Draft

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

DCAS-PER-080, SUBTASK 4

REVIEW OF FIVE CASES REEVALUATED BY NIOSH 

USING TBD-6000, APPENDIX BB, REVISIONS 2 AND 3

Contract No. 211-2014-58081 

SCA-TR-2018-PER080-ST4, Revision 0 

Prepared by

Robert Anigstein, PhD 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, VA 22201-3324 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

July 19, 2018 

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. 
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and 

Worker Health Review of NIOSH Dose Reconstruction Program 

DOCUMENT TITLE: DCAS-PER-080, Subtask 4: Review of Five Cases Reevaluated by 

NIOSH Using TBD-6000, Appendix BB, Revisions 2 and 3

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2018-PER080-ST4

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: July 19, 2018

TASK MANAGER Kathleen Behling [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S): John Mauro, PhD, CHP [signature on file] 

Record of Revisions

Revision 

Number

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0 (Draft) 7/19/2018 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 4

1 Background Information ......................................................................................................... 6

1.1 Guidelines for Reviewing a Program Evaluation Report ............................................... 7

2 Review of Individual Cases .................................................................................................... 8

2.1 Case [Redacted] .............................................................................................................. 8

2.1.1 Review of Job Category .............................................................................................. 8

2.1.2 Review of Occupational External Doses .................................................................... 8

2.1.3 Review of Internal Doses .......................................................................................... 10

2.1.4 Review of External Doses from Medical X Rays ..................................................... 10

2.2 Case [Redacted]............................................................................................................ 11

2.2.1 Review of Job Category ............................................................................................ 11

2.2.2 Review of Occupational External Doses .................................................................. 11

2.2.3 Review of Internal Doses .......................................................................................... 12

2.2.4 Review of External Doses from Medical X Rays ..................................................... 13

2.3 Case [Redacted] ............................................................................................................ 14

2.3.1 Review of Job Category ............................................................................................ 14

2.3.2 Review of Occupational External Doses .................................................................. 14

2.3.3 Review of Internal Doses .......................................................................................... 15

2.3.4 Review of External Doses from Medical X Rays ..................................................... 16

2.4 Case [Redacted]............................................................................................................ 16

2.4.1 Review of Job Category ............................................................................................ 16

2.4.2 Review of Occupational External Doses .................................................................. 16

2.4.3 Review of Internal Doses .......................................................................................... 17

2.4.4 Review of External Doses from Medical X Rays ..................................................... 18

2.5 Case [Redacted] ............................................................................................................ 18

2.5.1 Review of Job Category ............................................................................................ 18

2.5.2 Review of Occupational External Doses .................................................................. 18

2.5.3 Review of Internal Doses .......................................................................................... 19

2.5.4 Review of External Doses from Medical X Rays ..................................................... 20

3 Summary and Conclusions ................................................................................................... 21

4 References............................................................................................................................. 23
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ABBREVIATIONS AND ACRONYMS

ABRWH or

Advisory Board Advisory Board on Radiation and Worker Health 

AP antero-posterior 

AEC Atomic Energy Commission

CAD chronic annual dose 

CATI computer-assisted telephone interview

DCAS Division of Compensation Analysis and Support 

DCF dose conversion factor 

DOL U.S. Department of Labor 

DR dose reconstruction 

EE energy employee

GCS Granite City Steel 

GSI General Steel Industries, Inc. 

H*(10) ambient dose equivalent 

ICD International Classification of Diseases

ICRP International Commission on Radiological Protection

IMBA Integrated Modules for Bioassay Analysis

IREP Interactive RadioEpidemiological Program

LLI lower large intestine

mrem millirem

NCI National Cancer Institute at the National Institutes of Health

NIOSH National Institute for Occupational Safety and Health

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT technical information bulletin

PA postero-anterior 

PER program evaluation report 

POC probability of causation 

Ra radium 

R roentgen 

SCPR Subcommittee for Procedure Reviews

TBD technical basis document

U uranium 
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ULI upper large intestine

WG work group
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1 BACKGROUND INFORMATION 

On June 25, 2007, the National Institute for Occupational Safety and Health (NIOSH 2007a) 

issued Appendix BB to “Site Profiles for Atomic Weapons Employers that Worked Uranium and 

Thorium Metals.” This appendix was a site profile of the General Steel Industries, Inc. (GSI), 

steel foundry located in Granite City, Illinois. The issuance of the appendix was followed by 

extensive reviews of this document by SC&A, and meetings and interviews with former GSI 

employees and their advocates. The ensuing reports were presented first at meetings of the Work 

Group on Procedure Reviews of the Advisory Board on Radiation and Worker Health 

(ABRWH),1 later at the newly formed Work Group on TBD 6000/6001,2 and at meetings of the 

full Advisory Board. NIOSH issued detailed responses to the SC&A findings and observations, 

as well as to the work group recommendations. 

1 This work group was later redesignated the ABRWH Subcommittee for Procedure Reviews.

2 In March 2010, this work group was divided into two separate work groups—the Work Group on TBD 6000 and 

the Work Group on TBD 6001.

On June 23, 2014, following these reviews, NIOSH (2014) issued Appendix BB, Rev. 1, which 

embodied recommendations of the ABRWH and its Work Group on TBD 6000. The revised 

appendix was reviewed by SC&A and the work group (WG) and discussed at several WG 

meetings. It became apparent that further revisions were needed; however, due to the time 

elapsed since the original Appendix BB, NIOSH (2015) issued a Program Evaluation Report, 

DCAS-PER-057, based on revision 1, which reevaluated all previously completed claims. The 

ABRWH Subcommittee for Procedure Reviews (SCPR) tasked SC&A with reviewing this PER. 

Because SC&A had already performed a detailed review of revision 1, it was only necessary for 

us to perform a Subtask 4 review of selected cases that had been evaluated by NIOSH. The 

subcommittee directed SC&A to draft a set of criteria for selecting cases from this PER that 

embodied a cross section of periods of employment, job categories, and types of cancer. Based 

on our recommended criteria, the subcommittee asked NIOSH to furnish SC&A four or five 

cases to review; NIOSH subsequently furnished us five case numbers. SC&A (2016) submitted a 

Subtask 4 review of DCAS-PER-057 on December 12, 2016, which included four findings 

regarding incorrect or questionable assignments of workers to job categories that resulted in 

lower doses and incorrect dates for intake regimes. 

In parallel to PER-057, NIOSH continued work on Appendix BB, Rev. 2, addressing SC&A 

findings on revision 1 and the recommendations of the Work Group on TBD 6000. Revision 2 

(NIOSH 2016) was issued on May 26, 2016. Anigstein and Mauro (2016a) reviewed the revised 

appendix and concluded that NIOSH had resolved eight of the 10 findings on revision 1. 

NIOSH (2017a) resolved the two remaining findings by issuing Appendix BB, Rev. 3. NIOSH 

(2017b) then issued DCAS-PER-080, based on revisions 2 and 3, which reevaluated all 

previously completed claims. 

As requested by the SCPR during its meeting by teleconference on November 20, 2017, SC&A 

submitted a set of criteria for selecting cases for a Subtask 4 review that embodied a cross 

section of periods of employment, job categories, and types of cancer. NIOSH furnished SC&A 

five case numbers on January 25, 2018. The objective of the present review is to confirm that 

 
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cases affected by PER-080 were in fact reevaluated in accordance with revisions 2 and 3 of 

Appendix BB to TBD-6000 (NIOSH 2016, 2017a). 

1.1 GUIDELINES FOR REVIEWING A PROGRAM EVALUATION REPORT

SC&A (2009) drafted a set of protocols for conducting a PER review that were approved by the 

ABRWH. These protocols specify five subtasks that SC&A may be tasked to perform by the 

ABRWH, the SCPR, or a cognizant WG. The present assignment is to perform Subtask 4 and, by 

implication, Subtask 5, which are specified as follows: 

• Subtask 4: Conduct audits of dose reconstructions (DRs) affected by the PER under 

review. The number of DRs selected for audit for a given PER will vary, based on 

important elements such as (1) the number of target organs and tissues that may be 

impacted by a PER, and (2) the time period, work location, and job functions that 

characterize the DR of a claim. (It is assumed that the total number of DR audits for each 

PER will be determined by the ABRWH, the SCPR, or the cognizant WG, while the 

actual cases will be selected by NIOSH.)

• Subtask 5: Prepare a comprehensive written report that contains the results of the abovestated subtask, along with our review conclusions. 
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2 REVIEW OF INDIVIDUAL CASES

In fulfillment of the Subtask 4 guidelines listed above, we audited the five cases selected by 

NIOSH to represent the DRs that were affected by DCAS-PER-080 (NIOSH 2017b). Our goal 

was to determine if the exposure scenarios and the resulting DR methodology prescribed in 

Appendix BB, Rev. 3 (NIOSH 2017a) were applied correctly and if the methodology was 

consistent with NIOSH practices for other claimants and for other worksites. Because SC&A 

(2016) had already performed a Subtask 4 review related to Appendix BB, Rev. 1 (NIOSH 

2014), which also involved reviewing the DRs for five cases of presumed former GSI workers, it 

was expeditious to use the same format as that in our previous report in reviewing the new cases. 

2.1 CASE [REDACTED] 

This section of the report presents the results of an independent audit of a DR performed by 

NIOSH for an energy employee (EE) who was employed as a and a at GSI from 

 1963 through 1965, which was during the period of Atomic Energy Commission 

(AEC) operations, and again from 1967 through 1972, which was during the 

residual period. was diagnosed with cancer on , 2005. The original DR 

was approved on August 7, 2007. The probability of causation (POC), as listed in the file 

, which is found on the PER-080 web page and is accessible via the 

, was . The 

POC based on the DR that was revised to conform with the PER was . Because the 

revised POC was >45%, further runs of the Interactive RadioEpidemiological Program (IREP) 

were performed. As stated in , “The average PC value of 

the 99th percentiles from 30 runs with 10000 iterations is .” 

2.1.1 Review of Job Category 

Since the EE was employed during the operational period at GSI, the EE’s job category is 

relevant to the DR. The EE was assigned doses to operators. This is an appropriate assignment: 

as a and , the EE clearly worked inside the plant which, according to NIOSH 

(2017a), defines the operator category at GSI. 

2.1.2 Review of Occupational External Doses 

The external photon exposures assigned in this DR were derived in the Excel file 

, found on the PER-080 web page. 

The was selected as the target organ in the present case, in accordance with 

OTIB-0005 (ORAUT 2012), which listed the as the target organ for estimating doses 

from external exposure in cases of . 

External Photon Doses During 1963–1965 

The doses to the from external exposure to photon radiation during 1963–1965 were 

derived from an annual exposure rate of as listed by NIOSH (2017a, Table 8), 

multiplied by , the effective dose conversion factor (DCF) for converting exposure 
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to photons in the 30–250 keV energy range, incident in the antero-posterior (AP) orientation, to 

dose to the . The 1963 dose was prorated to reflect the EE’s assumed start of employment 

on , while the 1965 dose was prorated for the assumed end of the first period of the 

EE’s employment on . These doses were entered as fixed values in the IREP input file. 

Reviewer’s Comment

NIOSH used a fixed value of the DCF to convert exposures to photons to doses to the . 

This would appear to be inconsistent with the directions of OCAS-IG-001 (NIOSH 2007b), 

which state that an uncertainty distribution about the DCF is appropriate. In the present case, 

however, the use of fixed values is justified. The results of the MCNPX simulation that 

constitute the basis of the limiting exposure rate in 1963–1966 show that ~85% of the exposure 

is from photon energies >250 keV. The maximum DCF for exposure of the to photons in 

this energy range is . Use of a DCF of thus yields a bounding estimate; 

there is no need for an uncertainty distribution. NIOSH may wish to include some discussion of 

the use of fixed values vs. distributions of DCFs in any future revisions of Appendix BB to avoid 

the appearance of inconsistency with the guidance of OCAS-IG-001. We find that NIOSH 

correctly assigned doses to the from external exposure during the period of AEC 

operations in accordance with the guidance of NIOSH (2017a). 

External Photon Doses During the Residual Period 

In accordance with NIOSH (2017a), the DR assigned an exposure rate of during the 

residual period. The exposures were divided equally between photons of energies of 30–250 keV 

and >250 keV. These exposures were multiplied by the effective exposure-to- DCF for 

photons incident in the postero-anterior (PA) orientation in the applicable energy range: 

 for 30–250 keV photons or for photons with energies >250 keV. 

Because the exposure rates were bounding estimates, the DCFs were applied as fixed values 

according to the explicit direction from NIOSH (2017a) that supersedes the instructions of 

OCAS-IG-001 (NIOSH 2007b). The 1967 doses were prorated to reflect the start of the EE’s 

second period of employment on 1967. 

Neutron Doses

The DR used the neutron ambient dose equivalent (H*[10]) rate for organs, other than the skin of 

the hands and forearms, of 751 mrem/y, listed by NIOSH (2017a, Table 8), to assign neutron 

doses to the for the years 1963–1965. These doses were derived by multiplying the 

H*(10) rate by , the H*(10)-to- -dose-equivalent DCF for neutrons with energies 

<10 keV. Anigstein and Mauro (2016b) had found that assigning such DCFs produced claimantfavorable doses to all 14 organs and tissues for which neutron DCFs are listed by NIOSH 

(2007b). Since such doses constitute bounding estimates, they are appropriately entered as fixed 

values. The 1963 and 1965 doses were prorated to reflect the beginning and end of the EE’s first 

period of employment: , 1963– , 1965. 

We verified that all doses to the from occupational external exposures were correctly 

entered into the IREP input file, as shown in the Excel file . 
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2.1.3 Review of Internal Doses

NIOSH (2017a, Table 10) presented intakes of airborne uranium dust at GSI for the operational 

period (October 1, 1952–June 30, 1966), while NIOSH (2017a, Table 11) presented the 

corresponding information for the residual period (July 1, 1966–December 31, 1993). These 

intakes, both by inhalation and by ingestion, were tabulated in units of dpm/calendar day. The 

calculated doses from alpha rays for each calendar year, from the start of the EE’s 

employment in 1963 until the date of cancer diagnosis in 2005, were listed in the IREP input file, 

as shown in the Excel file . 

We audited the internal doses to the by performing independent calculations using 

integrated doses derived from the DCAL computer code (ORNL 2006). DCAL is “a 

comprehensive software system for the calculation of tissue dose and subsequent health risk 

from intakes of radionuclides or exposure to radionuclides present in environmental media” 

(Eckerman et al. 2006). This totally independent methodology allows us to audit the doses using 

the same International Commission on Radiological Protection (ICRP) models and parameters 

that are employed by the Integrated Modules for Bioassay Analysis (IMBA). We calculated the 

annual doses from intakes during , 1963– , 1965, and during , 1967–

, 1972, the EE’s first and second periods of employment. The doses for each 

calendar year were calculated, starting on , 1963, and ending on , 2005, 

the day before the cancer diagnosis, using the as a surrogate organ for the 

. 

We found notable relative differences between the NIOSH- and SC&A-calculated doses for 

some years. These differences were presumed to stem from the methodology in the chronic 

annual dose (CAD) workbook that assigned the daily intakes during the years of partial 

exposures uniformly during the entire calendar year, rather than assigning the actual daily intakes 

during the actual periods of exposure, as will be discussed in greater detail in section 2.2.3 of the 

present review. However, the total dose calculated for the 42-y period, from the beginning of the 

EE’s employment until the date of diagnosis, was mrem in both cases. Given this small value 

and the good agreement between the total doses, we concluded that the discrepancies in the 

annual doses would have no significant impact on this case and did not perform any further 

analyses. We confirmed that NIOSH correctly calculated the total internal dose to the , 

which we verified by summing the internal doses listed in the Excel file . 

2.1.4 Review of External Doses from Medical X Rays

In accordance with OTIB-0006 (ORAUT 2011), the EE was assumed to have had one chest x ray 

during each year of the operational period as part of the annual physical exam. An acute 

dose of was assigned for each year, 1963–1965, as a normal distribution, with a 

standard deviation of 0.0075 rem. This is the dose to the from a PA examination through 

1970 listed by ORAUT (2011, Table A-7). The standard deviation was computed as 30% of the 

mean dose, as recommended by ORAUT. We verified that all doses to the from medical 

x rays were correctly entered into the IREP input file, as shown in the Excel file 

. 
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2.2 CASE [REDACTED] 

This section of the report presents the results of an independent audit of a DR performed by 

NIOSH for an EE who was employed as a at GSI from 1962 through 

 1973, which included both the period of AEC operations and the residual period. The 

EE was diagnosed with cancer on , 1994. The original DR was approved on 

, 2007. The POC, as listed in the file , was . The POC 

based on the DR that was revised to conform with the PER was . Because the revised 

POC was >45%, further IREP runs were performed. According to the file

, “The average PC value of the 99th percentiles from 

30 runs with 10000 iterations is .” 

2.2.1 Review of Job Category 

Since the EE was employed during the operational period at GSI, the EE’s job category is 

relevant to the DR. The EE was assigned doses to operators. This is an appropriate assignment: 

as a , the EE clearly worked inside the plant which, according to NIOSH 

(2017a), defines the operator category at GSI. 

2.2.2 Review of Occupational External Doses 

The external photon exposures assigned in this DR were derived in the Excel file

. 

External Photon Doses During Period of AEC Operations 

One component of the external exposure of operators during 1962 was expressed by NIOSH 

(2017a, Table 8) as a triangular uncertainty distribution with a minimum, mode, and maximum 

of 6.279, 9.69, and 12 R/y, respectively. These parameters were multiplied by , the 

effective DCF for converting exposure to photons in the 30–250 keV energy range, incident in 

the AP orientation, to dose to the . The result was a triangular distribution of dose rates to 

the . The EE was also assigned an external dose to the from 30-keV photons, derived 

from an air kerma dose rate of 5.112 rad/y, multiplied by , the air-kerma-to- DCF for 

30-keV photons incident in the PA orientation. This dose was entered into IREP as a constant 

distribution. The 1962 doses were prorated to reflect the EE’s assumed start of employment on 

. 

The EE was assigned external photon exposures during 1963–1965 of as specified by 

NIOSH (2017a, Table 8). The 1966 exposure was , reflecting the end of the operational 

period on . These exposures were multiplied by the DCF of to yield doses to 

the that were entered into IREP as constant distributions. 

External Photon Doses During the Residual Period 

The DR assigned an exposure rate of 0.2925 R/y for the residual period from , 1966 to 

, 1973—from the beginning of the residual period to the end of the EE’s employment. 

The exposures were divided equally between photon energies of 30–250 keV and >250 keV. 

These exposures were multiplied by the effective exposure-to- -dose DCF for photons 
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incident in the PA orientation in the applicable energy range: for 30–250 keV 

photons or for photons with energies >250 keV. These DCFs were applied as fixed 

values, as discussed in section 2.1.2 of the present review. 

Neutron Doses

The DR assigned neutron doses to the for the years 1962–1966. These doses were based on 

the annual neutron doses for organs other than the skin of the hands and forearms listed by 

NIOSH (2017a, Table 8), multiplied by , the H*(10)-to- -dose-equivalent DCF for 

neutrons with energies <10 keV, the energy range specified by NIOSH, incident in the AP 

orientation. The 1962 dose was prorated to reflect the EE’s assumed start of employment on 

. The doses were listed as fixed values in the IREP input file. 

Reviewer’s Comment

NIOSH used a fixed value of the DCF to convert photon exposures to doses to the . This 

would appear to be inconsistent with the directions of OCAS-IG-001 (NIOSH 2007b), which 

states that an uncertainty distribution about the DCF is appropriate. However, in developing the 

triangular distributions used to estimate the external exposures in 1952–1962, NIOSH largely 

relied on information regarding radiography of steel castings using sealed 226Ra sources. Such 

sources, which contain all the radium progeny, emit photons with an average energy of 655 keV. 

Use of the effective exposure-to- -dose DCF of for 30–250 keV photons is 

highly claimant favorable, since the maximum DCF for photons with energies >250 keV 

incident in the AP orientation is . Since the derived doses represent bounding 

estimates, it is appropriate to use a fixed value of the DCF. 

NIOSH (2017a) assigned the hypothetical stray photon radiation from the betatron following 

shutdown a fixed energy of 30 keV and a fixed PA orientation. Such exposure conditions lead to 

a unique value of the DCF; there was thus no need to assign an uncertainty distribution. The 

justification for using a fixed value of the DCF with the external photon exposures in 1963–1966 

was discussed in section 2.1.2 of the present review, as was the use of a fixed value of the DCF 

to calculate neutron doses. 

We verified that all doses to the from occupational external exposures were correctly 

entered into the IREP input file, as shown in the Excel file . 

2.2.3 Review of Internal Doses

As previously noted, NIOSH (2017a, Table 10) presented intakes of airborne uranium dust at 

GSI for the operational period, while NIOSH (2017a, Table 11) presented the corresponding 

information for the residual period. These data were entered into the Excel worksheet

, which listed the daily intakes of 234U (used by NIOSH as a surrogate 

for the actual mix of uranium isotopes) by both pathways for the years 1962–1973. The 

doses from alpha rays for each calendar year, from the start of the EE’s employment in 1962 

until the date of cancer diagnosis in 1994, calculated by the CAD workbook, were listed in the 

IREP input file, as shown in the Excel file . 
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We audited the internal doses to the by performing independent calculations using 

integrated doses derived from the DCAL computer code (ORNL 2006), as discussed in 

section 2.1.3. We calculated the annual doses from intakes from , 1962 to , 

1973, the beginning and end of the EE’s employment. The doses for each calendar year were 

calculated, starting on , 1962, and ending on , 1994, the day before the cancer 

diagnosis. We found that the NIOSH dose for 1962 was 15% higher than our calculated value, 

with smaller differences in some subsequent years. 

Based on previous DR reviews, we hypothesized that these differences stemmed from the way 

NIOSH apportioned the intakes during years of partial exposures. Because the total internal dose 

of calculated by NIOSH was a significant contributor to the total dose of 

, and hence a potentially significant contributor to the POC, this issue required further 

study. We therefore performed new analyses in which the intakes during each calendar year were 

distributed over the entire year. During years of partial exposure, the daily intakes were reduced 

in proportion to the shorter exposure duration—the annual intakes remained the same. The 

results of these analyses matched the annual doses calculated by NIOSH within <1%, thus 

confirming our assumption. 

The NIOSH internal dose methodology was the subject of a finding in our previous GSI PER 

review (SC&A 2016). At that time, the CAD tool used by NIOSH could only accommodate fullyear exposures, requiring the DR analyst to prorate the daily intakes to account for shorter 

exposure durations. This issue was discussed at a subsequent SCPR meeting (ABRWH 2017), at 

which time David Allen (NIOSH/DCAS) stated that the CAD tool has been revised: it was now 

able to model the actual daily intakes and the actual beginning and end dates of the exposures. 

We confirmed that the version of the tool used in the current , did in fact 

list these dates and the actual daily intakes during these time intervals; its calculations 

nevertheless mimicked the earlier version of the tool by distributing the intakes over the entire 

year. 

Observation: NIOSH Used Efficiency Measures to Estimate Internal Doses

The total internal doses calculated by NIOSH and SC&A in the present case agree within 

0.3%, which we verified by summing the internal doses listed in the Excel file

. Given this good agreement, and the fact that the POC was , the 

differences in the annual doses were not likely to affect the compensation decision for this EE. 

However, this methodology could affect the outcome in cases where the POC was close to 50%. 

2.2.4 Review of External Doses from Medical X Rays

In accordance with OTIB-0006 (ORAUT 2011), the EE was assumed to have had one chest x ray 

during each year of the operational period as part of the annual physical exam. An acute 

dose of was assigned for each year, 1962–1966, as a normal distribution, with a 

standard deviation of 0.02514 rem. This is the dose to the from a PA examination through 

1970 listed by ORAUT (2011, Table A-7). The standard deviation was computed as 30% of the 

mean dose, as recommended by ORAUT. We verified that all doses to the from medical x 

rays were correctly entered into the IREP input file, as shown in the Excel file 

. 
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2.3 CASE [REDACTED] 

This section of the report presents the results of an independent audit of a DR performed by 

NIOSH for an EE who was employed as a at GSI from 1963 through 

 1973, which included the period of AEC operations and the residual period. He was 

also credited with employment from 1977.3

 He was diagnosed with 

cancer on , 1977. The original DR was approved on September 10, 2007. The POC, 

as listed in the file , was . The POC based on the DR that was 

revised to conform with the PER was . Because the revised POC was >45%, further 

IREP runs were performed. As stated in the file , “The 

average PC value of the 99th percentiles from 30 runs with 10000 iterations is .” 

3 The basis for the 1977 employment credit was earnings of from National Roll (a division of GSI) during 

the second quarter of 1977, reported by the Social Security Administration. The policy of the U.S. Department of 

Labor (DOL) is to accept Social Security records as proof of employment, and to credit an EE with employment for 

the entire quarter in the absence of more exact dates. In the present instance, however, the EE could not have been 

employed at the GSI steel foundry in Granite City, Illinois, during the period in question, since GSI had shut down 

operations at that facility by the end of 1973. The land and buildings occupied by the foundry were acquired by the 

Granite City Steel (GCS) Division of the National Steel Corporation in 1974 (SC&A 2008). Only GCS employees 

who worked in the area formerly owned by GSI, that became known as the South Plant, could have been 

occupationally exposed after 1973. Although NIOSH is obligated to follow DOL’s decision about the covered 

employment, we suggest that NIOSH inform DOL of this apparent discrepancy.

2.3.1 Review of Job Category 

Since the EE was employed during the operational period at GSI, the EE’s job category is 

relevant to the DR. The EE was assigned doses to operators. This is an appropriate assignment: 

as a , the EE clearly worked inside the plant which, according to NIOSH (2017a), defines 

the operator category at GSI.

2.3.2 Review of Occupational External Doses 

The external photon exposures assigned in this DR were derived in the Excel file

. 

External Photon Doses During Period of AEC Operations 

The EE was assigned an external exposure of during 1963–1965, and in 1966, 

as listed by NIOSH (2017a, Table 8). These exposures were multiplied by an exposure-toDCF of , which is for photons in the 30–250 keV energy range incident in the AP 

orientation. The 1963 dose was prorated to reflect the EE’s assumed start of employment on 

. The doses were entered into IREP as constant distributions. 

External Photon Doses During the Residual Period 

The DR assigned the exposure rate of for the residual period from , 1966 to 

, 1973—from the beginning of the residual period to the end of the EE’s first 

period of employment—and for , 1977, the assumed second period of 

employment. The exposures were divided equally between photon energies of 30–250 keV and 

 
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>250 keV. These exposures were multiplied by the effective exposure-to- DCF for photons 

incident in the AP orientation in the applicable energy range: for 30–250 keV 

photons or for photons with energies >250 keV. These DCFs were applied as fixed 

values, as discussed in section 2.1.2 of the present review. The 1966 dose was prorated to 

reflect the beginning of the residual period, while the 1973 and 1977 doses were prorated to 

reflect the periods of the EE’s employment. 

Neutron Doses

The DR assigned neutron doses to the for the years 1963–1966. These doses were based on 

the annual neutron doses for organs other than the skin of the hands and forearms listed by 

NIOSH (2017a, Table 8), multiplied by , the H*(10)-to- -dose-equivalent DCF for 

neutrons incident in the AP orientation with energies <10 keV, the energy range specified by 

NIOSH (2017a). The 1963 dose was prorated to reflect the EE’s assumed start of employment on 

. The doses were listed as fixed values in the IREP input file. 

Reviewer’s Comment

NIOSH used fixed values of the DCFs to convert external exposures to photon and neutron 

radiation to doses to the . The justification for this practice is discussed in sections 2.1.2

and 2.2.2 of the present review. We verified that all doses to the from occupational 

external exposures were correctly entered into the IREP input file, as shown in the Excel file 

. 

2.3.3 Review of Internal Doses

As previously noted, NIOSH (2017a, Table 10) listed intakes of airborne uranium dust at GSI for 

the operational period, while NIOSH (2017a, Table 11) listed the corresponding information for 

the residual period. NIOSH calculated the internal doses to the from these intakes using 

IMBA, performing eight separate runs. There were four runs each for intakes of 234U 

absorption types M and S. For each type, there were two runs for inhalation and two for 

ingestion. Pairs of runs were required, since IMBA is limited to 10 intake regimes and the 

intakes spanned 12 date ranges. The resulting doses were entered into IREP, as shown in the 

. 

We audited the internal doses to the by performing independent calculations using 

integrated doses derived from the DCAL computer code (ORNL 2006), as discussed in 

section 2.1.3 of the present review. Unlike IMBA, DCAL does not specify the as a target 

organ. However, the program does specify its two components: 

. According to the ICRP (2002, Table 6.9), the mean masses of these 

two organs in adult men are and g, respectively. We simulated the doses to the by 

taking the average of the doses to the , weighted by the relative mass of each organ, 

for each calendar year. We calculated the annual doses from intakes during , 1963–

, 1973, the beginning and end of the EE’s first period of employment, and during 

, 1977, the assumed second period of employment. The doses for each calendar 

year were calculated, starting on , 1963, and ending on , 1977, the day 

before the cancer diagnosis. We found a difference from the dose calculated by NIOSH for 1963 
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that most likely stemmed from the way IMBA apportioned intakes during years of partial 

exposures. However, the total internal doses calculated by NIOSH and SC&A for the 15-y period 

were mrem in both cases. Given this small value and the good agreement between the total 

doses, any discrepancies in the annual doses would have no significant impact on this case. We 

thus confirmed that NIOSH correctly calculated the total internal dose to the , which we 

verified by summing the internal doses listed in the Excel file . 

2.3.4 Review of External Doses from Medical X Rays

In accordance with OTIB-0006 (ORAUT 2011), the EE was assumed to have had one chest x ray 

during each year of the operational period as part of the annual physical exam. An acute 

dose of was assigned for each year, 1963–1966, as a normal distribution, with a 

standard deviation of 0.0075 rem. This is the dose to the from a PA examination through 

1970 listed by ORAUT (2011, Table A-7). The standard deviation was computed as 30% of the 

mean dose, as recommended by ORAUT. We verified that all doses to the from medical x 

rays were correctly entered into the IREP input file, as shown in the Excel file

.

2.4 CASE [REDACTED] 

This section of the report presents the results of an independent audit of a DR performed by 

NIOSH for an EE who was employed as a at GSI from 1952 through 

 1953, which included the period of AEC operations. He was diagnosed with 

cancer on , 1998. 

. 

However, since the purpose of the present review is to audit the doses received by workers at 

GSI, we will not examine the EE’s radiation exposures at . 

The original DR was approved on . The POC, as listed in the file 

, was . The POC based on the DR that was revised to conform with 

the PER was . Because the revised POC was >45%, further IREP runs were performed. 

According to the file : “The average PC value of the 99th 

percentiles from 30 runs with 10000 iterations is .” 

2.4.1 Review of Job Category 

Since the period of covered employment fell within the operational period at GSI, the EE’s job 

category is relevant to the DR. The EE was assigned doses to operators. This is an appropriate 

assignment: , the EE clearly worked inside the plant which, according to 

NIOSH (2017a), defines the operator category at GSI.

2.4.2 Review of Occupational External Doses 

The external photon exposures assigned in this DR were derived in the Excel file

. The was selected as the target

organ in the present case, as it was for the previous case of cancer discussed in section 

2.1.2 of the present review. 
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External Photon Doses 

One component of the external exposure of operators in 1952–1955 was expressed by NIOSH 

(2017a, Table 8) as a triangular uncertainty distribution with a minimum, mode, and maximum 

of 6.279, 11.345, and 15 R/y, respectively. These parameters were multiplied by , 

the effective DCF for converting exposure to photons in the 30–250 keV energy range, incident 

in the AP orientation, to dose to the . The result in the present case was a triangular 

distribution of dose rates to the during 1952–1953. The EE was also assigned an external 

dose rate to the from 30-keV photons, derived by assigning an air kerma dose rate of 

5.112 rad/y, multiplied by , the air-kerma-to- DCF for 30-keV photons incident in 

the PA orientation. 

Neutron Doses

The DR assigned neutron doses to the for the years 1952–1953. These doses were based 

on the annual neutron doses for organs other than the skin of the hands and forearms listed by 

NIOSH (2017a, Table 8), multiplied by , the effective H*(10)-to- -dose-equivalent 

DCF for neutrons with energies <10 keV, the energy range specified by NIOSH. 

The 1952 photon and neutron doses were prorated to reflect the start of the operational period on 

October 1, 1952, while the 1953 doses were prorated to reflect the end of EE’s employment at 

GSI on . All external doses were entered into IREP as constant distributions. 

Reviewer’s Comment

NIOSH used fixed values of the DCFs to convert external exposures to photon and neutron 

radiation to doses to the . The justification for this practice is discussed in sections 2.1.2

and 2.2.2 of the present review. We verified that all doses to the from occupational 

external exposure were correctly entered into the IREP input file, as shown in the Excel file

. 

2.4.3 Review of Internal Doses

We audited the internal doses to the by performing independent calculations using 

integrated doses derived from the DCAL computer code (ORNL 2006), as discussed in 

section 2.1.3, using the as a surrogate organ. We calculated the annual doses 

from intakes from , 1952 through , 1953—from the beginning of the 

operational period to end of the EE’s employment at GSI. The doses for each calendar year were 

calculated, starting on , 1952, and ending on , 1998, the day before the 

cancer diagnosis. We found differences in the calculated doses for the first two years. As 

discussed in section 2.1.3, these differences most likely stemmed from the way NIOSH 

apportioned the intakes during years of partial exposures. However, the total doses calculated by 

NIOSH and SC&A for the 46-y period were in each case, as we verified by summing the 

internal doses listed in the Excel file . Given these small values and the 

good agreement between the total doses, the differences in the annual doses were not significant. 

We thus verified the internal doses calculated by NIOSH and confirmed that these doses were 

correctly entered into IREP, as shown . 
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2.4.4 Review of External Doses from Medical X Rays

In accordance with OTIB-0006 (ORAUT 2011), the EE was assumed to have had one chest x ray 

during each year of the operational period as part of the annual physical exam. An acute 

dose of was assigned for each year, 1952–1953, as a normal distribution, with a 

standard deviation of 0.0075 rem. This is the dose to the from a PA examination through 

1970 listed by ORAUT (2011, Table A-7). The standard deviation was computed as 30% of the 

mean dose, as recommended by ORAUT. We verified that all doses to the from medical 

x rays were correctly entered into the IREP input file, as shown in the Excel file

.

2.5 CASE [REDACTED] 

This section of the report presents the results of an independent audit of a DR performed by 

NIOSH for an EE who was employed as a at GSI from 1963 through 

, 1969, which included the period of AEC operations and the residual period. He 

was diagnosed with , International Classification of Diseases

(ICD)-9 Code , on , 2013. According to the National Cancer Institute’s “Dictionary 

of Cancer Terms” (NCI n/d), “

” According to 

ORAUT (2012), the is to be selected for both internal and external DRs in cases assigned 

this ICD-9 code.

The original DR was approved on , 2014. The POC, as listed in the file 

, was . The POC based on the DR that was revised to conform with 

the PER was . Because the revised POC was >45%, further IREP runs were performed. 

As stated in the file , “The average PC value of the 99th 

percentiles from 30 runs with 10000 iterations is .” 

2.5.1 Review of Job Category 

Since part of the EE’s employment was during the operational period at GSI, the EE’s job 

category is relevant to the DR. According to the computer-assisted telephone interview (CATI) 

report, the EE “worked in all buildings including the betatron building and others. [As a] 

 as everyone went in and out of the plant. Then went all over the plant as necessary to 

perform other duties. to different places. 

.” Although the EE was not a 

production worker, the description of the duties clearly indicates that the EE worked inside the 

plant which, according to NIOSH (2017a), defines the operator category at GSI. Therefore, the 

EE was properly assigned doses to operators. 

2.5.2 Review of Occupational External Doses 

The external photon exposures assigned in this DR were derived in the Excel file

. 
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External Photon Doses During Period of AEC Operations 

The EE was assigned an external exposure of during 1963–1965, and in 1966, 

as listed by NIOSH (2017a, Table 8). These exposures were multiplied by an exposure-to-

 DCF of , which is for photons in the 30–250 keV energy range incident in 

the AP orientation. The 1963 dose was prorated to reflect the EE’s start of employment on 

. The doses were entered into IREP as constant distributions. 

External Photon Doses During the Residual Period 

The DR assigned the exposure rate of for the residual period. The exposures were 

divided equally between photon energies of 30–250 keV and >250 keV. These exposures were 

multiplied by the effective exposure-to- DCF for the applicable energy range: 

 for 30–250 keV photons or for photons with energies >250 keV. These 

DCFs were applied as fixed values, as discussed in section 2.1.2 of the present review. The 1966 

 dose was prorated to reflect the beginning of the residual period on July 1, while the 

1969 dose was prorated to reflect the end of the EE’s employment . 

Neutron Doses

The DR assigned neutron doses to the for the years 1963–1966. These doses were based 

on the annual neutron doses for organs other than the skin of the hands and forearms listed by 

NIOSH (2017a, Table 8), multiplied by , the H*(10)-to- -dose-equivalent DCF for 

neutrons incident in the AP orientation with energies <10 keV, the energy range specified by 

NIOSH (2017a). The 1963 dose was prorated to reflect the EE’s start of employment on 

. The doses were listed as fixed values in the IREP input file. 

Reviewer’s Comment

NIOSH used fixed values of the DCFs to convert external exposures to photon and neutron 

radiation to doses to the . The justification for this practice is discussed in sections 2.1.2

and 2.2.2 of the present review. We verified that all doses to the from occupational 

external exposure were correctly entered into the IREP input file, as shown in the Excel file

.

2.5.3 Review of Internal Doses

As stated previously, NIOSH (2017a, Table 10) presented intakes of airborne uranium dust at 

GSI for the operational period, while NIOSH (2017a, Table 11) presented the corresponding 

information for the residual period. These data were entered into the Excel worksheet

, which listed the daily intakes of 234U (used by NIOSH as a surrogate 

for the actual mix of uranium isotopes) by both pathways for the years 1963–1969. The 

doses from alpha rays during these years, calculated by the CAD workbook, were listed in the 

IREP input file, as shown in the Excel file . 

We audited the internal doses to the by performing independent calculations using 

integrated doses derived from the DCAL computer code (ORNL 2006), as discussed in section 

2.1.3 of the present review. We calculated the annual doses from intakes during , 
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1963– , 1969, the beginning and end of the EE’s employment. The doses for each 

calendar year were calculated, starting on , 1963, and ending on , 2013, the 

day before the cancer diagnosis. We found no significant differences in the calculated annual 

doses. We summed the internal doses listed in to obtain a total dose of 

, which matched the total dose calculated by SC&A. We thus verified the internal doses 

calculated by NIOSH for this case. 

2.5.4 Review of External Doses from Medical X Rays

In accordance with OTIB-0006 (ORAUT 2011), the EE was assumed to have had one chest x ray 

during each year of the operational period as part of the annual physical exam. An acute 

dose of was assigned for each year, 1963–1966, as a normal distribution, with a 

standard deviation of 0.0075 rem. This is the dose to the from a PA examination through 

1970 listed by ORAUT (2011, Table A-7). The standard deviation was computed as 30% of the 

mean dose, as recommended by ORAUT. We verified that all doses to the from medical 

x rays were correctly entered into the IREP input file, as shown in the Excel file

.
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3 SUMMARY AND CONCLUSIONS

SC&A has audited the five cases that were selected by NIOSH from the 71 claims that had been 

reevaluated in accordance with DCAS-PER-080 (NIOSH 2017b). The PER addressed changes in 

doses prescribed by revisions 2 and 3 to Appendix BB to TBD-6000 (NIOSH 2016, 2017a). At 

least one of the prescribed doses during each year of the operational period increased after 

Appendix BB, Rev. 1 (NIOSH 2014). NIOSH therefore reevaluated all GSI claims with DRs that 

were completed before February 9, 2017, the date of issuance of revision 3, with employment 

during the operational period, that had a POC <50%. 

SC&A (2016) had previously reviewed DCAS-PER-057 (NIOSH 2015), which was issued 

following revision 1 (NIOSH 2014). That review resulted in three findings and several 

observations. These arose out of the methods used by NIOSH to implement revision 1, not from 

failures to follow the prescriptions in that revision. We believe that only a case audit, which is 

prescribed by the SC&A (2009) protocol for performing a PER review, would uncover any such 

deficiencies that persisted in the cases subject to the current PER.

Our audits included a review of the job category assigned to each worker, which was the subject 

of major findings in our previous review (SC&A 2016). In our current review, we find that, in all 

five cases, the workers had been properly assigned to the operator category. 

We reviewed the external organ doses to verify conformity with the external exposures specified 

in revision 3 (NIOSH 2017a), and with the guidelines for converting these exposures to organ 

doses presented by NIOSH (2007b). Our previous review (SC&A 2016) uncovered some issues 

with the implementation of these guidelines; our current review found that these issues had been 

resolved. 

We verified that inhaled and ingested intakes of uranium had been correctly assigned for the 

calculation of internal doses. In our previous review (SC&A 2016), we had observed that NIOSH 

sometimes used efficiency measures in estimating internal doses that had the potential of 

changing the annual doses and hence the POCs. The NIOSH methodology could lead to lowering 

some annual doses in cases where the intake regime ended before the end of the year. As we 

stated in our previous review, NIOSH should perform IMBA analyses using the actual dates of 

intake to calculate internal doses for cases where the internal doses make significant 

contributions to the total doses and the POC is close to 50%. 

Finally, we confirmed that the doses from medical x rays were correctly assigned in each case. 

The prescribed methodology for assigning these doses had not changed from Appendix BB, 

Rev. 0 (NIOSH 2007a) to revision 3 (NIOSH 2017a). However, the files 

and , which summarized the results of the NIOSH reevaluation of the 

respective cases under DCAS-PER-057 (NIOSH 2015), showed changes in these doses from the 

original DRs. We therefore inspected the medical x-ray doses that were assigned under the 

present PER and concluded that these previous changes were apparent anomalies, since the final 

medical x-ray doses under the current PER were the same as those in the original DRs.
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In summary, we find that NIOSH has correctly implemented the changes to the DR methodology 

in Appendix BB, Rev. 3 (NIOSH 2017a), and therefore fulfilled the intent and purpose of 

DCAS-PER-080 (NIOSH 2017b). 
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4 REFERENCES

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