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-065, “ANACONDA” 

Contract No. 211-2014-58081 

SCA-TR-2017-PR004, Revision 0 

Prepared by

John Mauro, PhD, CHP 

Steve Ostrow, PhD 

Nicole Briggs

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, Virginia, 22201 

Saliant, Inc.

5579 Catholic Church Road

Jefferson, Maryland 21755 

June 2017 

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 report 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 Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

A Review of NIOSH’s Program Evaluation Report DCAS-PER-065, 

“Anaconda”

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2017-PR004 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: June 15, 2017

TASK MANAGER: John Mauro, PhD, CHP

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S):

Kathleen Behling, MS [signature on file]

John Stiver, MS, CHP [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 6/15/2016 Initial issue
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TABLE OF CONTENTS

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

1.0 Statement of Purpose .......................................................................................................... 6

2.0 Relevant Background Information ...................................................................................... 8

3.0 Subtask 1: Identify the Circumstances that Necessitated the Need for DCAS-PER-065 ... 8

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

4.1 Site-Specific Information and Guidance ............................................................... 11

4.1.1 Characterization of Operation During and Following AWE Activities .... 11

4.1.2 Occupational Medical Dose ...................................................................... 11

4.1.3 Occupational Internal Dose ....................................................................... 12

4.1.4 External Exposures .................................................................................... 15

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

Potentially Affected DRS .............................................................................................................. 19

6.0 Subtask 4: Conduct Audits of a Sample Set of DRS Affected by DCAS-PER-065 ......... 20

7.0 References ......................................................................................................................... 20

Appendix A: Air Dust Loading Data for American Brass (Anaconda) (SRDB Ref. ID 11452, 

pages 30–32) ............................................................................................................................... 22
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

AEC Atomic Energy Commission

AP anterior-posterior

AWE Atomic Weapons Employer

cm2 square centimeter

d/yr day per year

DCAS Division of Compensation Analysis and Support

DCF dose conversion factor

dpm, d/m disintegrations per minute

dpm/day disintegrations per minute per day

dpm/m2 disintegrations per minute per square meter

dpm/m3

, d/m/M3 disintegrations per minute per cubic meter

DOE (U.S.) Department of Energy 

DOL (U.S.) Department of Labor

DR dose reconstruction

Fi fraction of activity on the hand that is ingested

FUSRAP Formerly Utilized Sites Remedial Action Program

HASL Health and Safety Laboratory

hr/d hours per day

IMBA Integrated Modules for Bioassay Analysis

m meter

m3

/hr cubic meter per hour

m/sec meter per second

MAC maximum allowable concentration

MDL minimum detection limit

MED Manhattan Engineer District

mg milligram

mg/cm2 milligram per square centimeter

mg/m3 milligrams per cubic meter

mg/yr milligram per year

mR/year milliroentgen per year
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mrad/hr millirad per hour 

mrem millirem

mrep/hr millirep per hour 

m/s meters per second

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

PEP Program Evaluation Plan 

PER Program Evaluation Report 

R Roentgen

sec/hr seconds per hour 

SRDB Site Research Database

TBD technical basis document

TIB technical information bulletin

URL Uniform Resource Locator 
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1.0 STATEMENT OF PURPOSE

To support dose reconstruction (DR), the National Institute for Occupational Safety and Health 

(NIOSH) and the Oak Ridge Associated Universities Team (ORAUT) have assembled a large 

body of guidance documents, workbooks, computer codes, and tools. In recognition of the fact 

that all of these supporting elements in DR may be subject to revisions, provisions exist for 

evaluating the effect of such programmatic revisions on the outcome of previously completed 

DRs. Such revisions may be prompted by document revisions due to new information, 

misinterpretation of guidance, changes in policy, and/or programmatic improvements. 

The process for evaluating potential impacts of programmatic changes on previously completed 

DRs has been proceduralized in OCAS-PR-008, Preparation of Program Evaluation Reports 

and Program Evaluation Plans, Revision 02, (NIOSH 2006a), dated December 6, 2006. This 

procedure describes the format and methodology to be employed in preparing a Program 

Evaluation Report (PER) and a Program Evaluation Plan (PEP). 

A PER provides a critical evaluation of the effect(s) that a given issue/programmatic change may 

have on previously completed DRs. This includes a qualitative and quantitative assessment of 

potential impacts. Most important in this assessment is the potential impact(s) on the probability 

of causation (POC) of previously completed DRs with POCs of <50%. 

During the full Board meeting held January 25, 2017, SC&A was directed to perform a review of 

DCAS-PER-065, Anaconda, Revision 0 (NIOSH 2015, hereafter referred to as PER-065). Since 

the site profile (also known as the technical basis document – TBD) for the Anaconda site was 

never reviewed, SC&A was also directed to perform a full review of the site profile for 

Anaconda, as appears in Battelle-TBD-6000 Appendix G, Site Profiles for Atomic Weapons 

Employers that Worked Uranium Metals, Appendix G - Anaconda, Revision 01, dated August 

19, 2014 (NIOSH 2014a, hereafter referred to as TBD-6000-AppG, Revision 01). Section 2 of 

this PER-065 review constitutes a full review of the site profile.

In conducting a PER review, SC&A is committed to perform the following five subtasks, each of 

which is discussed in this report: 

Subtask 1: Assess NIOSH’s evaluation/characterization of the “issue” and its potential 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. 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. In this particular PER review, Subtask 

2 will serve as a site profile review since the Board and SC&A have never reviewed the 

Anaconda site profile. The implications of this review are that, unlike other PER reviews, 
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which focus on changes in the scope and technical approach made by NIOSH from a 

previous site profile to the site profile of interest to the PER, this PER review includes a 

full site profile review. 

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. SC&A will also 

evaluate the timeliness for the completion of the PER.

Subtask 4: Conduct audits of DRs affected by the PER under review. The number of DRs 

selected for audit for a given PER will vary. It is assumed that the selection of the DRs 

and the total number of DR audits per PER will be made by the Advisory Board using 

case selection criteria recommended by SC&A based on the results of Subtask 2. 

Subtask 5: Prepare a written report that contains the results of DR audits under Subtask 4, along 

with our review conclusions. 
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2.0 RELEVANT BACKGROUND INFORMATION

Section G.2 of the Anaconda site profile (TBD-6000-AppG, Revision 01) provides a description 

of the Atomic Weapons Employer (AWE) activities that took place at Anaconda and cites a 

number of references that describe the operations. The original site profile, Battelle-TBD-6000 

Appendix G, Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Appendix G – Anaconda Co., Revision 0, dated April 30, 2007 (NIOSH 2007, hereafter 

referred to as TBD-6000-AppG, Revision 0), provides similar material describing the site and its 

activities.

SC&A reviewed these citations and confirmed the completeness and accuracy of the description 

of AWE and post-AWE activities that are described in Section G.2 of the site profile. In 

summary, the Anaconda site (formerly known as the American Brass Company) located in 

Westbury, Connecticut, was first employed by the Manhattan Engineer District (MED, the 

predecessor to the Atomic Energy Commission [AEC]) to help in the development of gaseous 

diffusion barriers for use in uranium enrichment. These activities did not involve radioactive 

materials. However, in 1956, Anaconda was involved in a pilot project where four copper-clad 

uranium billets were extruded to evaluate uranium extrusion procedures to manufacture uranium 

fuel that could be used in support of weapons development. It is reported that these extrusion 

activities were performed over a one-hour time period. These pilot studies were followed by 

additional extrusions involving what appeared to be limited to 10 billets, although the original 

plan was to extrude 500 billets. In October 1959, as many as an additional 50 billets were 

extruded at an estimated rate of four billets per hour, for a total of 12.5 hours. 

It is apparent that these uranium metal-handling activities were not full production activities, as 

were performed at many other AWE facilities at that time (e.g., Bethlehem Steel) and involved 

relatively short run times and a limited number of workers. The site profile explains that the 

following assumptions are used as the basis for DR during AWE operations at Anaconda: 

1. The 1956 pilot study took place on September 29, 1956, and required 1 full 8-hour shift 

to perform.

2. 50 billets were extruded in March 1957, and required two full 8-hour shifts. 

3. Extrusion activities took place from October 19 to October 21, 1959, and required three 

full 8-hour shifts. 

TBD-6000-AppG, Revision 01 also explains that it is assumed that any individual worked only 8 

hours during a given shift. 

3.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR DCAS-PER-065

As explained in the “Record of Issues Resolution” section of the Anaconda site profile, TBD6000-AppG, Revision 0 was issued on April 30, 2007, and TBD-6000-AppG, Revision 01 was 

issued August 19, 2014. In both cases, the site profile was based on guidance provided in the 

contemporaneous versions of Battelle-TBD-6000 (Battelle-TBD-6000, PNWD-3738, Site 

Profiles for Atomic Weapons Employers that Worked Uranium and Thorium Metals, Revision 0, 
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dated December 13, 2006 [NIOSH 2006c, hereafter referred to as TBD-6000, Revision 0] and 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Metals, Revision 

01, dated June 17, 2011 [NIOSH 2011b, hereafter referred to as TBD-6000, Revision 01]). When 

TBD-6000 was revised, it was necessary to revise the Anaconda site profile, TBD-6000-AppG, 

which necessitated NIOSH issuing PER-065. 

Like many uranium-handling AWEs, DRs for workers at Anaconda were based primarily on 

TBD-6000 (NIOSH 2006c, NIOSH 2011b), and took into consideration the types of uraniumhandling activities at the facility, the worker job categories, the amount of uranium handled, the 

time period when the AWE activities took place, the potential and nature of exposures that took 

place during inactive AWE time periods when no AWE operations took place (i.e., time periods 

when the facility resumed its non-AWE operations, such as working with steel), and time periods 

following the termination of AWE operations (the residual period). 

Inspection of the original and revised site profiles for Anaconda reveals that the major changes 

made in the revision reflect corresponding changes to TBD-6000. Therefore, to understand the 

major changes that were made to the site profile for Anaconda, it is necessary to understand the 

changes that were made to TBD-6000 from Revision 0 (December 13, 2006) to Revision 01 

(June 17, 2011). 

A description of the revision made in going from Revision 0 to Revision 01 of TBD-6000 is

conveniently described in DCAS-PER-055, TBD-6000 Revision, Revision 0, September 12, 2014 

(NIOSH 2014b, hereafter referred to as PER-055), as follows: 

First, Table 3.10 contains conversion factors to determine the beta and gamma 

dose rates from uranium surface contamination. The photon value was 

recalculated in revision 1 causing a slight decrease. A beta dose rate value was 

added that did not exist in revision 0. 

The second change is that revision 0 estimated surface contamination from 

airborne activity by allowing it to settle. For internal dose, the calculation 

assumed the airborne settled for 365 days continuously. However, for external 

dose, some, but not all, the calculations assumed the airborne settled for only 7 

days. During a review of TBD-6000, it was determined that a 30 day settling time 

was appropriate and revision 1 used this value. 

In Table 5.1 and the same value summarized in Table 5.3, the external dose from 

surface contamination was based on 365 days of settling. As a result, the photon 

values in these tables decreased in revision 1. Beta dose was not accounted for in 

revision 0 but is included in revision 1. Therefore, the new beta doses included in 

these tables will result in increased reconstructed doses over revision 0. . 

In Table 6.4, the photon dose from contamination is higher in revision 1 due to 

the dose in this table being based on 7 days of settling. The beta dose is also 

higher in this table because revision 0 did not account for beta dose from 

contamination. 
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As a result of these changes, claims with external dose that was calculated from 

surface contamination could need to be re-evaluated. 

Though not explicitly addressed in PER-055, ORAUT-OTIB-0070, Dose Reconstruction during 

Residual Radioactivity Periods at Atomic Weapons Employer Facilities, Revision 01, March 5, 

2012 (NIOSH 2012, hereafter referred to as OTIB-0070), has applicability to the site profile for 

Anaconda with respect to exposure to residual radioactivity. OTIB-0070 applies to periods of 

time when AWE activities were not underway, and therefore, would apply at Anaconda 

following the termination of AWE activities. This is an important change to NIOSH guidance 

pertinent to AWE facilities that should also have necessitated a PER for Anaconda, even though 

it is not stated as such in PER-065. 

Another important change in guidance that might have applicability to the Anaconda PER-065 is 

revisions to the methods by which doses associated occupational medical exposures are 

reconstructed (i.e., medical x-ray examinations in ORAUT-OTIB-0006 Dose Reconstruction 

from Occupational Medical X-ray Procedures, Revision 04, June 20, 2011 [NIOSH 2011a, 

hereafter referred to as OTIB-0006]). This potentially applicable DR guidance is not explicitly 

referred to in the “Record of Issues Resolution” section of the Anaconda site profile, but is 

addressed in this PER-065 review.

It is important to note that the latest revisions to TBD-6000, OTIB-0070, and OTIB-0006 were 

reviewed and approved by the Board. Hence, the primary objectives of this PER-065 review are

to ensure that: (1) the assumptions used to define worker exposure scenarios that are specific to 

Anaconda are reflected in the PER and its supporting TBD, (2) any Anaconda-specific data 

pertinent to reconstructing external, internal, and medical exposure are reflected in the PER and 

its supporting TBD, and (3) any exposure scenarios that required the use of TBD-6000, OTIB0070, and/or OTIB-0006 are reflected in TBD-6000-AppG as used in support of the PER. 

4.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

SC&A reviews the site profile in this section, including comparing the original and revised 

versions, to: 

1. Ensure that the revised TBD-6000-AppG completely and accurately describes the AWE 

and post-AWE activities that took place at Anaconda. 

2. Ensure that the revision is complete in terms of reflecting all the site-specific information 

and data applicable to performing dose reconstructions. 

3. Ensure that the revision is complete in terms of taking into consideration the most recent 

generic guidance that might be applicable to DRs at Anaconda (i.e., TBD-6000, OTIB0070, and OTIB-0006). 

4. Ensure that TBD-6000-AppG makes use of all applicable information, data, and guidance 

in a scientifically sound and claimant-favorable manner.

These lines of inquiry represent a site profile review.
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4.1 SITE-SPECIFIC INFORMATION AND GUIDANCE

4.1.1 Characterization of Operation During and Following AWE Activities 

Section 3.0 summarizes the AWE and post-AWE activities that took place at Anaconda as 

described in the site profile. 

SC&A’s Comments 

The site profile description of AWE and post-AWE activities, as well as other important 

information for DR at Anaconda, rely on descriptive and quantitative information contained in 

cited sources that appear in the Reference section of the site profile. SC&A examined each of 

these data sources and found that the site profile accurately extracted and interpreted the 

information. In addition, SC&A examined all the data sources contained in the site research 

database (SRDB) returned by a search on “Anaconda” that were not cited in the site profile to 

determine if they contained any relevant additional information or contradicted any information 

relied upon in the site profile. In all cases, SC&A found that the information from these noncited data sources corroborated the information from the cited data sources.1

1 Eighty-three documents appeared under “Anaconda” in the SRDB as of the date of this report.

Observation #1. SC&A identified one minor discrepancy in reviewing the references. The correct 

uniform resource locator (URL) for the cited “U.S. Department of Energy website” (“DOE 

website”) is: https://ehss.energy.gov/search/facility/findfacility.aspx. SC&A recognizes that the 

DOE URL might have changed since NIOSH issued the site profile. 

4.1.2 Occupational Medical Dose

With respect to occupational medical exposures, Section G.3 of the site profile (TBD-6000-

AppG, Revision 01) explains the following: 

No detailed information regarding occupational medical dose was found in any of 

the site research or telephone interviews. Information to be used in dose 

reconstructions, for which no specific information is available, is provided in 

ORAUT-OTIB-0006, the technical information bulletin covering diagnostic x-ray 

procedures. This estimate will assume each employee received one AP chest x-ray 

each year of the covered period which includes 1942 as well as 1956 through 

1959. 

Based on SC&A’s understanding of NIOSH’s policy regarding medical x-ray exposure, workers 

at AWE facilities are not presumed to have been required, as a condition of employment, to 

receive annual x-ray examinations unless there is affirmative evidence that such exposures were 

actually part of the AWE’s contract with the government and the examinations were performed 

at the facility. However, all 17 of the appendices of TBD-6000 have guidance similar to that for 

Anaconda, as referenced above. Table 2 in Section 5 of this report shows that annual 

occupational medical doses were assigned for all of the non-compensable overestimate and best 

estimate DR cases performed to date for Anaconda. All of the TBD-6000 appendices recommend 

that dose reconstructors assign occupational medical dose for individuals who worked during the 

 
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covered periods at those AWE facilities using the guidance in OTIB-0006. This represents a 

consistent and claimant-favorable procedure. SC&A has no findings regarding the assignment of 

occupational medical dose. 

4.1.3 Occupational Internal Dose

Section G.4 of TBD-6000-AppG, Revision 01 describes the data and methods used by NIOSH to 

reconstruct internal exposures to workers at Anaconda. This information is not repeated here. In 

summary, the TBD explains that the Health and Safety Laboratory (HASL) monitored airborne 

dust concentrations of uranium during AWE operations in 1956 and 1959. The data consisted of 

both general air samples and breathing zone concentrations at the location of sawing operations. 

Internal Exposures During Extrusion Operations

Based on the reported data, NIOSH assumes that workers involved in extrusion operations were 

exposed to airborne uranium concentrations of 39 disintegrations per minute (dpm) per cubic 

meter (dpm/m3

) and makes standard assumptions regarding inhalation and ingestion rates and 

durations. For time periods between AWE operations, NIOSH assumes that workers are exposed 

to uranium deposited on surfaces and includes both external exposures and inhalation and 

ingestion internal exposures from resuspended uranium. 

SC&A’s Comments

SC&A briefly reviewed all 83 documents on the SRDB that are associated with the Anaconda 

facility. SRDB Ref. ID 9363 contains a letter dated December 2, 1959, from Harold Glauberman 

of the Field Services Branch to A.J. Breslin, Chief of the Field Services Branch. The letter, 

which is reproduced below, describes the types of surveys performed at Anaconda during the 

October 1959 operations and summarizes the results. It also makes reference to the survey 

performed following the October 1956 operation. 

General air samples were obtained around the press area and associated 

operations. Breathing zone samples were taken of the sawing, drilling and 

deburring operations as well as a few operations in the press area. Measurements 

of alpha surface contamination and beta air dose rate were obtained in a number 

of locations. 

Air samples and radiation measurements are listed in the attached tables. As in 

our previous survey of October 2, 1956, all samples were below the MAC; the 

highest concentration was 39 d/m/M3. In approximately 1/3 of the samples, no 

alpha activity was detected. 

Breathing zone concentrations at the sawing operations were nil, the average 

breathing zone concentrations at the drilling and deburring operation was 5 

d/m/M3

. The average general air concentration was 3.3 d/m/M3 in the vicinity of 

the press and adjacent areas and 0.3 d/m/M3 in the saw, drill and testing areas. 

Direct radiation measurements of surfaces for alpha contamination ranged from 

background (<200 d/m/100 cm2

) to 600 d/m/100 cm2, with the latter value found 
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at the die cutting station and the table adjacent to the Lindberg furnace. Beta 

radiation intensities at the billet storage area were 19 mrep/hr at one foot. 

Similar intensities were found near the extruded tubes on the run-out table and in 

the testing area. 

Summary 

Exposures to airborne alpha emitting dust are well below the permissible 

concentration. Surface contamination is confined to a few locations and is 

insignificant. Significant beta radiation intensities are to be found in the vicinity 

of uranium billets and tubes as would be expected. Although employees 

apparently remain in these areas for only short periods of time, there is potential 

exposure to direct radiation. An estimate of exposure could be obtained by issuing 

film badges for a few weeks. The need for continuing the service could be decided 

on the basis of the film data. 

Attachments: Tables I and II 

This document (Glauberman 1959) specifically states that the highest airborne dust loading 

observed was 39 dpm/m3

 and a substantial fraction of the airborne dust concentration 

measurements were below the minimum detection limit (MDL). Although the letter does not 

specify whether this was a general air or breathing zone sample, the recommendation of the 

highest measured value is claimant favorable. This letter does indicate that all of the air sample 

and radiation measurements were attached in two tables. However, SC&A could not find these 

data tables in this or any other SRDB document. Even though the use of 39 dpm/m3 appears 

sound and claimant favorable, a review of these air sampling data, if available, would reinforce 

the assumptions used in the TBD. Another document that was found during our research, Data 

Analysis Results 1947 Through 1961, SRDB Ref. ID 11452, is a compilation of all data analysis 

results at AWE facilities from 1947–1961. Pages 30 through 32 of that document are raw data air 

sampling results taken at Anaconda (referred to here as American Brass) but the data are not 

dated and most of the entries are illegible. They are included here as Appendix A. 

Internal Inhalation Exposures from Resuspension between AWE Campaigns

The internal inhalation exposures from resuspension between AWE campaigns are derived using 

the following data and assumptions: 

1. The measured general airborne concentration of the 39 dpm/m3 during uranium extrusion 

operations. 

2. A deposition velocity of 0.00075 meters per second (m/sec) for a 96-hour extrusion 

campaign, with no cleanup or natural attenuation. 

3. On this basis, the surface contamination level is assumed to be 10,109 dpm per square 

meter (dpm/m2) from 1956 through 1959. 

4. A resuspension factor of 1.0E-5/m, resulting in a chronic airborne uranium concentration 

from resuspension of 0.1 dpm/m3 during non-AWE operations. 
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SC&A’s Comments

These assumptions are scientifically sound and claimant favorable in light of our review of the 

site-specific AWE operation and air sampling data and the basic approach used in OTIB-0070 

for deriving residual surface contamination and resuspension of uranium following the 

termination of an AWE operation. The following presents the calculations that we believe were 

used by NIOSH to derive the airborne dust loadings during the time periods from 1956 through 

1959, when no extrusion activities were performed.

39 dpm/m3 × 0.00075 m/sec × 96 hr × 3,600 sec/hr = 10,109 dpm/m2

10,109 dpm/m2 × 1.0E-5/m = 0.1 dpm/m3

SC&A considers the last value claimant favorable because the highest dust loading of 39 dpm/m3

was used, when a more central value could have been used. A campaign duration of 96 hours 

was assumed, which is equivalent to 4 consecutive days of AWE operations; i.e., a long period 

compared to the duration of any of the individual extrusion campaigns. In addition, no credit is 

taken for natural attenuation of deposited uranium, and a reasonably conservative resuspension 

factor of 1.0E-5/m was employed. Taken in combination, these assumptions are plausible and 

claimant favorable in terms of deriving inhalation exposures in the time period between 

extrusion operations. 

Internal Ingestion Exposures between AWE Campaigns

Table G-1 of the site profile (TBD-6000-AppG, Revision 01) recommends an inadvertent 

ingestion rate of 5.34 dpm/day from inadvertent ingestion of deposited activity for each 8-hour 

shift. 

SC&A’s Comments 

Ingestion exposures during operations are derived using OCAS-TIB-009, Estimation of Ingestion 

Intakes, Revision 0, April 13, 2004 (NIOSH 2004). This procedure has been reviewed and 

approved by the Board for deriving inadvertent ingestion exposures to uranium during uraniumhandling operations. The basic approach is based on a model that assumes the following: 

The amount of activity ingested on a daily basis can be approximated by 

assuming it to be 0.2 times the activity per cubic meter of air. The [Fi] value for 

the ingestion should be the same as that used for inhalation 

Therefore, the inadvertent ingestion rate should be derived as follows: 

39 dpm/m3

 × 0.2 × 250/365 = 5.3 dpm/day 

The adjustment factor of 250/365 accounts for the fact that the input for Integrated Modules for 

Bioassay Analysis (IMBA), used to derive annual doses, assumes exposures for 365 days per 

year, while the actual exposures would be limited to 250 days per work year (assuming full-time 

employment). This value closely matches the value in Table G-1 of the site profile (TBD-6000-

AppG, Revision 01) of 5.34 dpm/day, and is claimant favorable, because it would apply to 
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inadvertent ingestion during AWE operations, when, in fact, the amount of deposited activity on 

surfaces would decline due to natural attenuation once uranium handling operations ceased. 

4.1.4 External Exposures

Table G.2 of the site profile (TBD-6000-AppG, Revision 01) presents the annual external 

exposures for 1956 through 1959, taking into consideration the duration of uranium-handling 

operations in each year as described above. The following is quoted directly from Table G.2 of 

the site profile:

Table G.2 – External Dose [NIOSH 2014a] 

Year Photon (mR/year) Beta – whole body 

(mrem/year)

Beta – hands and 

forearms (mrem/year)

1956 8.3 84 921

1957 16.6 167 1841

1958 0.008 0.77 0.77

1959 25.0 250 2761

SC&A’s Comments

Section G.5 of TBD-6000-AppG, Revision 01 explains that beta radiation surveys performed by 

HASL in 1959 observed exposure rates of 19 millirep per hour (mrep/hr) at one foot from billets 

and 6 mrep/hr at 3 feet from the billets, where a mrep can be considered equivalent to a mrem 

(Glauberman 1959).2

 The Glauberman memo also reports on alpha radiation measurements (not 

mentioned in the site profile):

Direct radiation measurements of surfaces for alpha contamination ranged from 

background (<200 d/m/100 cm2) to 600 d/m/100 cm2, with the latter value found 

at the die cleaning station and the table adjacent to the Lindberg 

furnace....Exposures to airborne alpha emitting dust are well below the 

permissible concentration. Surface contamination is confined to a few locations 

and is insignificant. 

2 Glauberman 1959 also notes that “Similar intensities were found near the extruded tubes on the run-out table and 

in the testing area”; this is not mentioned in the site profile.

The site profile (TBD-6000-AppG, Revision 01) also estimated the external exposure rates using 

the generic values adopted in TBD-6000, Revision 01, which has been thoroughly reviewed and 

approved by the Board. Given that TBD-6000 provides a more complete and thorough 

characterization of the radiation fields and exposure rates in the vicinity of uranium metal at 

uranium metal handling facilities and that these values are comparable to or more claimant 

favorable than the measured dose rate data reported by HASL for this facility, NIOSH elected to 

use the exposure and dose rate data provided in TBD-6000, Revision 01, as the basis for deriving 

external exposures at Anaconda. 

 
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Using TBD-6000, Revision 01, values as their basis, the site profile makes the following basic 

assumptions for deriving external exposure rates to operators near uranium metal at Anaconda. 

1. An external photon exposure rate of 2.08 millirem per hour (mrem/hr) and external beta 

exposure rate of 20.8 mrem/hr at 1 foot from uranium metal. 

2. An external skin exposure rate from beta exposure in contact with the uranium metal of 

230 mrem/hr. 

3. Operators are exposed at 1 foot from the metal and their hands are in direct contact with 

the metal for 50% of a work day for each 8-hour work shift that a worker is involved with 

uranium handling (i.e., operators).

4. Operators are also exposed to residual surface contamination, as recommended in Table 

3.10 of TBD-6000, Revision 01, every working day from 1956 through 1959. Note that 

Table 3.10 recommends a photon dose conversion factor (DCF) of 3.9E-10 milliroentgen 

per hour (mR/hr) per dpm/m2 and a beta exposure rate DCF of 3.82E-8 millirad per hour 

(mrad/hr) per dpm/m2 at 1 meter above a contaminated circle of with a 100-meter radius 

and with natural uranium aged 100 days (i.e., sufficient time for the short-lived progeny 

of uranium to grow in). 

These assumptions are consistent with those recommended in TBD-6000, Revision 01. For 

example, Table 6.1 of TBD-6000, Revision 01, recommends an external whole-body penetrating 

dose rate of 2.08 mrem/hr at one foot from a rectangular ingot. Section 6.3 of TBD-6000, 

Revision 01, recommends the following: “The 7 mg/cm2

 dose from non-penetrating radiation 

when the skin is in contact with an unshielded slab of uranium metal is 230 mrem/hour.” 

Section 6.2 of TBD-6000, Revision 01, also recommends the following assumption regarding 

exposure duration for different categories of workers: 

a worst-case assumption should be made, which is that all work was done with a 

uranium metal slab, and the following assumptions are made about a worker’s 

exposure conditions: 

• Operator: 50% of the workday was spent at 1 foot from the surface of 

the metal 

• General Laborer: 50% of the workday was spent at 1 meter from the 

metal surface 

• Supervisor: exposure was equal to 50% of a general laborer’s 

exposure 

• Clerical: exposure was equal to 10% of a supervisor’s exposure. 

Section 6.3 also recommends the following: 

Exposure assumptions for hands-on contact with uranium metal for the four job 

categories assumes: 
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• Operator: 50% of the workday was spent with hands in contact with the 

surface of the metal 

• General Laborer: exposure would be 50% of the exposure of the operator 

• Supervisor: exposure would be 10% of the exposure of the general laborer 

(assuming the supervisor seldom has a reason to touch metal) 

• Clerical: 0 (assuming the clerical worker has no reason to touch metal) 

Hence, the site profile and its associated PER-065 for Anaconda use fundamental assumptions 

and DCFs that have been reviewed by the Board and found to be scientifically sound and 

claimant favorable. 

Given these basic assumptions and DCFs, the site profile assigns the external annual exposures 

to Anaconda workers as shown in Table G.2 of the site profile (see above), which takes into 

consideration the number of shifts that operators performed AWE operations in 1956 through 

1959. As discussed above, based on the actual records of extrusion operations at Anaconda, the 

site profile uses the following assumptions to derive annual exposures during extrusion 

operations: 

1956: One 8-hour shift on September 29, 1956 

1957: Two 8-hour shifts in March 1957 

1958: No AWE operations in 1958 

1959: Three 8-hour shifts between October 19th and October 21st in 1959 

For example, for 1956, Table G-2 assigns a whole-body photon dose of 8.3 mR/year, a beta dose 

(at a distance of 1 meter) of 84 mrem/yr, and beta hands and forearm dose of 921 mrem/yr. The 

following is an attempt to match these values:

8 hours/yr × 2.08 mrem/hr × 0.5 = 8.3 mrem/yr for external whole-body dose from a billet during 

an 8-hour extrusion operation. This value closely matches the photon dose for 1956 in Table G.2 

of the site profile. Our calculations show that the external photon dose from deposited residual 

radioactivity is negligible. Also note that the photon doses associated with extrusion operations 

are directly proportional to the number of shifts each year when extrusion operations were 

performed. Hence, SC&A concurs with the annual exposures derived by NIOSH to reconstruct 

photon exposures during extrusion operations from 1956 through 1959, as provided in Table G.2 

of the site profile. 

Section G.5 of the site profile indicates that the beta dose at 1 foot from an ingot is 20.8 mrem/hr, 

or about 10 times the photon dose, which is a reasonable value. Hence, a beta dose at 1 foot of 84 

mrem/yr is appropriate for 1956. A contact beta skin dose of 921 mrem/yr for 1956 is considered 

plausible, since previous uranium metal investigations revealed the contact skin dose (primarily 

from beta emissions) of 230 mrem/hr. Hence, assuming exposure for 50% of the time during a 1-

hour shift yields a contact beta dose of 230 mrem/hr × 4 hrs = 920 mrem, which is essentially 

identical to the value reported in Table G.2 of the site profile. 
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With respect to external exposures in 1956, due to residual radioactivity, Section G.4 of the site 

profile explains that a simple bounding approach was used, as described in Section G.4. This 

approach assumes that, for the entire four-year period of AWE operations, the level of residual 

surface contamination was assumed to be 10,109 dpm/m2. Using this bounding assumption, we 

obtain the following penetrating and non-penetrating dose due to residual surface contamination: 

Penetrating 

10,109 dpm/m2 × 3.94E-10 mrem/hr per dpm/m2 × 8 hr/day × 250 days/yr = 7.9E-3 

mrem

Non-Penetrating 

10,109 dpm/m2

 × 3.82E-8 mrem/hr per dpm/m2 × 8 hr/day × 250 days/work year = 0.77 

mrem

These exposures to residual surface contamination are negligible as compared to the exposures 

associated with handling a billet and can be ignored. 

For time periods where extrusion operations were not being performed, there was the potential 

for external exposures from residual radioactivity. However, as described in Section G.6 of the 

site profile (TBD-6000-AppG, Revision 01), 

Residual contamination potentially existed between operations with uranium at 

Anaconda. However, surveys showed the potential was low and so no residual 

contamination period was designated after 1959. The periods between operations 

is[sic] accounted for in a favorable manner in sections G.4 and G.5. Also, since 

there was no radioactive material associated with the operations described for 

1942, no residual contamination is assumed prior to 1956.

Several sources corroborate this statement, including one reporting on elimination of the 

Anaconda site from the Formerly Utilized Sites Remedial Action Program (FUSRAP):

The Anaconda Company site was surveyed by the Health and Safety Laboratory 

(HASL) during 1956 and 1959. All radiation levels associated with the AEC 

operations were found to be within typical background levels for Connecticut. The 

Director of the Division of Remedial Action determined that the radiation levels 

are below the criteria for remedial action and the Anaconda Company site is to 

be terminated from the Formerly Utilized Sites Remedial Action Program for 

unrestricted use (Coffman undated). 

SC&A concurs with the methods used in the site profile for reconstructing external penetrating 

and non-penetrating exposures.
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5.0 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE UNIVERSE OF POTENTIALLY AFFECTED 

DRS

Section 3.0 of PER-065 states that all DRs with POCs less than 50% will be revisited under this 

PER and that 10 claims were identified. SC&A concurs with this comprehensive approach to 

reevaluating cases associated with this PER.

SC&A reviewed all the Anaconda DRs and found a total of 14 cases in various stages of 

completion. Of these 14 cases, SC&A identified a total of 10 claims with a POC <50%, one 

claim which was compensated and 3 cases which were not completed. Table 1 below 

summarizes the 14 Anaconda claims. 

Table 1. Anaconda Claims

Case 

ID

Date DR 

completed

Target 

organ(s)

Assigned 

dose (rem)

POC PER-065 

status

Assigned 

X-ray

Procedures Used

2004 colon 34.965 38.47% no records annual no TBD-6000

2006 bile duct 1.42 40.26% no records annual no TBD-6000; OTIB-6

2004 red bone 

marrow

75.7 46.94% No 

records

annual OTIB-4, OTIB-6

2004, 2007 pancreas, 

kidney

0.367, 

0.367

1.49% no records annual TBD-6000, OTIB-6, 

PROC-61

2007 lung 0.381 1.19% no records annual TBD-6000, OTIB-6 

2005 vocal 

cords

2246 94.64% no records no OTIB-4 

2004 prostate 33.215 24.45% no records annual OTIB-4

2004 colon 28.52 28.20% no records annual OTIB-4

2007 prostate 10.812 0.53% no records annual TBD-6000, OTIB-4, 

OTIB-6, PROC-61

2008 lung 0.168 0.45% no records annual TBD-6000, OTIB-6

2009 prostate 0.139 0.27% pulled annual TBD-6000, OTIB-7

n/a colon, 

SCC, 

BCC

n/a n/a pulled n/a claim submitted but DR 

not completed, no files 

on NOCTS

n/a BCC, 

colon

n/a n/a pulled n/a claim submitted but DR 

not completed, no files 

on NOCTS

n/a colon 0.179 <50% n/a n/a Final DOL decision not 

on file

SC&A’s Comments

The information on the NIOSH OCAS Claims Tracking System (NOCTS) site did not appear to 

include the PER status of the 14 cases. There are no findings pertaining to the selection criteria 

used to identify claims potentially affected by PER-065 and the need for re-evaluation of doses 

for these claims.
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6.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DRS

AFFECTED BY DCAS-PER-065

Based on information presented in Subtasks 1 through 3, SC&A recommends the selection of 

three (3) cases with significant employment periods as operators/laborers for the time period 

1956 through 1959. In addition, the cases should be selected such that we can evaluate the degree 

to which the DR methodologies employed the most recent guidance provided in TBD-6000, 

Revision 01 (for the time periods involving uranium extrusion operations), OTIB-0070 (for the 

time periods between extrusion operations), and OTIB-0006 (to ensure that the assigned doses 

associated with occupational medical x-ray examinations followed the most recent revision to 

OTIB-0006). 

7.0 REFERENCES

Coffman undated. F.E. Coffman, Statement of Certification, Director Office of Terminal Waste 

Disposal and Remedial Action, U.S. Department of Energy, undated. [SRDB Ref. ID 85958] 

Glauberman 1959. Memo from Harold Glauberman to A.J. Breslin, Survey at American Brass 

Company, Waterbury, Connecticut, December 2, 1959. (SRDB Ref. ID 9363, pp. 7 & 8). 

NIOSH 2004. Estimation of Ingestion Intakes, OCAS-TIB-009, Revision 0, National Institute of 

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

Ohio. April 13, 2004. 

NIOSH 2006a. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

OCAS-PR-008, Revision 2, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. December 6, 2006. 

NIOSH 2006b. Estimating the Maximum Plausible Dose to Workers at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0004, Revision 03 PC-2, Oak Ridge Associated 

Universities, Cincinnati, Ohio. December 6, 2006. [Cancelled July 12, 2012.] 

NIOSH 2006c. Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Battelle-TBD-6000, PNWD-3738, Revision 0, National Institute for Occupational Safety 

and Health, Division of Compensation Analysis and Support, Cincinnati, Ohio, December 13, 

2006. 

NIOSH 2007, Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Appendix G – Anaconda Co., Battelle-TBD-6000 Appendix G, Revision 0, National 

Institute for Occupational Safety and Health, Division of Compensation Analysis and Support, 

Cincinnati, Ohio, April 30, 2007. 

NIOSH 2010. Occupational Medical X-ray Dose Reconstruction for DOE Sites, ORAUT-PROC0061, Revision 03, Oak Ridge Associated Universities, Cincinnati, Ohio. March 3, 2010. 

NIOSH 2011a. Dose Reconstruction from Occupational Medical X-ray Procedures, ORAUTOTIB-0006, Revision 04, Oak Ridge Associated Universities, Cincinnati, Ohio. June 20, 2011. 
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NIOSH 2011b. Site Profiles for Atomic Weapons Employers that Worked Metals, Battelle-TBD6000, Revision 01, National Institute for Occupational Safety and Health, Division of 

Compensation Analysis and Support, Cincinnati, Ohio. June 17, 2011. 

NIOSH 2012. Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0070, Revision 01, Oak Ridge Associated Universities, 

Cincinnati, Ohio. March 5, 2012. 

NIOSH 2014a. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, 

Appendix G – Anaconda, Battelle-TBD-6000, Appendix G, Revision 01, National Institute for 

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

Ohio. August 19, 2014. 

NIOSH 2014b. TBD-6000 Revision, DCAS-PER-055, Revision 0, National Institute for 

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

Ohio. September 12, 2014. 

NIOSH 2015. Anaconda, DCAS-PER-065, Revision 0, National Institute for Occupational 

Safety and Health, Division of Compensation Analysis and Support, Cincinnati, Ohio. November 

30, 2015. 

U.S. AEC (Atomic Energy Commission) Undated. Data Analysis Results 1947 Through 1961, 

U.S. Atomic Energy Commission, New York Operations Office Health and Safety Division, 

New York, New York. Undated. [SRDB Ref. ID: 11452]
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APPENDIX A: AIR DUST LOADING DATA FOR AMERICAN BRASS

(ANACONDA) (SRDB REF. ID 11452, PAGES 30–32)

Figure 1. Example 1 of Illegible Anaconda Air Dust Loading Data 

Figure 2. Example 2 of Illegible Anaconda Air Dust Loading Data 
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Figure 3. Example 3 of Illegible Anaconda Air Dust Loading Data