DRAFT 

DCAS-PER-033, SUBTASK 4 

REVIEW OF IMPACTED CASES REWORKED FOR THE 

EVALUATION OF INTERNAL INTAKES AND 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

January 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. 
Effective Date:

January 15, 2014

Revision No.

0 (Draft)

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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. 

DCAS-PER-033, Subtask 4 Review

Effective Date: 

Draft – January 15, 2014

DCAS-PER-033, SUBTASK 4 REVIEW OF 

CASES REWORKED FOR THE 

EVALUATION OF INTERNAL INTAKES 

AND SHALLOW DOSE FROM THE 

HUNTINGTON PILOT PLANT

Page 2 of 12

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) 01/15/2014 Initial issued.
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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. 

TABLE OF CONTENTS 

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

2.0 Review of DCAS-PER-033 Issue for Case #[ A – redacted] (HPP).................................. 7

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

2.2 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ................ 7

2.3 SC&A’s Review of DCAS-PER-033 Issue Related to Case #[ A – redacted]......... 8

3.0 Review of DCAS-PER-033 Issue for Case #[ B –redacted] (HPP).................................... 9

3.1 Background Information for Case #[ B –redacted]................................................... 9

3.2 Comparison of NIOSH’s Original and Reworked Dose Reconstructions ................ 9

3.3 SC&A’s Review of DCAS-PER-033 Issue Related to Case #[ B –redacted] ........ 10

4.0 Summary Conclusions ...................................................................................................... 11

5.0 References ......................................................................................................................... 12
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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 on Radiation and Worker 

Health to conduct a review of DCAS-PER-033, Huntington Pilot Plant TBD Revision (DCAS 

2011). 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. 

DCAS-PER-033 was issued to determine the number of claims impacted by the revision to the 

HPP technical basis document (TBD) of 2008, OCAS-TKBS-0004 (OCAS 2008). The revised 

TBD provided an increase in the recommended internal intakes for the periods 1956–1963 and 

1978–1979, and additional hand/forearm shallow dose recommendations.

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

of NIOSH’s program evaluation report (PER), DCAS-PER-033 (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 DCAS-PER-033 (DCAS 2011), NIOSH identified the 

following issue, for which some cases may require re-evaluation. 

Several changes in the Dose Reconstruction methodology occurred in this revision to 

the TBD. Most changes reflect a decrease in the estimated dose. However, the 

estimate of internal dose increased from 1956 through 1963 and for 1978 and 1979. 

The inhalation estimate for operators went from approximately 3.83 pCi/day 

(1400 pCi/yr) to 44 pCi/day. The original intake was the geometric mean of a 

lognormal distribution with a geometric standard deviation of 4.3. The new estimate 

is a single bounding value.

Using the following criteria as outlined in Section 3.0 of DCAS-PER-033, NIOSH identified 32 

cases that were completed before OCAS-TKBS-0004 (OCAS 2008) was released. 

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

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

August 13, 2008 

3. Employed at the Reduction Pilot Plant between 1956 and 1963 or during 1978 or 

1979 

According to DCAS-PER-033, NIOSH recalculated all the external and internal doses for all 32 

cases using the dose recommendations in OCAS-TKBS-0004 (OCAS 2008) and found that, 

while some of the probability of causation (POC) values increased and some decreased, none of 

the POCs exceeded 50%; therefore, NIOSH did not ask the Department of Labor (DOL) to return 

any of the claims for a complete DR revision. 

SC&A reviewed the potential claims on the NIOSH/DCAS Claims Tracking System (NOCTS) 

database and concurs with NIOSH’s identification of the number of cases potentially impacted 

by DCAS-PER-033. Therefore, SC&A recommended that the Advisory Board assign the 

necessary cases for SC&A’s evaluation concerning the correct implementation of DCAS-PER033.

At the November 7, 2013, PRSC meeting, the following criteria for evaluation of reworked cases 

for DCAS-PER-033 were selected: 

For PER-033, HPP, the applicable criteria for selection of cases are as follows 

(must have POC<50% and DR after 8/13/2008): 

1) A case that includes internal dose assignment during 1956–1963 and/or 

1978, and/or 1979 (these are the periods the intakes increased). 

2) A case that includes shallow dose assignment to the hands and forearms 

during the period 1956–1963 and/or 1978, and/or 1979 (there [sic] are the 

periods of additional recommendations). 
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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. 

SC&A was tasked with reviewing the applicable reworked dose evaluations. It was determined 

that SC&A’s review should be limited to evaluating only those methods and corrective actions 

introduced in the re-evaluated dose that relate strictly to issues addressed in DCAS-PER-033. 

Two relevant cases were provided to SC&A by NIOSH on December 9, 2013. Presented in 

Section 2.0 is SC&A’s focused review to determine whether the internal doses and hand/forearm 

doses associated with the two selected cases were correctly assigned per recommendations in 

DCAS-PER-033. In reviewing the two cases selected by the PRSC, SC&A found that the 

NIOSH file “PER-033 Reduction Pilot Plant.xls” dated June 5, 2013, appears to list the incorrect 

PER CLAIM ID cross reference code to the case number for Cases #[ A – redacted] and #[ B –

redacted]. Comparing the POC values from the original and reworked cases, SC&A found that 

the POC values listed in the table in Section 3.2 of DCAS-PER-033, page 2, match Case #[ A –

redacted] to Claim AE, and Case #[ B –redacted] to Claim R; whereas, the “PER-033 

Reduction Pilot Plant.xls” document lists Case #[ A – redacted] as Claim P, and Case #[ B –

redacted] as Claim AB. This did not impact the dose or POC determinations, but did create 

initial tracking issues.
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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 DCAS-PER-033 ISSUE FOR CASE #[ A – REDACTED]

(HPP) 

2.1 BACKGROUND INFORMATION FOR CASE #[ A – REDACTED]

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

[redacted]. During this worker’s employment, the EE worked as a [redacted], and, according to 

the Computer-Assisted Telephone Interview (CATI), the EE worked throughout the site on 

various equipment. The EE was diagnosed with cancer of the skin of the hand (ICD-9 Code 

172.6) in [redacted]. The EE was not monitored for external photon and electron exposures or 

internal intakes during employment; therefore, the recommendations for assigning internal 

intakes from OCAS-TKBS-0004 (ORAUT 2008) Table 5, page16, were used in this case. 

2.2 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case #[ A – redacted] in February 2004. The claim was 

reworked in June 2011 due to revisions in the TBD for HPP. 

NIOSH indicated that the original DR was an overestimate of dose. In the original DR, NIOSH 

calculated a total dose of 10.580 rem to the skin of the hand, using recommendations in 

ORAUT-TKBS-0004 (ORAUT 2004). Based on this assigned dose estimate, the DOL 

determined the POC to be 39.20% and the claim was denied. 

Using the most current TBD, OCAS-TKBS-0004 (OCAS 2008), a total dose to the skin of the 

hand of 5.058 rem was derived. Table 1 provides a comparison of the original and revised 

external and internal organ dose estimates for the skin of the hand, and POC values. It should be 

noted that the values cited in Table 1 were extracted directly from NIOSH’s IREP tables and 

files. With the exception of internal dose and shallow hand dose, SC&A has not assessed the 

accuracy/correctness of other external doses listed in Table 1, since performing such an 

assessment is beyond the scope of this Subtask 4 report. 

Table 1. Comparison of NIOSH Estimated External/Internal Dose to the Skin of the Hand 

and Resulting POC in the Original DR and from Applying DCAS-PER-033 

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

External Photon 1.258 0.393

External Electron 8.217 1.890

Medical X-ray 1.100 2.700

Internal 0.004 0.075

Total: 10.580 5.058

POC 39.2% 22.55%

As shown in Table 1, a revised hand skin dose of 5.058 rem was derived by NIOSH, with a 

resulting POC of 22.55%.
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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. 

2.3 SC&A’S REVIEW OF DCAS-PER-033 ISSUE RELATED TO CASE #[ A –

REDACTED]

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

dose, and the shallow dose to the hand, as specified by the criteria in DCAS-PER-033. Case #[A

– redacted] required the doses to be reworked, since the EE worked at HPP sometime during 

the period 1956–1963.

Original DR 

The original DR (performed in 2004) assigned internal intakes using the recommended intake 

values from Table 5, page 8, of ORAUT-TKBS-0004 (ORAUT 2004) in the chronic annual 

workbook (CADW) and entered the resulting doses in the Interactive Radioepidemiological 

Program (IREP) Input table. NIOSH also assigned a shallow dose to the hand of 0.85 rem/year 

(>15 keV electrons), as recommended on page 12 of that document. 

Reworked DR 

In the reworked dose evaluation (performed in 2011), NIOSH used the recommended internal 

intake values from Table 5, page 16, of OCAS-TKBS-0004 (OCAS 2008) in the CADW and 

entered the resulting doses in the IREP Input table. Additionally, NIOSH used the recommended 

annual 0.270 rem shallow electron dose to the hand for non-operators from Table 6, page 17, of 

OCAS-TKBS-0004. The new IREP Input table (which contained other revised doses according 

to OCAS-TKBS-0004 recommendations) was used to determine the revised POC. 

SC&A’s Evaluation

SC&A evaluated the recent dose evaluation and concurs that NIOSH used the correct intake 

values and assigned the higher dose considering the potential solubility types (Type M and 

Type S). Additionally, NIOSH correctly re-evaluated the shallow dose to the hand. The 

resulting dose values were entered correctly in the IREP Input table [along with other revised 

dose values according to OCAS-TKBS-0004 (OCAS 2008)] and used to determine the final 

POC. SC&A had no findings concerning this case in view of DCAS-PER-033.
Effective Date:

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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 REVIEW OF DCAS-PER-033 ISSUE FOR CASE #[ B – REDACTED]

(HPP) 

3.1 BACKGROUND INFORMATION FOR CASE #[ B – REDACTED]

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

[redacted]. During this worker’s employment, the EE worked as a [redacted], and, according to 

the Computer-Assisted Telephone Interview (CATI), the EE worked at various locations in the 

plant. The EE was diagnosed with Left Bronchogenic Carcinoma (ICD-9 Code 162) in 

[redacted]. The EE was not monitored for external photon and electron exposures or internal 

intakes during employment; therefore, the recommendations for assigning internal intakes from 

OCAS-TKBS-0004 (OCAS 2008) Table 5, page16, were used in this case. 

3.2 COMPARISON OF NIOSH’S ORIGINAL AND REWORKED DOSE 

RECONSTRUCTIONS 

NIOSH performed the original DR of Case #[ B – redacted] in November 2003. The claim was 

reworked in June 2011 due to revisions in the TBD for HPP. 

NIOSH indicated that the original DR was an overestimate of dose. In the original DR, NIOSH 

calculated a total dose of 5.795 rem to the lung, using recommendations in ORAUT-TKBS-0004 

(ORAUT 2003). (SC&A found that the dose entries in the original IREP Table were correct, but 

that the summation in the right column was incorrect, which led to an additional 0.055 rem being 

listed in the dose reconstruction report, i.e., 5.850 rem total dose was reported instead of the 

correct total dose of 5.795 rem. However, the IREP table and resulting POC were not impacted 

by this error.) Based on this assigned dose estimate, the DOL determined the POC to be 13.85%

and the claim was denied. 

Using the most current TBD, OCAS-TKBS-0004 (OCAS 2008), a total dose to the lung of 

20.289 rem was derived. Table 2 provides a comparison of the original and revised external and 

internal organ dose estimates for the lung and POC values. It should be noted that the values 

cited in Table 2 were extracted directly from NIOSH’s IREP tables and files. With the exception 

of internal dose, 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 2. Comparison of NIOSH Estimated External/Internal Dose to the Skin of the Hand 

and Resulting POC in the Original DR and From Applying DCAS-PER-033 

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

External Photon 1.925 0.475

Medical X-ray 1.596 1.006

Internal 2.274 18.808

Total: 5.795 20.289

POC 13.85% 21.63%

As shown in Table 2, a revised lung dose of 20.289 rem was derived by NIOSH, with a resulting 

POC of 21.63%.
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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.

3.3 SC&A’S REVIEW OF DCAS-PER-033 ISSUE RELATED TO CASE #[ B –

REDACTED]

As directed by the PRSC, SC&A’s review of Case #[ B – redacted] focused on revised internal 

dose, as specified in DCAS-PER-033. Case #[ B – redacted] required the doses to be reworked,

since the EE worked at HPP sometime during the period 1956–1963.

Original DR

The original DR (performed in 2003) assigned internal intakes using the recommended intake

values in ORAUT-TKBS-0004 (ORAUT 2003) in the CADW and entered the resulting doses 

into the IREP Input table.

Reworked DR

In the reworked dose evaluation (performed in 2011), NIOSH used the recommended internal 

intake values from Table 5, page 16, of OCAS-TKBS-0004 (OCAS 2008) in the CADW and 

entered the resulting doses in the IREP Input table. The new IREP Input table (which contained 

other revised doses according to OCAS-TKBS-0004 recommendations) was used to determine

the revised POC.

SC&A’s Evaluation

SC&A evaluated the recent dose evaluation and concurs that NIOSH used the correct intake 

values and assigned the higher dose considering the potential solubility types (Type M and 

Type S). The resulting dose values were entered correctly in the IREP Input table [along with 

other revised dose values according to OCAS-TKBS-0004 (OCAS 2008)] and used to determine 

the final POC. SC&A had no findings concerning this case in view of DCAS-PER-033.
Effective Date:

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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 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 DCAS-PER-033, there were 32 cases that met the applicable criteria.

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

cases concerning the application of DCAS-PER-033.

This current report satisfies the Subtask 4 requirement. For the two cases selected from the 

32 cases impacted by DCAS-PER-033, SC&A provided an overview of the case and a brief 

comparison of doses assigned in the original dose reconstructions and the revised dose estimates. 

Based on directives from the PRSC, SC&A’s audit of the two cases focused on those elements of 

the dose reconstructions that were affected by the issuance of DCAS-PER-033. Therefore, our 

audit determined if internal doses and hand doses were appropriate for these cases, and if so, if 

they were assigned correctly.

As discussed in Section 2, SC&A found that NIOSH did correctly derive the appropriate doses as 

recommended by DCAS-PER-033. SC&A had no findings in the two cases reviewed concerning 

the reworked doses as per DCAS-PER-033.
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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.

5.0 REFERENCES

DCAS 2011. Huntington Pilot Plant TBD Revision, DCAS-PER-033, Rev. 0, National Institute 

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

Ohio. December 9, 2011.

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

Virginia, OCAS-TKBS-0004, Rev. 00, Office of Compensation Analysis and Support, National 

Institute for Occupational Safety and Health, 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.

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., Jefferson, Maryland. 

December 2009.

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

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