Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

OCAS–PER–011, SUBTASK 4

REVIEW OF SELECT CASES REWORKED FOR THE 

EVALUATION OF K-25 TECHNICAL BASIS DOCUMENT AND 

TECHNICAL INFORMATION BULLETIN REVISIONS 

Contract No. 211-2014-58081 

SCA-TR-2016-PER011-ST4, Revision 0 

Prepared by

Rose Gogliotti

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

October 2016 

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 report 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: 

OCAS–PER–011, Subtask 4: Review of Select Cases Reworked for

the Evaluation of K-25 Technical Basis Document and Technical 

Information Bulletin Revisions

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-PER011-ST4

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: October 25, 2016

TASK MANAGER: Kathleen Behling [signature on file]

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

DOCUMENT 

REVIEWER(S): John Stiver, MS, CHP [signature on file] 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 10/25/2016 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 5

1.0 Relevant Background Information ...................................................................................... 6

2.0 Review of OCAS-PER-011 Issues Related to K-25 ........................................................... 8

3.0 Background Information for Case ....................................................................... 9

3.1 Comparison of NIOSH’s Original and Reworked Dose Reconstructions .............. 9

3.2 SC&A’s Review of OCAS-PER-011 Issues Related to this Case ........................ 10

4.0 Background Information for Case ..................................................................... 11

4.1 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ............ 11

4.2 SC&A’s Review of OCAS-PER-011 Issues Related to this Case ........................ 12

5.0 Background Information for Case ..................................................................... 13

5.1 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ............ 13

5.2 SC&A’s Review of OCAS-PER-011 Issues Related to this Case ........................ 13

6.0 Background Information for Case ..................................................................... 16

6.1 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ............ 16

6.2 SC&A’s Review of OCAS-PER-011 Issues Related to this Case ........................ 16

7.0 Summary Conclusions ...................................................................................................... 19

8.0 References ......................................................................................................................... 21
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LIST OF TABLES

Table 3-1. Comparison of NIOSH-Derived External and Internal Dose Estimates Assigned for 

the and in the Original and Reworked DRs .......................................................... 9

Table 4-1. Comparison of NIOSH-Derived External and Internal Dose Estimates Assigned for 

the in the Original and Reworked DRs ........................................................................... 11

Table 5-1. Comparison of NIOSH-Derived External and Internal Dose Estimates Assigned for 

the in the Original and Reworked DRs ................................................................................. 13

Table 6-1. Comparison of NIOSH-Derived Dose Estimates Assigned in the Original and 

Reworked DRs .............................................................................................................................. 16

Table 6-2. Summary of Coworker Model Applied to Each Year ................................................. 18
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ABBREVIATIONS AND ACRONYMS

Advisory Board Advisory Board on Radiation and Worker Health 

CATI computer-assisted telephone interview

CTW construction trade worker 

DCF dose conversion factor 

DOE U.S. Department of Energy

DOL U.S. Department of Labor 

DR dose reconstruction 

DRR dose reconstruction report 

EE energy employee

ICD International Classification of Diseases

IREP Interactive RadioEpidemiological Program

keV kiloelectron volts 

mrem millirem

NIOSH National Institute for Occupational Safety and Health

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team

PER program evaluation report 

POC probability of causation 

TBD technical basis document

TIB technical information bulletin
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1.0 RELEVANT BACKGROUND INFORMATION

During an Advisory Board on Radiation and Worker Health (Advisory Board) Subcommittee on 

Procedures Review meeting on July 21, 2012, the Advisory Board tasked SC&A to conduct a 

review of OCAS-PER-011, Program Evaluation Report: K-25 TBD and TIB Revisions (hereafter 

“PER-011”). PER-011 was initiated following the issuance of a series of technical revisions to 

the technical basis document (TBD) (ORAUT-TKBS-0009-6) and two ORAUT technical 

information bulletins (TIBs) (ORAUT-OTIB-0026 and ORAUT-OTIB-0052) that affected K-25 

cases. While some changes incorporated into these revisions increased the assigned dose, others 

resulted in a decrease. Thereafter, PER-011 was necessary to assess cases affected by these 

document revisions. 

In conducting a program evaluation report (PER) review, SC&A is committed to perform five 

subtasks: 

• Subtask 1: Assess the National Institute of Occupational Safety and Health’s (NIOSH’s) 

evaluation and characterization of the “issue” and its potential impacts on dose 

reconstruction (DR). SC&A’s assessment intends to ensure that the “issue” was fully 

understood and characterized in the PER. 

• Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where 

the PER involves a technical issue that is supported by documents (e.g., white papers, 

TIBs, procedures) that have not yet been subjected to a formal SC&A review, Subtask 2 

will include a review of the scientific basis and/or sources of information to ensure the 

credibility of the corrective action and its consistency with current and consensus science.

Conversely, if such technical documentation has been formalized and previously 

subjected to a review by SC&A, Subtask 2 will simply provide a brief summary and 

conclusion of this review process. 

• Subtask 3: Evaluate the PER’s stated approach for identifying the universe of potentially 

affected DRs and assess the criteria by which a subset of potentially affected DRs was 

selected for reevaluation. The second step may have important implications in instances 

where the universe of previously denied DRs is very large and, for reasons of practicality, 

NIOSH’s reevaluation is confined to a subset of DRs that, based on NIOSH’s scientific 

judgment, have the potential to be significantly affected by the PER. In behalf of 

Subtask 3, SC&A will also evaluate the timeliness of the completion of the PER. 

• Subtask 4: Conduct audits of 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/tissues that may be impacted by a PER, (2) the method 

and data that were employed in the original DR, and (3) the time period, work location, 

and job functions that characterize the DR of a claim. (It is assumed that the selection of 

the DRs and the total number of DR audits per PER will be made by the Advisory 

Board.) 

• Subtask 5: Prepare a comprehensive written report that contains the results of the above 

subtasks, along with SC&A’s review conclusions. 
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On April 24, 2013, SC&A submitted to the Subcommittee on Procedures Review SCA-TRPR2013-0080, A Review of NIOSH’s Program Evaluation Report OCAS-PER-011, K-25 TBS 

and TIB Revisions, Revision 0 (SCA 2013). This review satisfied all but the Subtask 4 

requirement. At the time the PER-11 review was submitted, SC&A recommended and the 

Subcommittee agreed that it was necessary to delay the selection of claims until the findings 

identified in the initial review were resolved by the Subcommittee. This was done because the 

pool of impacted claims could be affected by the findings’ resolution. Resolution of these 

findings was completed during the May 16, 2016, meeting of the Advisory Board’s 

Subcommittee on Procedures Review. During the meeting, the Subcommittee tasked SC&A to 

complete Subtask 4 under the review of PER-011. 

This report fulfills the requirement defined in Subtask 4 above. The population of claims 

impacted by documentation changes was limited by the PER to the 432 K-25 claims that were 

evaluated between November 24, 2004, and August 31, 2006, and had a probability of causation 

(POC) of less than 50%. This value excludes claims that were subsequently returned to NIOSH 

for any other reason. According to the PER, NIOSH requested claims that met one of the 

following two criteria:

• Claims that were completed prior to May 21, 2005, and determined to have been 

completed using external coworker data 

• Claims completed between May 21, 2005, and August 31, 2006, that used external 

coworker data and were deemed construction trade workers (CTWs)

As discussed in Section 4.2 of SC&A’s PER-011 review (SC&A 2013), from the pool of 

impacted claims, 94 were returned to NIOSH. From the claims returned to NIOSH, only 69 

required rework. 

Finding 2 from SC&A’s initial PER-011 review (SC&A 2013) identified that, “The end date of 

the first selection criteria, May 21, 2005, is 10 days before the issuance of ORAUT-OTIB-0026 

Rev. 00.” During issues resolution, this was found to be a typographical error that was carried 

through PER-011’s execution. NIOSH found that two claims were initially completed in that 

10-day window of time; however, both claims were reevaluated under the PER. 

Following the resolution of the initial review’s findings, SC&A recommended the review of four 

cases from the 69 cases reworked as a result of PER-011. SC&A recommended two cases be 

selected from each of the following two criteria: 

• Claims originally completed before May 31, 2005, using an external coworker model and 

revised as a result of PER-011 

• CTW claims that were originally completed between May 21, 2005, and August 31, 

2006, using external coworker data and revised as a result of PER-011 

During the May 16, 2016, meeting of the Subcommittee on Procedures Review, the 

Subcommittee agreed with SC&A’s recommendations and tasked SC&A to proceed with 

Subtask 4. Cases were assigned to SC&A on June 28, 2016. 
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The Subcommittee on Procedures Review determined that SC&A’s audit of selected DRs should 

be limited to (1) evaluating those methods and corrective actions introduced in the reworked DRs 

that relate strictly to issues addressed in OCAS-PER-011 and (2) evaluating applicable 

documentation and workbooks to ensure they properly reflect the updated coworker guidance. 

Section 2.0 through Section 5.0 below present SC&A’s focused review to determine whether the 

reworked application of coworker dose was appropriately handled. 

2.0 REVIEW OF OCAS-PER-011 ISSUES RELATED TO K-25

In evaluating PER-011, SC&A compared the guidance in ORAUT-OTIB-0052, Parameters to 

Consider when Processing Claims for Construction Trade Workers, Revision 01, for assessing 

unmonitored CTW coworker dose with the guidance from ORAUT-OTIB-0026, External 

Coworker Dosimetry Data for the K-25 Site, Revision 00 PC-2. For the convenience of the 

reader, ORAUT-OTIB-0052 guidance is cited below: 

Use the guidance in ORAUT-OTIB-0020 (ORAUT 2008) to assign a penetrating 

dose that is favorable to unmonitored CTWs. Apply an adjustment factor of 1.4 to 

the appropriate percentile of the measured coworker data for the site, plus the 

assigned coworker missed dose, to determine the total assigned penetrating dose 

that is favorable to unmonitored CTWs.

SC&A reviewed ORAUT-OTIB-0026, Revision 00 PC-2, which was issued on November 15, 

2006, due to the issuance of ORAUT-OTIB-0052. Revision 00 PC-2 added Table 3 for CTW 

coworker dose. SC&A found that missed and measured doses are reported in a single value for 

each percentile of coworker dose and, therefore, an adjustment of 1.4 could not be applied 

directly. This is equivalent to the way other documents incorporate ORAUT-OTIB-0052 

guidance. 

PER-011 identified 432 K-25 claims as potentially affected by the series of document revisions. 

Of these claims, 69 were sent back to NIOSH for revision. SC&A recommended that four 

claims, two from each category, be assigned to evaluate Subtask 4. NIOSH provided SC&A with 

Cases and that satisfied the first criteria and Cases and that 

satisfied the second criteria.
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3.0 BACKGROUND INFORMATION FOR CASE 

Case represents an energy employee (EE) who worked at the Oak Ridge Gaseous 

Diffusion Plant (K-25) from , 1974, through , 1985, and the Y-12 Plant 

from 1985, through 1994. The EE’s job functions during employment were

laborer, , and . The EE was 

diagnosed with of the (International 

Classification of Diseases [ICD]-9 Code ) in 1987 and cancer (ICD-9 Code ) 

in 2007. 

3.1 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case in May 2005. The claim was reworked in 

February 2009 to evaluate the potential for additional dose based on new guidance for processing 

claims and to include the 2007 cancer diagnosis. Both the original and revised DRs 

stated that the EE’s radiation dose was overestimated using efficiency measures. In the original 

DR, NIOSH calculated a dose of 2.592 rem to the . Based on this assigned dose estimate, 

the U.S. Department of Labor (DOL) determined the POC to be 0.43%, and the claim was 

denied. 

Using the most current technical guidance documents, a dose of 11.707 rem was 

recalculated in the revised DR. The revised DR also included a dose of 3.434 rem.

Table 3-1 compares the original and revised external and internal organ dose estimates for the 

 and . It should be noted that the values cited in Table 3-1 were extracted directly 

from NIOSH’s reworked DR. With the exception of potential coworker external dose at K-25, 

SC&A has not assessed the accuracy and correctness of these doses, because performing such an 

assessment is beyond the scope of this Subtask 4 report. 

Table 3-1. Comparison of NIOSH-Derived External and Internal Dose Estimates Assigned 

for the and in the Original and Reworked DRs

Dose Categories

Previous 

 Dose 

(rem)

Revised 

 Dose 

(rem)

Previous 

Dose (rem)

Revised 

Dose (rem)

External Measured and Missed 0.370 0.679 NA 0.844

External Coworker 0.150 0.835 NA 1.039

Ambient External 0.000 0.727 NA 1.121

Medical X–ray 0.335 0.273 NA 0.003

Internal 1.737 9.194 NA 0.427

Total 2.592 11.707 NA* 3.434

* Not included in previous DR. 

Using the EE’s U.S. Department of Energy (DOE) records and claimant-favorable assumptions, 

a dose of 11.707 rem and a dose of 3.434 rem resulted in a POC of 13.76%. On 

this basis, the revised claim was denied. 
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3.2 SC&A’S REVIEW OF OCAS-PER-011 ISSUES RELATED TO THIS CASE

As directed by the Subcommittee on Procedures Review, SC&A’s review of Case 

strictly focused on the external coworker model. Case was included in the pool of 

claims that required the DR to be reworked because it met the OCAS-PER-011 criteria that

(1) the original DR was performed before May 31, 2005, (2) coworker dose was assigned, and 

(3) the POC was less than 50%. 

In the original DR, NIOSH identified the years 1974, 1986, and 1987 as times when the EE was 

not monitored for ionizing radiation and should have been. For these years, NIOSH assigned an 

unmonitored coworker photon dose of 50 millirem (mrem) per year. This resulted in a total 

photon unmonitored coworker dose of 0.150 rem to the . 

In the reworked DR, NIOSH assigned a single year of coworker dose to the year 1974, when the 

EE was monitored internally. NIOSH used ORAUT-OTIB-0026, Revision 00-PC-2, Table 2, to 

assign the 50th percentile K-25 coworker dose. NIOSH assumed the EE was exposed to 100% 

30–250 kiloelectron volts (keV) photons and applied an organ dose conversion factor (DCF) of 

1.000 to modify dose to the and a DCF of 1.244 to modify dose to the . NIOSH 

did not prorate dose to reflect a partial year of employment. This resulted in a photon dose of 

0.835 rem to the and 1.039 rem to the . 

In the reworked DR, unlike the original DR, no coworker dose was assigned to 1986 or 1987. 

This is not addressed in the DR; however, during those years, the EE worked at Y-12. Assessing 

Y-12 coworker dose is outside the scope of this review; therefore, the discrepancy between the 

original and reworked DR was not further investigated. 

Finding 6: CTW Correction Not Applied

NIOSH did not assume the EE qualified as a CTW. On page 24 of the initial claim document 

filed by the claimant, the EE indicates that from 1974 through 1975 or 1976, the EE worked as a 

 laborer. OCAS-PER-014, Program Evaluation Report: Construction Trades 

Workers, Revision 0, another PER that relates to ORAUT-OTIB-0052 recommendations, 

includes “machinist,” “metal worker,” and “laborer” as job functions that qualify as CTWs. 

SC&A believes that the EE qualifies as a CTW and that assigning a modified CTW coworker 

dose would have been appropriate in this case. NIOSH’s determination that the EE did not 

qualify as a CTW resulted in the omission of 0.028 rem to the and 0.035 rem to the 

.

SC&A acknowledges that until early 2014, NIOSH incorrectly excluded CTWs working for the 

prime contractor from receiving CWT adjustments. This exclusion was and remains inconsistent 

with the ORAUT-OTIB-0052 guidance. NIOSH has committed to addressing this issue in the 

form of a PER. SC&A suspects CTW adjustments were incorrectly omitted from the DR because 

the EE worked for prime contractors and .
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4.0 BACKGROUND INFORMATION FOR CASE 

Case represents an EE who worked at the Oak Ridge Gaseous Diffusion Plant (K-25) 

from , 1947, through , 1948; from 1952, through , 1961; and 

from 1965, through , 1981, and at the Y-12 Plant from , 1961, through 

, 1965. The EE was diagnosed with (a cancer of the 

 ICD-9 code ) in March 2003. The computer-assisted telephone interview (CATI) 

report and DOE files indicate the EE worked as a and . Although not 

mentioned in the NIOSH dose reconstruction report (DRR) or CATI report, the NIOSH OCAS 

Claims Tracking System (NOCTS) also lists the EE as a and during the 

years 1965 through 1981. 

4.1 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case in December 2004. The claim was reworked 

in November 2009 based on current practices used in dose reconstruction. This was done to 

incorporate changes in guidance for K-25 and Y-12 that included coworker dose. Both the 

original and revised DRs stated that the EE’s radiation dose was overestimated using claimantfavorable assumptions. Based on this assigned dose estimate, DOL determined the POC to be 

25.16%, and the claim was denied. 

Using the most current technical guidance documents and considering CTW coworker dose 

modifications, NIOSH calculated a dose of 22.212 rem in the revised DR. Table 4-1 

compares the original and revised external and internal organ dose estimates for the . It 

should be noted that the values cited in Table 4-1 were extracted directly from NIOSH’s 

reworked DR. With the exception of external coworker doses, SC&A has not assessed the 

accuracy and correctness of these doses, because performing such an assessment is beyond the 

scope of this Subtask 4 report. 

Table 4-1. Comparison of NIOSH-Derived External and Internal Dose Estimates Assigned 

for the in the Original and Reworked DRs

Dose Categories Previous Dose (rem) Revised Dose 

(rem)

External Measured and Missed 1.433 0.735 

External Coworker 5.541 19.736 

Medical X–ray 0.311 0.318 

Internal 13.311 1.423 

Total 20.520 22.212 

Using the EE’s DOE records and best-estimate assumptions, a dose of 22.212 rem 

resulted in a POC of 31.95%. On this basis, the revised claim was denied. 
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4.2 SC&A’S REVIEW OF OCAS-PER-011 ISSUES RELATED TO THIS CASE

As directed by the Subcommittee on Procedures Review, SC&A’s review of Case is 

strictly focused on external coworker models. Case was included in the pool of claims 

that required the DR to be reworked because it met the OCAS-PER-011 criteria that (1) the 

original DR was performed prior to the issuance of ORAUT-OTIB-0026, Revision 00 PC-1, on 

May 31, 2005, (2) the EE coworker dose was assigned, and (3) the POC was less than 50%. 

In the original DR, NIOSH identified that the EE was likely exposed to external radiation prior 

to 1980. The EE was assigned average deep doses for K-25 workers from Table 6-4 of ORAUTTKBS-0009-6, Technical Basis Document for the K-25 Site – Occupational External Dose,

Revision 00, for each year for which no monitoring was provided. These doses were applied for 

all years that the EE worked at the K-25 site and were assigned a lognormal or normal 

distribution. This resulted in a total unmonitored dose of 5.541 rem to the . 

In the reworked DR, NIOSH identified that the EE may have received unmonitored radiation 

dose in 1947, 1948, 1952 through 1961, and 1965 through 1981 at K-25. The EE was assigned 

the 50th percentile coworker dose from Table 2 of ORAUT-OTIB-0026, Revision 00 PC-2. 

NIOSH assumed the EE was exposed to 100% 30–250 keV photons and applied a DCF of 1.244 

to the . For those years in which the EE was only employed part of the year, the dose was

prorated. NIOSH assigned an unmonitored dose of 19.736 rem to the in the reworked 

DR.

Observation 1 

NIOSH made no adjustments to the DR to account for CTW coworker dose. SC&A notes that 

the DOE files and NOCTS state that the EE worked as a and during the 

years 1965 through 1981. This is not reflected in the CATI report, initial claim report, or NIOSH 

DRR; instead, these documents say the EE worked as an during this time.

It is unclear to SC&A where the career designation “ ” originated, though 

SC&A speculates it originated from a DOL-confirmed employment. It is unclear to SC&A if a 

CTW correction would have been appropriate for 1965 through 1981, though the addition of a 

CTW correction would not affect compensation. 
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5.0 BACKGROUND INFORMATION FOR CASE 

Case represents an EE who worked at K-25 from , 1952, through 

1955, and from , 1955, through 1957. Additionally, the EE worked at 

the Y-12 Plant from , 1960, through , 1960; 1960, through 

, 1960; , 1960, through , 1962; and , 1962, through 

, 1984. The EE was diagnosed with of the (ICD-9 

Code ) in 1979 and of the (ICD-9 Code ) in 1999. 

5.1 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case in February 2006. The claim was reworked 

in March 2010 to reevaluate this case based on “current methods and procedures.” The original 

DR stated that the EE’s radiation dose was overestimated using claimant-favorable assumptions. 

In the original DR, NIOSH calculated doses of 29.201 rem to the on the and 

14.460 rem to the on the . Based on this assigned dose estimate, DOL determined the 

POC to be 46.66%, and the claim was denied. 

Using the most current technical guidance documents and considering the revised coworker dose 

methodology, NIOSH recalculated the two cancer doses in the revised DR. The revised DR

was completed with best estimate assumptions. Table 5-1 compares the original and revised 

external and internal organ dose estimates for the . It should be noted that the values cited in 

Table 5-1 were extracted directly from NIOSH’s reworked DR. With the exception of external 

coworker dose, SC&A has not assessed the accuracy and correctness of these doses, because

performing such an assessment is beyond the scope of this Subtask 4 report. 

Table 5-1. Comparison of NIOSH-Derived External and Internal Dose Estimates Assigned 

for the in the Original and Reworked DRs

Dose Categories Previous 

Dose (rem)

Revised 

Dose (rem)

Previous 

 Dose 

(rem)

Revised 

 Dose 

(rem)

External Measured and Missed 8.850 9.154 9.048 9.996 

External Coworker 0.720 1.724 0.720 1.845 

Medical X–ray 18.585 26.132 3.483 2.155 

Internal 0.176 0.472 0.519 1.020

Total 29.201 37.482 14.640 15.016

Using the EE’s DOE records and claimant-favorable assumptions, a dose of 37.482 rem to 

the and 15.016 rem to the resulted in a POC of 51.98%. On this basis, the revised 

claim was compensated. 

5.2 SC&A’S REVIEW OF OCAS-PER-011 ISSUES RELATED TO THIS CASE

As directed by the Subcommittee on Procedures Review, SC&A’s review of Case 

strictly focused on external coworker models. Case was included in the pool of claims 
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that required the DR to be reworked because it met the PER-011 criteria that (1) original DR was 

completed between May 21, 2005, and August 31, 2006, (2) the EE worked as a construction 

trade worker, (3) coworker dose was assigned, and (4) the POC was less than 50%. 

In the original DR, NIOSH identified that the EE was potentially exposed to external photons 

and electrons during 1957 but was unmonitored for external exposure. NIOSH assumed the EE 

was likely exposed to 100% 30–250 keV photons and assumed a DCF equal to 1.00. No photon 

adjustment factor was applied. NIOSH assigned each cancer the 50th percentile coworker photon 

dose in 1957 from Table 2 of ORAUT-OTIB-0026, Revision 00 PC-1. This resulted in the total 

coworker photon dose of 0.720 rem to each cancer site. 

In the reworked DR, NIOSH identified that the EE was unmonitored in 1957. Based on elevated 

dosimetry values in 1956, NIOSH assumed the EE was exposed to the 95th percentile gamma 

and non-penetrating values from Table 2 of ORAUT-OTIB-0026, Revision 00 PC-2, which does 

not include an adjustment for work as a CTW. NIOSH prorated the table values to reflect a 

fractional year of employment. For the of the , the calculated electron doses were 

multiplied by 0.855, which represents the midpoint of the uranium attenuation factors reported 

for two pairs of coveralls, including the paper liner (0.80) and one Dacron/cotton lab coat (0.91).

NIOSH states in the DR report that while “this factor does not apply specifically to a glove worn 

on the hand, the records indicated that he wore a thin glove during assembly of parts and also 

that he performed meticulous work and did not list gloves as protective clothing worn.” 

SC&A could only locate a single K-25 workbook in the EE’s files that was used to calculate the 

single year of coworker dose at K-25. As part of this Subtask 4 review, SC&A verified that the 

calculated dose was properly assigned in the Interactive RadioEpidemiological Program (IREP) 

input documents for both cancers.

Finding 7: CTW Correction Not Applied

In the CATI report, the EE reports working as a “ and Maintenance 

.” Attachment A to OCAS-PER-014, which like PER-011 is related to ORAUT-OTIB0052, identified both “ ” and “maintenance” as career descriptions of CTWs. Although 

PER-11 does not go into the same level of detail, SC&A believes that this list is equally 

applicable for identifying CTW jobs at K-25. Based on this logic, SC&A believes this EE 

qualifies as a CTW and thus should receive the larger CTW coworker gamma dose. Using 

Table 3 from ORAUT-OTIB-0026, Revision 00 PC-2, and the parameters specified above, 

SC&A calculated a CTW coworker dose of 1.134 rem from 30–250 keV photons 

(0.120 rem larger than the NIOSH assigned coworker dose.) 

SC&A acknowledges that until early 2014, NIOSH incorrectly excluded CTWs working for the 

prime contractor from receiving CWT adjustments. This exclusion was and remains inconsistent 

with the current ORAUT-OTIB-0052 guidance. NIOSH has committed to addressing this issue 

in the form of a PER. SC&A suspects CTW adjustments were incorrectly omitted from the DR 

because the EE worked for prime contractors; however, SC&A could not find evidence 

supporting the company that employed the EE.
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Observation 2 

SC&A questions the use of a beta dose attenuation factor of 0.855 that was used to modify 

coworker dose. Although it is consistent with ORAUT-OTIB-0017, Interpretation of Dosimetry 

Data for Assignment of Shallow Dose, Revision 01, guidance for when the specific level of 

protection is unknown, SC&A questions if the assignment is claimant favorable. ORAUT-OTIB0017 directs that more information can be found in DOE Standard DOE-STD-1136-2000, Guide 

of Good Practices for Occupational Radiological Protection in Uranium Facilities. This 

reference has three types of gloves listed with associated beta reduction fractions. All three glove 

types have less beta attenuation than the assumed value. Additionally, the EE’s reference to 

meticulous work in gloves was in reference to employment at Y-12, not K-25. In an instance 

where it is unclear what gloves, if any, the EE wore, it would be more appropriate to assign no 

attenuation factor. The assumption that gloves were worn reduced the beta coworker dose 

assigned by approximately 0.122 rem. 

SC&A notes that, because Case was compensated; resolution of Finding 7 and 

Observation 2 will not affect the compensation decision for this case.
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6.0 BACKGROUND INFORMATION FOR CASE 

Case represents an EE who worked at the Oak Ridge Sites K-25, Y-12, and X-10 

during intermittent employment periods between 1953, and 1989. 

Records indicate the EE worked as an electrician during all employment periods. The EE 

was diagnosed with (ICD-9 Code ) in June 1992. 

6.1 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case in February 2006. The claim was reworked 

in March 2010 to reevaluate this case in accordance with updated guidance that included 

coworker guidance. Both the original and revised DRs stated that the EE’s radiation dose was 

overestimated using claimant-favorable assumptions. In the original DR, NIOSH calculated a 

 dose of 20.424 rem. Based on this assigned dose estimate, DOL determined the POC to 

be 22.11%, and the claim was denied.

Using the most current technical guidance documents and considering the revised coworker dose 

methodology, NIOSH recalculated the dose to the in the revised DR. Table 6-1 

compares the original and revised external and internal organ dose estimates for the . It 

should be noted that the values cited in Table 6-1 were extracted directly from NIOSH’s 

reworked DR. With the exception of external coworker dose, SC&A has not assessed the 

accuracy and correctness of these doses, because performing such an assessment is beyond the 

scope of this Subtask 4 report. 

Table 6-1. Comparison of NIOSH-Derived Dose Estimates Assigned in the Original and 

Reworked DRs

Dose Categories

Previous 

 Dose 

(rem)

Revised 

 Dose 

(rem)

External Measured and Missed 0.572 0.155

External Coworker 6.583 19.241

Medical X-ray 2.073 0.334 

Internal 11.196 7.115 

Total (rem) 20.424 26.845 

Using the EE’s DOE records and claimant-favorable assumptions, a dose of 26.845 rem 

resulted in a POC of 32.58%. On this basis, the revised claim was denied. 

6.2 SC&A’S REVIEW OF OCAS-PER-011 ISSUES RELATED TO THIS CASE

As directed by the Subcommittee on Procedures Review, SC&A’s review of Case 

strictly focused on external coworker models. Case was included in the pool of claims 

that required the DR to be reworked because it met the PER-011 criteria that (1) the original DR 

was performed between May 31, 2005, and August 31, 2006, (2) coworker dose was assigned, 

(3) the EE qualified as a CTW, and (4) the POC was less than 50%. 
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In the original DR, NIOSH identified that the EE was potentially exposed to external photons 

from 1951, through 1979 but was unmonitored for external exposure. A best estimate 

of the organ dose was assigned using the lognormally distributed annual photon doses at 

Y-12 from ORAUT-OTIB-0013, Technical Information Bulletin: Individual Dose Adjustment 

Procedure for Y-12 Dose Reconstruction, Revision 00, using Monte Carlo techniques in 

accordance with OCAS-IG-001, External Dose Reconstruction Implementation Guideline. 

Coworker dose from X-10 and K-25 was not assessed because the EE “was monitored for 

external dose at Y-12 after 1979,” according to the DRR. This resulted in a total 

coworker dose assigned of 6.583 rem. 

In the reworked DR, NIOSH identified that the EE was unmonitored from 1951 through 1958, 

and from 1967 through 1979. NIOSH assumed the EE was exposed to the 50th percentile gamma 

CTW coworker dose. Because the EE worked between the three Oak Ridge Sites, NIOSH 

compared the 50th percentile annual coworker doses at the facilities for each year and assigned

the highest annual value to the EE for each year. SC&A could not locate specific guidance on 

how to treat coworker dose in employment scenarios like the EE’s; however, the method used is 

logical and claimant favorable.

K-25 coworker values were obtained from Table 3 of ORAUT-OTIB-0026, Revision 00 PC-2. 

Values representing Y-12 and X-10 CTW coworker doses were extracted from Table 7-2 of 

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

Complex, Revision 01, and Table 3 of ORAUT-OTIB-0021, Coworker External Dosimetry Data 

for the K-25 Site, Revision 01, respectively. SC&A previously assessed CTW coworker dose at 

X-10 and Y-12 during its evaluation of OCAS- PER-014; further evaluation is outside the scope 

of this review. NIOSH found that from 1967 through 1974, K-25 50th percentile CTW coworker 

dose was most claimant favorable. The remaining years of coworker dose assigned by NIOSH 

are summarized in Table 6-2. 
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Table 6-2. Summary of Coworker Model Applied to Each Year

Coworker 

Year Model Used

1951 Y-12 50th percentile CTW

1952 Y-12 50th percentile CTW

1953 Y-12 50th percentile CTW

1954 Y-12 50th percentile CTW

1955 X-10 50th percentile CTW

1958 Y-12 50th percentile CTW

1967 K-25 50th percentile CTW

1968 K-25 50th percentile CTW

1969 K-25 50th percentile CTW

1970 K-25 50th percentile CTW

1971 K-25 50th percentile CTW

1972 K-25 50th percentile CTW

1973 K-25 50th percentile CTW

1974 K-25 50th percentile CTW

1975 X-10 50th percentile CTW

1976 X-10 50th percentile CTW

1977 X-10 50th percentile CTW

1978 X-10 50th percentile CTW

1979 X-10 50th percentile CTW

NIOSH assumed the EE was likely exposed to 100% 30–250 keV photons and assumed a DCF 

equal to 1.244 for the . This resulted in the total coworker photon dose of 19.241 rem to 

the .

NIOSH used the case-specific workbook to model coworker dose for this claimant. As part of 

this Subtask 4 review, SC&A verified that the calculated dose was properly assigned in the IREP 

input documents for the cancer. SC&A’s review of OCAS-PER-011 did not find any 

issues related to the reconstruction of coworker dose for Case . 
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7.0 SUMMARY CONCLUSIONS

Under SCA-TR-PR2009-0002, A Protocol to Review NIOSH’s Program Evaluation Reports 

(PERs), Revision 1 (SC&A 2009), Subtask 4 requires the audit of DR cases reworked as a result 

of the PER under review. Based on guidance in OCAS-PER-011, cases required rework if they 

met the following criteria: 

• Claims that were completed prior to May 21, 2005, and determined to have been 

completed using external coworker data 

• Claims completed between May 21, 2005, and August 31, 2006, that used external 

coworker data and were deemed CTWs

Therefore, in order to satisfy Subtask 4, SC&A recommended in SCA-TR-PR2013-0080 

(SC&A 2013) the selection of two cases from the following modified categories: 

• Claims originally completed before May 31, 2005, using an external coworker model and 

revised as a result of PER-011 

• CTW claims that were originally completed between May 21, 2005, and August 31, 

2006, using external coworker data and revised as a result of PER-011 

Cases and were assigned to SC&A because they meet the first category. 

Cases and were assigned to SC&A because they meet the second category. 

Each case’s coworker dose reconstruction was reviewed.

For each of the four reviewed cases, SC&A provided an overview of the case and a brief 

comparison of external and internal doses assigned in the original and revised DRs. Based on 

directives from the Subcommittee on Procedures Review, SC&A’s audit of these cases focused 

strictly on those elements of the DR that were affected by the issuance of OCAS-PER-011. 

SC&A’s Subtask 4 review resulted in the identification of two findings. Because this Subtask 4 

evaluation is a continuation of the review of PER-011 documented in SCA-TR-PR2013-0080 

(SC&A 2013), and that review identified five findings, the finding numbers in this review begin 

at 6. These findings are summarized below. 

• Finding 6 – No CTW adjustment is made for employment as a 

laborer. 

• Finding 7 – No CTW adjustment is made for employment as a 

and maintenance . 

Both findings highlight the concern SC&A expressed in its initial review of PER-011 relating to 

the proper identification of CTWs. Critical to processing each claim correctly is the proper 

identification of a CTW, which, as it stands, is a subjective term. SC&A remains concerned that 

without clearly defined criteria to identify CTWs, identical claims could potentially be processed 

as both CTW and non-CTW by different reviewers. SC&A acknowledges that a degree of 

professional judgment will always be required by DRs; however, clearly defined criteria such as 
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those used by OCAS-PER-014 are the only way to ensure claims are identified and handled 

consistently. 

SC&A notes that as a result of the initial SC&A review of PER-011 (SC&A 2013), it was 

determined that NIOSH was incorrectly excluding CTWs employed by the prime contractor from 

receiving CWT adjustments. This exclusion was and remains inconsistent with the current 

ORAUT-OTIB-0052 guidance, and NIOSH has committed to addressing this issue in the form of 

a PER. SC&A suspects CTW adjustments may have been omitted in both cases because NIOSH 

determined the EE worked for a prime contractor. In any case, NIOSH needs to confirm that the 

cases will be covered under the PER to correct this error.

In Sections 3 through 6 above, SC&A also made two observations. In the first observation, 

SC&A notes that the case files appear to contradict the EE’s job category. NIOSH did not apply 

a CTW correction, but it was unclear to SC&A if a CTW correction should have been applied. In 

the second observation, SC&A points out that the use of a beta dose attenuation factor may result 

in a not-claimant-favorable underestimate of the coworker dose received by the EE.
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8.0 REFERENCES

DOE-STD-1136-2000. 2000. Guide of Good Practices for Occupational Radiological Protection 

in Uranium Facilities, U.S. Department of Energy, Washington, DC. August 2000. 

OCAS-IG-001. 2007. External Dose Reconstruction Implementation Guideline, Revision 03, 

Office of Compensation Analysis and Support, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. November 21, 2007. 

OCAS-PER-011. 2007. Program Evaluation Report: K-25 TBD and TIB Revisions, Revision 0, 

Office of Compensation Analysis and Support, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. September 26, 2007. 

OCAS-PER-014. 2007. Program Evaluation Report: Construction Trades Workers, Revision 0, 

Office of Compensation Analysis and Support, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. November 28, 2007. 

ORAUT-OTIB-0013. 2009. Technical Information Bulletin: Individual Dose Adjustment 

Procedure for Y-12 Dose Reconstruction, Revision 00, Oak Ridge Associated Universities Team, 

Oak Ridge, Tennessee. September 9, 2009. 

ORAUT-OTIB-0020. 2008. Use of Coworker Dosimetry Data for External Dose, Revision 02, 

Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. December 4, 2008. 

ORAUT-OTIB-0017. 2005. Interpretation of Dosimetry Data for Assignment of Shallow Dose, 

Revision 01, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. October 11, 

2005. 

ORAUT–OTIB-0021. 2006. External Coworker Dosimetry Data for the X-10 Site, Revision 01, 

Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. November 7, 2006. 

ORAUT-OTIB-0026. 2005. External Coworker Dosimetry Data for the K-25 Site, Revision 00, 

Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. May 31, 2005. 

ORAUT-OTIB-0026. 2005. External Coworker Dosimetry Data for the K-25 Site, 

Revision 00 PC-1, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. July 29, 

2005. 

ORAUT-OTIB-0026. 2006. External Coworker Dosimetry Data for the K-25 Site, 

Revision 00 PC-2, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. 

November 15, 2006. 

ORAUT-OTIB-0052. 2011. Parameters to Consider when Processing Claims for Construction 

Trade Workers, Revision 01, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. 

February 17, 2011. 
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ORAUT-OTIB-0064. 2009. Coworker External Dosimetry Data for the Y-12 National Security 

Complex, Revision 01, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. 

December 18, 2009. 

ORAUT-TKBS-0009-6. 2004. Technical Basis Document for the K-25 Site – Occupational 

External Dose, Revision 00, National Institute for Occupational Safety and Health, Cincinnati, 

Ohio. November 24, 2004. 

ORAUT-TKBS-0009-6. 2006. Technical Basis Document for the K-25 Site – Occupational 

External Dose, Revision 00 PC-1, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. September 26, 2006. 

SC&A 2007. Review of ORAUT-OTIB-0052, Parameters to Consider when Processing Claims 

for Construction Trade Workers, SCA-TR-TASK3-0004, Draft, SC&A, Inc., Vienna, Virginia. 

July 30, 2007. [SRDB Ref. ID 88584] 

SC&A 2009. A Protocol to Review NIOSH’s Program Evaluation Reports (PERs), SCA-TRPR2009-0002, Revision 1, SC&A, Inc., Vienna, Virginia. December 1, 2009. 

SC&A 2013. A Review of NIOSH’s Program Evaluation Report OCAS-PER-011, SCA-TRPR2013-0080, Revision 0, SC&A, Vienna, Virginia. April 24, 2013.