DRAFT 

OCAS-PER-025, SUBTASK 4 

REVIEW OF ONE IMPACTED CASE REWORKED FOR THE 

EVALUATION OF SHALLOW DOSE FROM THE 

HUNTINGTON PILOT PLANT 

Contract No. 200-2009-28555 

Ron Buchanan 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182

December 2013 

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. 
Effective Date:

December 05, 2013

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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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-025, Subtask 4 Review

Effective Date: 

Draft – December 05, 2013

OCAS-PER-025, SUBTASK 4 REVIEW OF 

ONE CASE REWORKED FOR THE 

EVALUATION OF SHALLOW DOSE FROM 

THE HUNTINGTON PILOT PLANT

Page 2 of 10

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer:

 John Stiver

Record of Revisions

Revision 

Number Effective Date Description of Revision

0 (Draft) 12/05/2013 Initial issued.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

TABLE OF CONTENTS 

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

2.0 Review of OCAS-PER-025 Issue for Case [Redacted] (HPP)........................................... 6

2.1 Background Information for Case [Redacted].......................................................... 6

2.2 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ................ 6

2.3 SC&A’s Review of OCAS-PER-025 Issue Related to Case [Redacted].................. 7

3.0 Summary Conclusions ........................................................................................................ 9

4.0 References ......................................................................................................................... 10
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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1.0 RELEVANT BACKGROUND INFORMATION 

S. Cohen and Associates (SC&A) was tasked by the Advisory Board to conduct a review of 

OCAS-PER-025, Huntington Pilot Plant TBD Revision (OCAS 2007). The terms Huntington 

Pilot Plant and Reduction Pilot Plant are often used interchangeably; therefore, the term 

Huntington Pilot Plant (HPP) will be used in this report. OCAS-PER-025 was issued to 

determine the number of claims impacted by the revision to the HPP technical basis document 

(TBD). That revision provided an estimate of shallow dose (electron dose) that did not appear in 

the original version of the TBD. Electron dose is used primarily for skin dose estimates, but also 

for the breast and testes. 

On July 18, 2013, SC&A submitted to the Procedures Review Subcommittee (PRSC) our review 

of NIOSH’s program evaluation report (PER), OCAS-PER-025 (SC&A 2013). In conducting a 

PER review, SC&A is committed to perform five subtasks, as specified below: 

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

on Dose Reconstruction (DR). Our 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 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 third 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. 
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

This report fulfills the requirement defined in Subtask 4, “Conduct audits of DRs affected by the 

PER under review.” Under Section 2.0 of OCAS-PER-025, NIOSH identified the following set 

of criteria for identifying those claims for which shallow dose may be necessary, which in turn 

may require application of the electron dose. 

Claims in which the external target organ is skin, breast, or testes may be affected 

if they were completed prior to revision 1 of the TBD. 

Using this criterion, NIOSH identified only one case that was completed before Rev. 01 of the 

HPP TBD was released (ORAUT 2004). SC&A reviewed the potential claims on the 

NIOSH/OCAS Claims Tracking System (NOCTS) database and concurs with NIOSH’s 

identification of the case potentially impacted by OCAS-PER-025. Therefore, SC&A 

recommended that the Advisory Board assign this case for SC&A’s evaluation concerning the 

correct implementation of OCAS-PER-025. 

At the November 7, 2013, PRSC meeting, the subcommittee selected the reworked case in 

accordance with SC&A’s recommendations and tasked SC&A with reviewing the reworked DR.

It was determined that SC&A’s review should be limited to evaluating only those methods and 

corrective actions introduced in the re-evaluated DR that relate strictly to issues addressed in 

OCAS-PER-025. Presented in Section 2.0 below is SC&A’s focused review to determine 

whether the shallow doses associated with the case were correctly assigned per recommendations 

in OCAS-PER-025.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

2.0 REVIEW OF OCAS-PER-025 ISSUE FOR CASE [REDACTED]

(HPP) 

2.1 BACKGROUND INFORMATION FOR CASE [REDACTED]

Case [redacted] represents an energy employee (EE) who worked at the HPP from [redacted],

through [redacted], and [redacted], through [redacted]. During this worker’s employment, the 

EE’s job title was [redacted] and, according to the Computer-Assisted Telephone Interview 

(CATI), the EE worked throughout the site [redacted]. The EE was not monitored for external 

photon and electron exposures during employment; therefore, the recommendation for assigning

dose values from ORAUT-TKBS-0004 (ORAUT 2003), Table 6, page 17, was used in this case. 

The EE was diagnosed with l[redacted] (ICD Code [redacted]) in [redacted]. 

2.2 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case [redacted] in [redacted]. The claim was reworked 

in [redacted] due to revisions in the TBD for HPP, as well as a change in the dates of 

employment for the EE. The original employment dates were [redacted]; the later confirmed 

dates by the Department of Labor (DOL) were [redacted] and [redacted].

NIOSH indicated that the original DR was a reasonable overestimate of dose, and the revised

DR was a reasonable estimate of dose. In the original DR, NIOSH calculated a dose of 

[redacted] to the [redacted]. Based on this assigned dose estimate, the DOL determined the 

probability of causation (POC) to be [redacted] and the claim was denied. 

Using the most current technical guidance documents, a [redacted] dose of [redacted] rem was 

assigned in the revised DR. Table 1 provides a comparison of the original and revised external 

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

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

external shallow doses, SC&A has not assessed the accuracy/correctness of these doses, since 

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

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

the [redacted] in the Original and Reworked DRs 

Dose Categories Original Dose (rem) Revised Dose (rem)

External [redacted] [redacted]

Medical X-ray [redacted] [redacted]

Internal [redacted] [redacted]

Total [redacted] [redacted]

As shown in Table 1, a revised [redacted] dose of [redacted] rem was derived by NIOSH. 

According to the DOL files, the revised POC was [redacted].
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

2.3 SC&A’S REVIEW OF OCAS-PER-025 ISSUE RELATED TO CASE 

[REDACTED]

As directed by the PRSC, SC&A’s review of Case [redacted] strictly focused on revised shallow

doses, as specified in OCAS-PER-025. Case [redacted] required the DR to be reworked, since

the cancer site was the [redacted] (which could be impacted by shallow dose).

Original DR

The original DR, performed in [redacted], did not assign shallow dose, and there were no 

recommendations in Rev. 00 of the HPP TBD (ORAUT 2003) for shallow dose assignments.

Reworked DR

In the reworked DR, performed in [redacted], NIOSH did not assign shallow dose, did not 

mention shallow dose in the DR Report, and did not refer to OCAS-PER-025. SC&A 

investigated this issue, because OCAS-PER-025 (OCAS 2007), HPP TBD Rev. 01 (ORAUT 

2004, page 12), and HPP TBD, Rev. 00 (OCAS 2008, page 17) all contain recommendations for 

assigning shallow dose. Therefore, the reworked DR, being performed in [redacted], would 

have been expected to incorporate shallow dose into the reworked DR according to the revised 

TBD and OCAS-PER-025. The claimant’s file on the NOCTS database lists PER #025 at the 

top of page, and contains a letter dated [redacted], informing the claimant that the case would be 

reworked under OCAS-PER-025, and the DR was reworked in [redacted].

SC&A’s Evaluation

SC&A’s investigation indicates that, while the reworked DR Report used the EE’s job category 

of “Production Worker” (page 5 of the DR Report) for assignment of photon dose from Table 6

of the TBD, and also used “Production Worker” for internal intakes (page 6 of the DR Report), 

which included the intake values for production workers from Table 5 of the TBD, NIOSH 

apparently did not consider the EE a production worker when applying shallow dose from 

Table 6 of OCAS-TKBS-0004 (OCAS 2008, page 17), which is reproduced below as Exhibit A. 

As can be seen from this table, the DR has the choice of assigning an annual shallow dose of 

0.540 rem for Operators, 0.270 rem for other Production Workers, or none for Administrative 

Workers (the 1.000 rem to the hands and forearms would not apply in this case). Apparently, 

NIOSH did consider the EE a production worker for other exposures, but not for shallow doses.

Although NIOSH’s choice to assign dose to this EE as an [redacted] is somewhat subjective, 

SC&A found that, based on statements made on page 8 of the CATI Report, the EE was involved 

in [redacted] (the EE was not generally involved in [redacted] away from the production 

facility). Therefore, SC&A concluded that the EE would have had the potential for shallow dose 

exposures from [redacted], which prompted the following finding:

Finding #1: Since the EE had the potential for shallow dose exposure as an [redacted] in 

operations and the [redacted] was the site of the [redacted], shallow dose should have been 

assigned. The most appropriate category from Table 6 of the TBD would have been other 

Production Workers at 0.270 rem/year, >15 keV electrons, for the years 1960–1963. This dose 

would be modified by clothing and overlying tissue attenuation, which would result in a dose 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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multiplication factor of 0.3 per ORAUT-OTIB-0017 (ORAUT 2005, page 18). An example of 

the annual shallow dose to the [redacted] would be as follows:

Shallow dose = 0.270 rem × 0.3 = 0.081 rem/year

For the period 1960–1963, this would result in a total dose of 0.324 rem to be added to the 

reworked DR dose of [redacted] rem. Assigning this additional dose in the Interactive 

RadioEpidemiological Program (IREP) Input table and running the POC program results in a 

POC of [redacted].

Exhibit A: Table 6 from OCAS-TKBS-0004
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

3.0 SUMMARY CONCLUSIONS

Under SC&A’s A Protocol to Review NIOSH’s Program Evaluation Reports (PERs) (SC&A

2009), Subtask 4 requires the audit of DR case(s) reworked as a result of the PER under review. 

For OCAS-PER-025, there was only one case that met the applicable criteria. 

During the November 7, 2013, PRSC meeting, SC&A was tasked with evaluating this case 

concerning the application of OCAS-PER-025. 

This current report satisfies the Subtask 4 requirement. For the one case impacted by OCASPER-025, 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 PRSC, 

SC&A’s audit of this case focused strictly on those elements of the DR that were affected by the 

issuance of OCAS-PER-025. Therefore, our audit determined if shallow dose was appropriate 

for this case, and if so, if it was assigned correctly.

As discussed in Section 2, SC&A found that NIOSH did not assign shallow dose as 

recommended by OCAS-PER-025. Therefore, SC&A had one finding associated with the 

rework of the case selected for review by the PRSC in behalf of OCAS-PER-025. The 

correction of the error identified in this finding would have a small impact on the case and not 

affect the outcome of the compensation of the case.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

4.0 REFERENCES

OCAS 2007. Huntington Pilot Plant TBD Revision, OCAS-PER-025, Rev. 00, National Institute 

for Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. September 27, 2007.

OCAS 2008. Technical Basis Document for the Huntington Pilot Plant, Huntington, West 

Virginia, OCAS-TKBS-0004, Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. August 13, 2008.

ORAUT 2003. Technical Basis Document: Basis for Development of an Exposure Matrix for 

Huntington Pilot Plant, ORAUT-TKBS-0004, Rev. 00, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. October 31, 2003.

ORAUT 2004. Technical Basis Document: Basis for Development of an Exposure Matrix for 

Huntington Pilot Plant, ORAUT-TKBS-0004, Rev. 01, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. January 16, 2004.

ORAUT 2005. Technical Information Bulletin: Interpretation of Dosimetry Data for 

Assignment of Shallow Dose, ORAUT-OTIB-0017, Rev. 01. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. October 11, 2005.

SC&A 2009. A Protocol to Review NIOSH’s Program Evaluation Reports (PERs), SCA-TRPR2009-0002, Rev. 01. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Maryland. December 

2009.

SC&A 2013. A Review of NIOSH’s Program Evaluation Reports OCAS-PER-025 and OCASPER-033, “Huntington Pilot Plant TBD Revisions.” SCA-TR-PR2013-0082, Rev. 0. SC&A, 

Inc., Vienna, Virginia, and Saliant, Inc., Maryland. July 18, 2013.

U.S. DHHS (United States Department of Health and Human Services) 2007. External Dose 

Reconstruction Implementation Guideline, Rev. 3, Appendix B, National Institute of 

Occupational Safety and Health, 2007.