DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

DCAS-PER-053, “ALLIED CHEMICAL CORPORATION”

Contract No. 211-2014-58081 

SCA-TR-PR2015-0096, Rev. 0

Prepared by 

U. Hans Behling, PhD, MPH 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

July 2015 

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: 

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S. COHEN & ASSOCIATES: Document No. 

SCA-TR-PR2015-0096 

Technical Support for the Advisory Board on Effective Date: 

Radiation & Worker Health Review of Draft – July 7, 2015 NIOSH Dose Reconstruction Program 

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORT DCAS-PER-053, Page 2 of 16 

“ALLIED CHEMICAL CORPORATION”

Supersedes: 

Task Manager: 

N/A 

________________________ Date: ___________ 

U. Hans Behling, PhD, MPH 

Reviewer: 

Project Manager: 

 John Stiver 

________________________ Date: ___________ Kathleen Behling 

John Stiver, MS, CHP 

Record of Revisions 

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/7/2015 Initial issue
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TABLE OF CONTENTS 

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

1.0 Statement of Purpose ...........................................................................................................5

2.0 Relevant Background Information Pertaining to Facility Operations, Potential 

Source Terms and Worker Monitoring Protocols ................................................................7

2.1 Facility Operations ...................................................................................................7

2.2 Source Terms ...........................................................................................................7

2.3 Worker Monitoring at ACCP ...................................................................................7

3.0 Subtask 1: Identify the Circumstances that Necessitated the Need for 

DCAS-PER-053 ...................................................................................................................9

3.1 Chronology of Events ..............................................................................................9

3.2 SC&A’s Comments ...............................................................................................10

4.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action .............................11

4.1 An Overview of SC&A’s Previous Review of ORAUT-OTIB-0070 ...................11

4.2 Recommendations Cited in SC&A’s Draft Review of the ACCP Site 

Profile, Rev. 01 ......................................................................................................11

4.3 SC&A’s Comments ...............................................................................................12

5.0 Subtask 3: Evaluate the PER’s Stated Approach for Identifying the Number of 

DRs Requiring Re-evaluation of Dose ..............................................................................13

5.1 NIOSH’s Selection Criteria ...................................................................................13

5.2 SC&A’s Comments ...............................................................................................13

6.0 Subtask 4: Conduct Audits of a Sample Set of Re-evaluated DRs Mandated by 

DCAS-PER-053 .................................................................................................................14

7.0 References ..........................................................................................................................15
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ABBREVIATIONS AND ACRONYMS 

Advisory Board 

or Board Advisory Board on Radiation and Worker Health 

ACCP Allied Chemical Corporation Plant 

AEC U.S. Atomic Energy Commission 

DCAS Division of Compensation Analysis and Support 

DR dose reconstruction 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 

2000 

NIOSH National Institute for Occupational Safety and Health 

NRC Nuclear Regulatory Commission 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team 

PEP Program Evaluation Plan

PER Program Evaluation Report 

POC Probability of Causation 

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

SEC Special Exposure Cohort 

TIB technical information bulletin

TLD thermoluminescent dosimeter 

UF4 uranium tetrafluoride 

UF6 uranium hexafluoride 

U3O8 triuranium octoxide 
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1.0 STATEMENT OF PURPOSE 

To support dose reconstruction (DR), 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 DR may be subject to revisions, provisions exist for evaluating the 

effect of such programmatic revisions on the outcome of previously completed DRs. 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 

DRs has been proceduralized in OCAS-PR-008, Preparation of Program Evaluation Reports 

and Program Evaluation Plans (OCAS 2006), Rev. 2, dated December 6, 2006. This procedure 

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 DRs. This includes a qualitative and quantitative assessment of 

potential impacts. Most important in this assessment is the potential impact(s) on the Probability 

of Causation (POC) of previously completed DRs with POCs of <50%. 

During a teleconference by the Advisory Board’s Procedures Review Subcommittee meeting on 

April 28, 2015, SC&A was tasked by the Board to conduct reviews of two PERs. Included 

among the PERs is DCAS-PER-053, Allied Chemical Corporation (DCAS 2015). In conducting 

a PER review, SC&A is committed to perform the following five subtasks, each of which is 

discussed in this report: 

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. 

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 (TIBs), procedures] that have not yet been subjected to a formal 

SC&A review, Subtask 2 will include a review of the scientific basis and/or sources of 

information to ensure the credibility of the corrective action and its consistency with 

current/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 
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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. (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 written report that contains the results of DR audits under Subtask 4, along 

with our review conclusions. 
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2.0 RELEVANT BACKGROUND INFORMATION PERTAINING TO 

FACILITY OPERATIONS, POTENTIAL SOURCE TERMS AND 

WORKER MONITORING PROTOCOLS 

 

2.1 FACILITY OPERATIONS 

The Allied Chemical Corporation Plant (ACCP) in Metropolis, Illinois, was under contract to the 

U.S. Atomic Energy Commission (AEC) to convert uranium ore concentrations (U3O8) to 

uranium hexafluoride (UF6) from January 1, 1959, to December 31, 1976.1 ACCP processed 

about 5,000 tons per year of ore to supply UF6 feed for the Paducah Gaseous Diffusion Plant. 

After 1976, ACCP, under ownership of Honeywell and under license to the Nuclear Regulatory 

Commission (NRC), resumed ore processing to provide UF6 to gaseous diffusion plants for the 

production of UF6 used by commercial fuel fabrication facilities that are not covered by 

EEOICPA. 

Due to the fact that residual contamination that resulted from ore processing associated with 

weapons-related activities under contract to the AEC is indistinguishable from later 

contamination (produced under NRC license for the commercial sector), the residual 

contamination period for ACCP has been defined for the time period from January 1, 1977,

through March 1, 2011. 

2.2 SOURCE TERMS 

For the production of UF6, feed materials of uranium ores (or yellowcake) generally contain 70% 

to 75% uranium by mass representing U-238, U-235, and U-234. In addition, these 

concentrates included potentially significant trace quantities of radioactive impurities 

representing Th-232, Th-230, and Ra-226, depending on the mines and mills that produced the 

yellowcake. 

Based on the uranium conversion process employed at ACCP, exposure to non-uranium 

radionuclides varied during the conversion process that begins with the receipt of ores contained 

in drums. For example, radon concentrations and exposures to workers would likely have been 

elevated from the buildup and release of radon during the initial opening of the drums and from 

the continuous production and release of radon in the feed area/work areas where the radium 

containing-ore and waste streams existed. 

2.3 WORKER MONITORING AT ACCP

Internal Monitoring. During the years of UF6 production at ACCP, workers were monitored for 

uranium by means of urinalysis. Bioassays were typically performed at time of hire to establish 

a baseline, and periodically thereafter. In vitro urinalysis data by uranium fluorimetry were 

reported in micrograms uranium per liter urine, which for natural uranium is readily converted to 

corresponding activity contributions by U-238, U-235, and U-234.

1

 Records indicate that the ACCP was closed on June 30, 1964, and resumed operation in February 1968. 

 
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Based on the likely presence of non-uranium radionuclides at ACCP and the absence of 

corresponding monitoring data, NIOSH concluded that internal dose to non-uranium 

radionuclides cannot be reconstructed with sufficient accuracy for the full ACCP operational 

period 1959 through 1976. As a result, the U.S Department of Health and Human Services 

designated a class of ACCP employees for inclusion in the Special Exposure Cohort (SEC). 

External Monitoring. With some gaps in monitoring data during operational years, ACCP 

workers were generally monitored for gamma and beta exposures with film dosimeters for years 

1959 through March 1976, and by means of thermoluminescent dosimeter (TLDs) thereafter, 

which included the residual period. 

When alpha particles from the decay of uranium isotopes interact with select materials, such as 

fluorine atoms, neutrons are generated. A limited amount of neutron monitoring data exist for 

the years 1959–1969, but may not be complete or reliable for DR due to monitoring practices at 

the site. 
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3.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR DCAS-PER-053 

3.1 CHRONOLOGY OF EVENTS 

ORAUT-TKBS-0044, Rev. 00. On February 1, 2006, NIOSH issued a Site Profile for the 

ACCP, ORAUT-TKBS-0044, Rev. 00 (ORAUT 2006), which included an exposure matrix 

aimed at providing data and guidance for DR of ACCP workers. 

ORAUT-TKBS-0044, Rev. 01. In recognition of residual and variable amounts of non-uranium 

radioisotopes (i.e., Th-230 and Ra-226) that remained in the feedstock of U3O8 processed at 

ACCP, and the realization that internal doses from non-uranium radionuclides cannot be 

reconstructed with sufficient accuracy, a class of ACCP workers was added to the SEC in 2007 

(Leavitt 2007). The inability to reconstruct internal doses from non-uranium isotopes and the 

designation of the SEC class mandated Rev. 01 of ORAUT-TKBS-0044, which was issued on 

October 1, 2007 (ORAUT 2007).

SC&A’s Draft Review of ORAUT-TKBS-0044, Rev. 01. SC&A was tasked to conduct a 

technical review of Rev. 01 of ORAUT-TKBS-0044 (ORAUT 2007). In its review (SC&A 

2011), SC&A cited findings that impacted the reconstruction of worker doses. One finding that 

impacted the reconstruction of ACCP worker dose during the operational years was NIOSH’s 

model for estimating neutron exposure from the alpha/neutron reaction of UF4 and UF6. Other 

recommendations by SC&A pertained to non-uranium contaminants to which workers were 

exposed during the residual period. 

Revision to ORAUT-OTIB-0070. In Rev. 01 of the ACCP Site Profile (ORAUT 2007) issued 

on October 1, 2007, the depletion of the source term during the residual period was defined in 

Section 5.0 as follows: 

Current project guidance (ORAUT-OTIB-0004) establishes a source term depletion 

factor of 1% of the surface activity per day. Use of this 1% depletion factor is favorable 

to claimants, based on the depletion behavior reported above, however, to account for 

the observed steady-state resuspension condition, this factor is held constant after 1979. 

The factors to account for depletion of the pre-1977 source term during the residual 

period are presented in Table 5-2. [Emphasis added.] 

Table 5-2, Adjustment factors to account for depletion of pre 1977 

source term during the residual contamination period. 

Year Factor

1977 1

1978 0.03

1979-Present 0.0007

This source term depletion factor of 1% per day originally cited in ORAUT-OTIB-0004 was 

subsequently adopted in ORAUT-OTIB-0070, Rev. 00, Dose Reconstruction During Residual 
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Radioactivity Periods at Atomic Weapons Employer Facilities (ORAUT 2008), issued on March 

10, 2008.

On March 5, 2012, Rev. 01 of ORAUT-OTIB-0070 was issued (ORAUT 2012), which revised 

the source term depletion factor from 0.01 day-1 to 0.0067 day-1.

ORAUT-TKBS-0044, Rev. 02. On May 5, 2014, NIOSH issued Rev. 02 (ORAUT 2014) of the 

ACCP Site Profile. Changes that were incorporated in Rev. 02 of ORAUT-TKBS-0044, and 

with potential impacts on previously derived dose estimates, included the following:

 New guidance in Section 4.1 of the Site Profile for the assignment of external dose for 

periods when monitoring records are incomplete or missing. The recommended approach 

for gaps in dosimetry records is to use dose data of “adjacent” time periods with available 

dose data. 

 Additions to and revised isotopic ratios for non-uranium radionuclide intakes during the 

residual period as shown in Section 5.3 and Tables 5-1 and 5-3 of the Site Profile. 

3.2 SC&A’S COMMENTS 

SC&A reviewed each of the documents leading up to changes incorporated in Rev. 02 of the Site 

Profile for Allied Chemical Corporation Plant (ORAUT 2014). SC&A agrees with NIOSH 

regarding these changes and their impacts on ACCP worker doses that mandate the need for 

DCAS-PER-053 (DCAS 2015).

There are no findings pertaining to Subtask 1. 
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4.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION 

In the Publication Record of Rev. 02 of the ACCP Site Profile (ORAUT 2014), NIOSH 

acknowledged the following: 

Revision initiated to add text in Section 5.0 and to incorporate changes to 

Table 5-2 based on ORAUT-OTIB-0070, Revision 01 [ORAUT 2012]. Revised 

Sections 2.3, 2.4, 2.5, 2.7, 3.0, 3.2, 4.0, and 5.0, including Tables 5-1 and 5-3, as 

indicated pursuant to recommendations in Report-SCA-TR-SP2011-0012-PA

[SC&A 2011]. . . . [Emphasis added.] 

In brief, critical changes that were incorporated in Rev. 02 of the ACCP Site Profile (ORAUT 

2014) and the need for DCAS-PER-053 (DCAS 2015) principally reflect changes incorporated 

in Rev. 01 of ORAUT-OTIB-0070 (ORAUT 2012), and recommendations cited in SC&A’s draft 

review of Rev. 01 of the ACCP Site Profile (SC&A 2011).

In instances where the PER involves technical issues that are supported by a document(s) that

was previously subjected to a review by SC&A, Subtask 2 will simply provide a brief 

summary/conclusion of this review process. 

4.1 AN OVERVIEW OF SC&A’S PREVIOUS REVIEW OF ORAUT-OTIB-0070

SC&A reviewed Rev. 00 of ORAUT-OTIB-0070 in August 2008 (SC&A 2008). It was SC&A’s 

opinion that surrogate models/data and specific default values recommended in Rev. 00 of 

ORAUT-OTIB-0070 (ORAUT 2008) for the derivation of air concentrations were likely to 

underestimate inhalation doses. Surrogate models of concern included those identified in 

NUREG-1400 (Hickey et al. 1993) and in Attachment B of ORAUT-OTIB-0070 and assumed 

default values pertaining to the source term depletion rate of 1% per day, and to the 

resuspension of residual contamination of 1 × 10-6 m

-1

.

Rev. 01 of ORAUT-OTIB-0070 (issued on March 5, 2012) deleted the NUREG-1400 source 

term approach and Attachment B, and revised the source term depletion rate from 0.01 d-1 to 

0.0067 d-1. With the exception of the footnote in Table 5-1, the resuspension factor of 

1 × 10-6 m

-1, however, remained unchanged.

In summary, a critical change in Rev. 02 of the ACCP Site Profile (ORAUT 2014) that prompted 

the need for DCAS-PER-053 (DCAS 2015) was the revision of the source term depletion rate 

from 0.01 d-1 to 0.0067 d-1. For ACCP worker DR, the revised source term depletion rate has the 

potential to significantly increase internal and external doses during the residual period. 

4.2 RECOMMENDATIONS CITED IN SC&A’S DRAFT REVIEW OF THE ACCP 

SITE PROFILE, REV. 01 

In Section 4.0 of SC&A’s draft review issued in September 2011 (SC&A 2011), a critical 

finding that impacted the reconstruction of worker external dose during the operational period
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pertained to NIOSH’s model for estimating neutron exposures from the alpha, neutron reaction 

of UF4 and UF6. SC&A questioned (1) NIOSH’s assumed source term of a “500 pound drum,” 

(2) NIOSH’s use of ORAUT-OTIB-0024, Rev. 00 [Estimation of Neutron Dose Rates from 

Alpha-Neutron Reactions in Uranium and Thorium Compounds (ORAUT 2005)], and (3) 

NIOSH’s inappropriate use of the inverse square law involving a 500-pound source term for 

deriving neutron dose rate at a 3-foot distance. 

Section 5.1 of the SC&A draft review questioned NIOSH’s failure to include Ra-228 and other 

non-uranium radionuclide contaminants in the reconstruction of internal dose during the residual 

period. 

4.3 SC&A’S COMMENTS 

In Rev. 02 of the ACCP Site Profile (ORAUT 2014), NIOSH acknowledged the revised source 

term depletion rate defined in ORAUT-OTIB-0070, Rev. 01 (ORAUT 2012) and SC&A’s 

recommendations for modeling neutron dose during operational years and internal inhalation 

dose from non-uranium contaminants during the residual period. 

There are no findings associated with Subtask 2. 
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5.0 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DRS REQUIRING REEVALUATION OF DOSE 

5.1 NIOSH’S SELECTION CRITERIA 

Section 3.0 of DCAS-PER-053 identified the following criteria employed by NIOSH to identify 

previously completed claims requiring re-evaluation using guidance cited in Rev. 02 of ORAUTTKBS-0044 (ORAUT 2014) and mandated by DCAS-PER-053 (DCAS 2015): 

 The database for completed DRs was queried for containing the word “allied” as in the 

document title of the Site Profile for Allied Chemical Corporation Plant. This search 

identified a total of 205 claims. 

– 58 claims were removed from this list because the claims yielded POC values ≥ 50%

– 42 claims were removed from this list because the word “allied” was not associated 

with the ACCP facility. 

– 4 additional claims met the criteria for ACCP SEC status and were removed from 

further consideration 

– During this PER review process, 3 DRs had been completed using Rev. 02 of the 

ACCP Site Profile (ORAUT 2014) 

– Lastly, 2 claims were removed from further consideration, because one qualified for 

SEC status at another facility, and the other involved the claimant’s long-term 

employment at another facility that is being evaluated under a different PER 

5.2 SC&A’S COMMENTS

Selection criteria used by NIOSH for previously completed DRs that require re-evaluation under 

DCAS-PER-053 are valid. There are no findings associated with Subtask 3.
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6.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF REEVALUATED DRs MANDATED BY DCAS-PER-053

Previous sections of this report cited changes introduced in Rev. 02 of the ACCP Site Profile 

(ORAUT 2014), which impact/increase the assignment of dose during the operational period 

(e.g., NIOSH’s neutron dose model), as well as the residual period (e.g., revision of the source 

term depletion factor; addition of non-uranium radioactive contaminants). 

In order for SC&A to satisfy its commitment under Subtask 4, a single DR may be selected for 

review, provided the employment period at ACCP covers both the operational and residual 

periods. Alternatively, two DRs may be selected that represent the operational period and the 

residual period separately.
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7.0 REFERENCES 

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal

Register/Vol.67, No. 85/Thursday, May 2, 2002, p. 22314. 

DCAS 2015. Allied Chemical Corporation, Rev. 00, DCAS-PER-053, NIOSH’s Division of 

Compensation Analysis and Support, Cincinnati, Ohio. March 4, 2015.

Hickey, E.E., G.A. Stoetzel, D.G. Strom, G.R. Cicotte, C.M. Wiblin, and S.A. McGuire, 1993. 

Air Sampling in the Workplace, Final Report, NUREG-1400, U.S. Nuclear Regulatory 

Commission, Office of Nuclear Regulatory Research, Washington, DC, September. [SRDB Ref. 

ID: 20129} 

Leavitt, M. O., 2007. HHS Designation of Additional Members of the Special Exposure Cohort 

under The Energy Employees Occupational Illness Compensation Program Act of 2000, 

Designating a Class of Employees from Allied Chemical Corporation Plant, Metropolis, Illinois, 

Office of the Secretary, Washington, D.C., February 1, 2007. 

OCAS 2006. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

OCAS-PR-008, Rev. 2, NIOSH’s Office of Compensation Analysis and Support, Cincinnati, 

Ohio. December 6, 2006. 

ORAUT 2005. Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium 

and Thorium Compounds, ORAUT-OTIB-0024, Rev. 00. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. April 7, 2005.

ORAUT 2006. Site Profile for Allied Chemical Corporation Plant, ORAUT-TKBS-0044, 

Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 1, 2006. 

ORAUT 2007. Site Profile for Allied Chemical Corporation Plant, ORAUT-TKBS-0044, 

Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 1, 2007. 

ORAUT 2008. Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0070, Rev. 00. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. March 10, 2008. 

ORAUT 2012. Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0070, Rev. 01. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. March 5, 2012. 

ORAUT 2014. Site Profile for Allied Chemical Corporation Plant, ORAUT-TKBS-0044, 

Rev. 02. Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 28, 2014. 
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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.

SC&A 2008. Review of ORAUT-OTIB-0070: Dose Reconstruction during Residual

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