to reevaluation of pathways 

addressed in PER-065

 External doses increased due to Anaconda site profile changes

 SC&A also assessed internal exposure to evaluate significant 

differences in NIOSH’s original and reworked doses
59

PER-065 case background

 EE worked at Anaconda for three decades

 EE worked throughout site

 EE was not monitored for radiation exposure

 Diagnosed with qualifying cancer several years after 

employment termination
60

Comparison of NIOSH’s reworked doses and 

original doses for PER-065 case

Dose categories Reworked vs. original dose percentage

External 95% reduction

Occupational medical 261% increase

Internal 99.6% reduction

Total 71% reduction

POC 86% reduction
61

Original external dose calculations for 

PER-065 case

 Performed prior to issuance of TBD-6000, appendix G, using 

Scherpelz (2006)

 Assumed EE exposed 1 foot from a rectangular uranium slab 

for 3 days in 1956 and 30 days in 1959 for 10 work hours/day 

at 2.08 mrem/hour

 Bladder assumed as surrogate organ for photon DCF of 1.523

 Assigned external dose of >1.000 rem
62

Reworked external dose calculations for 

PER-065 case

 Used guidance in TBD-6000, appendix G, rev. 1

 Calculated external dose using annual photon doses for each 

year of uranium operations from table G.2

 Per ORAUT-OTIB-0005, rev. 05, liver assumed as surrogate 

organ for photon DCF of 1.064

 Assigned external dose of ~0.050 rem
63

Original medical dose calculations for 

PER-065 case

 Assumed annual x-ray for each year of employment

 Urinary bladder assumed as surrogate organ 

 Used dose data from table 6-5 of OTIB-0006, rev. 03 PC-1

 Assigned external dose of ~0.1 rem
64

Reworked medical dose calculations for 

PER-065 case

 Assumed annual x-ray for each year of employment

 Gallbladder assumed as surrogate organ 

 Used dose data from table 6-5 of OTIB-0006, rev. 04

 Assigned external dose of >0.3 rem
65

Original internal dose calculations for 

PER-065 case

 Uranium intakes assigned for extrusion (2,965 pCi/day) and rolling 

(10,559 pCi/day) in 1956 and 1959 using operator data from 

table 7.8 of Scherpelz (2006)

 Air sampling data derived from summary of AWE metal-working 

sites

 30-day intake for each process applied for each year

 Intakes of recycled uranium components from plutonium-239 and 

neptium-237 were scaled from uranium intakes

 Using IMBA, type M solubility was claimant favorable

 Inhalation and ingestion intakes applied as inhalation

 Assigned internal dose of ~0.250 rem
66

Reworked internal dose calculations for 

PER-065 case

 Uranium intakes assigned based on inhalation and ingestion intakes 

from TBD-6000, appendix G, table G.1

 Inhalation values ranged, based on year of operation, from 0.66 to 

3.74 dpm/day, as specified in table G.1

 Table G.1 ingestion value of 5.34 dpm/day used for all years

 Appendix G used highest reported air monitoring data (39 dpm/m3) 

in work areas in 1956 and 1959

 Doses calculated for each year of uranium operations

 Using IMBA, type M solubility found to be claimant favorable

 Assigned internal dose of 0.001 rem
67

SC&A’s conclusions on external dose for 

PER-065 case

 Reworked external dose:

– Appropriate dose assigned based on appendix G, rev. 1

– Surrogate organ based on current revision of ORAUT-OTIB-0005

– Doses entered in IREP correctly

– Note: If the original DR was performed using appendix G, rev. 0, the 

reworked external doses would have increased

 Reworked occupational medical dose:

– Appropriate dose assigned based on OTIB-0006

– Surrogate organ selection based on OTIB-0005

– Doses entered in IREP correctly
68

SC&A’s conclusions on internal dose for 

PER-065 case

 Reworked internal dose:

– Appropriate intake values used as specified in appendix G, rev. 0

– Input data entered in IMBA correctly

– Assumptions claimant favorable

 SC&A had no findings about the selected reworked case 

impacted by PER-065
69

Board discussion of DCAS-PER-065
70

DCAS-PER-064, rev. 0

 Title: “DuPont Deep Water Works”

 Issued November 16, 2015

 Determines the effect of several changes to DuPont Deepwater 

Works DR methodology:

– Original DRs used Battelle-TBD-6001, appendix B

– Standalone document (DCAS-TKBS-0006; “TBD”) created 2/15/2011 

after TBD-6001, appendix B, cancelled; some operational period doses 

increased, others decreased

– TBD rev. 01 (12/13/2013) increased operational period inhalation 

intakes and external dose rates and residual period ingestion intakes

– TBD rev. 02 (3/20/2015) increased ingestion intakes
71

SC&A’s review of DCAS-PER-064, rev. 00

 SC&A separately reviewed DuPont Deepwater TBD

 PER-064 review consisted of only subtask 4 protocol for evaluation 

of a sample set of impacted cases

 SC&A reviewed two cases under its subtask 4 protocol:

– One case resulting in a POC between 45% and 50%

– One case with external and internal dose assignments during the operational 

and residual periods

 SC&A submitted its subtask 4 report December 12, 2016

 No findings identified

 Presented case review to SCPR October 31, 2018
72

PER-064 case 1 background

 EE worked at DuPont Deepwater Works for three decades

 EE worked throughout site

 EE was not monitored for radiation exposure

 Diagnosed with two qualifying cancers several years after 

employment termination
73

Comparison of NIOSH’s reworked doses and 

original doses for PER-064 case 1

Dose categories (a) Reworked vs. original 

dose percentage for 

cancer 1

Reworked vs. original 

dose percentage for 

cancer 2

External 52% decrease 43% decrease

Occupational medical 14% increase 14% increase

Internal 1% increase 04% increase

Total (b) 34% decrease 12% decrease

(a) SC&A’s review only evaluated external and internal doses, as addressed in PER-064.

(b) Reworked vs. original combined POC increased by 30%.
74

Original external dose calculations for 

PER-064 case 1

 Assumed a job category of “Plant Floor Low”

 Operational doses assigned using values in table B.3 of TBD-6001, 

appendix B, rev. 0

 Operational dose for 1942 = 642 mR/yr; 1943–1948 = 1,161 mR/yr

 Appendix B, table B.3, annual dose of 0.040 R assigned during 

residual period

 Applicable OCAS-IG-001, rev. 3, anterior-posterior (AP) geometry 

exposure-to-organ DCF values applied

 Assigned dose of ~3.0 rem to cancer 1 and ~5.0 rem to cancer 2

 Annual doses were entered in IREP as constant values
75

Reworked external dose calculations for 

PER-064 case 1

 Operational doses: 

– Assumed job category of “Laborers”

– Used value (672 mR/yr) in table 7 of the DuPont Deepwater TBD, rev. 02

– Photon energy ranges 50% 30–250 keV and 50% >250 keV

– Applied IG-001, rev. 3, AP geometry, exposure-to-organ DCF values

– Entered in IREP as lognormal with geometric standard deviation (GSD) of 5

 Residual doses:

– Assigned TBD table 8 annual dose of 7.3 mR for all workers

– Photon energy range 100% 30–250 keV

– Applied IG-001, rev. 3, AP geometry, exposure-to-organ DCF value

– Entered in IREP as constant

 Assigned dose of ~2.0 rem to cancer 1 and ~1.5 rem to cancer 2
76

SC&A’s conclusions on the reworked external 

doses for PER-064 case 1 

 SC&A was able to match operational external doses:

– Using Laborer doses from table 7, DuPont Deepwater TBD, rev. 02

– Applying appropriate IG-001 exposure-to-organ DCF values

– Assigning doses to 50% 30–250 keV and 50% >250 keV 

 SC&A was able to match residual external doses:

– Using doses from table 8 of DuPont Deepwater TBD, rev. 02

– Applying appropriate IG-001 exposure-to-organ DCF values

– Assigning doses to 100% 30–250 keV

 SC&A verified all annual doses were entered in IREP as specified in 

guidance

 No findings
77

Original internal dose calculations for 

PER-064 case 1

 Operational intakes for inhalation (1,428 dpm/day) and 

ingestion (25 dpm/day) from TBD-6001, appendix B, table B.1

 Residual period intakes for inhalation (0.329 dpm/day) and 

ingestion (0.00385 dpm/day) from TBD-6001, appendix B, 

table B.2

 Type F solubility uranium-234 assumed

 Assigned dose of ~2.0 rem to cancer 1 and ~7.0 rem to 

cancer 2

 Annual doses entered in IREP as constant
78

Reworked internal dose calculations for 

PER-064 case 1

 Assumed job category of “Supervisors/Laborer”

 Operational intakes for inhalation (1,428 dpm/day) and ingestion 

(27 dpm/day) from DCAS-TKBS-0006, table 1

 Residual period intakes for inhalation (0.329 dpm/day) and ingestion 

(30.1 dpm/day) from TBD table 10

 Compared types F, M, and S uranium-234 for operational period with 

type F solubility most claimant favorable

 Compared types M and S uranium-234 for residual period with type M 

solubility most claimant favorable

 Total assigned dose of ~2.0 rem to cancer 1 and ~7.0 rem to cancer 2

 Annual doses entered in IREP as constant
79

SC&A’s conclusions on the reworked internal 

doses for PER-064 case 1 

 SC&A’ assessment of internal doses:

– Ran IMBA using inhalation and ingestion intake values specified in DCAS- TKBS-0006, rev. 02

– Compared solubility types F, M, and S for the operational period and verified 

type F was most claimant favorable

– Compared types M and S for the residual period and verified type M was 

claimant favorable

– Found that annual doses were entered in IREP correctly and in accordance 

with TBD guidance

 SC&A re-ran IREP using the reworked external and internal doses 

and was able to derive a POC that approximated NIOSH’s POC

 Note: Doses decreased but POC increased, primarily due to 

entering operational dose in IREP as lognormal with a GSD of 5
80

PER-064 case 2 background

 EE worked at DuPont Deepwater Works for three decades

 EE was not monitored for radiation exposure

 Diagnosed with one qualifying cancer several years after 

employment termination
81

Comparison of NIOSH’s reworked doses and 

original doses for PER-064 case 2

Dose categories Reworked vs. original dose 

percentage

External 51% decrease

Occupational medical 14% increase

Internal 0.03% increase

Total 10% decrease

POC 16% increase
82

Original external dose calculations for 

PER-064 case 2

 Assumed a job category of “Plant Floor High”

 Operational doses assigned using values in table B.3 of TBD-6001, 

appendix B, rev. 0

 Operational dose for 1942 = 642 mR/yr; 1943–1948 = 1,161 mR/yr

 Appendix B, table B.3, annual dose of 0.040 R assigned during 

residual period

 Applied IG-001, rev. 3, AP geometry exposure-to-organ DCF value 

for bladder, as surrogate organ

 Assigned dose of ~10.0 rem 

 Annual doses were entered in IREP as constant values
83

Reworked external dose calculations for 

PER-064 case 2

 Operational doses: 

– Assumed job category of “Operators”

– Used value (672 mR/yr) in table 7 of the DuPont Deepwater TBD, rev. 02

– Photon energy ranges 50% 30–250 keV and 50% >250 keV

– Applied IG-001, rev. 3, AP geometry, exposure-to-organ DCF value for bladder as 

surrogate organ

– Entered in IREP as lognormal with GSD of 5

 Residual doses:

– Assigned TBD table 8 annual dose of 7.3 mR for all workers

– Photon energy range 100% 30–250 keV

– Applied IG-001, rev. 3, AP geometry, exposure-to-organ DCF value for bladder as 

surrogate organ

– Entered in IREP as constant

 Assigned dose of ~5.0 rem 
84

SC&A’s conclusions on the reworked external 

doses for PER-064 case 2 

 SC&A was able to match operational external doses:

– Using Operators dose from table 7, DuPont Deepwater TBD, rev. 02

– Applying appropriate IG-001 exposure-to-organ DCF values

– Assigning doses to 50% 30–250 keV and 50% >250 keV 

 SC&A was able to match residual external doses:

– Using dose from table 8 of DuPont Deepwater TBD, rev. 02

– Applying appropriate IG-001 exposure-to-organ DCF values

– Assigning doses to 100% 30–250 keV

 SC&A confirmed all annual doses entered in IREP as specified in 

guidance

 No findings
85

Original internal dose calculations for 

PER-064 case 2

 Operational intakes for inhalation (1,428 dpm/day) and 

ingestion (25 dpm/day) from TBD-6001, appendix B, table B.1

 Residual period intakes for inhalation (0.329 dpm/day) and 

ingestion (0.00385 dpm/day) from TBD-6001, appendix B, 

table B.2

 Type F solubility uranium-234 assumed

 Assigned dose of ~46.0 rem 

 Annual doses entered in IREP as constant
86

Reworked internal dose calculations for 

PER-064 case 2

 Assumed job category of “Operators”

 Operational intakes for inhalation (25,245 dpm/day) and ingestion 

(478 dpm/day) from DCAS-TKBS-0006, table 1

 Residual period intakes for inhalation (0.329 dpm/day) and ingestion 

(30.1 dpm/day) from TBD table 10

 Compared types F, M, and S uranium-234 for operational period, 

with type F solubility most claimant favorable

 Compared types M and S uranium-234 for residual period, with 

type M solubility most claimant favorable

 Total assigned dose of ~46.0 rem 

 Annual doses entered in IREP as constant
87

SC&A’s conclusions on the reworked internal 

doses for PER-064 case 2

 SC&A’s assessment of internal doses:

– Ran IMBA using inhalation and ingestion intake values specified in DCAS- TKBS-0006, rev. 02

– Compared solubility types F, M, and S for the operational period and verified 

type F was most claimant favorable

– Compared types M and S for the residual period and verified type M was 

claimant favorable

– Found that annual doses were entered in IREP correctly and in accordance 

with TBD guidance

 SC&A re-ran IREP using the reworked external and internal doses 

and was able to derive a POC that approximated NIOSH’s POC

 Note: Doses decreased but POC increased, primarily due to 

entering operational dose in IREP as lognormal with a GSD of 5
88

Board discussion of DCAS-PER-064
89

Reference

 Scherpelz, R. I. (2006). Site profiles for Atomic Weapons 

Employers that worked uranium and thorium metals (PNWD3738, rev. 0). Pacific Northwest Division, Battelle, Richland, 

WA.