DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORTS 

OCAS-PER-025 AND OCAS-PER-033, “HUNTINGTON PILOT 

PLANT TBD REVISIONS”

Contract No. 200-2009-28555

SCA-TR-PR2013-0082, Rev. 0 

Prepared by 

Ron Buchanan, PhD, CHP 

SC&A, Inc. 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

July 2013 

Disclaimer

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Effective Date:

July 18, 2013

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0 – Draft

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2 of 16

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.

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No. 

SCA-TR-PR2013-0082

Effective Date: 

Draft – July 18, 2013

Revision No.

0 – Draft

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORTS OCAS-PER-025 

AND OCAS-PER-033, “HUNTINGTON 

PILOT PLANT TBD REVISIONS”

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Task Manager:

________________________ Date: ___________

Ron Buchanan, PhD, CHP 

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer(s):

 Steve Marschke

 John Stiver

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/18/2013 Initial issue
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

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

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

TABLE OF CONTENTS

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

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

2.0 Subtask 1: Assess NIOSH’s Identification of the Issues and Their Impact on DR............7

2.1 Issuance of PER-025 and PER-033 .........................................................................7

2.2 SC&A’s Assessment of The Development of PER-025 and PER-033 ...................8

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

3.1 SC&A’s Evaluation of Changes in HPP TBD.........................................................9

3.2 SC&A’s Evaluation of NIOSH’s Corrective Action Plan .....................................10

3.2.1 Conclusions................................................................................................11

4.0 Subtask 3: Evaluate the PERs’ Stated Approach for Identifying the Number of 

DRs Requiring Re-evaluation of Dose ..............................................................................12

5.0 Subtask 4: Conduct Audits of a Sample Set of DRs Affected by OCAS-PER-025 

and OCAS-PER-033 ..........................................................................................................13

6.0 Subtask 5: Prepare a Comprehensive Written Report That Contains the Results of 

the Above-Stated Subtasks, Along With Our Review Conclusions. .................................14

7.0 References..........................................................................................................................15

Attachment A: SC&A’s Previous Findings Concerning the Huntington Pilot Plant TBD...........16
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ABBREVIATIONS AND ACRONYMS

Advisory Board

 or ABRWH Advisory Board on Radiation and Worker Health

CFR Code of Federal Regulations

Ci curies

DOL Department of Labor

DR dose reconstruction

HPP Huntington Pilot Plant

keV kilo electron volt

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH/OCAS Claims Tracking System

OCAS Office of Compensation Analysis and Support

ORAUT Oak Ridge Associated Universities Team

pCi picocuries

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

TIB Technical Information Bulletin

yr year
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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.

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, technical basis documents (TBD), 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, 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%.

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.

S. Cohen and Associates (SC&A) was tasked by the Advisory Board on Radiation and Worker 

Health (Advisory Board) to conduct a review of OCAS-PER-025 “Huntington Pilot Plant TBD 

Revisions” and OCAS-PER-033 “Reduction Pilot Plant TBD Revision.” 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. In conducting a PER review, SC&A is 

committed to perform the following five subtasks (as per protocol outlined in SCA-TR-PR2009-

0002, 2009), 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. 
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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.

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 

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. Based on information 

contained in the PER (and discussed in Section 5 below), 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 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.

2.0 SUBTASK 1: ASSESS NIOSH’S IDENTIFICATION OF THE ISSUES

AND THEIR IMPACT ON DR

NIOSH has issued a TBD for the HPP, along with a number of revisions. As stated in OCASPER-025 and OCAS-PER-033, these documents have been utilized to perform DRs for claims 

from the HPP. Although many of the revisions only added annotation and attribution or 

corrected errors that did not affect the DR methods, there were a number of substantial changes 

made that could affect the outcome of a DR. In preparation of OCAS-PER-025 and OCAS-PER033, the technical changes made in the revisions of the TBD were reviewed to determine if any 

previously completed DR would result in an increased dose using the current methods. The 

review was limited to identifying any increase in assigned dose, rather than any change or an 

overall increase.

A summary of the HPP TBD (OCAS-TKBS-0004) revisions are listed below:

 10/31/2003, Rev. 00 (OCAS 2003)

 01/16/2004, Rev. 01 (OCAS 2004)

 08/12/2008, Rev. 02 (OCAS 2008)

SC&A noted that the 2008 edition of the TBD has the same revision number assigned as the 

original 2003 edition. Each page of the 2008 edition is labeled as Revision No. 00, when it 

would appear it should read Revision No. 02. SC&A will use the Rev. 02 notation in this report 

to refer to the 2008 edition to avoid confusion with 2003 edition.

2.1 ISSUANCE OF PER-025 AND PER-033

OCAS-PER-025

On September 28, 2007, NIOSH issued OCAS-PER-025, which contained the following major 

sections:

Section 1.0 – This section provides a description of the reason there is a need to consider the 

changes in the revised HPP TBD (Rev. 01 of January 16, 2004) that could potentially increase 

assigned dose to claimants whose claims had previously been processed, with a resulting POC

<50%, using an earlier version of the HPP TBD (Rev. 00 of October 31, 2003).

Section 2.0 – This section provides a summary of the issue identified by NIOSH from their

evaluation of the changes in the HPP TBD as follows:

The revision to the Huntington Pilot Plant TBD provides an estimate of shallow 

dose (electron dose) that did not appear in the original version. This dose is used 

primarily for skin dose estimates but also for breast and testes. Claims in which 

the external target organ is skin, breast, or testes may be affected if they were 

completed prior to revision 1 of the TBD. 
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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.

Section 3.0 – This section states that there was one HPP potentially impacted claim completed 

with a POC <50% prior to the issuance of the January 16, 2004, TBD revision. This section

provides a plan of corrective action to resolve the issue created by the revision by requesting that 

this claim be returned for a new dose estimate. A new DR will be completed using the latest revision 

to the HPP TBD.

OCAS-PER-033

On December 9, 2011, NIOSH issued OCAS-PER-033, which contained the following major 

sections:

Section 1.0 – This section provides a description of the reason there is a need to consider the 

changes in the revised HPP TBD (Rev. 02 of August 13, 2008) that could potentially increase 

assigned dose to claimants whose claims had previously been processed, with a resulting POC 

<50%, using an earlier version of the HPP TBD (Rev. 01 of January 16, 2004).

Section 2.0 – This section provides a summary of the issues identified by NIOSH from their 

evaluation of the changes in the HPP TBD as follows:

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. 

While the internal dose estimate increased, other exposure pathways decreased. 

Due to the nature of some of the changes, the magnitude of the effect on 

individual dose estimates will vary from claim to claim.

Section 3.0 – This section states that there were 32 HPP potentially impacted claims completed 

with a POC <50% prior to the issuance of the August 13, 2008, TBD revision. This section

provides a plan of corrective action to resolve the issues created by the revision by recalculating 

the dose for each of the 32 claims using all current DR methods, including the current version of the 

TBD. From that recalculated dose, a new POC was determined.

2.2 SC&A’S ASSESSMENT OF THE DEVELOPMENT OF PER-025 AND PER-033

SC&A’s review of the applicable HPP TBD revisions, OCAS-PER-025, and OCAS-PER-033

indicates that NIOSH properly outlined the necessary steps to re-evaluate the claims potentially 

impacted by the revisions in the TBD as proceduralized in OCAS-PR-008, Preparation of 

Program Evaluation Reports and Program Evaluation Plans, Rev. 02. 

SC&A will provide detailed analyses of their review in the following sections of this report. 
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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 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

In instances where the PER involves a technical issue that is supported by documents [e.g., white 

paper(s), TIB(s), and/or procedure(s)] that have not yet been subjected to a formal SC&A 

review, Subtask 2 will assess 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. 

3.1 SC&A’S EVALUATION OF CHANGES IN HPP TBD 

A complete formal review of all the applicable HPP TBD revisions would be out of the scope 

and time resources of SC&A’s task of evaluating OCAS-PER-025 and OCAS-PER-033, and 

would be considered a complete HPP site profile review. SC&A had performed in the past, or 

presently performed, the following evaluation/review of the HPP site profile and related 

documents:

(1) SC&A Reviewed HPP TBD in 2013 – The HPP technical document (OCAS-TKBS-0004, 

Rev. 02, August 13, 2008) was previously reviewed by SC&A in 2013. That revision of 

the TBD would contain the changes in the TBD that would be relevant to OCAS-PER025 and OCAS-PER-033. A short summary of SC&A’s evaluation of the TBD is

provided in Attachment A of this report.

(2) SC&A Current Evaluation – In conjunction with the evaluation of OCAS-PER-025 and

OCAS-PER-033, SC&A recently performed a paragraph-by-paragraph comparison of the 

following documents to determine if there were any changes in the later revisions that 

could potentially increase the assigned dose:

 01/16/2004, Rev. 01, was compared to 10/31/2003, Rev. 00

 08/12/2008, Rev. 02, was compared to 01/16/2004, Rev. 01

From this evaluation, SC&A identified the following changes that have the potential to 

increase assigned dose during dose reconstruction (DR):

Comparing Rev. 01 to Rev. 00:

Electron Skin Dose – Page 12 of Rev. 01 contains a paragraph concerning the 

assignment of electron dose to the skin. This paragraph was not contained in Rev. 00, 

and could result in an increase in assigned dose in some cases. However, this change was 

addressed in OCAS-PER-025 and was the basis for initiating OCAS-PER-025. SC&A 

evaluated OCAS-PER-025 and found it to sufficiently address this issue. SC&A had no 

findings from this comparison.
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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.

Comparing Rev. 02 to Rev. 01:

Occupational Medical Dose – The Occupational Medical Section 9.0 of Rev. 02 (page 

17) recommends using ORAUT-OTIB-0006 to assign medical x-ray doses. However, it 

is recommended in Rev. 01 to use organ doses as listed in Table 8, page 12, of the TBD. 

Comparing the recommended dose in ORAUT-OTIB-0006, Table 6-5, to Table 8 of the 

TBD Rev. 01 indicates that this change could cause an increase in dose to the skin, 

stomach, and thymus in some cases. However, if a new DR is performed as 

recommended by OCAS-PER-033 using the current TBD, this issue will be addressed. 

Shallow Dose – Table 6 of Rev. 02 (page 17) provides for lower annual deep and shallow 

dose assignments than those recommended on page 12 of Rev. 01; except Rev. 02 

recommends an annual dose of 1.000 rem shallow dose to the hands and forearms for 

Operators and Maintenance personnel, whereas only 0.85 rem per year skin dose is 

recommended in Rev. 01 (page 12), without reference to hands or forearms. This could 

result in an increase in assigned skin dose in some cases. However, if a new DR is 

performed as recommended by OCAS-PER-033 using the current TBD, this issue will be 

addressed. 

Period of Internal Intake – Table 5 of Rev. 02 (page 16) provides a summary of the 

recommended inhalation and ingestion intakes for the periods 1956–1963 and 1978–

1979. However, Rev. 01 addresses the period 1951–1963, but does not specifically 

address the period 1978–1979. Therefore, in some cases, the inclusion of the period 

1978–1979 could increase the assigned dose. However, if a new DR is performed as 

recommended by OCAS-PER-033 using the current TBD, this issue will be addressed. 

Internal Intake Values – Table 5 of Rev. 02 (page 16) provides a summary of the 

recommended inhalation and ingestion intakes for the periods 1956–1963 and 1978–

1979. The values assigned in this table were derived from an updated inhaled intake of 

44 pCi/day of total uranium. Table 5 of Rev. 01 (page 8) recommends only 3.83 pCi/day; 

therefore, in some cases, this change could increase the assigned dose. However, if a 

new DR is performed as recommended by OCAS-PER-033 using the current TBD, this 

issue will be addressed. This change was the basis for initiating OCAS-PER-033.

SC&A had no findings from these comparisons.

3.2 SC&A’S EVALUATION OF NIOSH’S CORRECTIVE ACTION PLAN

OCAS-PER-025

According to OCAS-PER-025, NIOSH will identify the claims that were completed prior to the 

issuance of Rev. 01 (January 16, 2004) of the HPP TBD, and which had a POC below 50%. 

NIOSH will then request that these claims be returned for a new dose estimate. A new DR will be 

completed using the latest revision to the HPP TBD.

SC&A evaluated the TBD changes (concerning electron dose to the skin) and concurs with NIOSH’s 

corrective action plan.
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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.

OCAS-PER-033

NIOSH will identify the claims that were completed prior to the issuance of Rev. 02 (August 13, 

2008) of the HPP TBD, and which had a POC below 50% and the worker was employed at HPP 

from 1956–1963 or 1978–1979. NIOSH will recalculate the dose for each of the claims using all 

current DR methods, including the current version of the TBD. From that recalculated dose, a 

new POC will be determined. 

SC&A evaluated the TBD changes (concerning occupational medical dose, extremity shallow 

dose, periods of internal intake, and internal intake values) and concurs with NIOSH’s corrective 

action plan.

3.2.1 Conclusions

SC&A found that OCAS-PER-025 and OCAS-PER-033 sufficiently addressed the changes in 

the HPP TBD and that the PERs recommended proper corrective actions. 
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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 SUBTASK 3: EVALUATE THE PERs’ STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DRs REQUIRING 

RE-EVALUATION OF DOSE

OCAS-PER-025

According to Section 3.0 of OCAS-PER-025, at the time OCAS-PER-025 (September 28, 2007) 

was issued, NIOSH identified one claim that was completed prior to the issuance of Rev. 01 

(January 16, 2004) of the HPP TBD, and which had a POC below 50%. NIOSH is requesting that 

this claim be returned for a new dose estimate. A new DR will be completed using the latest revision 

to the HPP TBD.

SC&A used the NIOSH/OCAS Claims Tracking System (NOCTS) database to verify that only 

one HPP claim was impacted by OCAS-PER-025, and that a new DR has been performed for 

this claim.

OCAS-PER-033

According to Section 3.0 of OCAS-PER-033, at the time OCAS-PER-033 (December 9, 2011) 

was issued, NIOSH identified 32 HPP claims that were completed prior to the issuance of 

Rev. 02 of the HPP TBD (August 13, 2008), and which had a POC below 50% and were

employed at HPP between 1956–1963 or 1978–1979. NIOSH recalculated the dose for each of the 

32 claims using all current DR methods, including the current version of the TBD. From that 

recalculated dose, new POCs were determined. The table on pages 2 and 3 of OCAS-PER-033 

summarizes the results and shows that the TBD revisions resulted in an increase in the POC for 12 of 

the 32 claims (37.5%), while the POC decreased for the remaining 62.5% of the claims. The highest 

revised POC did not exceed 50%. Therefore, NIOSH will not ask the Department of Labor (DOL) to 

return any of the previously completed Reduction Pilot Plant (or HPP) claims based on the revision 

to the TBD.

SC&A used the NOCTS database to verify that there were 32 HPP claims impacted by OCASPER-033. Using the appropriate search criteria, the NOCTS database identified 55 potential 

claims; of these 55 claims, SC&A found 14 to be duplicate claim numbers (i.e., worked at HPP 

during several different periods), 3 of the claims had previously been returned to DOL for other 

reasons, 4 of the claims had employment periods prior to 1956, and 3 of the claims had second 

DRs performed using the new 2008 TBD prior to OCAS-PER-033 being issued (55 – 14 – 3 – 4 

– 3 = 32). It is recommended that SC&A review the 32 remaining claims, as will be described in 

Section 5 of this report.
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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 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DRs

AFFECTED BY OCAS-PER-025 AND OCAS-PER-033

Selection of DRs to Audit for PER-025

Because there was only one case that was impacted by OCAS-PER-025, it is recommended that 

SC&A review this case and evaluate the recalculated and assigned doses to verify that they 

conform to the new recommendations in the revised TBD and OCAS-PER-025.

Selection of DRs to audit for PER-033

Because there was numerous (32) claims impacted by OCAS-PER-033, it is recommended that 

SC&A review this list of claims and select 5 to 10 of the claims that would most likely be 

impacted by OCAS-PER-033. SC&A will then evaluate the recalculated and assigned doses to 

verify they conform to the new recommendations in the revised TBD and OCAS-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.

6.0 SUBTASK 5: PREPARE A COMPREHENSIVE WRITTEN REPORT 

THAT CONTAINS THE RESULTS OF THE ABOVE-STATED 

SUBTASKS, ALONG WITH OUR REVIEW CONCLUSIONS. 

This report consists of SC&A’s evaluation of OCAS-PER-025 and OCAS-PER-033 (Subtasks 1, 

2, and 3). When the Advisory Board has selected the number of cases that should be reviewed, 

SC&A will review these cases (Subtask 4) using the methods previously outlined in this report, 

and will then summarize the evaluation of these selected cases and provide an additional report 

to the Advisory Board (Subtask 5).
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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.

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.

Enterline, P.E., and G.M. Marsh, 1982. Mortality among Workers in a Nickel Refinery and Alloy

Manufacturing Plant in West Virginia, Journal of the National Cancer Institute, 1982; 6:925-933.

OCAS-PR-008. 2006. Preparation of Program Evaluation Reports and Program Evaluation 

Plans, Rev. 02, NIOSH’s Office of Compensation Analysis and Support, Cincinnati, Ohio. 

December 6, 2006.

OCAS-PER-025. 2007. Huntington Pilot Plant TBD Revisions, Rev. 0, National Institute for 

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

Ohio. September 27, 2007.

OCAS-PER-033. 2011. Reduction Pilot Plant TBD Revisions, Rev. 0, National Institute for 

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

Ohio. December 9, 2011.

ORAUT-OTIB-0006. 2011. Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures, Rev. 04, Oak Ridge Associated 

Universities, Cincinnati, Ohio. June 20, 2011.

OCAS-TKBS-0004. 2003. Technical Basis Document: Basis for Development of an Exposure 

Matrix for Huntington Pilot Plant, Rev. 00, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. October 31, 2003.

OCAS-TKBS-0004. 2004. Technical Basis Document: Basis for Development of an Exposure 

Matrix for Huntington Pilot Plant, Rev. 01, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. January 16, 2004.

OCAS-TKBS-0004. 2008. Technical Basis Document for the Huntington Pilot Plant, 

Huntington, West Virginia, Rev 00. [02], Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. August 13, 2008.

SCA-TR-PR2009-0002. 2009. A Protocol to Review NIOSH’s Program Evaluation Reports 

(PERs), Rev. 01. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Maryland. December 2009.

SC&A 2013. Review of the Revised Huntington Pilot Plant Site Profile, Rev. 0, SCA-TRSP2013-0043. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. June 2013.
Effective Date:

July 18, 2013

Revision No.

0 – Draft

Document No.

SCA-TR-PR2013-0030

Page No.

16 of 16

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.

ATTACHMENT A: SC&A’S PREVIOUS FINDINGS CONCERNING THE

HUNTINGTON PILOT PLANT TBD

On June 4, 2013, SC&A issued a draft report (SC&A 2013) SCA-TR-SP2013-0043 titled,

Review of the Revised Huntington Pilot Plant Site Profile. This draft report presents SC&A’s 

evaluation of the National Institute for Occupational Safety and Health (NIOSH) Site Profile for 

the HPP, Rev. 00 [02], of August 13, 2008 (OCAS-TKBS-0004, 2008). The following is a 

summary of these findings:

Finding 1: Since the three diffusion plants (the source of the HPP nickel) had 

additional isotopes of concern, NIOSH should clearly provide the basis for only 

specifying Pu-239 and Np-237 as isotopes of concern for recycled uranium.

Finding 2: NIOSH should clearly state which uranium-specific activity was used 

in the analysis and ensure that it was used consistently throughout the analysis.

Finding 3: There is a unit conversion error in going from Table A2 column 3 

(Photons per decay 238U) to column 4 (Photons per second per Ci 238[U]).

Finding 4: The dose breakdown between 0–250 keV and >250 keV varies from 

50/50 to about 70/30, depending on the gamma spectrum.

Finding 5: Provide justification for including modern airborne nickel 

concentrations in the concentration distribution, when Enterline and Marsh 1982 

indicate that the historical concentrations were (in most cases) of greater 

magnitude.

Finding 6: Provide justification for excluding from the concentration distribution 

the airborne nickel concentration in the crushing, grinding, and handling areas 

and the area around the calciners reported by Enterline and Marsh (1982).

Finding 7: There are three typographical errors in the numerical values given in 

Section 6.2 of ORAUT-TKBS-0004, 2008. Despite the erroneous numerical 

values, the annual doses are reported correctly, thus SC&A has characterized 

them as “typographical,” rather than “numerical” errors. Nonetheless, because 

the erroneous numerical values make it difficult to understand how the annual 

doses were calculated, SC&A has identified these three typographical errors as a 

finding rather than an observation.

Most of these findings would not directly impact the issues caused by the changes in the TBD 

that were addressed in OCAS-PER-025 and OCAS-PER-033. Resolution of Findings 5 and 6 

could potentially result in an increase in intake, which could require the initialization of a new 

PER; however; the current OCAS-PER-033 correctly addresses the present TBD.