Issues Matrix for Chapman Valve SEC Petition Evaluation Report12 

(February 14, 2007) 

Issue No. 

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SC&A Findings NIOSH Response t

Findings 

1 The petitioners claim that NIOSH disagrees with these SC&A concurs with the petitioner SC&A the bioassay data are not claims related to the available that the bioassay data from Chapman Report adequate to support the bioassay data and contends Valve alone are not sufficient to Section reconstruction of doses with that the bioassay data are support internal dose reconstruction 3.1 sufficient accuracy. They 

claim that the data (1) are not representative of the exposed worker population, (2) were collected without any understanding of the individuals’ exposure histories, and (3) do not assess exposures from a number of industrial processes, such as the cracking furnace, chip 

representative of the potential exposures from uranium operations performed by Chapman Valve, because bioassay samples were collected from employees accessing the restricted Chapman AEC areas in job categories that are considered representative of the workers involved in the AEC project. 

with sufficient accuracy for the very reasons cited by the petitioners. However, there is a vast amount of air sampling data and bioassay data collected at other uranium metal handling and processing facilities at the time that can be used to supplement and complement the bioassay data available from Chapman Valve for estimating routine exposures to uranium. 

1 Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on Radiation a(ABRWH) to maintain all possible openness in its deliberations. However, the ABRWH and its contractor, SC&Athat at the time of its release, this report is pre-decisional and has not been reviewed by the Board for factual acapplicability within the requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’from the report’s conclusions. Thus, the reader should be cautioned that this report is for information only and 

interpretations regarding its conclusions are unwarranted. 

Notice: This information is protected by Privacy Act 5 USC §552a; disclosure to any third party without the written consent of the individual to wh

pertains is strictly prohibited. 

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incinerator, or possible rolling operations 

2 The petitioners express NIOSH explains that it was SC&A believes that petitioner SC&A concern that NIOSH standard practice at that time concerns regarding why bioassay Report concedes that they have no for urine samples to be samples were collected and the LLD Section documentation about why collected in order to assess do not preclude NIOSH from using 3.2 bioassay samples were 

collected, and that most of the data were below the LOD. It appears that the petitioners are concerned that the bioassay program was poorly designed and did not detect intakes for the more highly exposed individuals. 

exposure conditions at the site. In addition, NIOSH states that, although the exact selection criteria regarding who should be included in the bioassay program are not stipulated in any of the records, it was standard practice for AEC to want to know what were the worst-case exposures so that they could determine where additional controls might be needed. 

the bioassay data and data from other facilities to supplement Chapman data to develop and implement an exposure matrix that can be used to reconstruct chronic exposures to 

workers with sufficient accuracy. 

3 Petitioners claim that there NIOSH disagrees with these SC&A believes that the bioassay data 

SC&A is insufficient bioassay data claims because the bioassay and the limited information regarding Report with which to estimate a program was consistent with uranium milling operations at Section plausible upper-bound dose, such programs at that time, Chapman Valve, together with a 3.3 that process information is 

too limited to characterize exposures, and there is only one day of air monitoring data. As such, it is not feasible to estimate dose with sufficient accuracy. 

and that enough is known about Chapman Valve production to estimate doses with sufficient accuracy. NIOSH also states that airmonitoring data were not used to reconstruct doses, and, as a result, the fact that the amount of air monitoring data is extremely limited is not a significant issue. Finally, NIOSH summarizes the basic 

great deal of data collected from many uranium facilities at that time, allows NIOSH to develop an exposure matrix for internal dose that is scientifically plausible and claimant favorable for chronic exposures 

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approach used to develop the exposure matrix and explains that those assumptions are compatible with experience at Y-12 at that time. 

4 Petitioners claim that, since NIOSH’s response to this SC&A concurs with the petitioner’s SC&A the actual date of the fire is concern re-states quotes taken concerns. SC&A believes that Report not known, the actual from historical records that a explicit consideration should be Section uranium intakes associated fire occurred in early June, given to the possibility (i) that there 3.4 with the May/June 1948, 

fire cannot be estimated. 

and that the exposure matrix takes the exposures associated with the fire into consideration using the urine bioassay data collected on June 11, 1948, from 7 workers that were involved in putting out the fire and cleanup following the fire. 

were more than 1 fire and (ii) that the date of the June fire could have been before June 10, 1948. NIOSH has not developed an approach to address these two issues. 

5 The petitioners express NIOSH’s response to this SC&A generally concurs with SC&A concern that enriched concern is to disregard the NIOSH’s position that natural Report uranium may have been cited measurement for a uranium was processed at Chapman Section machined at Chapman number of reasons. First, the during the period under consideration 3.5 Valve. This concern is 

based on an airborne dust measurement taken in the 1990s as part of the site remediation program. 

historical records indicate that Chapman Valve was commissioned by the AEC to machine uranium rods for the Brookhaven reactor. NIOSH also stated that the 1997 report, where the slightly enriched uranium was observed, attributed the value to background levels. In addition, NIOSH cites evidence that enriched uranium was only handled by 

(1948-1949). However, for the reasons discussed in Section 2.1 of the SC&A review report, some additional investigation is needed of the enriched uranium issue for an earlier period not covered by the NIOSH Evaluation Report. 

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government facilities at that time. Finally, NIOSH concludes that whether or not enriched uranium may have been processed at Chapman Valve has no bearing on the feasibility of dose reconstruction, and does not pose an SEC issue. 

6 The petitioners expressed NIOSH’s response to these SC&A believes that the petitioners’ SC&A concern that the site profile concerns is that the site profile concerns regarding exposures Report does not take into does take into consideration associated with a chip burner and Section consideration other the fact that there was a chip possible rolling operations are valid, 3.6 industrial processes that 

may have taken place at Chapman Valve, such as the use of a cracking furnace, chip incinerator, or possible rolling operations. 

burner at the facility and cites data collected at the burner’s exhaust location. In addition, NIOSH states that the bioassay data upon which the exposure matrix is based captures any exposures that may have been associated with a chip burner. With respect to possible rolling operations, NIOSH states that there is no documented evidence that rolling operations took place at Chapman Valve. NIOSH further states that, even if rolling operations took place, the bioassay data would have captured such exposures. 

and that NIOSH’s response to those concerns is not convincing. SC&A believes that there could have been short-term elevated exposures associated with chip burning or possible rolling operations that the limited bioassay program at Chapman Valve could have missed. 

7 SC&A Report 

Petitioners express concern that there is only one day of uranium air samples, and 

NIOSH agrees with petitioners’ statements and concerns, but explains that the 

SC&A concurs with NIOSH’s position on this matter so long as NIOSH does not use the air sampling 

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Section that one set of samples limited air sampling data were data in question in its dose 3.7 shows that there were 

elevated levels of uranium throughout the facility. 

not used for dose reconstruction. 

reconstructions for Chapman Valve.. 

8 Petitioners express concern NIOSH explains that the SC&A believes that the method SC&A that there may have been records only indicate one adopted in the exposure matrix to Section numerous fires at the facility significant fire in early June model the acute exposures associated 3.8 that NIOSH has not taken 

into consideration. 

that is taken into consideration in the exposure matrix. They also explain that the assumptions used in the exposure matrix for chronic exposure account for the possibility that other fires may have occurred, because, if the bioassay results were in fact associated with incidents, the approach used by NIOSH overestimates the exposures. 

with the June fire is not claimant favorable. However we believe that this is a tractable problem since an earliest feasible date can be reasonably ascertained. As regards other fires, SC&A interviews did not reveal information about other fires, but none of the workers interviewed worked in the relevant department full time. The issue of other fires merits further investigation. 

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