DRAFT 

OCAS-PER-009, SUBTASK 4 

REVIEW OF THREE CASES REWORKED FOR THE 

EVALUATION OF LYMPHOMAS AFFECTED BY CHANGES 

TO INTERNAL AND/OR EXTERNAL TARGET ORGANS 

Contract No. 200-2009-28555 

Revision 0 

U. Hans Behling, PhD, MPH 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182

February 2014 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted. 
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S. Cohen & Associates:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No.:

OCAS-PER-009, Subtask 4

Effective Date: 

February 4, 2014

OCAS-PER-009, SUBTASK 4

REVIEW OF THREE CASES REWORKED 

FOR THE EVALUATION OF LYMPHOMAS 

AFFECTED BY CHANGES TO INTERNAL 

AND/OR EXTERNAL TARGET ORGANS

Page 2 of 30

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD, MPH

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewers:

 John Stiver

 Kathleen Behling

Record of Revisions

Revision 

Number Effective Date Description of Revision

0 (Draft) 02/04/2014 Initial issue.
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TABLE OF CONTENTS 

1.0 Relevant Background Information ...................................................................................... 4

2.0 Review of OCAS-PER-009 Issues for Case #[A-redacted]................................................ 7

2.1 Background Information for Case #[A-redacted]................................................... 7

2.2 Comparison of NIOSH’s Original and Reworked DRs ........................................ 10

3.0 Review of OCAS-PER-009 Issues for Case #[B-redacted].............................................. 14

3.1 Background Information for Case #[B-redacted] ................................................. 14

3.2 Comparison of NIOSH Original and Reworked DRs ........................................... 14

4.0 Review of OCAS-PER-009 Issues for Case #[C-redacted].............................................. 16

4.1 Background Information for Case #[C-redacted] ................................................. 16

4.2 Comparison of NIOSH’s Original and Reworked DRs ........................................ 16

5.0 Summary Conclusions ...................................................................................................... 20

References ..................................................................................................................................... 21

Attachment A-1: Amended NIOSH Referral Summary Information .......................................... 22

Attachment A-2: DOL E-mail Correspondence .......................................................................... 23

Attachment A-3: Amended NIOSH Referral Summary Information .......................................... 24

Attachment A-4: Notice of Recommended Decision Sheet ........................................................ 25

Attachment A-5: Notice of Recommended Decision .................................................................. 28

Attachment A-6: Cover Page of Revised DR .............................................................................. 30

LIST OF TABLES 

Table 1-1. Changes and Impacts Associated with OCAS-PER-009 on 

Three Lymphoma Cases .............................................................................................. 6

Table 2-1. External Doses Assigned in Original DR for Case #[A-redacted] ............................. 10

Table 2-2. Internal Doses Assigned in Original DR for Case #[A-redacted] .............................. 11

Table 2-3. Assigned External Doses in the Revised DR ............................................................. 12

Table 2-4. Assigned Internal Doses in the Revised DR............................................................... 13

Table 3-1. Original External Doses Assigned to Case #[B-redacted] ......................................... 14
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1.0 RELEVANT BACKGROUND INFORMATION 

During the full Board conference call held on November 27, 2007, SC&A was directed to 

perform a review of Program Evaluation Report (PER) OCAS-PER-009. The purpose of a PER 

is to establish a formal process for evaluating the effects of new information on previously 

adjudicated claims that have been denied. 

As a result of ongoing internal reviews, it became apparent to NIOSH that the methods being 

used to reconstruct the doses to workers that contracted lymphoreticular neoplasms (cancer of 

the lymph nodes) required revision; revisions that could result in very large increases in the 

derived doses to the organs of concern and the possible reversal of previously denied claims. 

NIOSH’s standard procedure for deriving doses to lymph nodes had been based on the 

assumption that an upper bound on the doses to the lymph node could be derived by using the 

colon (or the highest non-metabolic organ) as a surrogate organ. 

The issuance of OCAS-TIB-012 changes the internal target organ for most forms of nonHodgkin’s lymphoma and some other forms of lymphoma (primarily in the 200–202 ICD-9 

series) from the highest non-metabolic organ (HNMO) or remainder to the thoracic lymph nodes 

(LN(TH)) or extrathoracic lymph node (LN(ET)). The calculated internal doses in these cases 

are almost invariably higher, resulting in a higher probability of causation (POC). 

In addition, the external target organ was changed from bone marrow to various other organs 

(stomach, spleen, thyroid, lung, bladder, etc.), for most forms of lymphoma, as described in 

OCAS-TIB-012. Because the organ-specific dose conversion factors (DCFs) are lower for red 

bone marrow than for most other organs, this change also results in an increase in organ dose and 

the resulting POC. 

In order to correct this problem, NIOSH implemented OCAS-PER-009, which establishes a new 

protocol for reconstructing the doses to the organ of concern for workers with cancer of the 

lymph nodes. NIOSH used this new methodology to reconstruct the doses to all workers whose 

reconstructed doses could be impacted by this new procedure and whose claims were previously 

denied. The outcome of this process was the re-evaluation of 528 claims. Of these, 152 

previously denied claims were now granted compensation, 23 claims were returned to NIOSH 

for rework, and 348 claims remained denied. 

The Advisory Board requested that SC&A review the entire process under which the 528 

lymphoma claims were reviewed. Our review process was divided into the following five 

subtasks. This report fulfills the requirement defined in Subtask 4, “Conduct audits of DRs 

affected by the PER under review. 

Subtask 1: Assess NIOSH’s evaluation/characterization of the “issue” and its potential impacts 

on DR. Our assessment intends to ensure that the “issue” was fully understood and 

characterized in the PER. 
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Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where the PER 

involves a technical issue that is supported by document(s) (e.g., white papers, technical 

information bulletins, 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/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/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 re-evaluation. 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 re-evaluation is confined to a subset of DRs that, based on their scientific 

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

Subtask 3, SC&A will also evaluate the timeliness for 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/data that 

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

function(s) 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-stated 

subtasks, along with our review conclusions. 

In summary, OCAS-PER-009 has the potential to change (1) the internal exposure from HNMO 

to either LN(TH) or LN(ET) and/or (2) the external exposure from bone marrow to various other 

organs (e.g., stomach, spleen, thyroid, lung, bladder, etc.). For many types of lymphomas, both 

the internal and external target organ changed, while for a minority of cases, only the external 

target organ changed. Thus, for selecting a minimum number of cases for audit, SC&A 

requested two cases (representing lymph nodes LN(TH) and LN(ET) along with change in the 

external target organ). Alternatively, a total of four cases would be required in the event that 

both the LN(TH) and LN(ET) lymphomas retained the original external target organ. 

On December 4, 2013, NIOSH identified and forwarded three cases to SC&A for review/audit. 

Table 1-1 summarizes changes introduced in the revised dose reconstructions of lymphomas that 

reflect the selection of internal/external target organs and their impacts on their respective POC 

values. 
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Table 1-1. Changes and Impacts Associated with OCAS-PER-009 on 

Three Lymphoma Cases 

Case No. / Lymphoma Type

Revision of Target Organs Revision of POC

Internal

From → To

External

From → To From → To

#[A-redacted]/ B-Cell lymphoma Heart wall → LN(TH) DCF of 1 → DCF of 1 19.57 % → 33.984%

#[B-redacted]/ Lymphosarcoma Heart wall → LN(TH) Remainder organs → NA* 37.51% → 94.87%

#[C-redacted]/ Hodgkin’s Lymphoma Heart wall → LN(ET) Thyroid → NA* 2.17% → 68.32%

*

 Revised DR reflects a partial dose reconstruction that was limited to internal occupational exposure to the lymph 

 node. 
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2.0 REVIEW OF OCAS-PER-009 ISSUES FOR CASE #[A-REDACTED]

2.1 BACKGROUND INFORMATION FOR CASE #[A-REDACTED]

Case #[A-redacted] represents an energy employee (EE) who worked as a [redacted] 

intermittently at the Hanford Site from [redacted] through [redacted], and [redacted] through 

[redacted]. 

In the initial dose reconstruction (DR) approved on March 8, 2005, the EE was diagnosed with 

two primary cancers: 

(1) B-cell Lymphoma Intermediate Grade Large Cell in left neck (ICD-9 code 202.81) on 

[redacted] 

(2) B-cell Lymphoma Intermediate Grade Large Cell in right tonsil (ICD-9 code 202.81) on 

[redacted] 

Less than 7 months after the first DR Report had been issued on March 8, 2005, the EE was 

diagnosed with a malignant neoplasm of the bladder on [redacted].

A revised DR Report for the EE that addressed changes in DR identified in OCAS-PER-009 was 

issued on October 1, 2007. The revised DR also derived doses for the bladder cancer that had 

not been diagnosed at the time of the original DR. Lastly, the Department of Labor (DOL) 

identified the following revised cancers to NIOSH for DR: 

(1) Malignant neoplasm, bladder (ICD-9 code 188.2) 

(2) Lymphoma, lymph node, right tonsil, left neck (ICD-9 code 202.01) 

In summary, for the revised DR, which addressed changes mandated by OCAS-PER-009, the 

DOL also changed its original position that treated (1) the B-Cell Lymphoma Intermediate Grade 

Large Cell left neck and (2) the B-cell Lymphoma Intermediate Grade Large Cell, right tonsil, as 

two separate primary cancers to a single primary lymphoma. 

Due to DOL’s decision to reclassify the two primary lymphomas as a single primary 

lymphoma (which introduced a significant change in the methodology for estimating organ dose 

and POC), SC&A reviewed DOL files in order to understand the basis for this change. 

Summarized below is a chronological citation of statements contained in DOL files with the 

changing ICD-9 codes assigned to the EE’s claim file highlighted; redacted copies of these 

documents that comply with the Privacy Act are provided in Attachments A-1 through 

Attachment A-6. 
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Summary Statements/Data Contained in Attachments 

 Attachment A-1. Amended NIOSH Referral Summary Information, dated October 8, 2002, 

identifies the following two primary cancers and their ICD-9 codes: 

(P)rimary or

(S)econdary

Cancer ICD-9 Code Date of 

Diagnosis

P B-Cell Lymphoma Intermediate 

Grade Large Cell, Right Tonsil

146 [redacted]

P B-Cell Lymphoma Intermediate 

Grade Large Cell, Left Neck

200.01 [redacted]

 This is to correct the ICD 9 code for cancer of the left neck & right tonsil. 

 Attachment A-2. DOL e-mail correspondence dated December 15 and December 16, 2004: 

 E-mail, December 15, 2004 

The NIOSH HP reviewing this claim asked if DOL would review the ICD 

code for the Tonsil lymphoma. NIOSH currently has 146 as the ICD9. 

[Emphasis added.] 

 E-mail, December 16, 2004 

. . . regarding this ICD code, I researched this and discovered the correct

ICD code should be 202.81 since it is a lymphoma of the head/neck rather 

than a cancer. [Emphasis added.] 

 Attachment A-3. Amended NIOSH Referral Summary Information dated December 20, 2004, 

listed the following cancer information for each primary cancer: 

Primary [X] or Secondary (Metastatic) [ ]

Cancer Description/Type lymphoma of the right tonsil

Associated ICD-9 Code 202.81

Date of Cancer Diagnosis [redacted]

Primary [X] or Secondary (Metastatic) [ ]

Cancer Description/Type lymphoma of the left neck

Associated ICD-9 Code 202.81

Date of Cancer Diagnosis [redacted]

 Attachment A-4. Notice of Recommended Decision Sheet dated April 11, 2005, included the 

following statements: 

. . . [the EE] submitted a medical report from [EE’s physician] dated [redacted]

indicating a diagnosis of large B-cell lymphoma. Also submitted was a pathology 

report of the right tonsil and left neck dated [redacted], which formed the basis 
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for the diagnosis of lymphoma. This medical evidence is sufficient to document 

the diagnoses of cancer under the EEOICPA. 

A copy of the case file and a National Institute for Occupational Safety and 

Health (NIOSH) Referral Summary was forwarded to NIOSH for dose 

reconstruction in February of 2002. On 3/21/2005, the Office received the 

“NIOSH Report of Dose Reconstruction under EEOICPA,” dated 3/82005, which 

provided the estimates of dose to the primary cancer sites of the right tonsil and 

left neck. 

NIOSH estimated annual doses totaling 6.765 rem (roentgen equivalent man) 

each for the left neck and right tonsil lymphomas. Based on these dose estimates, 

the calculation of probability of causation was completed using NIOSH-IREP 

(NIOSH-Interactive RadioEpidemiological Program), which is an interactive 

software program. The total probability of causation for the two primary cancers 

was determined to be 19.57 percent. [Emphasis added.] 

 Attachment A-5. Notice of Recommended Decision dated December 20, 2007, included the 

following statements regarding the revised DR that was prompted by OCAS-PER-009 (and the 

new cancer of the bladder): 

In support of the claim, the District Office received medical evidence which 

included a surgical pathology report from [redacted], dated [redacted], which 

diagnosed B cell lymphoma on [redacted]. The District Office also received 

medical evidence which included a post operative diagnosis from [redacted], 

dated [redacted], which diagnosed a bladder tumor on [redacted], and a medical 

report from [redacted] which reported a history of bladder cancer. 

On 02/07/2007, the District Office referred the file to the District Medical 

Consultant for a determination of whether the cancer reported in the neck and 

tonsil supprted a diagnosis to two primary cancers or only a single primary 

lymphoma. 

On 05/15/2007, the District Office received the report of the District Medical 

Consultant, who opined that “lesions to the tight [sic] tonsil and the the left sided 

neck mass represent one singular primary cancer, a B cell lymphoma”.

In 05/2007 a copy of the case file, along with a National Institute for 

Occupational Safety and Health (NIOSH) Referral Summary, was forwarded to 

NIOSH for dose reconstruction for lymphoma and bladder cancer. [Emphasis 

added.] 
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 Attachment A-6. Cover Page of Revised DR which Addresses OCAS-PER-009 

Concurrent with DOL’s decision to reclassify the two primary lymphomas as a singular 

primary cancer, DOL also assigned yet a third ICD-9 code of 202.01 to the tonsillar 

large B-cell lymphoma. 

Finding #1: SC&A Questions the Technical Basis/Protocol for the Assignment of and/or 

Subsequent Change(s) to ICD-9 Codes. SC&A was unable to find any of the EE’s medical 

records, which might offer an explanation for multiple changes in the assignment of ICD-9 codes 

and, more importantly, the consolidation of two primary lymphomas to one lymphoma. 

2.2 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DRs 

NIOSH approved/finalized the original DR for Case #[A-redacted] on March 3, 2005. At that 

time, the EE had only been diagnosed with two primary lymphomas (one in the left neck and 

one in the right tonsil) with each assigned the ICD-9 code 202.81. 

On [redacted], the EE was diagnosed with a malignant bladder cancer. On March 8, 2007, 

OCAS-PER-009 was issued, which determined that the internal and external dosimetry target 

organs for various forms of lymphomas had changed.

The revised DR Report for Case #[A-redacted], therefore, included dose estimates for the 

bladder cancer (which had not been included in the original DR) and reworked dose estimates in 

accordance with OCAS-PER-009 that were now limited to a single primary B-cell lymphoma. 

Due to the fact that the malignant bladder cancer in the revised DR is not affected by OCASPER-009, derived doses to the bladder are not included in this audit.

NIOSH indicated in both the original and revised DRs that the EE’s radiation doses were 

overestimated using claimant-favorable assumptions. 

2.2.1 Original DR: Summary Assumptions, Methods, and Doses for External and 

Internal Exposures 

External Doses. Estimates assigned to each of the two primary lymphomas for recorded 

dosimeter doses, missed dose, onsite ambient dose, and occupational medical dose are 

summarized in Table 2-1 below. 

Table 2-1. External Doses Assigned in Original DR for Case #[A-redacted]

External Source Dose (rem)

Lymphoma Neck Lymphoma Tonsil

Dosimeter recorded 5.870 5.870

Missed Photon 0.040 0.040

Onsite Ambient 0.637 0.637

Occupational Medical 0.108 0.108

Total 6.655 6.655
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Internal Doses. Internal dose estimates were derived for the heart wall as the HNMO for each 

of the two primary lymphomas from missed plutonium and associated radionuclides, missed 

fission products, and missed strontium. These doses are summarized in Table 2-2 below. 

Table 2-2. Internal Doses Assigned in Original DR for Case #[A-redacted]

External Source Dose (rem)

Lymphoma Neck Lymphoma Tonsil

Missed Pu and others 0.015 0.015

Missed Fission Products 0.096 0.096

Missed Sr <0.001 <0.001

Total 0.111 0.111

When internal and external doses are combined, the total dose of 6.766 rem was assigned to 

each of the two primary lymphomas, yielding a POC value of 19.57%. 

SC&A Comments/Findings/Observations for Original DR Report 

Although SC&A generally agrees with the assigned doses that pre-date the issue date of OCASPER-009, as part of the audit, SC&A compared the doses cited in Tables 2-1 and 2-2 against 

values and statements cited in the text of the DR Report and found the following discrepancies: 

(1) As a general assumption, the DR Report states: 

. . . The external dose for the neck and tonsil lymphomas was determined by 

using the dose calculated for the “”remainder organs” . . . use of the 

“remainder organs” to calculate the external dose to the neck and tonsil 

lymphomas is a claimant-favorable assumption. [Emphasis added.] 

A review of DCF values in OCAS-IG-001 for photon energies of 30–250 keV identifies 

values for “remainder organs” that are well below 1.00. In conflict with the above-cited 

statement, in a subsequent section of the DR Report, the dose reconstructor states: 

For the purpose of this dose reconstruction, the distribution of the [EE’s] 

exposure geometry and radiation energies were selected to maximize dose. . . . 

For photon radiation, a 100% 30–250 keV energy range with an organ dose 

conversion factor of 1.00 was applied. [Emphasis added.] 

(2) In behalf of missed dose, the dose reconstructor stated the following: 

. . . The total number of zero dosimeter readings assigned was 4 for photons. . . . 

this results in a maximum potential missed dose for [the EE] of 0.080 rem to the 

affected organs from photons. . . . this value was used as the 95th percentile of a 

lognormal distribution for the purpose of calculating probability of causation. 

[Emphasis added.] 

(Note: These statements imply an assigned dose of 0.020 rem for each of the four 

years for “missed dose.”)
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A review of the IREP Input tables in Attachment 1 of the DR Report (rows 14 through 17), 

however, shows missed doses of 0.010 rem with a GSD of 1.52 for the years [redacted], 

[redacted], [redacted], and [redacted].

Note: Similar parallel discrepancies between the text and values cited in the IREP Input 

tables were identified in the revised DR Report discussed below. 

Observation #1. Inconsistencies between statements/values cited in the text of the DR Report 

versus values cited in IREP Input tables of the report introduce confusion and loss of credibility 

that should be avoided. Discrepancies of this nature have been identified in other DR audits and 

reflect the tendency of dose reconstructors to make use of generic wording/phrases found in 

guidance documents and DR templates that are inappropriate for a given EE’s DR.

Finding #2: Unknown Basis for Assignment of Occupational Medical Doses. For occupational 

medical doses assigned to each lymphoma, organ doses were based on the following reference: 

Attachment E of the ORAUT-PROC-0006, External Dose Reconstruction, Rev. 00, June 27, 

2003. A review of ORAUT-PROC-0006 shows that there is no Attachment E. Thus, the basis 

for the assigned occupational medical dose is unknown. 

2.2.2 Revised DR: Summary Assumptions, Methods, and Doses Cited for External and 

Internal Exposures to the Singular Lymphoma 

As previously noted, the two primary lymphomas assessed separately in the original DR Report 

were combined and assessed as a single lymphoma in the revised DR that was prompted by 

OCAS-PER-009.

External Doses. Dose estimates for the “singular lymphoma” from external sources included: 

recorded dosimeter values, missed dose, onsite ambient, and occupational medical dose. 

Table 2-3 below cites external doses assigned to the singular lymphoma. 

Table 2-3. Assigned External Doses in the Revised DR 

External Source Single Lymphoma (rem)

Dosimeter Readings 5.870

Missed Photon 1.680

Onsite Ambient 0.636

Occupational Medical 0.261

Total 8.447

Since OCAS-PER-009 primarily impacts internal dose, and since both DRs defaulted to a DCF 

of 1.0, all external doses would have been expected to remain the same. 

Comparison of Table 2-1 to Table 2-3, however, shows that only the dosimeter readings of 

5.870 rem and onsite ambient dose of 0.636 rem remained the same, while missed photon dose 

and occupational medical dose increased from 0.040 to 1.680 rem and from 0.108 to 0.261 rem, 

respectively. 
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A questionably claimant-favorable approach was used in the revised DR to derive missed dose. 

Although the original DR identified only four recorded zero readings, the dose reconstructor in 

the revised DR elected to assign a total of 168 missed doses for a total missed photon dose of 

1.680 rem. This conflicts with the facts that (1) the EE was only intermittently onsite at the 

Hanford facility during the 14-year period; and (2) actual records identify recorded doses for all 

but four monitoring periods. 

Finding #3: Inappropriate Use of Maximizing Assumptions. While claimant-favorable/ 

maximizing assumptions are appropriate under select conditions of uncertainty or as an 

efficiency measure, neither of these conditions apply in this case. 

Internal Dose. Internal doses to the single lymphoma were based on the internal target organ 

LN(TH) from internal exposure to (1) 10-year-aged fuel-grade Pu (12%) representing Pu-238, 

Pu-239, Pu-241, and Am-241; and (2) missed fission products as given in Table 2-4. For Pu, 

solubility Type Super S was assumed. 

Table 2-4. Assigned Internal Doses in the Revised DR

Internal Source Single Lymphoma (rem)

Pu + Others 26.340

Missed FP 6.489

Total 32.829

In summary, the revised DR yielded a POC of 33.984% and reflects the following changes: 

(1) Higher internal and external doses that reflect impacts defined by OCAS-PER-009 on a 

lymphoma cancer 

(2) The diagnosis and inclusion of a bladder cancer that post-dates the original DR 

(3) A decision by DOL to combine two primary lymphoma cancers to a single lymphoma 

SC&A Comments/Findings//Observations for Revised DR Report 

For external doses, the revised DR employed dosimeter doses and environmental doses that are 

identical to the original DR, which had assumed a “claimant favorable” DCF value of 1.0. 

Under OCAS-PER-009, the external target organ for ICD-9 code 202.01 in ORAUT-OTIB-0005 

identifies thymus/lungg; footnote g further states that “. . . The external target organ should be 

lung if the lymphoma is known to be a B-cell variety. 

For full compliance with OCAS-PER-009, all external exposures (with the exception of 

occupational medical) should have been derived using the lower DCF value of the lung. 

However, due to the fact that the dose reconstructor stated the use of claimant-favorable

assumptions, this deviation will not be considered significant or a finding.

SC&A’s review of internal doses specifically impacted by OCAS-PER-009 found no 

errors/findings.
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3.0 REVIEW OF OCAS-PER-009 ISSUES FOR CASE #[B-REDACTED]

3.1 BACKGROUND INFORMATION FOR CASE #[B-REDACTED]

Case #[B-redacted] represents an EE who worked at Bridgeport Brass Company from 

[redacted] until [redacted] as a [redacted]. However, potential exposure to radiation during the 

years of uranium processing at the Bridgeport Brass facility would have been limited to the years 

1950–1962 with resultant dose calculated until the time of cancer diagnosis on [redacted]. The 

EE was diagnosed with lymphosarcoma, ICD-9 code 200.18.

No radiation monitoring records for external or internal exposure (inclusive of occupational 

medical dose) were found for the EE, and reconstruction of organ doses was based on source 

term information and claimant-favorable assumptions. 

3.2 COMPARISON OF NIOSH ORIGINAL AND REWORKED DRs 

3.2.1 Original DR 

NIOSH approved the original DR for Case #[B-redacted] on May 26, 2004, which was based on 

worst-case/claimant-favorable assumptions regarding external and internal exposure during the 

13 years of uranium processing (1950–1962) and from residual contamination for the 6 years of 

1963–1968.

External photon doses from uranium were assumed to represent energies between 30–250 keV as 

well as energies >250 keV to the lymphoma. For estimates of external dose, the external target 

organ “remainder organs” was assumed. In addition, one annual diagnostic x-ray was assumed 

for the years 1950 through 1962. Table 3-1 summarizes total external organ doses for the 

operational and post-operational periods. 

Table 3-1. Original External Doses Assigned to Case #[B-redacted]

Occupational External Doses Total Dose (rem)

 Uranium Sources (1950–1962)

 - 30–250 keV 21.704

 - >250 keV 26.527

 Contaminated Surfaces (1950-1962)

 - 30–250 keV 0.265

 - >250 keV 0.265

 Residual Contamination (1963–1968)

 - 30–250 keV 0.132

 - >250 keV 0.132

 Occupational Medical (1950–1962) 1.430

Total 50.437
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Internal Dose. Modeled assumptions for internal exposure assumed chronic inhalation and 

ingestion of uranium. For internal dose, the heart wall was selected as the highest nonmetabolic organ (HNMO). For inhalation dose, absorption Type M was assumed; and for 

ingestion, the fractional uptake of 0.02 was assumed. 

The total combined inhalation and ingestion dose for 1950 through 1972 for was 14.646 rem. 

Based on claimant-favorable dose modeling, the external organ dose of 50.437 rem and the 

internal organ dose of 14.646 rem yielded a POC value of 37.51%. 

SC&A Comments/Findings/Observations 

SC&A critically reviewed assumptions and methodologies used for the original reconstruction of 

external and internal doses assigned to the target organs assumed for the EE’s lymphosarcoma. 

In the absence of external and internal monitoring records for the EE, SC&A concludes that the 

DR consistently employed claimant-favorable assumptions/methods and there are no findings. 

However, SC&A did identify the following non-technical error/observation. 

Observation #2. On page 5 of the original DR Report, the EE is referenced by a wrong name. 

In the mind of the EE/claimant, such an oversight may be detrimental to the credibility of the DR 

and the assumed notion that a DR is uniquely tailored to a given individual’s claim.

3.2.2 Reworked DR 

Following the issuance of OCAS-PER-009 on March 8, 2007, Case #[B-redacted] was 

reworked/ approved on October 2, 2007.

Under OCAS-PER-009 and ORAUT-OTIB-0005, the internal and external target organs (for 

lymphosarcoma with ICD-9 code 200.13) were revised to lymph node thoracic (LN(TH)) and 

thyroid, respectively. 

Based on a preliminary review of assumptions and facts that defined Case #[B-redacted], 

NIOSH suspected that a complete DR may not be required and for efficiency reasons focused on 

internal occupational exposure.

The EE’s internal dose was calculated using only the inhalation intakes of natural Type S 

uranium from June 26, 1952, through June 26, 1963. For this partial internal DR, the derived 

radiation dose to the thoracic lymph node was 2,218.197 rem, yielding a POC of 94.87%. Based 

on the POC value, NIOSH considered this dose complete. 

SC&A Comments, Findings, Observations 

SC&A concurs with the efficiency approach, the assigned internal target organ for DR of the 

lymphosarcoma, and the assigned LN(TH) organ dose. There are no findings/observations.
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4.0 REVIEW OF OCAS-PER-009 ISSUES FOR CASE #[C-REDACTED]

4.1 BACKGROUND INFORMATION FOR CASE #[C-REDACTED]

Case #[C-redacted] represents an energy employee (EE) who worked at the Feed Materials 

Production Center (FMPC) from [redacted] until [redacted] as a [redacted]. The EE was 

diagnosed with lymphosarcoma on [redacted].

The EE was monitored for external radiation on a weekly dosimetry exchange cycle. For 

internal exposure, the records show a single termination urine bioassay dated March 9, 1956, 

which was evaluated for uranium.

4.2 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DRs

4.2.1 Original DR

NIOSH approved the original DR for Case #[C-redacted] on October 26, 2005, which identified 

the Hodgkins lymphoma by the ICD-9 code 201.61. In the report, the dose reconstructor stated 

that:

For the purpose of this dose reconstruction [the EE’s] radiation dose was 

overestimated using claimant-favorable assumptions. [Emphasis added.]

External Dose. For the EE’s lymphosarcoma, the external target organ was defined by the 

thyroid. A review of dosimeter records shows that positive dosimeter responses for the shallow 

dose were recorded; there were no recorded deep doses. Thus, external deep dose was defined 

for the 75 dosimeter cycles as “missed dose” for a dosimeter limit of detection (LOD) value of 

30 mrem that was further modified by (1) a 40%/60% split in photon energies and their 

respective energy-dependent thyroid DCFs and dosimeter correction factors (CFs).

Based on these assumptions and default parameters, the original DR Report states:

. . . this results in a maximum potential missed dose for [the EE] of 2.646 rem 

from penetrating photon radiation. . . . these values were used as the 95th

percentile of a lognormal distribution for the purpose of calculating probability of 

causation. [Emphasis added.]

For unmonitored neutrons, the DR Report states:

The 95th percentile neutron-to-photon ratio was applied to the measured and 

missed photon doses to determine the unmonitored neutron dose. . . . this results 

in a maximum potential missed dose for [the EE] of 1.124 rem from neutron 

radiation. [Emphasis added.]
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In addition to estimated doses associated with site operation, occupational medical doses were 

included in external dose. The following statements were cited in the text of the EE’s DR 

Report:

. . . an assumed annual X-ray procedure each year of employment, up to the date 

of diagnosis, a total X-ray dose of 0.006 rem was assigned. [Emphasis added]

Assigned organ doses from external and internal exposures in the original DR yielded a POC 

value of 2.17%.

SC&A Comments, Findings, and Observations

SC&A compared the foregoing statements in the text of the DR Report to actual doses assigned 

as given in the IREP Input tables of Attachment 1 of the DR Report. For example, the DR text 

implies that the EE was assigned a total dose of 2.646 rem from penetrating photon radiation and 

1.124 rem from neutron radiation. 

Inspection of the IREP Input table of the DR’s Attachment 1 shows that the actual assigned 

photon dose was 1.323 rem and 0.562 rem for neutrons. Thus, the assigned doses were reduced 

by a factor of two, which implies that the assigned doses were based on the LOD/2 value for the 

film dosimeter.

SC&A concludes that the wording in the text is inconsistent with the actual method used to 

derive assigned doses cited in the IREP Input tables. Moreover, the use of LOD/2 for missed 

doses represents a best-estimate approach and should not be labeled as “overestimated,” 

“claimant favorable,” or by the following summary statements on page 8 of the DR Report:

 The missed doses estimated for [the EE] are likely much larger than any doses 

that were unmonitored or unrecorded.

 Maximizing assumptions were used to convert potential whole body dose to dose 

to the lymphatic system. Had more realistic assumptions been applied, the 

estimated dose to the lymphatic system would have been smaller.

Lastly, SC&A attempted to duplicate the assigned external photon doses cited in rows #1 

through #9. Our assessment showed that the dosimeter CFs of 1.43 for 30–250 keV and 1.3 

for >250 keV photons had not been included; and since the unmonitored neutron dose was 

based on the faulty photon dose, both assigned photon and neutron doses were 

underestimated. More importantly, our review showed that the failure to include the 

dosimeter CFs may represent a systemic error that involves the Fernald Calculation 

Workbook version 1.19.

Observation #3. Wording in DR Report is Misleading. In describing external organ doses 

from photons and neutrons, the text of the original DR Report misrepresented the actual 

values assigned to the EE as cited in Attachment 1 IREP Tables of the report. For 

occupational medical dose, the yearly correct dose of 0.002 rem was, in fact, assigned for 
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employment years 1954, 1955, and 1956. However, the above-cited statement “. . . up to the 

date of diagnosis” is irrelevant and misleading since the diagnosis of the EE’s lymphoma 

occurred in [redacted], or [redacted] years post-employment.

Finding #4. Error Identified in Workbook. The cited values for external photon and neutron

doses contained an error, which appears to reflect a deficiency in the Fernald Calculational 

Workbook version 1.19. This error seems to have been corrected in the most current version 

(version 1.50) of the FEMP Workbook. However, SC&A does not know when this 

correction was made and whether other DRs that were completed using the incorrect 

workbook have been reworked.

Internal Doses. To calculate the internal organ dose for the EE’s lymphoma, the heart wall was 

used as the selected internal target organ. A single bioassay representing a termination urinalysis 

was used for estimating the internal dose from inhalation and ingestion of natural uranium. The 

total estimated dose for all years up to the date of cancer diagnosis was 0.346 rem.

4.2.2 Reworked DR

A revised DR for Case #[C-redacted] that addressed changes introduced in OCAS-PER-009 and 

ORAUT-OTIB-0005 was approved on October 26, 2005. For the reworked DR, the original 

ICD-9 code 201.61 for the EE’s Hodgkin’s lymphoma was changed to 201.01 without 

explanation. For both ICD-9 codes, the internal and external target organs, however, are 

identical and, therefore, had no impact on revised dose estimates.

Nevertheless, an explanation/justification for a change in ICD-9 code would help the audit 

process and eliminate potential questions/concerns.

Given the potential impact of OCAS-PER-009 on internal exposure for select radionuclides, the 

revised DR was limited to a partial estimate of internal exposure to a lymph node of the 

extrathoracic region (LN(ET)), as explained by the following statements:

[the EE] submitted one bioassay termination sample . . . which was greater than 

the detection limit of uranium. However, it was not necessary to evaluate the 

potential dose from this positive result. . . . The chronic intake rate was 

determined using half the minimum detection activity (MDA) for that 

radionuclide and assigned the mode excretion rates below the detection limit. . . . 

For the purposes of this dose reconstruction, it was only necessary to assign 

missed dose considering one year of uranium intake (Jan. 1, 1955 through Dec. 

31, 1955). The internal dose assigned to the lymph nodes of the extrathoracic 

region was 245.445 rem.

NIOSH’s partially derived internal dose yielded a POC of 68.32% and was, therefore, of 

sufficient magnitude to consider the DR complete.
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SC&A’s Comments/Findings/Observations

SC&A reviewed the partial DR as specified in the reworked DR Report, and the minimum 

detectable activity (MDA) value of 14 μg/l (specified in Table 5-19 of ORAUT-TKBS-0017-5). 

SC&A identified the assumed daily urine excretion value of 6.69 pCi/d and verified NIOSH’s 

IMBA-generated dose of 245.5 rem for an assumed chronic intake during the year 1955.

SC&A concludes that the efficiency process that employed a partial internal DR method was 

done correctly and compliant with OCAS-PER-009, and there are no findings.

As an interesting sideline that demonstrates the quantitative impact of OCAS-PER-009, SC&A 

compared the internal dose to the lymph node of 0.346 rem derived in the original DR to the 

internal dose that would have been derived if recorded termination bioassay data had been used 

and calculated for an inhalation period that spanned from September 15, 1954, to March 16, 

1956. For the full duration of employment (and assumed chronic internal exposure), SC&A 

derived an organ dose of 3,710 rem to the LN(ET), which is more than four orders of magnitude 

higher than the original DR internal dose estimate of 0.346 rem.
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5.0 SUMMARY CONCLUSIONS

Under SC&A’s A Protocol to Review NIOSH’s Program Evaluation Reports (PERs) (SCA-TRPR2009-0002), Subtask 4 requires the audit of a sample set of reworked DR cases that met 

criteria specified in OCAS-PER-009. In support of Subtask 4, NIOSH (instead of the Procedures 

Review Subcommittee) selected three DRs for audit in order to allow completion within SC&A’s 

contract period.

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

comparison of external and internal doses assigned in the original and revised DRs. SC&A’s 

review of the three cases identified a total of four findings and three observations, which are 

summarized below.

Findings

 Finding #1: SC&A questions the technical basis/protocol for the assignment of and/or 

subsequent changes to ICD-9 codes that included the consolidation of two primary 

lymphomas to one lymphoma.

 Finding #2: For medical occupational dose, an incorrect reference was cited for the 

assigned dose.

 Finding #3: Misuse of claimant-favorable/maximizing assumptions that may be 

appropriate under conditions of uncertainty or as an efficiency measure, but should not 

be used when neither of these conditions apply.

 Finding #4: In the Fernald Calculational Workbook, Version 1.19 (which was used in the 

reworked DR), an error was identified which was subsequently corrected in version 1.50 

of the FEMP Workbook. (Note: SC&A does not know when the correction was made 

and whether other DRs were based on the incorrect Version 1.19.)

Observations

 Observations #1 and #3: NIOSH’s use of generic boilerplate phrases/statements taken 

from guidance documents not applicable, inconsistent, and/or misleading for a specific 

EE’s DR. Note: Over the years, SC&A has repeatedly raised this concern in behalf of 

other DRs.

 Observation #2: In Case #[B-redacted], the EE is referenced by a wrong name. This 

kind of oversight is detrimental to the credibility of the DR.
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REFERENCES

OCAS-IG-001. 2002. External Dose Reconstruction Implementation Guideline, Rev. 1, 

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

Support, Cincinnati, Ohio. August 2002.

OCAS-PER-009. 2007. Target Organs for Lymphoma, Rev. 0, NIOSH’s Office of 

Compensation Analysis and Support, Cincinnati, Ohio. March 8, 2007.

OCAS-TIB-012. 2005. Selection for Internal and External Dosimetry Target Organs for 

Lymphatic/Hematopoietic Cancers, Rev. 0, NIOSH’s Office of Compensation Analysis and 

Support, Cincinnati, Ohio. August 15, 2005.

ORAUT-OTIB-0005. 2006 Internal Dosimetry Organ, External Dosimetry Organ, and IREP 

Model Selection by ICD-9 Code, Rev. 02 PC-1, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. February 10, 2005.

ORAUT-PROC-0006. 2003. External Dose Reconstruction, Rev. 00, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. June 27, 2003.

ORAUT-TKBS-0017-5. 2004. Technical Basis Document for the Fernald Environmental

Management Project (FEMP) – Occupational Internal Dose, Rev. 00, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. May 28, 2004.

SCA-TR-PR2009-0002. 2009. A Protocol to Review NIOSH’s Program Evaluation Reports 

(PERs), Rev. 1, SC&A, Inc.: Vienna, Virginia. December 1, 2009.
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ATTACHMENT A-1: AMENDED NIOSH REFERRAL 

SUMMARY INFORMATION
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ATTACHMENT A-2: DOL E-MAIL CORRESPONDENCE

[This document has been redacted in full.]
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ATTACHMENT A-3: AMENDED NIOSH REFERRAL SUMMARY 

INFORMATION
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ATTACHMENT A-4: NOTICE OF RECOMMENDED DECISION SHEET
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ATTACHMENT A-4: NOTICE OF RECOMMENDED DECISION SHEET 

(CONTINUED)
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ATTACHMENT A-4: NOTICE OF RECOMMENDED DECISION SHEET 

(CONTINUED)
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ATTACHMENT A-5: NOTICE OF RECOMMENDED DECISION
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ATTACHMENT A-5: NOTICE OF RECOMMENDED DECISION (CONTINUED)
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ATTACHMENT A-6: COVER PAGE OF REVISED DR