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-052, “WESTINGHOUSE NUCLEAR FUELS 

DIVISION”

Contract No. 211-2014-58081

SCA-TR-PR2014-0094, Rev. 0 

Prepared by 

U. Hans Behling, PhD, MPH 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

October 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. 

SCA-TR-PR2014-0094

Effective Date: 

Draft – October 06, 2014

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORT DCAS-PER-052, 

“WESTINGHOUSE NUCLEAR FUELS 

DIVISION”

Page 2 of 15

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD, MPH 

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) 10/06/2014 Initial issue
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TABLE OF CONTENTS 

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

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

2.0 Relevant Background Information .......................................................................................7

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

DCAS-PER-052 ...................................................................................................................8

4.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ...............................9

4.1 An Overview of the Westinghouse Facility’s “Old Template” ...............................9

4.2 An Overview of the Westinghouse Facility’s “New Template” ............................10

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

Potentially Affected DRs ...................................................................................................13

6.0 Subtask 4: Conduct Audits of a Sample Set of DRs Affected by DCAS-PER-052 .........14

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

Advisory Board 

or Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

d day 

DCAS Division of Compensation Analysis and Support 

DR dose reconstruction 

DCF dose conversion factor

dpm/m3

disintegration per minute per cubic meter 

DR dose reconstruction 

EE Energy Employee 

EEOICPA Energy Employees Occupational Illness Program Act of 2000 

GM geometric mean 

GSD geometric standard deviation

NIOSH National Institute for Occupational Safety and Health 

OCAS Office of Compensation Analysis and Support (now DCAS) 

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.) 

SRDB Site Research Database 

TBD technical basis document 

TIB technical information bulletin
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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) have 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), Revision 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 

August 28, 2014, SC&A was tasked by the Board to conduct reviews of two PERs. Included 

among the PERs is DCAS-PER-052, Westinghouse Nuclear Fuels Division (DCAS 2014). 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 impact(s) 

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 

For the years 1971 and 1972, the Westinghouse Nuclear Fuels Division received nuclear 

materials of enriched uranium from the Atomic Energy Commission’s (AEC’s) Fernald plant and 

a shipment of plutonium from the West Valley facility, which had originally come from the 

Hanford facility. Records suggest that the plutonium also included thorium, and both 

radionuclides were used at the Westinghouse facility for experimentation and in the manufacture 

of mixed oxide fuels. 

Although the Westinghouse facility was actively engaged in work with other radioactive 

materials in other years that post-date 1972, these activities were not related to nuclear weapons 

production and are, therefore, not covered under the Energy Employees Occupational Illness 

Program Act of 2000 (EEOICPA). 

For DR, facility operations at Westinghouse are confined to the years 1971 and 1972, along with 

the residual period for years 1973 through 1979. 
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3.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR DCAS-PER-052

Perhaps for the reason that the Westinghouse facility’s AEC operations were limited to two 

years, no Technical Basis Document (TBD) was developed for this site. In lieu of a Site Profile 

for guidance in DR, NIOSH had developed a “template” that provided a limited overview of 

facility operations, radiological source terms, and personnel monitoring practices. 

The original template also referenced a total of 3,093 air samples taken routinely around facility 

process areas and the stack. These air samples were regarded as general area air samples and 

reported as gross total alpha activity in dpm/m3of air; a lognormal distribution was developed, 

which identified the 95% value, the geometric mean (GM) value, and the geometric standard 

deviation (GSD) for use in assigning intakes to unmonitored workers. 

Subsequently, a substantial number of air samples were discovered that raised the total number 

to 12,694. When analyzed, the expanded air sample data significantly raised calculated intakes 

over previous estimates. 

The original template for the Westinghouse Nuclear Fuels Division site was updated with 

higher estimates of inhalation and ingestion uptakes on June 8, 2012; and on March 25, 2014, 

NIOSH issued DCAS-PER-052 in order to address potential impacts of the revised template on 

previously completed DRs.

SC&A’s Comments 

Among programmatic revision that may impact the outcome of previously completed DRs and 

the need for a Programmatic Evaluation Report (PER), none is more justifiable than the 

discovery of new information/data that significantly raises estimates of radiation exposure/dose. 

Based on the acquisition of new data, SC&A concurs with the issuance of DCAS-PER-052, and 

there are no findings.
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4.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION 

In instances where the PER involves a technical issue that is supported by a document that has 

been formalized, Subtask 2 will provide a brief summary.

4.1 AN OVERVIEW OF THE WESTINGHOUSE FACILITY’S “OLD TEMPLATE”

Prior to June 8, 2012, the air monitoring results of 3,093 general air samples of gross alpha 

activity were used to define a lognormal distribution of daily inhalation and ingestion values that 

were based on a breathing rate of 9.6 m3

per day and for 250 working-days per year during the 

operational years 1971 and 1972. Airborne activities (and estimates of intakes) during the 

residual period were reduced in accordance with ORAUT-OTIB-0070 (ORAUT 2012). Table 1 

identifies daily intakes of alpha-emitting radionuclides through inhalation and ingestion. 

Table 1. Recommended Intakes Defined Under “Old Template”

Year

OTIB-0070 

Adjustment 

Factor

Inhalation Intake (dpm/d) Ingestion Intake (dpm/d)

Geometric 

Mean GSD* 95thPercentile

Geometric 

Mean

95th

Percentile

1971–1973 1 9.122 4.638 40.938 1.824 8.188

1974 0.03 0.274 4.638 1.228 0.055 0.246

1975–1979 0.007 0.064 4.638 0.287 0.013 0.057

In support of data provided in Table 1, the “Old Template” contained the following guidance for 

the assignment of either the 95th percentile values or the geometric mean: 

Partially-monitored workers (i.e., those who have bioassays for uranium and/or 

plutonium) should be assigned unmonitored exposure for those radionuclides 

(uranium, plutonium, or natural thorium) for which the workers were 

unmonitored, based on the 95th percentile intake rate minus any missed dose 

calculated from the bioassay data. Since these results are based on gross alpha 

results, any intakes accounted [sic] from bioassay data would also be accounted 

for in a gross alpha result. 

For completely unmonitored workers, unmonitored exposures should be based 

on the geometric mean intake rate and assigned as uranium, plutonium, or 

natural thorium, based on whichever nuclide provides the most claimantfavorable result. [Emphasis added.] 

SC&A’s Comments

Under the “Old Template,” a distinction was made that the 95th percentile was to be used only 

for those workers with a documented history with some bioassay monitoring. Even a limited 

history of bioassay monitoring would support the assumption of potential exposure to airborne 

environments. Conversely, in the complete absence of documented bioassay data, potential 

exposures to airborne contaminants may justifiably assume lower exposure potential, along with 

the recommended assignment of the GM and GSD values. 
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4.2 AN OVERVIEW OF THE WESTINGHOUSE FACILITY’S “NEW TEMPLATE”

With the discovery of 9,601 additional air samples that brought the total to 12,694 samples, a 

revised distribution of gross alpha air concentrations was developed. From these data, the 

following new inhalation and ingestion intakes were derived at the 95th percentile for Operators 

and General Labors; Supervisors are assumed to be 50% of the Operator/General Labors 

exposure; and All Other Workers are assumed to be 10% of the Supervisor’s exposures. 

Tables 2a, 2b, and 2c identify revised intake values for the three classifications of workers. 

Tables 2a, 2b, and 2c. Recommended Intakes Based on Worker Classification under the 

Revised New Template 

Table 2a. Intakes for Unmonitored Operators and General Labor

Year OTIB-0070 Adjustment 

Factor

Inhalation Intake 

(dpm/d)

Ingestion Intake 

(dpm/d)

1971–1972 1.000 965.121 19.302

1973 1.000 965.121 19.302

1974 0.783 965.121 19.302

1975 0.613 755.690 15.114

1976 0.480 591.619 11.832

1977 0.376 463.258 9.265

1978 0.294 362.886 7.258

1979 0.231 283.746 5.675

Table 2b. Intakes for Unmonitored Supervisors

Year OTIB-0070 Adjustment 

Factor

Inhalation Intake 

(dpm/d)

Ingestion Intake 

(dpm/d)

1971–1972 1.000 482.561 9.651

1973 1.000 482.561 9.651

1974 0.783 482.561 9.651

1975 0.613 377.845 7.557

1976 0.480 295.810 5.916

1977 0.376 231.629 4.633

1978 0.294 181.443 3.629

1979 0.231 141.873 2.837

Table 2c. Intakes for Unmonitored “Other” Workers

Year OTIB-0070 Adjustment 

Factor

Inhalation Intake 

(dpm/d)

Ingestion Intake 

(dpm/d)

1971 - 1972 1.000 48.256 0.965

1973 1.000 48.256 0.965

1974 0.783 48.256 0.965

1975 0.613 37.785 0.756

1976 0.480 29.581 0.592

1977 0.376 23.163 0.463

1978 0.294 18.144 0.363

1979 0.231 14.187 0.284

In support of Tables 2a, 2b, and 2c, the Revised Template provides the following additional 

guidance for assigning doses to each of the three worker classifications: 
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Intake ratios between the classifications of workers are based on the guidance 

found in the Technical Basis Document: Site Profiles for Atomic Weapons 

Employers That Worked Uranium Metals (SRDB Ref ID 101251) [Battelle 2011] . 

. . .

During the operational period (1971–1972), partially-monitored workers, those 

who have bioassays for uranium and/or plutonium, should be assigned 

unmonitored exposure in excess of any missed dose calculated from the bioassay 

data, i.e. subtracting missed intake activity from the 95th percentile intake activity 

described in the tables above, and assigning the remainder as either uranium, 

plutonium, or natural thorium (excluding the ones accounted for via bioassay), 

based on which nuclide provides the most claimant favorable result. 

For completely unmonitored workers, unmonitored exposures should be based 

on the geometric mean intake rate and assigned as either uranium, plutonium, or 

natural thorium, based on which nuclide provides the most claimant[-]favorable 

result. 

During the residual period (1973–1979), intakes should be based on the tables 

above. These should be assessed as either uranium, plutonium, or natural 

thorium, based on which nuclide provides the most claimant[-]favorable result. 

These intakes should be limited by the worker’s bioassay data if they would result 

in higher excretions then detected. [Emphasis added.] 

SC&A’s Comments and Findings

Under the Revised Template, exposure potential was based on worker classification, which 

reduced the intake values of the “Unmonitored Other Workers” to 48.256 dpm/d or onetwentieth of the 965.121 dpm/d assigned to the highest exposed workers (i.e., Operators and 

Labor). Conceptually, it would appear that a secondary adjustment that considers the “partial 

existence” or the “complete absence” of bioassay data is redundant. 

Furthermore, the recommendation that “. . . For completely unmonitored workers, unmonitored 

exposures should be based on the geometric mean intake rate . . .” [emphasis added] is, in fact, 

not possible, since Tables 2a, 2b, and 2c do not provide the GM and GSD for the newly acquired 

air sample dataset of 12,694 air samples. 

Lastly, NIOSH’s assignment of “unmonitored” internal dose based on “worker classification” 

may be of limited relevance/credibility. Perhaps a more reliable indicator of potential internal 

exposure is a quantitative evaluation of the worker’s external exposure records on the reasonable 

assumption that a quantitative relationship between internal and external exposures exists. 

Finding 1. Guidance for adjusting intakes based on “partially monitored” versus “completely 

unmonitored” status of a worker not only appears redundant, but more importantly, this 

distinction cannot be made with available data provided in the revised Westinghouse template. 
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The assessment of internal dose also requires that the dose reconstructor evaluate exposures to all 

three potential sources of alpha-emitting radionuclides representing (1) 2% enriched recycled 

uranium, (2) 12% 10-year-old fuel-grade plutonium, and (3) natural thorium, and select the one 

with the most claimant-favorable result. To do so requires the use of radionuclide ratios among 

those with alpha emissions. For the 12% 10-year-old fuel-grade plutonium mixture, NIOSH 

provided the following table:

Radionuclide 12% 10-year-old Fuel-Grade Plutonium Ratios

Pu-238:Alpha 0.117

Pu-239:Alpha 0.593

Pu-241:Alpha 14.201

Am-241:Alpha 0.289

The fractional contributors of alpha emitters include Pu-238 at 0.117, Pu-239 at 0.593, and 

Am-241 at 0.289, for a total of 1.0. The table identifies Pu-241 as an alpha emitter, which is 

incorrect. Thus, the assignment of a daily intake of alpha emitters defined in Tables 2a, 2b, and 

2c must be proportionately divided among Pu-238, Pu-239, and Am-241, and separate internal 

exposures must be evaluated for Pu-241, which has a half-life of 13.2 years and decays to 

Am-241, an alpha emitter.

Finding 2. The designation of Pu-241 as an alpha emitter is incorrect.
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5.0 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE UNIVERSE OF POTENTIALLY AFFECTED 

DRs

Under Section 3.0 of DCAS-PER-052, NIOSH’s plan for resolution or corrective actions 

included the following steps and criteria:

(1) Given the issue date of the revised template for the Westinghouse facility on June 8, 2012, 

NIOSH assessed the number of claims that had been completed after June 8, 2012, to 

ensure that the revised template had been used. None were found.

(2) NIOSH reviewed DRs that were completed prior to June 8, 2012, under the original 

template. A total of 68 claims were completed prior to June 8, 2012, with POC values less 

than 50%.

(3) Using data and guidance contained in the revised template issued on June 8, 2012, NIOSH 

recalculated the doses for all 68 claims.

(4) The re-evaluation of the 68 claims yielded (a) 17 claims with a revised POC greater than 

50%, (b) one claim with a POC between 45% and 50%, which upon further evaluation, 

nevertheless, remained below 50%, and (c) 50 claims with revised POCs below 45%.

SC&A’s Comments

Selection criteria for the re-evaluation of DRs potentially impacted by DCAS-PER-052 were 

correctly based on the issue date of the revised Westinghouse facility’s template on June 8, 2012,

along with the standard required POC values of <50%.

Under Subtask 3, there were no findings.
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6.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DRs

AFFECTED BY DCAS-PER-052

The re-evaluation for internal exposure of DRs performed under the original template required 

the need to assign the energy employee (EE) to one of three worker classifications under the 

revised template; and depending on the resolution of Finding 1, workers may have further been 

defined as partially monitored or completely unmonitored.

Thus, depending upon the resolution of Finding 1, SC&A recommends the selection of either 3 

or 6 cases from among the 51 re-evaluated DRs with POCs less than 50%:

 Three DRs, if all 51 re-evaluated DRs were assigned intakes defined for “partially 

monitored” workers.

 Six DRs, if re-evaluated DRs involved workers representing both partially monitored 

workers and completely unmonitored workers whose intakes were reduced by the use of

GM and GSD values that were not cited in the new template.
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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.

Battelle 2011. Technical Basis Document: Site Profiles for Atomic Weapons Employers That 

Worked Uranium Metals, Rev. 1, Battelle Memorial Institute. June 17, 2011, SRDB Reference 

ID 101251.

DCAS 2014. Westinghouse Nuclear Fuels Division, Rev. 0, DCAS-PER-052, NIOSH’s 

Division of Compensation Analysis and Support, Cincinnati, Ohio. March 25, 2014.

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 2012. Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

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

Cincinnati, Ohio. March 5, 2012.