Division of Compensation Analysis and 

Support

Program Evaluation Report

Document Number: DCAS-PER-071 

Effective Date: 9/25/2018 

OTIB-0079 Rev. 02, Offsite X-Ray Guidance Page 1 of 5

Author: Signature on file Date: 9/25/2018 

 Dave Allen, HP Team Leader

Approval: Signature on file Date: 9/25/2018 

 J. W. Neton, Associate Director for Science

Supersedes: none 

RECORD OF ISSUE/REVISIONS

ISSUE 

AUTHORIZATION 

DATE

EFFECTIVE

DATE

REV. NO. DESCRIPTION

9/25/2018 9/25/2018 none New document to determine the effect of 

revisions to ORAUT-OTIB-0079

(Guidance on Assigning Occupational XRay Dose under EEOICPA for X-rays 

Administered Off Site) on previously 

completed claims.

1.0 Description

A complex wide document (ORAUT-OTIB-0079) was issued on 1/3/2011 titled

Guidance on Assigning Occupational X-Ray Dose under EEOICPA for X-rays 

Administered off Site. This document summarized information gathered about the 

location of medical x-rays associated with particular sites. On 3/18/2016 revision 1 of 

the document was issued. No PER was issued for that revision because an effort was 

underway to verify and summarize information about additional sites. That effort 

culminated in the issuance of revision 2 on 6/15/2017. 

The effect of these revisions on previously completed claims is the subject of this PER.

2.0 Issue Evaluation 

This OTIB lists sites and time frames for which information exists to indicate that routine 

x-rays were taken at off-site locations that are not covered by EEOICPA. The document 

also contains a list of sites where x-rays were taken on-site or that no location 

information exists. 
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Program Evaluation Report

Document Number: DCAS-PER-071 

Effective Date: 9/25/2018 Page 2 of 5

Not all sites are listed in the document. Revision 0 listed most major sites. Revision 1 

included many more sites along with changes to information available on some sites that 

were included in revision 0. 

Table 1 in revision 0 (Table 3-1 in revision 1 and 2) lists sites and time frames when 

routine x-rays were taken at off-site facilities not covered under EEOICPA. Table 2 in 

revision 0 (Table 3-2 in revision 1 and 2) lists sites where x-rays were taken on-site or for 

which no location information is available. Sites not listed in ORAUT-OTIB-0079 

would follow site specific guidance or default to complex wide guidance that assumes 

standard x-rays were taken on-site.

In order to evaluate the effect of these revisions on previous dose reconstructions, the 2 

lists and notes were compared in each revision. Changes that would not have the 

potential to increase dose were not considered in this PER. An example would be an 

addition to Table 1 indicating x-rays previously assigned would no longer be included. 

The review found 6 sites for which a change could potentially cause an increase in dose. 

Those 6 sites are discussed below.

Extrusion Plant 

Prior to revision 1 of OTIB-79 being issued, x-rays at the Extrusion Plant were assumed 

to be taken on-site. Revision 0 of OTIB-79 indicated x-rays were taken off-site prior to 

1977 and after 1996. Revision 1 indicated x-rays were taken off-site before 1981 and 

after 2006. Therefore, x-rays taken between 1996 and 2006 would now be covered when 

previously they were not. A revision to the Extrusion Plant TBD was issued on 3/7/2017 

which is after revision 1 of OTIB-79. Instructions in that revision match those in OTIB79 revision 1 (and revision 2). PER-78 is being issued to evaluated changes to Extrusion 

Plant claims including those associated with changes to assigned x-ray dose. Therefore, 

this PER will not consider this site. 

Hanford

Prior to revision 0 of OTIB-79 being issued, x-rays at the Hanford site were assumed to 

be taken on-site. Revision 0 of OTIB-79 indicated x-rays were taken off-site at the 

Kadlec hospital from 1944 to 1955. Revision 1 included the new information that the 

Kadlec hospital was actually owned by the AEC in that time frame making those x-rays a 

covered exposure. Therefore, Hanford claims completed after the issuance of revision 0 

and before revision 1 are reevaluated under this PER.
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Program Evaluation Report

Document Number: DCAS-PER-071 

Effective Date: 9/25/2018 Page 3 of 5

Portsmouth

Prior to revision 0 of OTIB-79 being issued, x-rays at Portsmouth were assumed to be 

taken on-site. Revision 0 of OTIB-79 indicated x-rays were taken off-site from 1954 to 

1981. Revision 1 of OTIB-79 removed that statement but indicated x-rays were taken 

off-site in 2010, 2011 and from April 2012 to May 4th 2014. The information that x-rays 

were taken on-site even prior to 1982 was known prior to the publication of OTIB-79 

revision 1 and information about the location of the x-ray equipment was included in 

revision 3 of ORAUT-TKBS-0015-3 (Portsmouth TBD medical section) issued on 

4/8/2013. Therefore, Portsmouth claims with employment prior to 1982 that were 

completed between the publication of OTIB-79 revision 0 and the publication of revision 

3 of the ORAUT-TKBS-0015-3 will be included in this PER. 

Sandia National Lab at Livermore (SNL-L)

The TBD for SNL-L indicates that worker x-rays ceased in the 1980s and the x-ray 

equipment was removed from the site in 1990. OTIB-79 (all revisions) indicates that 

after 1989, x-rays were taken at Lawrence Livermore National Lab (LLNL) which is a 

covered facility so the x-rays should be accounted for. Due to the inconsistency, x-ray 

records began to be routinely requested from LLNL for SNL-L employees. This process 

started sometime after revision 0 of OTIB-79 was issued but before revision 1. 

Therefore, claims completed prior to revision 1 of OTIB-79 will be included in this PER. 

Also, a note existed in revision 0 of OTIB-79 indicating in the 1950s, pre-employment xrays may have been taken off-site. That note was removed in revision 1 and any 

potentially affected claims are already part of the population to be reviewed.

Additional Sites

Each site added to revision 1 that was not mentioned in revision 0 were reviewed to 

determine if site documentation was consistent with revision 1 of OTIB-79. For most 

sites, the documentation was consistent. Eight sites were added to Table 1 resulting in a 

reduction in x-ray examinations assigned. For three sites (discussed below), the 

consistency was unclear so those three sites were added to the population of claims to 

review for this PER.

Albuquerque Operations Office (AOO)

AOO was included in Table 3-2 of revision 1 to OTIB-79. This indicates x-rays should 

be assigned in all years. It was not clear if x-rays were consistently applied for AOO 
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Program Evaluation Report

Document Number: DCAS-PER-071

Effective Date: 9/25/2018 Page 4 of 5

employment prior to revision 1. Therefore, all claims completed prior to revision 1 are 

included in this PER.

Amchitka

Prior to revision 0 of OTIB-79, x-rays were assigned for Amchitka employment as a 

default. Revision 0 did not mention Amchitka but it was decided on 3/20/2013 that there 

was no indication of any x-ray equipment at Amchitka so x-ray doses were excluded after 

that date. After that time, information was found indicating there was x-ray equipment at 

Amchitka and that information was included in revision 1 of OTIB. Therefore, Amchitka 

claims completed between 3/19/2013 and revision 1 of OTIB-79 will be included in this 

PER.

Clinton engineering Works (CEW)

CEW was added to revision 1 of OTIB-79 indicating x-rays should be assigned every 

year. Prior to that, assignment of x-rays may have been inconsistently applied as being 

from any one of the Oak Ridge sites. Therefore, all CEW claims completed prior to 

revision 1 of OTIB-79 will be reviewed as part of this PER.

3.0 Plan for Resolving Corrective Action

A search of the NIOSH Claims Tracking System (NOCTS) database identified 915

claims meeting one of the criteria above. Of those, 255 had a probability of causation 

(POC) of greater than 50% and were removed from further evaluation. An additional 34 

claims were removed because they had a status of “pulled” in NOCTS, meaning they 

have been pulled from the dose reconstruction process (primarily due to inclusion in a 

special exposure cohort (SEC)). Lastly, 63 claims were removed from consideration due 

to being eligible for an SEC without any additional medical benefits.

Of the remaining 563 claims, 11 were returned to NIOSH from the Department of Labor 

for a rework before they could be evaluated under this PER. For those claims, a new 

dose reconstruction would be completed using all current methods so no evaluation under 

this PER was necessary. Those claims were therefore removed from further evaluation.

The remaining 552 claims were evaluated to determine if any change to the estimated 

dose was necessary based on the revisions to OTIB-79 as well as all other applicable 

procedures. 542 resulted in either no change or a new POC below 45%. Two claims 

resulted in a new POC that was greater than 52% while eight claims resulted in a new 

POC that fell between 45% and 52%. For those eight claims, IREP was run 30 times at 
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Program Evaluation Report

Document Number: DCAS-PER-071

Effective Date: 9/25/2018 Page 5 of 5

10,000 iterations per NIOSH procedures. The resulting POC remained below 50% for 

seven of the claims while one resulted in a POC greater than 50%.

NIOSH will provide the Department of Labor with the list of all the claims evaluated 

under this PER. Further, NIOSH will request the return of the 3 claims that would now 

result in a probability of causation greater than 50%.