DRAFT 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

REVIEW OF NIOSH/ORAUT PROCEDURES AND METHODS 

USED FOR DOSE RECONSTRUCTION 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

DCAS-PER-038, “HOOKER ELECTROCHEMICAL TBD 

REVISION”

Contract No. 200-2009-28555 

SCA-TR-PR2013-0038, Rev. 0 

Prepared by 

W.C. Thurber 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

May 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.
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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. 

SCA-TR-PR2013-0038

Effective Date: 

Draft — May 20, 2013

Revision No. 0 – (Draft)

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORT 

DCAS-PER-038, “HOOKER 

ELECTROCHEMICAL TBD REVISION”

Page 2 of 16

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer(s):

 Hans Behling

 John Mauro
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................4

Executive Summary ....................................................................................................................5

1.0 Statement of Purpose .......................................................................................................6

2.0 Subtask 1: Identify the Circumstances that Necessitated the Need for DCAS-PER038 ..................................................................................................................................7

3.0 Subtask 2: Assess NIOSH’s Evaluation/Characterization of the Issues and Their 

Potential Impacts on Dose Reconstruction .......................................................................9

4.0 Subtask 3: Assess NIOSH’s Specific Methods for Corrective Action............................10

5.0 Subtask 4: Evaluate the PER’s Stated Approach for Identifying the Universe of 

Potentially Affected Dose Reconstructions; and Assess the Criteria by Which a 

Subset of Potentially Affected Dose Reconstructions Was Selected for Reevaluation......................................................................................................................11

6.0 Subtask 5: Conduct Audits of Dose Reconstructions Affected by OCAS-PER-038 .......13

7.0 References.....................................................................................................................14

Attachment A: Comparison of Assigned Doses and Intake Rates (Source – DCAS 2012).........15
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

DCAS Division of Compensation Analysis and Support

dpm disintegrations per minute

IREP Interactive RadioEpidemiological Program

MCNPX Monte Carlo N-Particle eXtended

mr milliroentgen

mrem millirem

NIOSH National Institute for Occupational Safety and Health

OCAS Office of Compensation Analysis and Support

ORAUT Oak Ridge Associated Universities Team

pCi picocurie

PEP Program Evaluation Plan

PER Program Evaluation Report

POC probability of causation

SC&A S. Cohen and Associates (SC&A, Inc.)

TBD Technical Basis Document
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EXECUTIVE SUMMARY

SC&A has been requested by the Advisory Board on Radiation and Worker Health (ABRWH) to 

conduct an audit of the Program Evaluation Report (PER) OCAS-PER-0038, Hooker 

Electrochemical TBD Revisions, which was prompted by revisions to Appendix AA – Hooker 

Electrochemical Company of TBD-6001. These revisions were incorporated into a stand-alone 

technical basis document (TBD), Technical Basis Document for the Hooker Electrochemical 

Company, DCAS-TKBS-0009 (DCAS 2011a). 

In OCAS-PER-038, NIOSH developed criteria to screen claims that had been reviewed prior to

the publication of DCAS-TKBS-0009 for the impact of any changes to dose reconstructions that 

would result from use of the Hooker TBD. NIOSH found that 53 claims met the screening 

criteria for re-examination. Of these, 33 claims were eliminated for various reasons, such as the 

worker had already been classified in a job that maximized doses. Probabilities of causation 

(POCs) were calculated for the remaining 20 claims and for every claim, the POC was less than 

50%. SC&A believes that the claim selection criteria in the PER properly identified the 

population of claims requiring re-examination and that the PER was being correctly implemented 

given the changes to the TBD. However, there may be a need for additional changes to the TBD 

based on SC&A’s recent review of that document. The findings from that review have not yet 

been considered by NIOSH and the appropriate ABRWH Work Group.
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1.0 STATEMENT OF PURPOSE

To support dose reconstruction, the National Institute for Occupational Safety and Health 

(NIOSH) and the Oak Ridge Associated Universities Team (ORAUT) assembled a large body of 

guidance documents, workbooks, computer codes, and tools. In recognition of the fact that all of 

these supporting elements in dose reconstruction may be subject to revisions, provisions exist for 

evaluating the effect of such programmatic changes on the outcome of previously completed 

dose reconstructions. Such revisions may be prompted by document revisions due to new 

information, misinterpretation of guidance, changes in policy, and/or programmatic 

improvements.

The process for evaluating potential impacts of programmatic changes on previously completed 

dose reconstructions has been documented in OCAS-PR-008, Preparation of Program 

Evaluation Reports and Program Evaluation Plans, Revision 2 (OCAS 2006). That document

describes the format and methodology to be employed in preparing a Program Evaluation Report 

(PER) and a Program Evaluation Plan (PEP).

A PER provides a critical evaluation of the effect(s) that a given issue/programmatic change may 

have on previously completed dose reconstructions. A PER includes a qualitative and, in some 

cases, quantitative assessment of potential impacts. Most important in this assessment is the 

potential impacts on the probability of causation (POC) of previously completed dose 

reconstructions with POCs of <50%.

As needed, a PEP may be issued that serves as a formal notification of an impending PER. The 

PEP provides a preliminary description of the issue(s) that will be addressed in the PER, and 

summarizes the likely scope of the effort required to complete the PER.

SC&A has been tasked by the Advisory Board to conduct an audit of DCAS-PER-038, Hooker 

Electrochemical TBD Revision (DCAS 2012). In conducting the PER review, SC&A is 

committed to perform five subtasks, each of which is discussed in this report.
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2.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR DCAS-PER-038

On June 15, 2006, NIOSH issued Appendix AA – Hooker Electrochemical Company (Battelle 

2007) to Battelle-TBD-6001(Battelle 2006). The purpose of Appendix AA was to describe the 

use of TBD-6001 for performing dose reconstructions for Hooker employees. 

Based on initial reviews, NIOSH determined that TBD-6001 should be cancelled and that the 

various site-specific appendices to that report would be re-issued as stand-alone TBDs. On April 

4, 2011, NIOSH issued DCAS-TKBS-0009, Technical Basis Document for Hooker 

Electrochemical Company (DCAS 2011a), replacing Appendix AA. Changes noted by NIOSH 

included:

Changes Battelle-TBD-6001 Appendix to a standalone document. Revises dose 

models to eliminate dependence on Battelle-TBD-6001. Provides more detailed 

description of dose models. Incorporate review comments.

Subsequently, on June 17, 2011, NIOSH issued Revision 1 to DCAS-TKBS-0009 with the 

following changes (DCAS 2011b):

Revision initiated to correct errors in Tables 2, 3, and 6. Renumber tables after 

Table 4. Added language on page 10 to indicate the 95th percentile of the airborne 

values was used. Corrected typographical errors on page[s] 7 and 14. 

On July 24, 2012, NIOSH issued DCAS-PER-038 to address the impacts that use of DCASTKBS-0009 Revision 0 and Revision 1 would have on previously completed dose 

reconstructions. 

It is important to note that, after the PER was issued, SC&A was requested by the ABRWH to 

review DCAS-TKBS-0009. SC&A’s review published in March 2013 identified several findings 

that have not been yet been discussed and resolved (SC&A 2013). Based on the review 

presented here, SC&A concludes that the criteria developed in the PER to select claims for 

review and the methods used to review these selected claims against TKBS-0009 are appropriate. 

However, until SC&A’s findings regarding TKBS-0009 are resolved, an open issue remains as to 

whether the claims were reviewed against a technically correct baseline. For completeness,

SC&A’s findings based on its review of DCAS-TKBS-0009 are listed below.

Finding 1. NIOSH should review the assumptions regarding the composition of 

the incoming slag and the outgoing concentrate in light of the new material 

provided in Thomas 1944.

Finding 2: NIOSH should re-examine its position that external exposures were 

based on slag input to the leaching process of 10 tons per month. It is possible 

that external exposures are understated by a factor of about 5.
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Finding 3. The basis for assuming that internal exposure from slag dust occurred 

5% of the time needs to re-examined as does the assumption that the concentrate 

contained 2% U. It appears that the exposure time is understated by about a 

factor of five and the amount of uranium in the concentrate is understated by at 

least a factor of 2.5.

Finding 4: NIOSH should review the ingestion intake to ensure that it is 

calculated in a manner consistent with calculation of the inhalation intake.

Finding 5: NIOSH should confirm that the correct units of measure are cited in 

Tables 2 and 3.

Finding 6: NIOSH should review the units of measure for the photon DCF in 

Table 4 and determine if they are correct. If the units are correct, the text needs 

to be revised to discuss exposure rates rather than dose rates.

It is apparent that some of these findings have implications regarding the doses received by 

Hooker employees.
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3.0 SUBTASK 2: ASSESS NIOSH’S 

EVALUATION/CHARACTERIZATION OF THE ISSUES AND 

THEIR POTENTIAL IMPACTS ON DOSE RECONSTRUCTION

Under Subtask 2, SC&A is to ensure that PER issue(s) is/are fully addressed and characterized in 

the PER.

Section 2.0 of PER-038 notes that no doses or intakes were higher in Revision 1 than in 

Revision 0 of TKBS-0009. (See Attachment A from TKBS-0009 included here also as 

Attachment A). Consequently, comparisons were made between Revision 1 and Appendix AA.

Inhalation intakes were marginally higher for “operators” in Appendix AA, but were lower for 

all other job categories compared to Revision 1. Inhalation intakes for the residual period were 

unchanged. Consequently, the internal dose during the residual period did not need to be 

reconsidered.

The external gamma dose was lower in Revision 1 for both the operational and residual periods.

External doses to the hands and forearms and to the skin other than the hands and forearms were 

lower in Revision 1 for the operational period but higher for the residual period.

Based on this assessment, doses that increased in Revision 1 compared to Appendix AA 

included:

 Inhalation intakes during the operational period for all job categories except “operators”

 Skin doses during the residual period for all job categories

.
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4.0 SUBTASK 3: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

In this section, we assess the methods proposed by NIOSH to address the impacts of the 

increased doses summarized in Section 3 on completed dose reconstructions. We note that 

SC&A recently completed a review of Revision 1 of TKBS-0009 (SC&A 2013). During this 

review, SC&A uncovered new material suggesting that some of the assumptions in Revision 1 of 

TKBS-0009 may require further revision.

SC&A examined all relevant changes introduced in DCAS-TKBS-0009, Revision 1 (and 

Revision 0) that gave rise to DCAS-PER-038 and observes the following:

(1) Changes introduced in DCAS-TKBS-0009 added radiation exposure for external skin 

dose during the residual period which was not considered in Appendix AA.

(2) Changes in DCAS-TKBS-0009 reduced external radiation exposure from both photons 

and electrons during the operating period because of improved modeling using MCNPX 

to calculate doses. Originally, Appendix AA had relied on empirical data from TBD6001, which was cancelled. These revisions were based on credible science or employed 

reasonable, plausible assumptions that were claimant favorable.

(3) Changes in DCAS-TKBS-0009 increased internal exposures to non-operators because 

differentiation by job category was eliminated—a simplifying, claimant-favorable 

assumption. Operator exposure was used for all job categories in the TBD.

The corrective action implemented by NIOSH was to develop criteria based on these changes to 

Appendix AA to select claims requiring review, and then to recalculate the POCs to determine if 

these changes altered the prior conclusions regarding the selected claims. SC&A agrees with the 

NIOSH corrective action approach.
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5.0 SUBTASK 4: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE UNIVERSE OF POTENTIALLY AFFECTED 

DOSE RECONSTRUCTIONS; AND ASSESS THE CRITERIA BY 

WHICH A SUBSET OF POTENTIALLY AFFECTED DOSE 

RECONSTRUCTIONS WAS SELECTED FOR RE-EVALUATION

In Section 3.0 of DCAS-PER-038 titled, “Plan for Resolution or Corrective Action,” NIOSH 

notes that two populations were considered. Criteria for the first population are: 

1. Probability of Causation (PC) less than 50% 

2. Most recent version of the dose reconstruction approved by DCAS on or prior to 

April 4, 2011 (issue date of revision 0 of the TBD. Revision 1 decreased doses 

from there). 

3. Employed at the Hooker Electrochemical between 1946 and 1976 (residual 

period). 

4. Diagnosed with a skin cancer (only the shallow dose was increased). 

NIOSH identified 14 claims that met the criteria for the first population.

Criteria for the second population are:

1. Probability of Causation (PC) less than 50% 

2. Most recent version of the dose reconstruction approved by DCAS on or prior to 

April 4, 2011 (issue date of revision 0 of the TBD. Revision 1 decreased doses 

from there). 

3. Employed at the Hooker Electrochemical between 7/11/1944 and 1/15/1946

(operational period). 

NIOSH identified 39 claims that met the criteria of the second population. Of these, 33 claims 

were based on the “plant-floor high” or operator job category. Since the inhalation intakes for 

this category were slightly higher in Appendix AA than in Revision 1 to TKBS-0009, these 

claims required no further review.

For the remaining 20 claims, NIOSH recalculated the dose using the information in Revision 1 of 

TKBS-0009, and then calculated the POC for each claim using the Interactive 

RadioEpidemiological Program (IREP). For 19 claims, the POC was less than 45%, indicating 

that no further action was required. The remaining claim had a POC between 45% and 50%. 

NIOSH procedures require that if the initial POC estimate is within that range, 30 additional runs 

of 10,000 iterations each must be made and averaged 

(http://www.cdc.gov/niosh/ocas/ocasirep.html). NIOSH determined that even with the 

augmented number of IREP runs, the POC remained below 50%. 

To summarize: Of the claims reviewed prior to the publication of DCAS-TKBS-0009 and for 

which the calculated POC was less than 50%, NIOSH identified a total of 20 claims for which 
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dose reconstructions needed to be redone. POCs for these claims were recalculated and, in every 

case, based on Revision 1 to DCAS-TKBS-0009, the POC remained below 50%. SC&A concurs 

that the selection criteria used by NIOSH do, in fact, encompass the universe of potentially 

affected dose reconstructions and that none of these dose reconstructions exceed a 50% POC

using Revision 1 of DCAS-TKBS-0009 as the basis of comparison. However, as discussed in 

Section 2, SC&A has recently reviewed TKBS-0009 and made several findings which have not 

yet been resolved. 
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6.0 SUBTASK 5: CONDUCT AUDITS OF DOSE RECONSTRUCTIONS

AFFECTED BY OCAS-PER-038

The selection and number of dose reconstructions to be audited by SC&A will be made by the 

Advisory Board. SC&A recommends that such audits be deferred until the resolution of findings

on Revision 1 of DCAS-TKBS-0009.
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7.0 REFERENCES

Battelle 2006. Site Profiles for Atomic Weapons Employers that Refine Uranium and Thorium. 

Battelle-TBD-6001. Revision F0. December 13, 2006.

Battelle 2007. Site Profiles for Atomic Weapons Employers that Refine Uranium and Thorium –

Appendix AA Hooker Electrochemical Company. Battelle-TBD-6001, Appendix AA. June 15, 

2007.

DCAS (Division of Compensation Analysis and Support) 2011a. Technical Basis Document for 

the Hooker Electrochemical Company, Rev. 0. DCAS-TKBS-0009. Division of Compensation 

Analysis and Support, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

April 4, 2011.

DCAS 2011b. Technical Basis Document for Hooker Electrochemical Company, Rev. 1. 

DCAS-TKBS-0009. Division of Compensation Analysis and Support, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. June 17, 2011.

DCAS 2012. Hooker Electrochemical TBD Revisions. Program Evaluation Report. DCASPER-038. Division of Compensation Analysis and Support, National Institute for Occupational 

Safety and Health, Cincinnati, Ohio. July 24, 2012.

OCAS 2006. Preparation of Program Evaluation Reports and Program Evaluation Plans, OCASPR-008, Revision 2, Office of Compensation Analysis and Support, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. December 6, 2006.

SC&A 2013. Review of the NIOSH Technical Basis Document for the Hooker Electrochemical 

Company, DCAS-TKBS-0009. SCA-TR-SP2013-0034, Rev. 0. SC&A, Inc., Vienna, Virginia. 

March 2013.

Thomas, W.G., 1944. Technical Report – Concentration of C-2 Slag. M-4562. OSTI Identifier 

4337668. http://www.osti.gov/energycitations/servlets/purl/4337668.
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ATTACHMENT A: COMPARISON OF ASSIGNED DOSES AND INTAKE 

RATES (SOURCE – DCAS 2012)

The “Plant Floor High” job category in Appendix AA is equivalent to the “Operator” job 

category in the TBD. The “Plant Floor Low” job category in Appendix AA is equivalent to the 

“Laborer” job category in the TBD.

Inhalation Intakes

App. AA Rev. 0 Rev. 1

Operational – Operator 343 dpm/day 340 dpm/day 340 dpm/day

Operational – Laborer 172 dpm/day 340 dpm/day 340 dpm/day

Operational – Supervisor 85.8 dpm/day 340 dpm/day 340 dpm/day

Operational – Clerical 8.58 dpm/day 340 dpm/day 340 dpm/day

Residual – All 2.2 dpm/day 2.2 dpm/day 2.2 dpm/day

 Ingestion intakes are proportional to the inhalation intakes in each revision 

 Appendix AA inhalation rates converted from pCi/day to dpm/day 

External Gamma

App. AA (mr/year) Rev. 0 (mr/year) Rev. 1 (mr/year)

Operational – Operator 147 14.755 1.885

Operational – Laborer 73.4 0.455 0.455

Operational – Supervisor 36.9 0.228 0.228

Operational – Clerical 3.69 0.0228 0.0228

Residual – Operator 137 0.455 0.455

Residual – Laborer 68.6 0.455 0.455

Residual – Supervisor 34.3 0.228 0.228

Residual – Clerical 3.43 0.0228 0.0228

 Appendix AA values converted from mr/day to mr/year 

External skin (other than hands and forearms)

App. AA (mrem/year) Rev. 0 (mrem/year) Rev. 1 (mrem/year)

Operational – Operator 358 334.5 69.9

Operational – Laborer 179 40.5 40.5

Operational – Supervisor 87.6 20.3 20.3

Operational – Clerical 7.3 2.03 2.03

Residual – Operator 0 40.5 40.5

Residual – Laborer 0 40.5 40.5

Residual – Supervisor 0 20.3 20.3

Residual – Clerical 0 2.03 2.03

 Appendix AA values converted from mrem/day to mrem/year 
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External skin (hands and forearms)

App. AA (mrem/year) Rev. 0 (mrem/year) Rev. 1 (mrem/year)

Operational – Operator 4,015 1,310.5 167.5

Operational – Laborer 2,007 40.5 40.5

Operational – Supervisor 986 20.3 20.3

Operational – Clerical 110 2.03 2.03

Residual – Operator 0 40.5 40.5

Residual – Laborer 0 40.5 40.5

Residual – Supervisor 0 20.3 20.3

Residual – Clerical 0 2.03 2.03

Appendix AA values converted from mrem/day to mrem/year