Draft

ISSUE RESOLUTION MATRIX FOR

SC&A FINDINGS ON PETION EVALUATION REPORT FOR 

JOSLYN SEC PETITION 00200

S. Cohen & Associates

1608 Spring Hill Road

Suite 400

Vienna, VA 22182

Original Date: December 18, 2013

Disclaimer

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

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

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

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

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

information only and that premature interpretations regarding its conclusions are unwarranted.
Draft Joslyn PER Issues Matrix 2 SC&A – December 18, 2013

NOTICE: This December 18, 2013, issues matrix has been clear for public distribution. Please note that future 

versions of this matrix will require another review for PA-protected information prior to public release.

INTRODUCTION

This document presents an issues matrix based on SC&A’s Review of Joslyn Manufacturing and 

Supply Company Petition Evaluation Report for Special Exposure Cohort (SEC) Petition 00200

dated March 2013. NIOSH has not yet commented on this matrix nor has it been discussed in 

any Work Group meetings. However, SC&A had the opportunity to develop additional 

information relevant to its findings on Joslyn during the preparation of a report on TBD-6000 

entitled, Supplementary Comments on Revision 01 of Battelle-TBD-6000. In particular, new 

information on uranium pit burning, floor sweeping and chip fires was generated. As discussed 

in Section 5 of that report, SC&A concluded that exposures from these sources were within the 

bounds specified in TBD-6000. Consequently, SC&A proposes to modify Issue 6 below 

eliminating any reference to Finding 8 and to completely eliminate Issue 8 below. 

Time Line of Joslyn PER Issues Matrix:

 December 3, 2012: NIOSH (2012) issued SEC Petition Evaluation Report SEC-00200, 

Joslyn Manufacturing. 

 March 28, 2013: SC&A (2013a) issued Review of Joslyn Manufacturing and Supply 

Company Petition Evaluation Report for Special Exposure Cohort (SEC) Petition 

00200.

 May 27, 2013: SC&A (SC&A 2013b) issued Supplementary Comments on Revision 01 

of Battelle-TBD-6000 (PA-cleared version). 

 December 18, 2013: SC&A distributed this “Issue Resolution Matrix for SC&A 

Findings on Petition Evaluation Report for Special Exposure Cohort Petition 00200 for 

Joslyn Manufacturing and Supply Company,” which lists 11 issues. These issues were 

taken from the list of 11 findings1presented in the executive summary of SC&A 2013.

 

1

 The “findings” in the earlier report are presented as “issues” in the present document. 
Draft Joslyn PER Issues Matrix 3 SC&A – December 18, 2013

NOTICE: This December 18, 2013, issues matrix has been clear for public distribution. Please note that future 

versions of this matrix will require another review for PA-protected information prior to public release.

Issue Resolution Matrix for SC&A Findings on Petition Evaluation Report for Special 

Exposure Cohort Petition 00200 for Joslyn Manufacturing and Supply Company

Issue 1: Incorrect Units of Measure

SC&A Finding: The units of measure for the data from Klevin (1952) in Table 6-1 are cited as 

pCi/m3, but the presented information is based on dpm/m3.

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 2: Incorrect Units of Measure

SC&A Finding: The units of measure in Table 6-2 should be dpm/m3, not pCi/m3.

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 3 – Basis for Start Date

SC&A Finding: NIOSH should document the basis for assuming that 1948 is the starting date 

for the site surveys upon which TBD-6000 is based. The 1948 date needs to be affirmatively 

established in order to ensure that the TBD-6000 data are claimant favorable.

NIOSH Response:

Board Action:

SC&A Observation Status:
Draft Joslyn PER Issues Matrix 4 SC&A – December 18, 2013

NOTICE: This December 18, 2013, issues matrix has been clear for public distribution. Please note that future 

versions of this matrix will require another review for PA-protected information prior to public release.

Issue 4 – Correction of Table 7-1

SC&A Finding: Table 7-1 needs to be corrected to assure that comparable units are used 

throughout, and that 1952 air concentrations from TBD-6000 are based on 2,200 work hours per 

year.

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 5 – Correction of Table 7-2

SC&A Finding: Typographical and calculational errors in Table 7-2 should be corrected.

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 6 – Use of TBD-6000 for Dose Reconstruction Not Sufficiently Prescriptive

SC&A Finding: The NIOSH approach for reconstructing internal doses due to metal-working 

operations at Joslyn for 1948 through 1952 appears reasonable for routine exposures. 

However, we have concerns that the exposure matrix does not adequately describe how the dose 

reconstruction methods in TBD-6000 are to be applied. In addition, as developed further under 

Finding 8, we have concerns regarding the degree to which the surrogate values in TBD-6000 

adequately account for exposures associated with outdoor uranium pit burning and with 

incidents such as uranium chip fires. [Note that the concerns regarding out door pit burning 

have been resolved (see introduction). Hence, we recommend closing this aspect of this issue.]

NIOSH Response:

Board Action:

SC&A Observation Status:
Draft Joslyn PER Issues Matrix 5 SC&A – December 18, 2013

NOTICE: This December 18, 2013, issues matrix has been clear for public distribution. Please note that future 

versions of this matrix will require another review for PA-protected information prior to public release.

Issue 7 – Uncertainty in Air Concentrations

SC&A Finding: To address uncertainty as to whether air concentrations are dependent upon 

production rates, NIOSH should consider using the 95th percentile values from TBD-6000 to 

reconstruct doses at Joslyn.

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 8 – Pit Burning, Floor Sweeping and Chip Fires must Be Considered

SC&A Finding: Though of short duration, the airborne uranium dust levels associated with 

uranium open pit burning and associated activities, such as shoveling the burn residue into 

containers, could contribute significantly to annual intakes of uranium. NIOSH needs to 

evaluate the degree to which outdoor open pit burning of uranium shards renders TBD-6000 

incomplete as a surrogate dataset for Atomic Weapons Employer (AWE) facilities with limited 

bioassay and air sampling data. NIOSH should do the same for uranium chip fires that may 

have occurred in the machining or scrap storage areas. A third area of concern is that there are 

no data for the frequent sweeping activities that likely generated considerable resuspension of 

uranium dust. The present intake matrix is incomplete in all three respects. [Note that the 

concerns regarding out door pit burning and shoveling have been resolved (see introduction). 

Hence, we recommend closing this issue.]

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 9 – Source Term Documentation

SC&A Finding: It would strengthen the report if the basis for the 90% coverage of the uranium 

source term was documented.

NIOSH Response:

Board Action:

SC&A Observation Status:
Draft Joslyn PER Issues Matrix 6 SC&A – December 18, 2013

NOTICE: This December 18, 2013, issues matrix has been clear for public distribution. Please note that future 

versions of this matrix will require another review for PA-protected information prior to public release.

Issue 10 – Need for Revised External Exposure Assumptions

SC&A Finding: SC&A does not agree with some of the assumptions proposed by NIOSH in 

Section 7.3.1 of the ER. SC&A suggests that NIOSH consider prorating the dose values in 

Table 6-4 based on actual working time, such as days per month. At a minimum, the NIOSH 

approach appears to underestimate external exposure in 1948. In addition, there is no need to 

differentiate between rolling and machining operations, since the doses are the same. However, 

there is one caveat—the units of measure for the data listed in Table 6-4 as Metal Whole Body 

Dose should be mrem/yr, not mR/yr. This is an important consideration when converting wholebody dose to organ dose.

NIOSH Response:

Board Action:

SC&A Observation Status:

Issue 11 – Documentation on Thorium Hazard Sources

SC&A Finding: NIOSH should document the sources of information they propose to use 

regarding the relative radiological hazard from thorium.

NIOSH Response:

Board Action:

SC&A Observation Status:

REFERENCES

Klevin, P.B., 1952. Joslyn Manufacturing and Supply Company Occupational Exposure to 

Radioactive Dust; March 25, 1952; SRDB Ref ID: 9664.

NIOSH 2012. SEC Petition Evaluation Report SEC-00200, Joslyn Manufacturing. National 

Institute for Occupational Safety and Health, Cincinnati, Ohio. December 3, 2012.

SC&A 2013a. Review of Joslyn Manufacturing and Supply Company Petition Evaluation Report 

for Special Exposure Cohort (SEC) Petition 00200. SCA-TR-SEC2013-0069, Rev. 0. SC&A, 

Inc., Vienna, Virginia. March 28, 2013.

SC&A 2013b. Supplementary Comments on Revision 01 of Battelle-TBD-6000. Rev. 0. SC&A, 

Inc., Vienna, Virginia. May 27, 2013 (PA-cleared version).