Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

SC&A RESPONSE TO NIOSH’S COMMENTARY ON FINDINGS 

REGARDING THE SITE PROFILE FOR 

DUPONT DEEPWATER WORKS 

Contract No. 200-2009-28555 

Prepared by 

John J. Mauro, PhD 

William C. Thurber 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

June 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 42CFR82. 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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Document No. 

 SCA-TR-SP2011-0035 

Effective Date: 

 Draft – June 6, 2013 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 (Draft) 

SC&A RESPONSE TO NIOSH’S COMMENTARY 

ON FINDINGS REGARDING THE SITE PROFILE 

FOR DUPONT DEEPWATER WORKS 

Page 2 of 16 

Task Manager/Lead Author: 

______________________________ Date:____________ 

John Mauro, PhD 

Supersedes: 

N/A 

Project Manager: 

______________________________ Date:____________ 

John Stiver, MS, CHP 

Peer Reviewer(s): 

 John Stiver 

 

 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 06/06/2013 Initial issue 
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TABLE OF CONTENTS 

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

1.0 Introduction..........................................................................................................................5 

1.1 SC&A’s Original Finding 1.....................................................................................5 

1.1.1 NIOSH’s Response ......................................................................................6 

1.1.2 SC&A Response ..........................................................................................6 

1.2 SC&A’s Original Finding 2.....................................................................................6 

1.2.1 NIOSH Response .........................................................................................6 

1.2.2 SC&A Response ..........................................................................................6 

1.3 SC&A’s Original Finding 3.....................................................................................7 

1.3.1 NIOSH Response .........................................................................................7 

1.3.2 SC&A Response ..........................................................................................7 

1.4 SC&A’s Original Findings 4 and 5..........................................................................7 

1.4.1 NIOSH Response .........................................................................................7 

1.4.2 SC&A’s Response .......................................................................................8 

1.5 SC&A Original Finding 6......................................................................................10 

1.5.1 NIOSH Response .......................................................................................10 

1.5.2 SC&A Response ........................................................................................10 

1.6 SC&A’s Original Finding 7...................................................................................11 

1.6.1 NIOSH Response .......................................................................................11 

1.6.2 SC&A Response ........................................................................................11 

2.0 Conclusions and Recommendations..................................................................................12 

2.1 References..............................................................................................................12 

Attachment 1: Sample IREP Calculations....................................................................................14 
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ABBREVIATIONS AND ACRONYMS 

Advisory Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

cSv cubic sievert 

DCAS Division of Compensation Analysis and Support 

DOL Department of Labor 

GM geometric mean 

GSD geometric standard deviation 

hr hour 

IREP Interactive Radio-Epidemiological Program 

MCNP Monte Carlo N-Particle 

keV kilo-electron volt 

MED Manhattan Engineer District 

mg/day milligrams per day 

mR milliroentgen 

mrad millirad 

mrep/hr millirep per hour 

NIH National Institutes of Health 

NIOSH National Institute for Occupational Safety and Health 

OCAS Office of Compensation Analysis and Support 

POC or PC probability of causation 

rem roentgen equivalent man 

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

SRDB Site Research Database 

TBD technical basis document 

TIB technical information bulletin 

U uranium 

UF4 uranium tetrafluoride 

U3O8 uranium oxide 

yr year
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1.0 INTRODUCTION 

On August 12, 2011, SC&A delivered to the National Institute for Occupational Safety and 

Heath (NIOSH) and the Advisory Board on Radiation and Worker Health (Advisory Board) its 

review of the site profile for DuPont Deepwater Works (SC&A 2011). In accordance with a 

request made by the AWE (Atomic Weapons Employer) Work Group during its September 7, 

2012, meeting, NIOSH responded to SC&A’s findings in a white paper dated March 18, 2013 

(Neton 2013) . This report is provided in response to that white paper. 

It has become common practice to provide these types of point-counterpoint exchanges of 

information in a running issues matrix, which is then used as the basis for discussion at work 

group meetings, in this case the AWE Work Group under the Chairmanship of Dr. Henry 

Anderson. However, in this case, we elected to prepare our responses in more of a narrative 

form, as was used by SC&A in its original review of the site profile and also used by NIOSH in 

its white paper dated March 18, 2013. We felt that this narrative approach will make it easier for 

all participants to follow the exchange of information and the rationale for any conclusions. At 

any time, these white papers can be converted into an exposure matrix format. 

In order to prepare our response, we are using the same approach adopted by NIOSH in its white 

paper. First, we reiterate each of SC&A’s original findings (in bold), followed in some cases by 

some additional explanatory material regarding the finding. This material is followed by a 

summary of NIOSH’s commentary on SC&A’s findings as provided in NIOSH’s March 18, 

2013, white paper. We then provide SC&A’s response to that commentary, either agreeing or 

disagreeing with NIOSH’s position and providing SC&A’s rationale for its position. We hope 

all parties find this format useful and informative. 

1.1 SC&A’S ORIGINAL FINDING 1 

Finding 1: The site profile should discuss the degree to which the air sampling data, which 

were collected in 1944 and 1945, can be used to reasonably bound doses in the earlier years 

of operation (e.g., 1942–1943). 

This is an issue that SC&A has encountered on many occasions when reviewing site profiles for 

old facilities, especially AWE facilities. What has often occurred in these situations is the 

Atomic Energy Commission (AEC) or, prior to the AEC, the Manhattan Engineer District 

(MED), hired a private company to perform some specialized metallurgical work due to that 

company’s experience related to the handling of metals. At that time, the nation was just 

learning about the properties and safe handling of uranium in its various forms, and it was not 

until later in the 1940s and early 1950s that improved radiation protection practices became 

widely employed at these types of facilities. Hence, uranium work performed in the early 1940s 

was often performed with minimal health safety controls. Thus, we are concerned with 

extrapolating data collected in 1944 and 1945 to exposures that might have occurred in 1942 and 

1943. 
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1.1.1 NIOSH’s Response 

In its March 18, 2013, response to SC&A’s findings, NIOSH pointed out that the air sampling 

data collected during the 1944–1945 time periods were likely bounding as applied to the 1942–

1943 time frame because uranium activities were very limited during the early years. In its 

response, NIOSH refers the reader to two Site Research Database (SRDB) reports (i.e., SRDB 

16272 [Chambers Works 1945] and page 16 of DuPont 1946) as the basis for this conclusion. 

1.1.2 SC&A Response 

Chambers Works (1945), History, Chambers Works Special Construction, identifies the preoperational phase as December 1942 to early January 1943, where temporary offices and 

structures were established for the projects outlined in Table 1 of NIOSH’s response. The 

earliest start-up date for the first equipment required by operations for Project 9595 was April 11, 

1943, and a test run made in May 1943. Projects 9634, 9757, 9233 and 9803 had start-up dates 

that ranged from mid-1943 through mid-1944. Chambers Works (1945) does state that the 

“advice of physical completion” was not issued until April 15, 1944. The start of full-scale 

operation is not indicated in Chambers Works (1945), but can be assumed to be after the advice 

of physical completion was issued, and that full-scale operations were not being conducted 

during 1942–1943. On this basis, we concur with NIOSH’s response and recommend that this 

finding be closed. 

1.2 SC&A’S ORIGINAL FINDING 2 

Finding 2: We would request that the site profile discuss the levels of surface 

contamination at the facility and explain that, at these levels, the default ingestion rate of 

0.5 mg/day, which is inherent to TIB-009 [OCAS 2004], applies to this facility. NIOSH 

should also describe how the ingestion intake in Table 1 was calculated.

1.2.1 NIOSH Response 

NIOSH explains that, “This finding pertains to the quantification of ingestion intakes which was 

transferred to the Procedures Subcommittee. The subcommittee appears to have completed its 

work and has concluded that no changes are necessary to TIB-009. However, in its response to 

this finding, NIOSH states that the implementation of TIB-009 in the residual period has been 

misinterpreted in the DuPont Deepwater works. These values will be revised in keeping with the 

discussions held in the Procedures Subcommittee.” 

1.2.2 SC&A Response 

SC&A concurs that the methods recommended in OCAS-TIB-009 apply to this case. However, 

it appears that NIOSH agrees that a revision is needed to the analysis as provided in the site 

profile with respect to this matter. SC&A will review the revised analysis when it becomes 

available. SC&A recommends that this item remain open until NIOSH’s revised analysis is 

provided and discussed with the Work Group. 
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1.3 SC&A’S ORIGINAL FINDING 3 

It appears that uranium metal was produced at the site using the UF4 to U magnesium 

bomb reduction process, which, because of the Putzier effect, could have produced 

uranium ingots that were associated with external beta radiation fields that were 10 to 20 

times greater than those adopted in the site profile. 

1.3.1 NIOSH Response 

In its response, NIOSH points out that the Putzier effect only applies when an ingot is recast for 

the purpose of further purification, and recasting did not occur at DuPont Deepwater. Hence, 

NIOSH concludes that the Putzier effect did not likely occur at this facility. 

1.3.2 SC&A Response 

SC&A concurs with NIOSH, and we recommend that this finding be closed. 

1.4 SC&A’S ORIGINAL FINDINGS 4 AND 5 

These two findings are combined because NIOSH’s responses to these findings are combined. 

Finding 4: There seems to be a substantial disparity between the explanation of how the 

annual photon doses to operators were derived and the actual values employed in the site 

profile.

 

Finding 5: There seems to be a substantial disparity between the explanation of how the 

annual contact doses to operators were derived and the actual values employed in the site 

profile. In addition, justification should be provided as to why TBD-6000 default values 

should not be used at DuPont, since no site data are available for external exposure during 

the operating period.

1.4.1 NIOSH Response 

NIOSH understands that SC&A calculated an annual photon exposure of 1,920 mR/yr by making 

the following assumptions: 

 An exposure rate of 1.3 mR/hr at 1 foot from either a slab of natural uranium or a 

55-gallon drum of U3O8

 An exposure rate of 0.3 mR/hr at 1 meter from either a slab of natural uranium or a 

55-gallon drum of U3O8

 A total exposure duration of 2,400 hours per year, half of which is spent at 1 foot and half 

of which is spent at 1 meter from the source of uranium. 

NIOSH explains, however, that it did not use the 1.3 mR/hr and the 0.3 mR/hr exposure rates at 

1 foot and 1 meter from a 55-gallon drum of uranium oxide (values which were derived by 
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NIOSH using MCNP and reported in Table 6 of the site profile, and with which SC&A agrees). 

Instead, NIOSH explains that it assumed that the MCNP-derived values were in fact the average 

exposure rates at these distances, and then proceeded to derive the geometric mean (GM) of 

these exposure rates assuming that the exposure rates at these distances are lognormally 

distributed with a geometric standard deviation (GSD) of 5. This results in a GM of 0.22 mR/hr 

for 2,400 hours per year, yielding an annual exposure of 529 mR/yr (NIOSH actually estimated 

an annual exposure of 519 mR/yr, a value that is slightly lower than the value SC&A derived 

using NIOSH’s approach.) 

The white paper also explains that the difference in extremity doses as derived by NIOSH and 

SC&A is also a result of the application of what we will refer to as the statistical method, as 

described above with respect to photon doses. Specifically, NIOSH understands that the 

assumptions SC&A used to derive its extremity dose of 121,800 mrad per year are based on the 

following assumptions: 

 An assumed contact dose rate of 203 mrad/hr to skin in direct contact with a slab of 

natural uranium 

 A total exposure duration of 2,400 hours per year, but only 25% of the time in direct 

contact with the uranium 

NIOSH explains that the dose rate of 203 mrad/hr is assumed to be the average contact dose rate 

to the skin, and then derived the GM of the dose rate by assuming that the contact dose rate is 

lognormally distributed with a GSD of 5. The outcome of this exercise is provided in Table 7 of 

the site profile. Specifically, assuming that the hands and forearms are in contact with pure 

unshielded uranium metal 25% of the time, the exposure rate would be 58.75 mrad/hr (we 

estimate a slightly lower value of 50.75 mrad/hr). Then, using the same statistical process 

described above, NIOSH estimates that the GM is 16.09 mrad/hr with a GSD of 5. Assuming 

skin contact 25% of the time, the annual dose to hands and forearms for operators is estimated by 

NIOSH to have a GM of 38,614 mrad/yr and a GSD of 5. 

NIOSH explains that this approach to deriving doses, and subsequently the probability of 

causation (POC), is more claimant favorable than the “non-statistical” approach used by SC&A 

because of the fact that using a GSD of 5 on the GM creates a distribution that, when inserted 

into IREP, results in a POC at the 99% confidence level that is higher than what would be 

obtained if a single fixed value is used as input to IREP, even though the fixed input value is 

substantially higher (by about a factor of 4) than the GM value used by NIOSH. NIOSH 

explains that this occurs because the POC is reported at the 99th percentile level, and a GSD of 5 

results in a higher POC, even though the GM is substantially lower than a fixed value for the 

organ dose. NIOSH demonstrates the validity of this argument in Attachment 1 in its March 18, 

2013, white paper. 

1.4.2 SC&A’s Response 

The assumptions and statistical method used by NIOSH to arrive at its annual exposures seem 

quite “strained,” in that NIOSH is employing a complex statistical manipulation of the numbers 

that, in the end, effectively means that the worker spent 2,400 hours per year about 1 meter from 
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a filled 55-gallon drum. We are troubled by the statistical manipulation of the numbers, and 

would have preferred that NIOSH simply choose a claimant-favorable distance from the drum 

and exposure duration; i.e., keep it simple. However, as described above, NIOSH argues that 

their approach actually results in a higher POC. In addition, when viewed from the simple 

perspective used by SC&A, NIOSH is effectively assuming that the worker is spending 

2,400 hours per year about 1 meter from a filled drum; an outcome that seems intuitively 

reasonable. On this basis alone, SC&A sees no problem recommending that this finding could 

be closed, but would like it to remain open until we can discuss this strategy a little further. 

Specifically, we are interested in exploring whether we agree that the “statistical approach” 

actually results in a higher POC than the approach SC&A employed, and that the statistical 

approach makes sense in this application. 

SC&A ran IREP to evaluate NIOSH’s conclusions. We first ran IREP using a fixed annual dose 

to a selected organ and a set of default assumptions regarding the other IREP input parameters to 

determine a POC. We then ran IREP using the same set of input parameters, except we assumed 

that the dose was lognormally distributed with a GM that is 1⁄4 the fixed dose and with a GSD of 

5. Our results confirm NIOSH’s conclusions that the statistical approach results in a higher POC. 

See Attachment 1 for the sample calculation we performed. 

The following summarizes the IREP calculation and our findings: 

John Doe was born in 1942. 

Diagnosed with lung cancer in 2002. 

White non-Hispanic, never smoked. 

One year (1982) of dose, which is 20 years prior to cancer diagnosis. 

Dose distribution #1 (lognormal): 50% 30–250 keV; 50% >250 keV (Chronic Exposure Rate) or 

0.240 rem GM with a GSD of 5.0 for each energy range. 

POC at 99th percentile = 12.60% 

Dose distribution #2 (constant): 50% 30–250 keV; 50% >250 keV (Chronic Exposure Rate) or 

0.960 rem 

POC at 99th percentile = 6.48%

Notwithstanding these results, the statistical approach as used here does not appear to be a 

coherent strategy. By “coherent” we mean that it seems illogical to assume a known exposure 

rate at a point in space that has essentially no uncertainty is assumed to have a very large degree 

of uncertainty. Perhaps NIOSH is attempting to account for uncertainty in worker placement 

relative to the source by applying an uncertainty term to the source dose rate. In any case, this 

subject needs further discussion. We recommend that Findings 4 and 5 be kept open until we 

have an opportunity to discuss this matter with the Work Group. 
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1.5 SC&A ORIGINAL FINDING 6 

Finding 6: Assuming 50% of the beta/gamma dose rate measured at 3 feet from a surface 

is 50% from gamma and 50% from beta does not appear to be appropriate. In addition, 

beta dose cannot contribute significantly to whole body dose.

It is important to point out that this finding pertains to the residual period, and that SC&A’s 

concern has to do with the method used by NIOSH to derive the penetrating and non-penetrating 

dose rates at 3 feet from surfaces that had residual uranium contamination. 

1.5.1 NIOSH Response 

The method used by NIOSH to derive the doses begins with gross beta/gamma measurements 

taken 3 feet above the floor at the locations surveyed in Building 708 and Building 845 after 

decontamination in 1948, where dose rates of 0.05 and 0.03 mrep/hr, respectively, were observed. 

A subsequent survey in 1977 indicated that contact doses on the walls and floors were typically 

about 0.1 mrad per hour. In order to cover the full range of possible contact dose measurements, 

NIOSH favorably assumed that the contact dose (beta/gamma) was 0.2 mrad/hr. Using a factor 

of 5 for the dose reduction between the surface and 3 feet, the site profile assumes that all 

workers experienced external whole body beta plus gamma dose rates of 0.04 mrad/hr, and that 

50% is due to photons and 50% is due to electrons. As stated in the site profile, “Therefore, this 

appendix will assume the 0.04 mrad/hr is composed of a whole body gamma dose rate of 

0.02 mR/hr and a beta whole body dose rate of 0.02 mrad/hr” (DCAS 2011a, p. 13, emphasis 

added). However, in its response, NIOSH agrees that the use of a one-to-one beta/gamma ratio 

is likely inappropriate, and a 10:1 ratio should be applied. 

1.5.2 SC&A Response 

In response to this finding, NIOSH makes a number of good points regarding the nature of the 

residual uranium contamination and how that thin layer of contamination, which is partly 

commingled in a thin veneer of concrete, would affect the beta radiation field above the surface 

in a complex manner. SC&A agrees with this discussion, but would like to explore this issue a 

little further. Specifically, Table 3.10 of TBD-6000 (DCAS 2011b) shows that beta nonpenetrating dose rates 1 meter above a concrete floor with a thin residue of uranium 

contamination would be about 100 times higher than the photon exposure rates at the same 

location. It is noteworthy that, in its response to this issue, NIOSH concludes the following: 

However, NIOSH agrees that the use of a one to one beta/gamma ratio is likely 

inappropriate. NIOSH states that a 10 to 1 ratio is used in TBD-6000, and during 

discussions in the TBD-6000 work group; it was shown that this ratio appears to 

be favorable for volume sources (uranium metal, uranium products in tanks, etc.). 

NIOSH recommends changing this assumption to a 10 to 1 ratio. 

As described above, we believe that Table 3.10 of TBD-6000 recommends a 100-to-1 ratio, not 

10-to-1, as stated in NIOSH’s response, for this type of exposure situation. In this case, NIOSH 

argues that it might be appropriate to use a 10:1 ratio for two reasons. First, given that the 
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NOTICE:

starting point for this calculation is a measured beta/gamma dose rate of 0.04 mrep/hr at 3 feet, a 

10:1 beta/gamma ratio would be claimant favorable for assigning penetrating doses, but not for 

assigning skin dose. In addition, a 10:1 beta/gamma ratio might be appropriate in this situation if 

the residual uranium is somewhat imbedded in the top layer of concrete. This would attenuate 

the beta somewhat, thereby reducing the beta/gamma ratio. 

It appears that NIOSH plans to revise the dose reconstruction protocol in a manner that the gross 

beta/gamma dose rate at 3 feet from the surface is 0.04 mrad/hr, and that the beta-to-gamma ratio 

will be 10:1. We would like to investigate this further. First, it appears that Table 3.10 in TBD6000 was developed specifically for this type of exposure scenario, and changing the ratio from 

100:1 to 10:1 seems somewhat arbitrary. Nevertheless, a 10:1 beta/gamma ratio in this case 

would be more claimant favorable when reconstructing deep doses. In fact, using a 1:1 ratio 

would be even more claimant favorable, but perhaps unrealistic. With respect to skin dose, the 

ratio really doesn’t matter, since 0.04 mrad/hr would be assigned either way (the only difference 

would be how much of this dose is assumed to be beta and how much is assumed to be photon). 

In light of this, we would suggest that a 10:1 ratio be used for reconstructing penetrating dose, 

but a ratio of 100:1 be used for reconstructing the non-penetrating dose. This would seem to be a 

more realistic but claimant-favorable strategy. 

We believe that we are converging on a resolution to Finding 6, but recommend that it remain 

open until we have an opportunity to discuss it with the Work Group. 

1.6 SC&A’S ORIGINAL FINDING 7 

Finding 7: The development of the photon dose is convoluted and not scientifically sound. 

A simpler approach would be to assume that the deep dose rate was 0.05 mrad/hr based on 

measurements at 3 feet from contaminated surfaces, and pro-rate this dose rate between 

beta and gamma based on Table 3.10 of TBD-6000. 

In reviewing this finding, we believe we made an error. We believe that the 0.05 mrad/hr 

number would certainly be a bounding deep dose, especially if the 0.05 mrep/hr measurement 

was an open window measurement that included both beta and photon exposures at 3 feet from 

contaminated surfaces. As discussed above in our discussion of Finding 6, perhaps a more 

realistic but claimant-favorable approach would be to assume a 10:1 beta gamma ratio. 

1.6.1 NIOSH Response 

NIOSH explains that a dose rate of 0.04 mrep/hr be used. 

1.6.2 SC&A Response 

SC&A agrees with NIOSH, but recommends keeping this finding open until we have an 

opportunity to discuss this matter with the Work Group. 
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2.0 CONCLUSIONS AND RECOMMENDATIONS 

Based on the above review, we have the following conclusions and recommendations: 

Finding Conclusions SC&A Recommendations 

1 

SC&A agrees with NIOSH’s position that the air 

sampling data collected in 1944 and 1945 can be 

used to reconstruct doses in 1942–1943 

Close this finding 

2 

SC&A agrees with NIOSH that some revision is 

required to the site profile with respect to this 

finding 

Remain open until the Work Group 

has an opportunity to review 

NIOSH’s revision to this part of the 

site profile 

3 SC&A agrees with NIOSH that the Putzier effect 

does not apply to this facility Close this finding 

4 and 5 

SC&A understands the rationale for NIOSH’s 

position on this matter and agrees that it is claimant 

favorable, but we believe the approach raises some 

scientific questions that need to be discussed with 

the Work Group 

Remain open until the Work Group 

has an opportunity to discuss 

NIOSH’s approach to this class of 

problem 

6 We are converging on a solution, but there remains 

a need for additional discussion 

Remain open until we have an 

opportunity to discuss this issue 

with the Work Group 

7 We are converging on a solution, but there remains 

a need for additional discussion 

Remain open until we have an 

opportunity to discuss this issue 

with the Work Group 

2.1 REFERENCES 

Chambers Works 1945. Report: History Chambers Works Special Construction. February 9, 

1945. Ref ID 16272. 

DCAS 2011a. Technical Basis Document for the DuPont Deepwater Works, Deepwater, New 

Jersey. DCAS-TKBS-0006, Rev. 00. National Institute for Occupational Safety and Health 

(NIOSH) Division of Compensation Analysis and Support (DCAS), Cincinnati, Ohio. March 8, 

2011. 

DCAS 2011b. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals. 

Battelle-TBD-6000. Rev. 1. National Institute for Occupational Health and Safety (NIOSH), 

Division of Compensation Analysis and Support (DCAS), Cincinnati, Ohio. June 17, 2011. 

OCAS 2004. Estimation of Ingestion Intakes. OCAS-OTIB-009, Rev. 0. National Institute for 

Occupational Health and Safety (NIOSH), Office of Compensation Analysis and Support 

(OCAS), Cincinnati, Ohio. April 13, 2004. 

Neton, J., 2013. DuPont Deepwater Works, NIOSH’s Response to Findings in SC&A’s Review, 

Dated August 12, 2011. National Institute for Occupational Health and Safety (NIOSH), 

Cincinnati, Ohio. March 18, 2013. 
Effective Date: 

June 6, 2013 

Revision No. 

0 (Draft)

Document No. SC&A Response to NIOSH Comments 

Regarding DuPont Deepwater Site Profile 

Page No. 

13 of 16

 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.

NOTICE:

SC&A 2011. Review of the NIOSH Site Profile for Dupont Chambers Works, Deepwater, NJ, 

Document No. SCA-TR-SP2011-0035, Rev. 0. SC&A, Inc., Vienna, Virginia. August 12, 2011. 

DuPont 1946. Design and Procurement History of Chambers Works Special Projects. E.I. du 

Pont Denemours and Company. March 1946. Ref ID 89139. 
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.

ATTACHMENT 1: SAMPLE IREP CALCULATIONS 

NIOSH-Interactive RadioEpidemiological Program 

Probability of Causation Results

Uploaded file: N/A DOL District Office: CL

Date of Run: 5/28/2013 NIOSH-IREP version: 5.7

Time of Run: 11:15:46 AM Analytica/ADE version: 3.0

NIOSH ID #: 123456 DOL Case No: 123-45-6789

Claimant Name: John Q. Doe

Claimant Cancer Diagnoses:

Primary Cancer #1: N/A Date of Diagnosis: N/A 

Primary Cancer #2: N/A Date of Diagnosis: N/A

Primary Cancer #3: N/A Date of Diagnosis: N/A

Secondary Cancer #1: N/A Date of Diagnosis: N/A

Secondary Cancer #2: N/A Date of Diagnosis: N/A

Secondary Cancer #3: N/A Date of Diagnosis: N/A

Claimant Information Used In Probability of Causation Calculation:

Gender: Male Race (skin cancer only): N/A

Birth Year: 1942 Year of Diagnosis: 2002

Cancer Model: Lung (162) Should alternate cancer model be run?: No

Smoking history (trachea, bronchus, or lung cancer only): Never smoked

NIOSH-IREP Assumptions and Settings:

User Defined Uncertainty Distribution: Lognormal(1,1) 

Number of Iterations: 2000 Random Number Seed: 99

General Exposure Information:

# Exp. Year Organ Dose (cSv) Exp. Rate Radiation Type

1 1982 Lognormal (0.24, 5) chronic photons E=30-250keV 

2 1982 Lognormal (0.24, 5) chronic photons E>250keV 

Radon Exposure Information:

 N/A (applies only to cases of Lung Cancer with Radon Exposures) 
Effective Date: 

June 6, 2013 

Revision No. 

0 (Draft)

Document No. SC&A Response to NIOSH Comments 

Regarding DuPont Deepwater Site Profile 

Page No. 

15 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.

Probability of Causation (PC) *

 1st percentile 0.01 %

 5th percentile 0.04 %

 50th percentile 0.38 %

 95th percentile 4.93 %

 99th percentile 12.60 %

* NIOSH-IREP is programmed with two different lung cancer risk models. Under current 

guidelines, each lung cancer claim is run separately using both risk models and the higher PC will 

determine the outcome of the claim. The results displayed above are derived from the NIOSHIREP lung model, which is the model that produced the higher PC at the 99th percentile for this 

particular claim. The lower PC at the 99th percentile, derived from the NIH-IREP lung model, is 

7.53 %. This lower PC value is reported here for information only and will have no bearing on the 

claim outcome. 

NIOSH-Interactive RadioEpidemiological Program 

Probability of Causation Results 

Uploaded file: N/A DOL District Office: CL

Date of Run: 4/18/2013 NIOSH-IREP version: 5.7

Time of Run: 11:47:16 AM Analytica/ADE version: 3.0

NIOSH ID #: 123456 DOL Case No: 123-45-6789

Claimant Name: John Q. Doe 

Claimant Cancer Diagnoses: 

Primary Cancer #1: N/A Date of Diagnosis: N/A 

Primary Cancer #2: N/A Date of Diagnosis: N/A

Primary Cancer #3: N/A Date of Diagnosis: N/A

Secondary Cancer #1: N/A Date of Diagnosis: N/A

Secondary Cancer #2: N/A Date of Diagnosis: N/A

Secondary Cancer #3: N/A Date of Diagnosis: N/A

Claimant Information Used In Probability of Causation Calculation: 

Gender: Male Race (skin cancer only): N/A 

Birth Year: 1942 Year of Diagnosis: 2002

Cancer Model: Lung (162) Should alternate cancer model be run?: No

Smoking history (trachea, bronchus, or lung cancer only): Never smoked 
Effective Date: 

June 6, 2013 

Revision No. 

0 (Draft)

Document No. SC&A Response to NIOSH Comments 

Regarding DuPont Deepwater Site Profile 

Page No. 

16 of 16

 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.

NIOSH-IREP Assumptions and Settings: 

User Defined Uncertainty Distribution: Lognormal(1,1) 

Number of Iterations: 2000 Random Number Seed: 99

General Exposure Information: 

# Exp. Year Organ Dose (cSv) Exp. Rate Radiation Type 

1 1982 Constant (0.96) chronic photons E=30-250keV 

2 1982 Constant (0.96) chronic photons E>250keV 

Radon Exposure Information: 

 N/A (applies only to cases of Lung Cancer with Radon Exposures) 

Probability of Causation (PC) * 

 1st percentile 0.09 % 

 5th percentile 0.24 % 

 50th percentile 1.04 % 

 95th percentile 4.07 % 

 99th percentile 6.48 % 

* NIOSH-IREP is programmed with two different lung cancer risk models. Under current 

guidelines, each lung cancer claim is run separately using both risk models and the higher PC will 

determine the outcome of the claim. The results displayed above are derived from the NIOSHIREP lung model, which is the model that produced the higher PC at the 99th percentile for this 

particular claim. The lower PC at the 99th percentile, derived from the NIH-IREP lung model, is 

2.79 %. This lower PC value is reported here for information only and will have no bearing on the 

claim outcome. 

NOTICE: