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.

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Presentation Handout

Carryover Items from February 2019 and 2021 SCPR Meetings

Meeting of the Subcommittee for Procedure Reviews

May 25, 2022 

Table 1. Summary of documents with outstanding issues from February 2019 and 

February 2021 SCPR meetings

Document 

number(a) Document title Total findings (b)

Total 

obs. (b)

SCPR

closed

In 

progress

DCAS-TIB-013 Selected Geometric Exposure 

Scenario Considerations for 

External Dose Reconstruction at 

Uranium Facilities

5 0 4 1

ORAUT-OTIB0029Internal Dosimetry Coworker 

Data for Y-12

5 0 4 1

ORAUT-OTIB0044Historical Evaluation of the Film 

Badge Dosimetry Program at the 

Y-12 Facility in Oak Ridge, 

Tennessee: Part 1 – Gamma 

Radiation

4 4 0 8

ORAUT-OTIB0045Historical Evaluation of the Film 

Badge Dosimetry Program at the 

Y-12 Plant in Oak Ridge, 

Tennessee: Part 2 – Neutron 

Radiation

2 3 0 5

ORAUT-OTIB0046Historical Evaluation of the Film 

Badge Dosimetry Program at the 

Y-12 Plant in Oak Ridge, 

Tennessee: Part 3 – Beta 

Radiation

3 5 0 8

ORAUT-OTIB0064Coworker External Dosimetry 

Data for the Y-12 National 

Security Complex

0 7 0 7

DCAS-PER-073 Birdsboro Steel and Foundry 

Company

1 7 0 8

No number 

assigned

Dose Reconstruction 

Methodology for the Peek Street 

Facility

8 2 0 10

(a) The Board Review System (BRS) was updated to include discussions from the February 2019 and February 2021 

meetings of the Subcommittee for Procedure Reviews (SCPR) before access was lost due to the Cybersecurity 

Modernization Initiative.

(b) Finding and observation details follow this table. 
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Details of Findings and Observations from Table 1

DCAS-TIB-013: Selected Geometric Exposure Scenario Considerations for External

Dose Reconstruction at Uranium Facilities

Finding 4: Technical information bulletin (TIB) underestimates maximum correction factor (CF)

to be applied to badge readings.

Status

2/13/2019: In progress – finding will be resolved with forthcoming issuance of ORAUTOTIB-0089.

3/17/2022: The Division of Compensation Analysis and Support (DCAS) does not have 

any new information to report. This TIB is being incorporated into DCAS-TIB-010 

during International Commission on Radiological Protection (ICRP) Publication 116 

implementation.

ORAUT-OTIB-0029: Internal Dosimetry Coworker Data for Y-12

Finding 4: The National Institute for Occupational Safety and Health (NIOSH) did not consider 

that urine samples were collected on a Monday morning, after a minimum of 48-hours absence 

from work area.

Status

Background: In 2012, ORAUT-OTIB-0029 was cancelled and the technical information 

was incorporated into the Y-12 technical basis document (TBD) for occupational internal 

dose, ORAUT-TKBS-0014-5, revision 03. SC&A was tasked with reviewing ORAUTTKBS-0014-5, revision 03, to assess whether finding 4 was adequately addressed. 

SC&A’s review determined the NIOSH did not consider that routine urine samples were 

collected after a minimum of 48 hours of absence from the work area. In addition, 

NIOSH did not show that, for all time periods, 40 percent or more of the samples were 

not collected on Mondays.

2/18/2021: In progress – NIOSH agreed to respond to SC&A’s February 26, 2019,

memorandum on Monday morning sampling.

3/17/2022: DCAS does not have any new information to report. This OTIB has been 

cancelled, and a new Y-12 internal co-exposure model is scheduled to be developed using 

DCAS-IG-006. Once developed, the internal co-exposure models will be a new chapter 7 

of the Y-12 site profile as ORAUT-TKBS-0014-7.

ORAUT-OTIB-0044: Historical Evaluation of the Film Badge Dosimetry Program at the

Y-12 Facility in Oak Ridge, Tennessee: Part 1 – Gamma Radiation

SCPR meeting 10/31/2018: SC&A identified four findings and four observations.

Finding 1: The actual data distributions should be retained rather than replaced with predictions 

generated using data from a possibly nonrepresentative subset of 147 workers. 
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Finding 2: The validity of the model may not extend beyond the sampling period due to changes 

in the underlying processes. If the model does apply, the estimated prediction errors derived from 

within-sample data may not be appropriate outside of the sampling period. 

Finding 3: It is highly unlikely that the uncertainty in predictions outside the sampling period 

should be as small as indicated by the precise estimates from the maximum likelihood regression 

model. The issue of out-of-sample validation is not resolved by using a large number of samples 

in the sampling period. 

Finding 4: The scaling procedures should also address the worker’s pre-1961 data where 

available. Additionally, it is not clear that historical records will be sufficient to document that 

the worker’s exposure potential remained fairly constant over the time period required for 

workers with missed doses.

Observation 1: The units of millirem (mrem) need to be added to table 7-1, as appropriate. 

Observation 2: The caption for table 7-1 should include the period 1947 to 1979, not 1947 to 

1965 as it presently states.

Observation 3: The second line of the second paragraph states, “with the appropriate quarterly 

GM and GSD from Table 7-1 and applying an individual scaling factor φ.” However, it appears 

that the geometric mean (GM) values are not used in tables 7-2 and 7-3. Should “GM” be 

replaced with “μ”?

Observation 4: The end of the second paragraph states, “Any calculated scaling factor that is 

less than one is changed to one so that the value of the expected quarterly dose can be increased 

but not decreased.” Because the scaling factor (φ) appears in the exponent, shouldn’t this 

sentence read: “Any calculated scaling factor that is less than zero is changed to zero so that the 

value of the expected quarterly dose can be increased but not decreased”?

Status

2/13/2019: All findings and observations in progress – NIOSH needs to address findings 

and observations. 

3/17/2022: DCAS does not have any new information to report. The Y-12 external 

co-exposure model is currently being updated using DCAS-IG-006 and is approximately 

80 percent complete. Once that is updated, this TIB will be cancelled. 

ORAUT-OTIB-0045: Historical Evaluation of the Film Badge Dosimetry Program at the 

Y-12 Plant in Oak Ridge, Tennessee: Part 2 – Neutron Radiation

SCPR meeting 2/13/2019: SC&A presented its review and identified four findings and four 

observations. 

Finding 1: The recommendation in OTIB-0045, page 16, to assume that 40 percent of the 

neutron dose equivalent falls below the 0.7 mega-electron volt (MeV) threshold of nuclear track 

emulsion, type A (NTA) film (correction factor of 1/(1.0 − 0.40) = 1.7) does not agree with the 
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recommendation in ORAUT-OTIB-0051, revision 00, “Effect of Threshold Energy and Angular 

Response of NTA Film on Missed Neutron Dose at the Oak Ridge Y-12 Facility.”

Finding 2: The recommendation in OTIB-0045, page 18, to assume that 40 percent of the 

neutron DE falls below the 0.7 MeV threshold of NTA film (correction factor of 1/(1.0 − 0.40) = 

1.7) does not agree with the recommendation in OTIB-0051.

Observation 1: The neutron-to-photon (n/p) GM values listed in OTIB-0045, table 7-1, are the 

same as the respective n/p GM values contained in the Q-Q plots in figures 6-2 through 6-5 

and 6-7. However, the n/p geometric standard deviation (GSD) values in table 7-1 are all slightly 

higher than the respective values contained in the Q-Q plots.

Observation 2: It is not clear from the guidance in section 6.2 of OTIB-0045 if the minimum 

detection level value of 30 mrem was used when the gamma dose was reported as zero in all the 

analyses for all the departments, or just for the four departments mentioned.

Observation 3: OTIB-0045, section 8.0, should state the exact years the n/p values in table 7-1 

are to be applied to provide for consistency in dose reconstruction (DR).

Status

2/13/2019: All findings and observations in progress – NIOSH needs to address findings 

and observations.

3/17/2022: DCAS does not have any new information to report. The Y-12 external 

co-exposure model is currently being updated using DCAS-IG-006 and is approximately

80% complete. Once updated, this TIB will be cancelled.

ORAUT-OTIB-0046: Historical Evaluation of the Film Badge Dosimetry Program at the 

Y-12 Plant in Oak Ridge, Tennessee: Part 3 – Beta Radiation

SCPR meeting 10/31/2018: SC&A presented its review and identified three findings and five

observations.

Finding 1: Potentially important information in a reference cited in OTIB-0046 and the very 

critical information in table 4-1 of OTIB-0046 were not considered in OTIB-0046 or in the 

newer OTIB-0044 gamma document of 2013. This information may clearly show that work done 

during the late 1940s and early 1950s was not the same as work done in later years. If so, that 

indicates the n-worker regression models should not be used for extrapolating either gamma or 

beta doses.

Finding 2: Inspection of figures 1 and 2 in appendix A shows no such difference in the pattern 

of reduction in gamma and beta doses from 1956 through 1961. Therefore, the use of two 

different models for gamma and beta doses is not supported.

Finding 3: The estimated GM increases linearly going back in years from 1961 to 1947 but 

decreases in the years after 1961. Examination of the first formula on page 40 shows that the GM 

becomes negative when (tttt−1961)> 151.71/56.83 = 2.67 years. Because the GM of a lognormal 

distribution must be a positive number, no predicted lognormal parameters can be estimated 
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using the linear dose model at any time after the fourth quarter of 1963. Note that the data used 

to estimate the model extend past 1963 to 1965, so the model cannot be used to make predictions 

in the final 2 years of the sampling period. 

Observation 1: The text in section 7.3 refers to data being shown in boxplots. However, no 

specific figure numbers are provided. It would be helpful to have references to specific figures in 

the report. 

Observation 2: Table 9-2 (which contains the key results of OTIB-0046) only provides 

prediction density parameters for the period 1947–1965. However, the “Purpose” section on 

page 8 states that the purpose of this document is to provide prediction densities for 1947 to 

1979. Where are the data to be used for DR for the period 1966–1979? 

Observation 3: The end of the first paragraph on page 43 states: “The adjustment is applied only 

if the calculated scaling factor is greater than 1, which will increase the value of the expected 

quarterly dose.” Because the scaling factor (φ) appears in the exponent, should this sentence 

read: “The adjustment is applied only if the calculated scaling factor is greater than zero, which 

will increase the value of the expected quarterly dose”? 

Observation 4: It appears that the units of mrem should be added to the dose of 2,361 near the 

end of the last sentence, just before the beginning of section 9.6. 

Observation 5: The end of the first paragraph in section 9.6 on page 45 states: “If the scaling 

factor is less than unity (1), the scaling factor is set equal to 1 and the monitored population dose 

distributions are applied to that worker before 1961.” Because the scaling factor (φ) appears in 

the exponent, should this sentence read: “If the scaling factor is less than zero, the scaling factor 

is set equal to zero and the monitored population dose distributions are applied to that worker 

before 1961”?

Status

2/13/2019: All findings and observations in progress – NIOSH needs to address findings 

and observations. 

3/17/2022: DCAS does not have any new information to report. The Y-12 external 

co-exposure model is currently being updated using DCAS-IG-006 and is approximately 

80 percent complete. Once that is updated, this TIB will be cancelled.

ORAUT-OTIB-0064: Coworker External Dosimetry Data for the Y-12 National Security 

Complex

SCPR meeting 10/31/2018: SC&A presented its review and identified seven observations. 

Observation 1: The reference of “UCNC (1957)” maybe be incorrect. It appears that it should 

read “McLendon (1957).” 

Observation 2: The reference of “UCNC (1957)” in the title for figure 6-1 maybe be incorrect. 

It appears that it should read “McLendon (1957).”
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Observation 3: It is not obvious why table 7-1a only covers the period 1947–1951, instead of 

the complete period under review of 1947–1979. It may have been because of the change in the 

method of excluding or including the missed doses that occurred between 1951 and 1952, as 

outlined on pages 14 and 15 of OTIB-0064, although this is not stated in the text. 

Observation 4: It is not obvious why table 7-1b and table 7-1c are separated between the years 

1951 and 1952, when the most likely method would be to separate the two tables into two 

periods of 1947–1956 (when the regression model was used) and then 1957–1979, when the 

Y-12 coworker badge data from the Center for Epidemiologic Research (CER) were used. In 

addition, the statement on page 14, “The gamma and beta doses available from CER (see 

Section 6.0) were converted to annual data by summing the reported quarterly data for 1952 to 

1979,” adds to the confusion of the source of the data in tables 7-1b and 7-1c (i.e., were the 

1952–1956 data derived from the regression model, or from the CER coworker data?). 

Observation 5: It was indicated in step 2 that missed dose was not added to the resultant gamma 

doses from OTIB-0044 for the period 1947–1951 in table 7-1c, because missed dose had already 

been included. Does this also apply to OTIB-0046 beta doses for 1947–1951?

Observation 6: In step 5 it is stated, “Beta dose 95th-percentile values for 1947 to 1951 might 

need adjustment for dose reconstruction.” However, there are no definite instructions to the dose 

reconstructor concerning the necessary steps to adjust these dose values to ensure consistence in 

DR.

Observation 7: The units of mrem need to be added to tables A-6 and A-7, and A-8, as 

appropriate. 

Status

2/13/2019: All findings and observations in progress – NIOSH needs to address findings 

and observations. 

3/17/2022: DCAS does not have any new information to report. The Y-12 external 

co-exposure model is currently being updated using DCAS-IG-006 and is approximately 

80 percent complete. Once that is updated, this TIB will be cancelled. The external 

co-exposure models will be a new chapter 8 of the site profile as ORAUT-TKBS-0014-8. 

DCAS-PER-073: Birdsboro Steel and Foundry Company

SCPR meeting 2/13/2021: SC&A presented its review and identified one finding and seven

observations. 

Finding 1: NIOSH neglected the external exposure to documented radiographic sources in 

assigning photon doses to Birdsboro workers. 

Observation 1: SC&A suggests that NIOSH refer to the site as the “Birdsboro Steel Foundry 

and Machine Company.” 
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Observation 2: The statement that TBD-6000 assumed that the standard workday was 8.8 hours 

is based on a misinterpretation. In fact, TBD-6000 assumed a 44-hour week, which was based on 

working 8 hours/day Monday–Friday and working half a day (4 hours) on Saturday.

Observation 3: SC&A recommends that NIOSH adopt April 19, 1951, as the date for processing 

the 346 lb of billets and April 19, 1951, for working on the five wafers.

Observation 4: The methodology used by NIOSH had the net effect of slightly overestimating 

the inhaled intakes of uranium.

Observation 5: NIOSH used an ingestion rate that is inconsistent with rates used in exposure 

assessments for other worksites that were based on OCAS-TIB-009 and is not claimant 

favorable. This is an overarching issue that applies to other sites and should be addressed in a 

wider context.

Observation 6: NIOSH erroneously cited the source of the ingestion rate of 1.1×10-4 m2

/h as 

NUREG/CR-5512, volume 1.

Observation 7: The beta dose rate to skin other than that of the hands and forearms in 1951 

should be based on the long billet, as described by TBD-6000.

Status

2/13/2019: All findings and observations in progress – NIOSH needs to address findings 

and observations.

3/17/2022: Responses are being developed; however, DCAS will not be prepared to 

discuss Birdsboro at the May 2022 SCPR meeting.

Dose Reconstruction Methodology for the Peek Street Facility

SCPR meeting 2/13/2021: SC&A presented its review and identified eight findings and two

observations.

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

photon energy distribution is unsupported and inconsistent with assumptions used in the Hanford 

technical basis document. 

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

the cited reference. 

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

references. 

Finding 4: The dosimeter limit of detection used in the DR Template is not specified in the 

template, and the value of 0.050 rem assumed based on NIOSH’s calculation is not consistent 

with the Hanford dosimeter information. 
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Finding 5: SC&A was unable to verify the Peek Street Facility (PSF) annual maximum ambient 

dose value using the cited reference. 

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

and outdated references. 

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

guidance in ORAUT-OTIB-0054, revision 04. 

Finding 8: No basis or reference is cited for the recycled uranium activity fractions in table 5 of 

the DR Template. 

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

plutonium dose conversion factors. 

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

in ORAUT 1997 and is not referenced. 

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

is outdated and needs updating. 

Status

2/13/2019: All findings and observations in progress – NIOSH needs to address findings 

and observations. 

3/17/2022: DCAS indicated that they should be prepared to discuss Peek Street DR 

Template findings and observations at the May 25, 2022, SCPR meeting.

References

McLendon, J. D. (1957, July 1). Cumulative external radiation exposures [Memorandum to 

J. S. Reece et al., Union Carbide Nuclear Company, Oak Ridge, Tennessee]. SRDB Ref. 

ID 23622 

Oak Ridge Associated Universities Team (ORAUT). (1997). Excerpts from the KAPL 

radiological history report. SRDB Ref. ID 34947 

Union Carbide Nuclear Company (UCNC). (1957, January 24). December health physics report 

– Mechanics Operation Division, Y-B94-8 (excerpt) [Letter to J. M. Case, Union Carbide 

Nuclear Company, Oak Ridge, Tennessee]. SRDB Ref. ID 23626