Draft 

SC&A’S EVALUATION OF NIOSH’S RESPONSE DATED 

MARCH 31, 2011, TO SC&A’S SECOND WHITE PAPER ON 

RECYCLED URANIUM (SEC ISSUE #3) AT FERNALD 

Contract No. 200-2009-28555 

Prepared by 

John H. Stiver, MS, CHP 

SC&A, Inc. 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

August 2011 

Disclaimer 

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

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

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

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

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

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

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Document No.: 

SC&A Evaluation of NIOSH 

Response of March 31, 2011 

Effective Date: 

 Draft – August 4, 2011 

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’s Evaluation of NIOSH’s Response dated March 

31, 2011, to SC&A’s Second White Paper on Recycled 

Uranium (SEC Issue #3) at Fernald

Page 2 of 21 

Task Manager: 

______________________________ Date:____________ 

John H. Stiver, MS, CHP 

Supersedes: 

N/A 

Project Manager: 

______________________________ Date:____________ 

John Mauro, PhD, CHP 

Peer Reviewer(s): 

 Robert Barton III 

 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 08/04/2011 Initial issue 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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

TABLE OF CONTENTS 

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

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

1.1 NIOSH Response dated March 31, 2011.................................................................5 

1.2 Historical Milestones Leading Up To This Report..................................................5 

2.0 SC&A’s SEC Issue #3 – Recycled Uranium.......................................................................6 

3.0

.............................................................................................9 

SC&A’s Summary of NIOSH’s March 31, 2011, Response to SC&A’s Second 

White Paper on RU at Fernald

3.1 Statement of Purpose ...............................................................................................9 

3.2 General Statements and Background Opinions.....................................................10 

3.3 Specific Discussion and Responses to the SC&A Report .....................................10 

3.3.1 Primary Issue – Viability of the DOE Mass Balance Reports...................10 

3.3.2 Second Major Issue – Specific RU Contaminant Defaults........................13 

3.3.3 Third Basic Issue – Fernald Radiation Safety Program Deficiencies........19 

4.0 References..........................................................................................................................20 
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

or Advisory Board 

AEC Atomic Energy Commission 

DCAS Division of Compensation Analysis and Support 

DOE U.S. Department of Energy 

DR dose reconstruction 

EEOICPA Energy Employees Occupational Illness Compensation Act of 2000 

EM Environmental Management 

FMPC Feed Material Production Center 

GDP Gaseous Diffusion Plant 

LEU Low Enriched Uranium 

M&O Management and Operations 

MgF2 magnesium fluoride 

NIOSH National Institute for Environmental Safety and Health 

NLO National Lead of Ohio 

POOS Plutonium Out Of Specification 

ppb parts per billion 

ppm parts per million 

PUREX Plutonium Uranium Extraction 

REDOX oxidation-reduction 

RU Recycled Uranium 

SC&A S. Cohen and Associates 

SEC Special Exposure Cohort 

SRDB Site Research Database 

SRS Savannah River Site 

TRU transuranic 

UNH Uranyl nitrate hexahydrate 

UF4 uranium tetrafluoride 

UO3 uranium trioxide 
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1.0 INTRODUCTION 

1.1 NIOSH Response dated March 31, 2011 

On April 17, 2011, the National Institute for Occupational Safety and Health (NIOSH) provided 

a response to SC&A’s second white paper on recycled uranium (RU) at Fernald in an e-mail by 

Mark Rolfes. That e-mail contained an attachment titled, NIOSH Response to 2-11 SCA RU 

whitepaper.docx. Below is an historical summary of the discussions and white paper exchanges 

regarding the RU issue at Fernald; NIOSH’s response of March 31, 2011; and SC&A’s 

evaluation of NIOSH’s response. 

1.2 Historical Milestones Leading Up To This Report 

During the Fernald Work Group meeting held on October 28, 2008, SC&A was tasked with 

reviewing the NIOSH white paper on RU entitled, Dose Reconstruction Considerations for RU 

Contaminants at Fernald (NIOSH 2008). The direction provided by the Advisory Board on 

Radiation and Worker Health (ABRWH or Advisory Board) stated that SC&A should focus on 

the appropriateness of the default values selected for RU contaminants [Pu-239/240 (referred to 

herein as Pu-239), Neptunium-237 (Np-237), and Technecium-99 (Tc-99)], and whether the 

selected values are bounding for all workers for all time periods. SC&A’s white paper on this 

issue entitled, SC&A’s Review of Issues Related to Reconstruction of Doses for Workers Exposed 

to Recycled Uranium at Fernald: Commentary on the NIOSH White Paper (SC&A 2009), 

identified 11 deficiencies (findings) in the NIOSH white paper, which were the subject of 

extensive discussions at the January 29, 2010, Work Group meeting. SC&A (2009) and the 

discussions provided at the January 29, 2010, meeting transcript (ABRWH 2010) thoroughly 

describe SC&A’s concerns regarding RU. During the January 2010 Work Group meeting, 

NIOSH stated that it was not prepared at that time to address the various issues raised, but agreed 

to prepare a response. 

Prior to the November 9, 2010, Work Group meeting, NIOSH submitted the report, Response to 

SC&A Findings related to the White Paper on Recycled Uranium at Fernald – October 2010, 

(NIOSH 2010), which provided NIOSH’s position on each of the 11 findings in SC&A (2009). 

The 11 findings and NIOSH’s responses to these findings were the subject of intensive 

discussions at the November 9, 2010, meeting. Two principal unresolved issues that emerged 

from that meeting prompted the Advisory Board’s request for a second white paper. First, 

SC&A provided a compelling argument as to why the 19 subgroup process means derived in the 

U.S. Department of Energy (DOE) Ohio Field Office Report (DOE 2000b) and reported in 

Table 5 of NIOSH (2008) do not provide a firm basis for bounding defaults for transuranics 

(TRU) and fission products. Second, SC&A’s preliminary review of the dust collector data 

reported in Appendix B of NIOSH (2008) indicated that the NIOSH default values may not be 

bounding for some classes of workers in some facilities during the proposed Special Exposure 

Cohort (SEC) period. 

SC&A’s second white paper on recycled uranium, SC&A Review of Issues Related to 

Reconstruction of Doses for Workers Exposed to Recycled Uranium at Fernald – A Second 

White Paper (SC&A 2011a), was transmitted to the Work Group prior to the February 9, 2011, 
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Work Group meeting. That paper identified nine new findings that supported our position 

regarding the questionable basis for NIOSH’s proposed RU defaults, and that some categories of 

workers were exposed to TRU and fission product levels in excess of the NIOSH defaults. The 

issues were discussed in detail at the February 9, 2011, Work Group meeting. At that meeting, 

NIOSH was tasked to respond to SC&A (2011a) prior to the next Work Group meeting, 

scheduled for April 19, 2011. 

On April 13, 2011, SC&A transmitted Revision 1 of our second white paper on RU at Fernald 

(SC&A 2011b). That revision contained editorial corrections and a revised Table 2 that limited 

comparisons of organ doses from intakes of RU constituents to specific absorption classes. Note 

that Revision 1 did not result in changes to the findings in SC&A (2011a). Thus, unless 

otherwise indicated, all references in this document to SC&A’s second white paper are to SC&A 

(2011b). 

On April 17, 2011, NIOSH provided a response to SC&A (2011a) entitled, NIOSH Response to 

Draft SC&A Review of Issues Related to Reconstruction of Doses for Workers Exposed to 

Recycled Uranium at Fernald – A Second White Paper – February 2011 (NIOSH 2011). 

Because SC&A did not have time to prepare a detailed response to NIOSH (2011) prior to the 

April 19th Work Group meeting, we prepared preliminary observations for discussion at the 

meeting. It is noteworthy that at the April 19th meeting, SC&A was not tasked to respond to 

NIOSH (2011) or perform any additional work on the RU issue. 

At the Advisory Board meeting held in St. Louis, Missouri, May 24–26, 2011, SC&A presented 

the status of our six main SEC findings regarding Fernald. Part of that presentation focused on 

our preliminary observations on NIOSH (2011). At the conclusion of the presentation, SC&A 

was tasked by the Advisory Board to provide a formal response to NIOSH (2011). This 

document fulfills that request. 

2.0 SC&A’S SEC ISSUE #3 – RECYCLED URANIUM 

SEC Issue #3 can be summarized by the following statement: Default concentrations (on U 

mass basis) of Pu-239, Np-237, and other isotopes associated with RU at Fernald may not 

be bounding for some classes of worker activities, buildings, and time periods. 

The following is a summary of SC&A’s findings from SC&A (2011b). The findings can be 

grouped into two main categories: 

 Those relating to whether the NIOSH defaults are bounding for all classes of workers at 

Fernald for the period during which RU was received, handled, and processed (1953–

1989) 

 Those relating to the veracity of the basis documents that underlie the NIOSH defaults 

Detailed discussions of the findings are found in SC&A (2011b) and are not replicated here. 

However, the relevant sections of SC&A (2011b) are identified. 
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Finding #1: Questionable basis for NIOSH presumptions regarding the integrity of Fernald 

radiation safety programs prior to 1986 (SC&A 2011b, pp. 21–27):

The DOE RU reports and related historical references indicate that prior to 1986, 

the radiation safety program at Fernald was probably not adequate to control 

potential exposures from contaminants in RU. In all likelihood, the 1986 changes 

were implemented by the new M&O contractor in response to problems 

encountered during RU processing in the preceding years. This raises concerns 

regarding NIOSH’s reliance on the integrity of such programs as assurance that 

their defaults were not exceeded during the proposed SEC period. This is not 

only of concern during the early years of RU processing, but also during the 

6 years that had elapsed from the time the most contaminated RU material was 

received in 1980 until the new program elements were implemented. 

Finding #2: Questionable basis for NIOSH default plutonium concentration (SC&A 2011b, 

pp. 27–29):

A formal specification for maximum transuranic and fission product contaminants 

in uranium recycled material had probably not existed either within or between 

sites. In fact, the only formal limit adopted by the Atomic Energy Commission 

(AEC) for RU was adopted in 1971 to accommodate commercial fuel shipments to 

the gaseous diffusion plant (GDP). The fact that there are several orders of 

magnitude of variability in the 4,000 analytical results reported for Pu-239 in 

DOE 2000b raises concerns as to NIOSH’s reliance on the Hanford ‘working 

specification’ of 10 ppb as the basis for their default plutonium concentration. 

SC&A believes that a re-analysis of the data to determine if there are classes of 

workers that are not sufficiently bounded by the current methodology would be 

highly beneficial. 

Finding #3: NIOSH provides no clear basis for the choices of 3,500 and 9,000 ppb U for 

Np-237 and Tc-99 defaults (SC&A 2011b, pp. 30–32):

NIOSH indicates that data from Table 5 of their RU white paper were used to 

develop the default activity ratios for use in the absence of specific bioassay data 

for workers involved in any of these process subgroups. However, it is not clear 

to SC&A how the values of 3,500 and 9,000 ppb U for Np-237 and Tc-99 (and the 

ratios of 35 and 90 for Np/Pu and Tc/Pu) were derived from these subgroup 

means. 

Finding #4: DOE 2000b is questionable as the basis for the NIOSH defaults; Source data 

should be reviewed in the context of an SEC Petition (SC&A 2011b, pp. 33–43):

The DOE 2000b report for RU data is neither comprehensive nor reliably 

representative and rigorous in its scrutiny of data validity. Clearly the subgroups 

listed in Tables ES-5A, 5C and 5D are not sufficiently detailed to reflect the wide 

range of RU sources that would result from analysis of the permutations of 
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processing facility, process operations, time of operation and fuel/target type. It 

is incumbent on NIOSH to review the source data for its adequacy in bounding 

worker doses in an SEC context. 

Finding #5: Gaps and limitations in the dust data render them questionable as a basis for 

establishing default levels of contaminants in RU for the SEC period (SC&A 2011b, pp. 44–

49):

SC&A believes that the 1985 dust collector data alone are not adequate as a basis 

for establishing default levels of RU contaminants. However, we believe that they 

have some utility in determining whether the NIOSH defaults are bounding for all 

classes of workers at Fernald during the proposed SEC period and potentially for 

estimating intakes for some classes of workers in the 1980s. 

Finding #6: Dust data do not support NIOSH defaults for some classes of workers in some 

facilities (SC&A 2011b, pp. 49–53):

The Plant 1 and Plant 5 dust data, while limited in space and time, tend to 

support the concentration and persistence of RU contaminants in those facilities, 

and suggest that some classes of workers were potentially exposed to levels of RU 

contaminants in excess of the NIOSH defaults. 

Finding #7: Boundary air concentrations of Pu do not support NIOSH defaults and are 

consistent with elevated levels observed in dust collector data (SC&A 2011b, pp. 53–57):

Elevated plutonium ratios in site boundary air measurements appear to correlate 

with the onset of processing of the highly contaminated Paducah tower ash 

shipments and are consistent with the elevated levels in Plants 1 and 5. Note also 

that one would expect boundary air concentration ratios to be lower than Plant 1 

and 5 source effluents due to dilution with uncontaminated uranium from other 

stacks. 

Finding #8: The 1989 air sampling data for Plants 4 and 8 do not support the NIOSH default 

levels as bounding. Potentially significant worker doses could have resulted from off-normal 

events (SC&A 2011b, pp. 57–60):

The statements in Bassett et al. 1989 indicate that the limited set of 24-hour air 

collections do not reflect incidents with high exposure potential such as the spills, 

hydrofluorination bank failures in Plant 4 or furnace temperature excursions in 

Plant 8, as identified in DOE 2000b (Table D.1-15). While measured air 

concentrations were low, the mass fractions of Pu and Np were high, exceeding 

the defaults in several instances. During high dust loading events, these levels 

could result in significant exposures to workers. 
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Finding #9: The Hanford UNH data from the early 1970s suggest that the working 

specification for Pu was exceeded on a frequent basis with some batches much higher than the 

NIOSH default (SC&A 2011b, pp. 60–62):

While it is recognized that this material could have been down-blended at later 

steps in production, it remains unclear whether batches of UO3 in excess of the 

NIOSH default were shipped to Fernald and if so, whether Fernald personnel 

were aware of it and took precautionary measures 

3.0 SC&A’S SUMMARY OF NIOSH’S MARCH 31, 2011, RESPONSE TO SC&A’S 

SECOND WHITE PAPER ON RU AT FERNALD 

NIOSH 2011 is organized into three major sections: a statement of purpose; general statements 

and background opinions; and specific discussion and responses to SC&A (2011a). This third 

section is further subdivided by major issues into three broad categories: a discussion of the 

viability of the DOE mass balance reports (DOE 2000a, DOE 2000b, DOE 2000c, and DOE 

2003); specific RU contaminant defaults; and Fernald radiation safety program deficiencies. 

NIOSH has grouped SC&A’s findings into one of these three issue-based categories and 

provided a general response to each. The following discussion provides SC&A’s responses to 

each of the categories identified in the NIOSH paper. 

3.1 Statement of Purpose 

NIOSH indicates in this section that: 

...the discussion leads to a proposed revision to the present contaminant default 

dose reconstruction recommendations. The present defaults have been questioned 

as to whether they actually “bound doses to RU contaminants to all classes of 

workers to the levels deemed appropriate to dose reconstruction under 

EEOICPA.” At issue is the interpretation of the degree of precision necessary to 

meet the intent of the quote. The other (and perhaps the issue of greatest 

concern) is the challenge to the primary sources of RU information and data, the 

DOE Mass Balance Reports. 

...The primary objective will be to re-examine existing data and information, 

coupled with newly retrieved information from the Legacy files, respond in 

general terms and evaluate the necessity of establishing another set of credible 

RU contaminant defaults.

SC&A has one comment regarding the statement of purpose. SC&A also questions whether the 

NIOSH defaults are bounding in an SEC context. That concern is captured on page 8 of SC&A 

(2011b) and is replicated here for convenience: 

The Board also requested that SC&A provide a focused review of available data 

pertaining to measurements of TRU and fission products in RU at Fernald for 

their applicability in assessing whether the default levels reported in Table 10 of 

NIOSH 2008 are bounding in the context of a Special Exposure Cohort (SEC) 
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petition. As such, our review addresses the ability of NIOSH to bound the RU 

dose (or estimate a dose more accurately than a bounding dose) for all workers in 

the proposed SEC class, which extends from 1951 to 1989, the year in which 

production activities at Fernald ceased permanently. 

3.2 General Statements and Background Opinions 

On page 1 of their report, NIOSH lists five general statements to lay the basis for their following 

recommendations. In summary, NIOSH acknowledges that the data and analysis in SC&A 

(2011a) has prompted a re-evaluation of the RU defaults and proposes to increase the defaults for 

Pu, Np-237, and Tc-99. Most importantly, NIOSH proposes to base the new defaults on the 95th

percentile of a lognormal fit to the 19 process subgroup data in Appendix F of DOE (2000b). 

Note that NIOSH’s previous reliance on “bootstrap means” of the process subgroup data as 

derived in DOE (2000b) was a principal source of concern to SC&A. Details of those concerns 

are provided on pages 35–38 of SC&A (2011b) and Findings 10 and 11 from SC&A (2009), in 

which SC&A recommends the use of an upper quantile of the lognormal distribution to account 

for variability and uncertainty in the data. 

The third and fourth general statements acknowledge the paucity of data upon which to build 

claimant-favorable defaults and provide some historical background on the underlying reasons. 

The fifth statement is in relation to SC&A’s concerns regarding the adequacy and completeness 

of the DOE mass balance reports for assigning bounding contaminant levels for use in dose 

reconstruction. This statement amounts to an assertion that the mass balance reports are credible 

and sufficient for conservative bounding. SC&A’s concerns regarding this issue are summarized 

in the discussion supporting Finding #4 from SC&A (2011b). The remainder of this section 

consists of a table outlining the history of RU from 1944 to 1966, and appears to have been 

drawn from the DOE mass balance reports. 

3.3 Specific Discussion and Responses to the SC&A Report 

3.3.1 Primary Issue – Viability of the DOE Mass Balance Reports 

This section begins with the following statement (NIOSH 2011, p. 5): 

The primary issue deals specifically with the challenge to the DOE 2000 Mass 

Balance studies and reports as viable information sufficient to provide for DR for 

the purposes of the EEOICPA [DOE 2000a-e]. The unstated implications are 

that the requirements for data integrity and accuracy should be held to a higher 

level of detail and accuracy than necessary for routine protection programs. 

[Emphasis added.] 

SC&A believes that this statement by NIOSH misrepresents our position, which is that the mass 

balance reports were not intended to provide a basis for dose reconstruction. While we believe 

that the reports and associated data represent an extraordinary effort on the part of DOE and are 

adequate for a mass balance study, the data are highly variable and uncertain; SC&A believes 
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that the variability and uncertainty must be taken into account if the data are to be used as the 

basis for RU defaults. 

NIOSH provided responses to this primary issue on three levels: basic effort and product; 

previous reports and resources; and industry limits and guides. Each of those topical responses is 

addressed below: 

Basic Effort and Product 

This section of NIOSH (2011) provides an overview of the organization and effort put forth by 

DOE in assembling the mass balance reports. It concludes with the following assertion as to the 

credibility of the reports: 

The DOE 2000 Mass Balance Reports [DOE 2000a-e] are credible and sufficient 

for the purposes for which they are proposed – to establish a conservative 

bounding for all classes of workers. Do they provide all the detail and 

availability of “raw” data for independent statistical manipulation expected? No 

– There is a tacit requirement to trust the professional integrity and capabilities 

of the work group assembled for the purpose. Even if the “raw” data were 

available, it would require the services of the work group members or equivalent 

experienced professionals to make sense of it and derive the presentation already 

provided. 

SC&A is in agreement with NIOSH that the team of process knowledge experts assembled to 

produce the DOE mass balance reports probably comprised the most knowledgeable persons on 

the subject, and that reconstituting that group or any other to build on the foundation set by these 

reports is probably not feasible. However, SC&A believes that if the DOE reports (principally 

DOE 2000b) are to be used as the basis for bounding values in the dose reconstruction or SEC 

contexts, there must be an accounting of the high variability in the available data and the 

associated uncertainties. The reader is referred to pages 38–44 of SC&A (2011b) for a detailed 

analysis of the DOE documents and their applicability to dose reconstruction. That section was 

prepared by an SC&A Associate who was formerly employed by the DOE Office of 

Environmental Management (EM) and who was involved in managing the preparation of DOE 

(2000b). 

A summary quote from SC&A 2011b (p. 41) follows: 

Nonetheless, despite the extraordinary accomplishment of preparing [DOE 

2000b] under such challenging circumstances, it cannot serve as a reliable source 

of information for precise or accurate data on TRU and fission product 

contaminant concentrations in recycled uranium that is reliably representative of 

the RU shipments to Fernald, Weldon Spring and other sites. It may or may not 

be possible to compile more complete and representative data, but the analysts 

who compiled [DOE 2000b] knew at the time that to obtain and analyze the full 

range of data needed to ensure a reasonably complete and representative 
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characterization of the contaminant concentrations would require more time than 

was available in late 1999–early 2000. 

Previous Reports and Resources 

This section of NIOSH (2011) lists five references to RU activities that took place in the DOE 

complex from about 1965 up to the mid-1980s. NIOSH concludes this section with the 

following statement (NIOSH 2011, page 8): 

These previous studies, recommendations, conclusions, etc. were available to the 

DOE 1999–2000 Mass Balance Study work groups, which was itself a follow on 

to those studies with the added mission of addressing current political concerns 

discussed in the SC&A paper. 

SC&A is aware of the listed documents and, in fact, utilized them extensively in the preparation 

of SC&A (2011b). Probably the most insightful of these is Report of the Joint Task Force on 

Uranium Recycle Materials Processing (DOE 1985). 

Industry Limits and Guides 

This section provides a brief listing of several references from NIOSH (2008) that were used to 

support the NIOSH assertion that Pu concentrations in RU receipts at Fernald were controlled to 

10 ppb U or less up until the early 1970s, when more highly contaminated tower and incinerator 

ashes were received. NIOSH acknowledges that, prior to 1986, the radiation protection and 

industrial hygiene programs at Fernald were probably not adequate to control exposures to these 

more highly contaminated sources. 

Pages 27–29 of SC&A (2011b) provide an in-depth discussion of why we believe that the 10 ppb 

U level for Pu cited by NIOSH may not have bounded the RU materials shipped to Fernald prior 

to 1973. Several quotes from DOE (1985) are central to our position. The following is a 

summary statement from that report: 

The FMPC has not been required by DOE to maintain accountability records of 

transuranic and fission product elements in the quantities generally received by 

the FMPC. As such, the Task Force could not determine, with confidence, the 

quantity of contaminants that may have been received and processed at the 

FMPC. Only best estimates were available for the review. (DOE 1985, p. xi) 

The section concludes with a discussion of Finding 5 from SC&A (2009) and Finding 9 from 

SC&A (2011b) (replicated below). Finding 5 is concerned with a potential source of RU that 

was not identified in the DOE mass balance reports. Finding 9 is in regard to a set of Hanford 

UNH data from 1971 that show a large number of samples far above 10 ppb U. 

Finding 5 (SC&A 2009): NIOSH has not taken into account the RU originating 

in the Hanford U Plant during the period of uranium recovery from high-level 

waste. This RU may have characteristics in regard to trace radionuclides, 
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including fission products that are very different from the ratios that NIOSH 

proposes to use. The validity of the ratios in the NIOSH paper for RU originating 

in the U Plant (directly or via some other DOE facility) has not been established. 

SC&A notes that additional research has indicated that the RU originating in the Hanford U 

Plant was most likely sent to the GDPs and not to Fernald. This finding was resolved at the 

April 19, 2011, Work Group meeting. 

Finding #9 (SC&A 2011b): The Hanford UNH data from the early 1970s suggest that the working 

specification for Pu was exceeded on a frequent basis with some batches much higher than the 

NIOSH default. 

NIOSH (2011) makes the following statement in reference to Finding #9: 

Also, please note that it is clearly stated that UNH that did not meet the specs 

were sent back to the extraction plant for another extraction cycle. 

Thus the examples of analyses of UNH product streams that were reported above 

the limits seems [sic] expected and trivial – and the implications that the 

materials were released to the UO3 plant unfounded. The product was either 

returned to the extraction process or blended down with a lower product. The 

PUREX process produced the better product from a contaminant standpoint and 

finished the recovery of stored uranium by 1958 (1952–1958). 

Note that SC&A did not imply that the out-of-specification UNH was sent to Fernald. Rather, 

we raised concerns that there are no data either confirming or refuting possible shipments of outof-specification batches. The following statement is from page 62 of SC&A (2011b): 

While it is recognized that this material could have been down-blended at later 

steps in production, it remains unclear whether batches of UO3 in excess of the 

NIOSH default were shipped to Fernald and if so, whether Fernald personnel 

were aware of it and took precautionary measures.

3.3.2 Second Major Issue – Specific RU Contaminant Defaults 

This section begins with a 3-page (pp. 11–13) list of findings from SC&A (2009) and SC&A 

(2011b) related to the default values in NIOSH (2008). The NIOSH response begins on page 14; 

selected passages are replicated below: 

Page 14 

The previous NIOSH defaults were chosen very simplistically by choosing the 

highest values from the 19 process streams from the [DOE 2000b] boot strap 

mean values, and excluding the high values represented by the process stream 

directly from the GDP tower ash and decontamination residues, i.e. sub group 

number 10A. This stream was recorded as a recognized high hazard and handled 
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accordingly and did not represent a continuous process or one with which any 

given worker would be exposed for an extended time period. 

The SC&A report represents a major effort and produced information not 

previously examined, which indicates the need to reconsider the defaults. Upon 

further analyses we agree that though there is much data spread, lognormal 

distributions best describe the data sets. In response, the data presented in 

Reference 5, Appendices C. Attachment 1, Attachment E.2, Attachment F, and 

Attachment F.1 have been re-examined and lognormal distributions used with a 

95th percentile value calculated for all operational process sub-groups. 

[Emphasis added] 

Pages 14–15 

Clearly the defaults are intended to represent the exposure potentials for the 

time period 1973 to the termination of processing and cleanup. The time period 

of 1961 (beginning of insertion of RU into the Fernald processes) to 1973 is a 

period represented by quite a different set of circumstances. First all the 

generator sites (Hanford, SRS, and a small amount from West Valley) used the 

PUREX process (in addition to REDOX for a time at Hanford), which 

demonstrated the ability to provide UO3 at <5 ppb at Hanford, <3 ppb at SRS 

and <10 ppb Pu at West Valley – with some additional contaminants identified 

from higher burn up commercial fuels. [Emphasis added]

Page 15 

The bulk of the data in the [DOE 2000b] report at Fernald was taken during the 

1970s and ‘80s when the RU contaminant levels increased dramatically. The 

contaminant levels were as high as 4 ppm for Pu, which were reduced through 

immediate blending prior to introduction into the processes and resulted in the 

analyses of the 19 process subgroups reducing by a factor of 10 to a 

conservative value of 400 ppb, which included the concentration mechanisms 

within specific processes. Since the care associated with handling of the RU 

materials in the early decade were less, the factor of 10 probably should not be 

applied to the maximum levels documented from the primary generating sites. 

[Emphasis added]

The old and new NIOSH default RU contaminant concentrations, and the bases for the new 

values as understood by SC&A, are summarized in Tables 1 and 2. A discussion of the new 

values and their bases follows. 

Table 1. Summary of Proposed NIOSH RU Default Values (1973–1989) 

Radionuclide NIOSH (2008) NIOSH (2011) Basis (DOE 2000b) 

Pu-239 100 ppb U 400 ppb U Subgroup 8; MgF2

Np-237 3,500 ppb U 11,000 ppb U Subgroup 11; Waste Residues 

Tc-99 9,000 ppb U 20,000 ppb U Subgroup 6B; LEU* products 

*low enriched uranium 
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Table 2. Summary of Proposed NIOSH RU Default Values (1961–1973) 

Radionuclide NIOSH (2008) NIOSH (2011) Basis 

Pu-239 100 ppb U 7 ppb U PUREX 

Np-237 3,500 ppb U 2 ppb U Not provided 

Tc-99 9,000 ppb U 19 ppb U Not provided 

To put the dosimetric significance of the default values in perspective, the reader is referred to 

SC&A (2011b), pp. 19–20. Organ dose ratios of the RU contaminants relative to uranium 

(U-234) were calculated using ICRP-68 dose coefficients and the default RU values in Table 1, 

column 2 (NIOSH 2008). By far, Pu-239 is the most significant, with 50-year equivalent doses 

to the liver and bone surfaces exceeding U-234 doses by factors of about 5 and 3, respectively 

(Classes M and S). The Np-237 ratio was slightly less than 1 for bone surfaces, and the highest 

ratio for Tc-99 was about 0.004 for stomach (Class M). 

Bases for New Defaults 

On pages 15 (see Section 3.3.2) and 17 of their response, NIOSH provides apparently 

inconsistent explanations for the selection of a new Pu default concentration for 1973–1989: 

Page 17 

The present choice of defaults is equally simplistic by choosing a default that was 

slightly higher than the highest process stream calculated at the 95th percentile of 

a lognormal distribution. The current choice of defaults should address the issues 

discussed in the SC&A findings above. 

This explanation for the defaults for 1973–1989 described on page 15 of NIOSH 2011 is 

problematic. In this explanation, NIOSH takes a high value from Subgroup 10A (tower ash 

residues), though not the highest,1

 and simply reduces it by a factor of 10, apparently to account 

for down-blending of the out-of-specification plutonium feed stocks. Note that these materials 

were historically referred to as Plutonium Out Of Specification (POOS) materials. SC&A 

believes this approach is without merit, because, (1) NIOSH has specifically excluded the 

Subgroup 10A data from their analysis, because they believe that these POOS materials are not 

representative of routine worker exposures, and (2) there is no technical basis for the selection of 

a factor of 10 for down-blending efficiency. In fact, Subgroup 10B from DOE (2000b), which 

represents UO3 actually produced at Fernald from the POOS tower ash residues, is represented 

by 146 data points, with Pu concentrations ranging from 2 to 50 ppb U with an average of 20 ppb 

U. Given that the highest measured Pu concentration in tower ash was 7,757 ppb U, an upper 

bound down-blending factor of about 385 would apply. 

The explanation for the defaults for 1973–1989 described on page 17 implies that they are based 

on the highest 95th percentile of lognormal fits to constituent levels for each of the 19 subgroup 

process datasets, excluding Subgroup 10A. This is the explanation provided by NIOSH at the 

April 19, 2011, Work Group meeting. The process subgroups from which the new NIOSH 

 1

 The highest Pu concentration in the tower ash shipments was in a 1980 shipment from the Paducah GDP. 

That value was 7,757 ppb U from Hopper T058. (NLO 1985) 
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u 

ut 

11). 

defaults were derived for 1973–1989 are provided in column 4 of Table 1; for the 1961–1973 

period, the only basis provided by NIOSH is the brief paragraph on PUREX output, as 

previously noted. 

New Defaults and Timeline for Exposures 

It is clear that the new defaults proposed in NIOSH (2011) are predicated on the assumption that 

the highly contaminated incinerator and tower ash receipts from the GDPs in the 1970s and 

1980s resulted in elevated exposure potential for all workers throughout the Fernald complex, 

and that prior to those receipts, concentrations were limited to levels at or below those presumed 

to have existed in the feed materials (Table 2). Common to both periods is the assumption that 

feedstock contaminant levels adequately characterize worker exposures. That is, concentrating 

mechanisms are not thought to result in higher exposure potential for some groups of workers. 

SC&A has investigated these assumptions and found them to be highly questionable. 

Discussions with a NIOSH Division of Compensation Analysis and Support (DCAS) subject 

matter expert at the April 19, 2011, Work Group meeting (ABRWH 2011, pp. 21–23) indicated 

that initial POOS repackaging took place in Plants 1 and 4; milling and down-blending took 

place primarily in Plant 1, as well as in other locations, but was upstream of refining and 

subsequent processes. Hinnefeld (1988, p. 5) indicates that the UO3 produced from the POOS 

feedstock averaged about 40 ppb U (four times the specification) and was further down-blended 

before going to Plant 4 to be converted to uranium tetrafluoride (UF4). NLO (1985) indicates 

that down-blending also took place in the rotary kiln in Plant 8, and that some of the UO3 was 

converted to UF4 in Plant 4 and down-blended with uncontaminated UF4 before being reduced 

to metal in Plant 5. As previously noted, the Subgroup 10B materials have very low P

concentrations in comparison to the Subgroup 10A feed stocks. This indicates that downblending efforts were by and large successful. Thus, constituent levels in UF4 to be reduced into 

metal, whether it originated from POOS feed stocks or some other source, would be expected to 

have been consistent, and likely fairly low. 

As discussed in detail in SC&A (2011) and in our presentation to the Advisory Board at the 

meeting in St. Louis, Missouri, on May 24, 2011, magnesium fluoride (MgF2) was known to 

concentrate transuranics and fission products, and was reused in crucible and reduction vessel 

liners for metal reduction throughout the production period of the plant. In addition, Plant 5 

(metals production plant) air dust concentrations were known to have been high (DOE 2000b, 

Table D.1-15). Pages 51 to 53 of SC&A (2011b) detail the concentrating processes in MgF2 that 

would give rise to much higher contaminant concentrations in Plant 5 than would be present in 

feedstock, and explains why Plant 5 production workers, and also Plant 1 Millwrights who 

reprocessed the MgF2 for reuse, were probably the most highly continuously exposed 

group of process workers, in terms of both dust loading and RU concentration througho

the entire period of RU processing. This topic was discussed at length in the April 19 Work 

Group meeting (ABRWH 20

SC&A notes that the 95th percentile of the lognormal fit to the MgF2 Pu data in DOE (2000b) is 

close to 400 ppb U and is based on a robust dataset of about 400 measurements taken at Fernald, 

which are well characterized by the lognormal distribution. The statistical parameters for that 
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dataset are found on pages 1143 to 1144 of DOE (2000b). A log-normal probability plot on page 

1184 of DOE (2000b) demonstrates that the log fit actually over predicts at the 95th percentile. 

The 95th percentile of the lognormal fit to the Np-237 data (Subgroup 11; waste residues) in 

DOE (2000b) is close to 11,000 ppb U and is based on a set of 94 measurements, which are well 

characterized by the lognormal distribution. The statistical parameters for that dataset are found 

on page 1144 of DOE (2000b). A log-normal probability plot on page 1197 of DOE (2000b) 

demonstrates that the log fit actually over predicts at the 95th percentile. Note that only subgroup 

10A has a higher 95th percentile for Np-237, at about 17,300 ppb U. 

The 95th percentile of the lognormal fit to the Tc-99 data (Subgroup 6B; low enriched uranium 

products) in DOE (2000b) is close to 60,000 ppb U and is based on a set of 178 measurements, 

which are overestimated by the lognormal distribution. The statistical parameters for that data 

set are found on page 1144 of DOE (2000b). A log-normal probability plot on page 1169 of 

DOE (2000b) demonstrates that the log fit over predicts the 95th percentile. However, based on 

the probability plot in DOE (2000b), it is not clear to SC&A how NIOSH derived a 95th

percentile of 20,000 ppb U for Tc-99. Note, however, that Tc-99 has the least internal dose 

impact of the three RU contaminants. 

SC&A believes that the 95th percentile of the MgF2 dataset (400 ppb U) is a credible 

bounding default Pu concentration representative of the most highly continuously exposed

group of Fernald process workers (Plant 5 metal workers and Plant 1 millwrights).2

 We 

also believe that the new higher defaults for Np-237 and Tc-99, though taken from different 

process streams, are credible bounds for these workers. 

In determining a timeline for exposures, it is critically important to understand that, 

because POOS materials were down-blended principally at the ‘front end’ before being 

reduced to metal, the elevated concentrations measured in MgF2 were independent of the 

feedstock concentrations and likely posed an elevated source of continuous exposure to 

Plant 5 workers throughout the period of RU processing. Thus, there is no technical basis 

for a lower set of default RU contaminant concentrations prior to 1973.

Adequacy of New Defaults for Down-blenders and Bystanders 

Because the MgF2 data may not bound potential exposures to POOS down-blenders and other 

nearby workers who were also potentially exposed to unblended POOS (referred to herein as 

bystanders), SC&A questions NIOSH’s exclusion of the Subgroup 10A data in the derivation of 

new defaults. While we believe that it is reasonable to assume that POOS handling and downblending was intermittent and would, therefore, be unlikely to pose a source of chronic exposure, 

we were unable to locate confirmatory data to that effect. Also, the inadequate radiation 

protection program under NLO’s tenure casts serious doubt on NIOSH’s contention that POOS 

worker exposures were carefully controlled in the pre-1986 environment. An excerpt from 

page 51 of SC&A 2011b summarizes our concern: 

 2

 This statement does not include potential exposure to millwrights from unblended POOS materials in 

Plant 1. 
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SC&A finds the assertion that contamination and worker exposures were 

carefully controlled during all periods of POOS processing to be questionable, as 

discussed in detail in Section 4.2 of this report. As noted in that section, DOE 

1985 states that some of the workers handling the tower ash material were 

‘requested’ (not required) to wear half-mask respirators, but it is uncertain 

whether this action was actually carried out and how many potentially exposed 

workers were covered. Also, radiation safety procedures to help control 

exposures from POOS material were not actually instituted until 1986. 

The Subgroup 10A data contain the highest Pu and Np-237 concentrations of the 19 subgroups 

and were discussed at the April 19, 2011, Work Group meeting (ABRWH 2011). SC&A notes 

that this dataset consists of only 39 points for Pu and Np, and that samples taken from the same 

hoppers and assayed independently for Pu (at Paducah and at Fernald) show large amounts of 

variability. Hopper 449, received from Paducah in 1980, is illustrative. Paducah reported a Pu 

concentration (sample basis) of 940 ppb for Hopper 449, while Fernald measured 2,789 ppb 

(sample basis). The corresponding Fernald measurement on a uranium mass basis was 7,005 ppb 

U (DOE 2000b, p. 663; NLO 1985, p. 28). The statistical parameters for Subgroup 10A are 

found on page 1144 of DOE (2000b). A log-normal probability plot on page 1190 of DOE 

(2000b) demonstrates that the log-normal fit is appropriate for this dataset. The 95th percentile 

for Pu from the probability plot appears to be about 3,000 ppb U; NIOSH (2011) cites a value of 

1,732 ppb U. As of the April 19 Work Group meeting, NIOSH had not quantified or estimated 

the impact of excluding the Subgroup 10A data. Thus, the question of whether the 400 ppb 

default for Pu based on the MgF2 dataset and the 11,000 ppb U for Np-237, based on waste 

residues are bounding for the POOS handlers, down-blenders, and bystanders, remains 

open. 

Summary Conclusions – New RU Contaminant Defaults

In summary, the new proposed higher defaults in NIOSH (2011) and the subsequent discussion 

at the April 19, 2011, Work Group meeting represent the first instances in which NIOSH and 

SC&A have reached consensus on the central issue of bounding default values for RU at Fernald. 

Specifically: 

 NIOSH has acknowledged the limitations and uncertainties in the data from the DOE 

reports upon which the NIOSH default values are based 

 NIOSH has acknowledged that the arithmetic mean concentrations for the 19 subgroup 

processes in DOE (2000b) are not bounding, due to a high degree of variability and 

uncertainty 

 NIOSH recognizes that chemical processes resulted in concentration of RU constituents 

above levels in feed materials (e.g., MgF2 ‘dolomite’ problem) and has proposed a set of 

new defaults that take this into consideration. 
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Based on the foregoing discussion SC&A believes that: 

 The lower default values proposed by NIOSH in Table 2 for 1961–1973 are not bounding 

for any group of workers for any period of time. 

 The new higher defaults in Table 1 are probably bounding for all workers during the 

period of RU production extending up to 1973. 

 From 1973 until 1986, POOS down-blenders, handlers, and bystanders may have been 

exposed to higher concentrations of RU contaminants. The question of whether the 

proposed higher defaults in Table 1 are bounding for these down-blenders and associated 

bystanders remains open. 

 In 1986, a robust radiation protection program was implemented. SC&A believes that 

the program adequately controlled potential RU exposures from 1986 to 1989. 

3.3.3 Third Basic Issue – Fernald Radiation Safety Program Deficiencies 

This section begins with a restatement of Finding #1 from SC&A (2011b) “Questionable basis 

for NIOSH presumptions regarding the integrity of Fernald radiation safety programs 

prior to 1986.” SC&A’s concerns regarding NLO radiation safety program deficiencies are 

addressed in detail in Section 4.2 of SC&A (2011b), as excerpted above on page 18. As 

discussed above, the greatest impact of these deficiencies is on bounding intakes for downblenders and bystanders from 1973–1986. NIOSH’s response is found on page 18 of NIOSH 

(2011). The following excerpt from page 18 acknowledges SC&A’s concerns regarding the 

adequacy of the worker protections in place prior to 1986: 

As previously discussed it seems there was an apparent lack of timely and 

comprehensive response to the findings of the levels of RU contaminants and the 

personnel dosimetry issues following the 1985 period (and possibly the 1973 

period) of increased contaminants from the GDP. 

SC&A notes that the author likely meant prior to 1980, as that was the year in which the most 

highly contaminated tower ash residues were received at Fernald. NIOSH goes on to justify the 

choice of a one-size-fits-all model. SC&A agrees that a single set of bounding defaults may be 

the best approach to reconstructing doses to RU at Fernald, since there is a paucity of data 

regarding worker locations at times during employment. Our concern, which has been repeated 

in this document and in previous communications with NIOSH, is that the credibility of such a 

model is entirely dependent on the selection of truly bounding yet plausible defaults. While we 

believe that the new higher defaults proposed by NIOSH are probably bounding for continuously 

exposed workers, the question of whether they are bounding for POOS handlers, down-blenders, 

and associated bystanders remains open. 
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4.0 REFERENCES 

ABRWH 2010. Transcript of the Advisory Board on Radiation Worker Health working group 

meeting on Fernald, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

January 29, 2010. 

ABRWH 2011. Transcript of the Advisory Board on Radiation Worker Health working group 

meeting on Fernald, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

April 19, 2011. 

Bassett, A.C., W.A. Goldsmith, J.M. Googin, J.G. Crawford, and K.F. Eckerman, 1989. Health and 

Safety Provisions for Recycle Uranium Processing at the FMPC, Fernald Environmental 

Management Project, Fernald, Ohio. March 7, 1989.

DOE (U.S. Department of Energy) 1985. The Report of the Joint Task Force on Uranium 

Recycle Materials Processing, DOE/OR-859, Oak Ridge Operations Office, September 1985. 

[SRDB 26854]

DOE (U.S. Department of Energy) 2000a. Review of Generation and Flow of Recycled Uranium 

at Hanford, DOE/RL-2000-43, Richland Operations Office, Richland, Washington, June 30,

2000. [SRDB - 4971] 

DOE (U.S. Department of Energy) 2000b. Recycled Uranium Project Report, DOE 00-0001, 

Ohio Field Office, May 15, 2000. 

DOE (U.S. Department of Energy) 2000c. Recycled Uranium Mass Balance Project Report,

Oak Ridge Gaseous Diffusion Plant Site Report, June 2000. [SRDB-29755] 

DOE (U.S. Department of Energy) 2000d. Recycled Uranium Mass Balance Project Report, 

Oak Ridge Y-12 National Security Complex Site Report, December 2000. [SRDB-16500] 

DOE (U.S. Department of Energy) 2000e. Recycled Uranium Mass Balance Project Report,

Paducah Gaseous Diffusion Plant Site Report, June 2000. [SRDB-16498] 

DOE (U.S. Department of Energy) 2003. Recycled Uranium-United States Production, 

Enrichment, and Utilization, DOE/SOO-0003, May 2003.

Hinnefeld, S.L. 1988. “POOS History and Risk Assessment,” WMCO:OSH(ODI):88-359, 

Westinghouse Materials Company of Ohio. September 19, 1988. 

ICRP (International Commission on Radiological Protection) 1994. Dose Coefficients for 

Intakes of Radionuclides by Workers. ICRP Publication 68. Ann. ICRP 24 (4), Pergamon Press,

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

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

NOTICE:

NIOSH 2008. Dose Reconstruction Considerations for RU Contaminants at Fernald, White 

Paper, Bryce L. Rich and Paul E. Ruhter, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. March 2008. 

NIOSH 2010. Response to SC&A Findings related to the White Paper on Recycled Uranium at 

Fernald - October 2010, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. 

NIOSH 2011. NIOSH Response to Draft SC&A Review of Issues Related to Reconstruction of 

Doses for Workers Exposed to Recycled Uranium at Fernald – A Second White Paper – 

February 2011, Rev. 0, March 31, 2011. National Institute for Occupational Safety and Health, 

Office of Compensation Analysis and Support, Cincinnati, Ohio. 

NLO (National Lead of Ohio, Inc.) 1985. Letter with attachments to J.A. Reafsnyder (DOE) 

from J.A. Spencely (NLO) entitled, Joint Task Force on Recycle Material Processing. April 29, 

1985. 

SC&A 2009. SC&A’s Review of Issues Related to Reconstruction of Doses for Workers Exposed 

to Recycled Uranium at Fernald: Commentary on the NIOSH White Paper, SC&A, Inc., Vienna, 

Virginia. March, 2009. 

SC&A 2011a. SC&A Review of Issues Related to Reconstruction of Doses for Workers Exposed 

to Recycled Uranium at Fernald – A Second White Paper, Rev. 0. SC&A, Inc., Vienna, 

Virginia. February 2011. 

SC&A 2011b. SC&A’s Review of Issues Related to Reconstruction of Doses for Workers 

Exposed to Recycled Uranium at Fernald – A Second White Paper, Rev. 1-Draft. SC&A, Inc., 

Vienna, Virginia. April 13, 2011.