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-093, “Texas City Chemicals, TBD Rev. 01” 

Contract No. 75D30119C04183

Document No. SCA-TR-2022-PER093, Revision 0

Prepared by

Rose Gogliotti, MS

SC&A, Inc.

2200 Wilson Blvd., Suite 300

Arlington, VA 22201-3324

May 5, 2022 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for 

Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker 

Health (ABRWH), including its Working Groups or Subcommittees. Documents produced by 

SC&A, such as memorandum, white paper, draft or working documents are not final NIOSH or 

ABRWH products or positions, unless specifically marked as such. This document prepared by 

SC&A represents its preliminary evaluation on technical issues.

NOTICE: This document has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 
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SC&A, Inc. technical support for the Advisory Board on Radiation and Worker Health’s 

review of NIOSH dose reconstruction program

Document title A review of NIOSH’s Program Evaluation Report DCAS-PER-093, 

“Texas City Chemicals, TBD Rev. 01”

Document number SCA-TR-2022-PER093

Revision number 0 (Draft)

Supersedes NA

Effective date May 5, 2022 

Task manager Kathleen Behling [signature on file]

Project manager Bob Barton, CHP [signature on file]

Document reviewer(s) Kathleen Behling [signature on file]

Bob Barton, CHP [signature on file]

Record of revisions

Revision number Effective date Description of revision

0 (Draft) 5/5/2022 Initial issue
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Table of Contents

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

1 Statement of Purpose............................................................................................... 5

2 Relevant Background Information............................................................................. 7

3 Subtask 1: Identify the Circumstances that Necessitated DCAS-PER-093 .............. 8

3.1 Chronology of events ......................................................................................... 8

3.2 SC&A’s comments ............................................................................................. 9

4 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action...................... 10

4.1 SC&A’s comments ........................................................................................... 10

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

Requiring Reevaluation of Dose.................................................................................... 11

5.1 NIOSH’s selection criteria ................................................................................ 11

5.2 SC&A’s comments ........................................................................................... 11

6 Subtask 4: Conduct Audits of a Sample Set of Reevaluated DRs Mandated by 

DCAS-PER-093 ............................................................................................................ 12

7 References ............................................................................................................. 13
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Abbreviations and Acronyms

ABRWH, Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission

DR dose reconstruction 

EEOICPA Energy Employees Occupational Illness Compensation Program Act

ER evaluation report 

NIOSH National Institute for Occupational Safety and Health

ORAUT Oak Ridge Associated Universities Team

PER program evaluation report

POC probability of causation

SDC Smith-Douglas Corporation 

SEC Special Exposure Cohort 

SRDB Site Research Database

TBD technical basis document

TCC Texas City Chemicals, Inc.
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1 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.

A program evaluation report (PER) provides a critical evaluation of the effects that a given issue 

or 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 on the probability of causation (POC) of previously completed DRs with POCs less than 

50 percent.

During a teleconference by the Advisory Board on Radiation and Worker Health (Board) 

Subcommittee for Procedure Reviews on February 15, 2022, the Board tasked SC&A to review 

DCAS-PER-093, revision 0 (NIOSH, 2021), which was issued to address the impacts of issuing 

revision 1 to the Texas City Chemicals, Inc. (TCC) technical basis document (TBD), DCASTKBS-0011 (NIOSH, 2020a), on previously completed claims. 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 and characterization of the issue addressed in the 

PER 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. When the PER 

involves a technical issue that is supported by documents (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 and 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 reevaluation. The second step may have important implications where the 

universe of previously denied DRs is very large and, for reasons of practicality, NIOSH’s 

reevaluation 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 of the completion of the PER.
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• 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 Board will select 

the DRs and the total number of DR audits for each PER.) 

• 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 Relevant Background Information 

The TCC plant in Texas City, TX, has an Energy Employees Occupational Illness Compensation 

Program Act (EEOICPA) Atomic Weapons Employer covered operational period from 

October 5, 1953, through September 1955. The site also has a covered residual contamination 

period from October 1, 1955, through 1977.

Construction on the TCC plant began in 1952. The site was designed to produce animal feed and 

fertilizer from phosphate rock. The plant had a contract with the Atomic Energy Commission 

(AEC) to construct a uranium recovery plant to extract uranium as a byproduct of the 

phosphates. TCC also had a development contract with the AEC to evaluate leach zone material. 

Preliminary operations began at both the new fertilizer plant and uranium recovery plant on 

October 5, 1953. The uranium recovery plant encountered a number of problems during startup 

and produced only a limited amount of uranium (approximately 400 pounds) for the AEC during 

the first few months of operation. Due to equipment problems, the plant never reached full-scale 

uranium production. TCC ceased operations in 1956 and filed for bankruptcy. Following 

bankruptcy in 1956, the Smith-Douglas Corporation (SDC) acquired TCC. SDC did not pursue 

uranium work with the AEC. SDC was later acquired by Borden Chemical, which operated the 

phosphate plant until it closed in 1977.
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3 Subtask 1: Identify the Circumstances that Necessitated 

DCAS-PER-093 

3.1 Chronology of events

Special Exposure Cohort (SEC) Petition Evaluation Report (ER) SEC-00088, revision 0: On 

August 17, 2007, Petition SEC-0088 qualified for evaluation. NIOSH issued revision 0 of the 

SEC petition ER for Petition SEC-00088 on January 18, 2008 (NIOSH, 2008). 

SC&A’s Draft Review of SEC Petition SEC-00088: During its April 7–9, 2008, meeting in 

Tampa, FL, the Board directed SC&A, Inc. to review the TCC SEC-00088 ER (ABRWH, 2008). 

That report was issued July 18, 2008, and identified nine findings (SC&A, 2008). 

SEC Petition ER SEC-00088, revision 1: During the May 8, 2009, Surrogate Data Work Group 

meeting, NIOSH reported that a series of developments, including the discovery of new 

information since the initial issue of the ER, led to the need to revise the ER (ABRWH, 2009). 

Because of this, SC&A’s findings in the ER review were not addressed in detail at the work 

group meeting. NIOSH amended the ER on October 19, 2010 (NIOSH, 2010). The amended ER 

modified the covered period to October 5, 1953, through September 30, 1955, based on newly 

discovered documentation. The amended ER also recommended granting the SEC based on an 

inability to bound radon dose with sufficient accuracy. 

SEC Granted for SEC Petition SEC-0088: On November 17, 2010, the Board voted to accept 

the NIOSH SEC class recommendation (ABRWH, 2010). The SEC class includes: 

all Atomic Weapons Employer employees who worked at Texas City Chemicals, 

Inc., from October 5, 1953, through September 30, 1955, for a number of work 

days aggregating at least 250 work days, occurring either solely under this 

employment or in combination with work days within the parameters established 

for one or more other classes of employees in the Special Exposure Cohort. 

[NIOSH, 2010, p. 4] 

DCAS-TKBS-0011, revision 00: On November 2, 2017, NIOSH issued a site profile for TCC, 

DCAS-TKBS-0011, revision 00 (NIOSH, 2017a), which included guidance for the DR of TCC

workers not covered during the SEC period and during the residual period. 

SC&A’s Draft Review of DCAS-TKBS-0011, revision 00: The Board tasked SC&A to 

conduct a technical review of revision 00 of DCAS-TKBS-0011 in December 2017. SC&A’s 

(2018) review looked at the extent to which previous site findings were incorporated into the 

TBD, because the SEC findings were never resolved formally by the Board. All previous 

findings were determined to be either no longer applicable or resolved and recommended to be 

closed. Additionally, the review evaluated the DR methods presented in the TBD. The review 

identified two new observations and no findings.

DCAS-TKBS-0011, revision 01: NIOSH issued revision 01 of the TBD for TCC on April 27, 

2020 (NIOSH, 2020a), to (1) address comments from SC&A’s (2018) review, (2) revise 

ingestion intakes during the residual period, and (3) implement text changes and update the 

document’s format. NIOSH issued a memorandum on May 19, 2020 (NIOSH, 2020b), 
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addressing SC&A’s two observations and SC&A’s summary of the nine SEC findings (SC&A, 

2018). This included making clarifying changes to tables 7, 8, and 9 in the TBD and revising the 

methods used to calculate ingestion intakes from residual contamination. As a result of these 

changes, ingestion intakes increased for the years 1955 through 1977. 

SC&A’s Draft Review of DCAS-TKBS-0011, revision 01: SC&A was tasked in June 2020 to 

review NIOSH’s May 2020 memorandum (NIOSH, 2020b) in conjunction with revision 01 of 

the TCC TBD (NIOSH, 2020a). SC&A’s (2020) review looked at the extent to which previous 

site issues were incorporated into the TBD, because the SEC findings and TBD observations 

were never resolved formally by the Board. All previous findings and observations were 

determined to be either no longer applicable or resolved and recommended to be closed. 

3.2 SC&A’s comments

SC&A reviewed each of the documents leading up to changes incorporated into revision 01 of 

the TCC site profile (NIOSH, 2020a). SC&A agrees with NIOSH that these changes and their 

impacts on TCC worker doses mandate the need for DCAS-PER-093 (NIOSH, 2021).

There are no findings pertaining to subtask 1. 
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4 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action

In the publication record of revision 01 of the TCC site profile, NIOSH (2020a) described some 

of the revisions as follows: 

Revision to address comments from SC&A on ingestion intakes and 

interpretation/format of Tables 7, 8 and 9. Revised methods to calculate ingestion 

intakes from residual contamination. Ingestion intakes in Table 9 increased for 

years 1955 through 1977. No other dose or intakes values were changed. The 

updated calculation methods are described in section 4.3. Changes were made in 

the explanation of calculations in sections 4.1 and 4.2 to better explain the 

ingestion calculations. Table 7 was revised to include dose for all of 1955 

(operational and residual periods). Tables 8 and 9 were changed to include intakes 

only for years 1956 through 1977. [NIOSH, 2020a, p. 3] 

4.1 SC&A’s comments

In revision 01 of the TCC site profile (NIOSH, 2020a), NIOSH modified the methods used to 

calculate ingestion doses during the residual period (October 1, 1955, through 1977). Revision 

01 of the TBD provides updated residual ingestion intake rates that assume the initial residual 

ingestion intake rate is equal to the ingestion intake rate during uranium recovery operations. The 

ingestion rate declines gradually according to the depletion factors in ORAUT-OTIB-0070, 

revision 01 (NIOSH, 2012). The ORAUT-OTIB-0070 depletion factors have been extensively 

discussed with the Board. 

There are no findings associated with subtask 2.
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5 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-093 described the following criteria NIOSH used to identify 

previously completed claims requiring reevaluation using guidance in revision 01 of DCASTKBS-0011 (NIOSH, 2020a): (1) claims with TCC employment after October 1, 1955, and (2) a 

POC below 50 percent. Application of these criteria identified 14 claims. NIOSH recalculated 

dose for all 14 claims using the guidance from revision 01 of DCAS-TKBS-0011; however, none 

of these claims were found to increase the POC above 50 percent. Thirteen of the claims resulted 

in a new POC less than 45 percent, and one resulted in a POC between 45 percent and 

50 percent. Therefore, NIOSH concluded DCAS-PER-093 with the following:

NIOSH will provide the Department of Labor with the list of all the claims 

evaluated under this PER. Since none resulted in a probability of causation greater 

than 50%, NIOSH will not request the return of any claims. [NIOSH, 2021, p. 2] 

5.2 SC&A’s comments

In November 2015, NIOSH provided SC&A with summary statistics on the number of claims 

filed at each site within EEOICPA. These statistics also contained information on the number of 

claims at each site that had POCs above and below 50 percent. At that time, 18 claims had been 

filed and received DRs for TTC. Three of those claims had a POC above 50 percent, and the 

remaining 15 claims had a POC below 50 percent. In February 2022, when updated data were

provided by NIOSH, no additional claims had been filed. However, the updated data do not 

contain POC information, so SC&A cannot definitely conclude that POC data have not changed. 

The selection criteria used by NIOSH for previously completed DRs that require reevaluation 

under DCAS-PER-093 are broad enough that they captured all but one previously 

uncompensated TCC claims. Presumably, the additional uncompensated claim did not have 

employment during the residual period. SC&A agrees that all potentially impacted claims were 

captured by selecting all uncompensated cases with employment during the residual period. 

There are no findings associated with subtask 3.
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6 Subtask 4: Conduct Audits of a Sample Set of Reevaluated DRs 

Mandated by DCAS-PER-093

Previous sections of this report described changes introduced in revision 01 of the TCC site 

profile (NIOSH, 2020a) that increased the dose assigned during the residual period. Since 

NIOSH’s evaluation of the TBD changes under DCAS-PER-093 did not warrant the return of 

any DR cases by the U.S. Department of Labor, SC&A recommends that the Board select a 

single case out of the 14 evaluated by NIOSH for additional evaluation. Since one case is 

specifically called out as having a higher POC than the others, SC&A believes the case with a 

POC between 45 and 50 percent is the ideal choice for evaluation.
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7 References

Advisory Board on Radiation and Worker Health. (2008). Meeting 54 Advisory Board on 

Radiation and Worker Health day one [Transcript]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2008/tr040708.pdf

Advisory Board on Radiation and Worker Health. (2009). Surrogate Data Workgroup Friday, 

May 8, 2009 [Transcript of teleconference meeting]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2009/wgtr050809.pdf 

Advisory Board on Radiation and Worker Health (ABRWH). (2010). 73rd meeting Wednesday 

November 17, 2010 [Transcript]. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2010/tr111710.pdf

National Institute for Occupational Safety and Health. (2008). SEC petition evaluation report 

Petition SEC-00088 (rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/arch/sec/texcityer.pdf

National Institute for Occupational Safety and Health. (2010). SEC petition evaluation report 

Petition SEC-00088 (rev. 1). https://www.cdc.gov/niosh/ocas/pdfs/sec/texascity/texascityer-88-

r1.pdf

National Institute for Occupational Safety and Health. (2012). Dose reconstruction during 

residual radioactivity periods at Atomic Weapons Employer facilities (ORAUT-OTIB-0070, 

rev. 01). https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t70-r1.pdf 

National Institute for Occupational Safety and Health. (2017a). Technical basis document for 

Texas City Chemicals, Inc. Texas City, Texas (DCAS-TKBS-0011, rev. 00). SRDB Ref. 

ID 168229 

National Institute for Occupational Safety and Health. (2020a). Technical basis document for 

Texas City Chemicals, Inc. Texas City, Texas (DCAS-TKBS-0011, rev. 01). 

https://www.cdc.gov/niosh/ocas/pdfs/tbd/texascity-r1-508.pdf

National Institute for Occupational Safety and Health. (2020b, May 19). Texas City Chemicals 

review [Memorandum]. https://ftp.cdc.gov/pub/FOIAREQ/181028-508.pdf 

National Institute for Occupational Safety and Health. (2021). Texas City Chemicals, TBD 

rev. 01 (DCAS-PER-093, rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/pers/dc-per93-r1-508.pdf

SC&A, Inc. (2008). A focused review of the NIOSH evaluation report for the Texas City 

Chemical Company SEC petition (SCA-SEC-TASK5-0063, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-txcitysec88-r0.pdf 

SC&A, Inc. (2018). Evaluation of technical basis document for Texas City Chemicals, Inc., 

Texas City, Texas (SCA-TR-2018-SP004, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-txcityevaltbd-r0-508.pdf
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NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

SC&A, Inc. (2020). Evaluation of revision 01 of the technical basis document for Texas City 

Chemicals, Inc., Texas City, TX (SCA-TR-2020-SP002, rev. 0). 

https://ftp.cdc.gov/pub/FOIAREQ/183182-508.pdf