Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE SITE PROFILE FOR THE SIMONDS SAW 

AND STEEL PLANT 

Contract No. 200-2009-28555 

SCA-TR-SP2012-0013 

Prepared by 

Bob Barton 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

June 2012 

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.

 
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Document No. 

SCA-TR-SP2012-0013 

Effective Date: 

June 13, 2012 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 0 – (Draft) 

Review of the Site Profile for the Simonds Saw 

and Steel Plant Page 2 of 61 

Task Manager: 

________________________ Date: ___________ 

John Stiver, CHP 

Supersedes: 

N/A 

Project Manager: 

________________________ Date: ___________ 

John Stiver, CHP 

Reviewer(s): 

 William C. Thurber 

 John Mauro 

Record of Revisions 

Revision 

Number Effective Date Description of Revision 

0 (Draft) 06/13/2012 Initial issue 
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................7 

1.0 Executive Summary.............................................................................................................9 

1.1 Summary of Findings.............................................................................................10 

1.1.1

......10 

Finding 1: More Substantive Discussion of the Proposed Operational 

External Dose Approach is Needed due to Limited Film Badge Data

1.1.2

.....................................................................................................10 

Finding 2: Representativeness of Available Urinalysis Data in 

relation to changing Industrial Hygiene Practices and Exposure 

Potential

1.1.3

...........................................11 

Finding 3: Further Discussion on “Pre-roll” versus “Post-roll” 

Urinalysis Sampling and 1 Versus 2 Shifts st nd

1.1.4

.............................................11 

Finding 4: Representativeness of Proposed Intake Model for 

Different Job Types and Exposure Potential

1.1.5

.........................................................................................................11 

Finding 5: Establish Claimant Favorability of Urinalysis Coworker 

Model versus Daily Weighted Exposure (DWE) Derived Coworker 

Model

1.1.6

............................12 

Finding 6: More Quantitative and Substantive Discussion of 

Available External Monitoring during Residual Period

1.1.7

...................................12 

Finding 7: Appropriateness of Chosen Internal Methodology during 

Residual Period and Consistency with OTIB-0070

1.2 Strengths ................................................................................................................12 

2.0 Scope and Introduction ......................................................................................................14 

2.1 Review Scope.........................................................................................................14 

2.2 Assessment Criteria and Methods..........................................................................15 

2.2.1 Objective 1: Completeness of Data Sources.............................................15 

2.2.2 Objective 2: Technical Accuracy..............................................................15 

2.2.3 Objective 3: Adequacy of Data.................................................................16 

2.2.4 Objective 4: Consistency among Site Profiles..........................................16 

2.2.5 Objective 5: Regulatory Compliance and Quality Assurance ..................16 

2.3 Report Organization...............................................................................................16 

3.0 Overview of NIOSH Methodologies.................................................................................18 

3.1 Reconstruction of External Exposures during the Operational Period ..................18 

3.2 Reconstruction of Internal Exposures during the Operational Period ...................20 

3.3 Reconstruction of External Exposures during the Post-Operational Period..........21 

3.4 Reconstruction of Internal Exposures during the Post-Operational Period...........22 

4.0 Vertical Issues....................................................................................................................24 

4.1

..................24 

Finding 1: More Substantive Discussion of the Proposed Operational 

External Dose Approach is Needed due to Limited Film Badge Data

4.2

............................27 

Finding 2: Representativeness of Available Urinalysis Data in relation to 

changing Industrial Hygiene Practices and Exposure Potential

4.3

.........................................................................37 

Finding 3: Further Discussion on “Pre-roll” versus “Post-roll” Urinalysis 

Sampling and 1 versus 2 Shifts st nd
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4.4

................................................................................39 

Finding 4: Representativeness of Proposed Intake Model for Different Job 

Types and Exposure Potential

4.5

....................41 

Finding 5: Establish Claimant Favorability of Urinalysis Coworker Model 

versus Daily Weighted Exposure (DWE) Derived Coworker Model

4.6

.........................................................44 

Finding 6: More Quantitative and Substantive Discussion of Available 

External Monitoring during Residual Period

4.7

...............................................45 

Finding 7: Appropriateness of Chosen Internal Methodology During 

Residual Period and Consistency with OTIB-0070

5.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................50 

5.1 Objective 1: Completeness of Data Sources.........................................................50 

5.2 Objective 2: Technical Accuracy..........................................................................50 

5.3 Objective 3: Adequacy of Data.............................................................................51 

5.4 Objective 4: Consistency among Site Profiles and Other NIOSH Documents ....51 

5.5 Objective 5: Regulatory Compliance and Quality Assurance ..............................52 

5.6 Inconsistencies and Editorial Errors in the Site Profile .........................................52 

6.0 References..........................................................................................................................54 

Attachment 1: Timeline of the Implementation and Use of Radiological Controls at 

Simonds Saw and Steel......................................................................................................58 
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NOTICE:

LIST OF TABLES 

Table 1. 1948 Survey Measurements (mrep/hr)* taken at Aliquippa Forge........................13 

Table 2. Proposed External Exposure Model for Simonds Saw and Steel ..........................18 

Table 3. Available Uranium Urinalysis Data at Simonds Saw and Steel ............................20 

Table 4. TBD Derived Coworker Intake Values..................................................................21 

Table 5.

..........................................................................................................22 

Measurements Taken at Locations Higher than 0.2 mreps Combined 

Beta/Gamma

Table 6.

....................................................................................23 

2007 Exposure Point Concentration (EPC) Values at Simonds Saw and 

Steel (dpm/100 cm – beta) 2

Table 7. Derived External Exposure Values........................................................................25 

Table 8.

............................................................................................26 

Film Badge Data from October 11, 1949–October 19, 1949 Extrapolated to 

a Full Year of Rolling

Table 9. Overview of Urinalysis Data during the Operational Period.................................28 

Table 10. Comparison of Pre-Roll and Post-Roll Sampling..................................................38 

Table 11. Comparison of Urinalysis Samples for the Two Different Shifts..........................39 

Table 12. Daily Weighted Exposures (dpm/m ) for the Most Common Job Categories.......40 3

Table 13.

...................................................................................................................41 

Urinalysis Results for the Most Common Job titles Identified in DWE 

Reports

Table 14.

............................................................42 

Comparison of TBD-Derived Intake Values based on Daily Weighted 

Exposure Reports and Urinalysis Samples

Table 15.

..........................................................................................................44 

Measurements Taken at Locations Higher than 0.2 mreps Combined 

Beta/Gamma

Table 16. Total Number of Air Samples by Year..................................................................46 

Table 17. Average Air Sampling Results by Year (dpm/m ) ................................................46 3

Table 18. Median Air Sampling Results by Year (dpm/m )..................................................46 3

Table 19. Geometric Mean Air Sampling Results by Year (dpm/m )...................................47 3
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LIST OF FIGURES 

Figure 1.

......................................................................................................................27 

Distribution of Urinalysis Results during the Operational Period (1948–

1957)

Figure 2.

............................................29 

Chronological Plot of the Uranium Urinalysis Sampling versus the Average 

Daily Weighted Exposure over the same Timeframe

Figure 3.

............................................30 

Chronological Plot of the Uranium Urinalysis Sampling versus the Median 

Daily Weighted Exposure over the same Timeframe

Figure 4.

..............................................................34 

The Number of Uranium Urinalysis Results Plotted versus the Timeline of 

Significant Changes in Industrial Control

Figure 5.

...................................................................................................35 

Median Daily Weighted Exposure and Proposed Type M Intakes based on 

Bioassay Data Plotted versus the Timeline of Significant Changes in 

Industrial Control

Figure 6.

...................................................................................................36 

Median Daily Weighted Exposure and Proposed Type M Intakes based on 

Bioassay Data Plotted versus the Timeline of Significant Changes in 

Industrial Control

Figure 7. Comparison of Derived Intake Values based on Urinalysis and DWE Data.........42 

Figure 8.

................................................43 

Comparison of Derived Intake Values (Type M) based on Urinalysis and 

DWE Data Adjusted for Later Year Methodology

Figure 9.

................................................43 

Comparison of Derived Intake Values (Type S) based on Urinalysis and 

DWE Data Adjusted for Later Year Methodology

Figure 10.

...........................................................................................47 

Comparison of the Number of Air Samples to the Average Air 

Sample Value by Year

Figure 11. Photo of the Main Operational Area of the Simonds Plant in 2010 ......................48 

Figure 12. Photo of the Condition of the Roof at the Simonds Plant in 2010.........................49 
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ABBREVIATIONS AND ACRONYMS 

ABRWH or 

Advisory Board Advisory Board on Radiation Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

cm

2 square centimeter 

DCAS Division of Compensation Analysis and Support 

dpm disintegrations per minute 

DWE daily weighted exposure 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

EPC Exposure Point Concentration 

GSD geometric standard deviation 

H&S Health and Safety 

hr hour 

IMBA Integrated Modules for Bioassay Analysis 

m meter 

m3 cubic meter 

μg/L microgram per liter 

μg/m3 microgram per cubic meter 

mg/L milligram per liter 

MAC Maximum Allowable Concentration 

MCNP Monte Carlo N-Particle code 

mR/hr milli-roentgen per hour 

mrem millirem 

mrep milli-roentgen equivalent physical 

NIOSH National Institute for Occupational Safety and Health 

NLO National Lead of Ohio 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team 

pCi picocuries 

R Roentgen 

rep roentgen equivalent physical 
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NOTICE:

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

SEC Special Exposure Cohort 

SRDB Site Research Database

TBD Technical Basis Document 

TIB Technical Information Bulletin
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1.0 EXECUTIVE SUMMARY 

This draft report presents the results of an independent review conducted by S. Cohen and 

Associates (SC&A) of ORAUT-TKBS-0032, Site Profile for Simonds Saw and Steel (ORAUT 

2011), the Simonds Saw and Steel technical basis document (TBD), which was issued by the 

National Institute for Occupational Safety and Health (NIOSH) as a summary site profile 

document. SC&A conducted this review during the period August 2011 through May 2012. 

This review was conducted in accordance with SC&A’s Board-approved Standard Operating 

Procedure for Performing Site Profile Reviews (SC&A 2004). SC&A evaluated the site profile 

for completeness, technical accuracy, adequacy of data, compliance with regulatory objectives, 

and consistency with other site profiles. Review criteria and methods are described in greater 

detail in Section 2.0 of this report. 

On March 8, 2010, Simonds Saw and Steel Company qualified for a Special Exposure Cohort 

(SEC) evaluation by NIOSH for the period of January 1, 1948, through December 31, 2006. On 

October 29, 2011, NIOSH recommended that SEC status be awarded to Simonds Saw and Steel 

for the period of January 1, 1948, through December 31, 1957, for all Atomic Weapons 

Employer (AWE) employees who worked an aggregate of 250 workdays. The basis of the SEC 

recommendation was the inability to reconstruct doses to thorium because of insufficient 

information on the quantity or frequency of thorium processing. On December 8, 2010, the 

Advisory Board on Radiation Worker Health (ABRWH or Advisory Board) recommended that 

the SEC be accorded for the NIOSH-recommended period at Simonds Saw and Steel. 

Consequently, the TBD will be used for dose reconstructions for AWE employees at Simonds 

who worked less than 250 days, did not have one of the cancers specified under the Energy 

Employees Occupational Illness Compensation Program Act (EEOICPA), and those who were 

employed during the residual period from January 1, 1958, to present. 

Simonds Saw and Steel is a steel rolling and fabrication facility located in Lockport, New York, 

that intermittently processed uranium and thorium beginning in early 1948. The frequency of 

radiological operations at the site varied from year to year until the end of 1957, when all 

radiological operations ceased. The primary material handled at Simonds Saw and Steel was 

natural uranium, although it is known that some enriched and depleted uranium were also 

handled in addition to thorium. 

Radiological/industrial hygiene controls at the site varied; however, it was known early on that 

certain steps needed to be taken to reduce the exposure potential to workers in the facility. Such 

improvements were implemented gradually from 1948 until about 1952, after which many of the 

controls and policies were removed or ignored. Radiological monitoring at the site consisted of 

air sampling (general air, process and breathing zone) as well as a urinalysis sampling program 

that was employed intermittently from late 1948 until the end of 1952. Individual external 

monitoring was virtually nonexistent at Simonds and consisted of a single set of 20 workers who 

wore film badges for approximately 7 working days. 
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1.1 SUMMARY OF FINDINGS 

A summary of SC&A’s primary findings for the Simonds Saw and Steel site profile is presented 

below. Detailed discussions of all findings and observations can be found in Section 4.0 of this 

report, “Vertical Issues.” It should be noted that some of the “findings” in this review represent 

initial concerns that may not necessarily preclude the ability to perform partial dose 

reconstructions, but rather are potential issues that may warrant additional analyses, discussion, 

or clarification.

1.1.1 Finding 1: More Substantive Discussion of the Proposed Operational External Dose 

Approach is Needed due to Limited Film Badge Data 

Monitoring for external dose was virtually nonexistent at Simonds Saw and Steel with the 

exception of one brief rolling period covering 20 workers for an assumed duration of 7 working 

days. Because this very limited sample of external measurements may not have been 

representative of the typical exposure potential to workers at Simonds Saw and Steel, an 

alternate external dose model was developed by NIOSH to simulate likely exposure conditions 

for workers who were directly involved in, or were in close vicinity to, uranium rolling 

operations. In addition to this, surrogate data from Aliquipa Forge and a single general area 

Atomic Energy Commission (AEC) study of the Simonds plant are also used (AEC 1949). 

When the available film badge results are extrapolated to a full year of uranium operations, it is 

evident they are very close in magnitude to the modeled doses developed by NIOSH. This 

would seemingly validate the proposed external dose model as being a realistic and accurate 

representation of external dose potential for Simonds workers. However, the assigned doses 

based on the TBD model would underestimate the potential annual external dose for 6 of the 20 

monitored workers when the film badge data are extrapolated to a full year of exposure. Given 

the uncertainties inherent in extrapolating a single film badging period to a full year, it is not 

clear how numerically significant the observed differences may be. Nevertheless, NIOSH should 

consider these data in the context of its proposed external dose model to ensure claimant 

favorability. 

1.1.2 Finding 2: Representativeness of Available Urinalysis Data in relation to changing 

Industrial Hygiene Practices and Exposure Potential 

The two main monitoring practices for internal exposure to uranium at Simonds Saw and Steel 

were urinalysis samples and air sampling (breathing zone and general air) used in developing 

daily weighted exposure (DWE) profiles by job title. Throughout the Simonds Saw and Steel 

operational period, various engineering and industrial hygiene controls were implemented at the 

direction of the AEC. However, during the operational period, the effectiveness of these controls 

fluctuated as certain practices were ignored or safety features in the plant were removed. These 

changes in industrial hygiene practices are naturally coupled with changes in exposure potential; 

this is reflected in the DWE profiles, which show a general decrease in airborne contamination 

for most job categories as the various controls were implemented. It is not clear to what extent 

the urinalysis data and the associated derived intake values are representative of these changes in 

industrial hygiene and relative exposure potential. The TBD would benefit from a more 
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substantive discussion and analysis of the representativeness of available urinalysis data in the 

context of these known changes in industrial practices. 

 

1.1.3 Finding 3: Further Discussion on “Pre-roll” versus “Post-roll” Urinalysis Sampling 

and 1st Versus 2nd Shifts 

Urinalysis reports often designated samples as either being before the rolling operation (pre-roll) 

or after the rolling operation (post-roll). It is not clear how these different types of samples were 

interpreted in developing coworker intakes. It would be beneficial for NIOSH to provide a more 

substantive discussion of the “pre- and post-roll” samples for individual workers and any 

observed fluctuations in sample results. In many cases, there was no significant increase in urine 

concentrations between pre-roll and post-roll, as would be expected with more soluble 

compounds. It is likely these observations could be a result of the rolling of insoluble materials, 

which would not likely show a marked increase in urine concentrations immediately after the 

rolling period. However, in some cases, the post-roll samples were actually lower than the preroll samples. The TBD might benefit from additional analysis and discussion of these variations. 

Additionally, there is mention in the TBD and associated source documentation that workers on 

the second shift may have had less supervision and therefore had a higher exposure potential. 

This issue should be further discussed and potentially quantified to assure that doses assigned to 

workers on the “second shift” are not underestimated by the developed coworker intakes. 

1.1.4 Finding 4: Representativeness of Proposed Intake Model for Different Job Types 

and Exposure Potential 

Based on the available DWE reports, it is apparent that the exposure potential for different job 

classifications varied significantly. In the earlier years, the difference between the highest and 

lowest DWE for individual job types could vary up to a factor of 27. Because of the large 

variability in exposure potential shown by the DWE data, it is important for NIOSH to establish 

that the proposed coworker model using the available bioassay data covers these highest exposed 

worker classifications, and that the assigned coworker doses are bounding to these groups of 

workers. 

1.1.5 Finding 5: Establish Claimant Favorability of Urinalysis Coworker Model versus 

Daily Weighted Exposure (DWE) Derived Coworker Model 

The TBD presents two different methodologies for estimating coworker intakes; one is based on 

the DWE reports, while the other is based on the available urinalysis monitoring data (see 

ORAUT 2011, Tables 10 and 17). Ultimately, NIOSH has selected the urinalysis-based intake 

model to assign coworker doses. However, the DWE-developed intakes for Type M are 

significantly higher during certain time periods. Although the use of bioassay data is preferable 

from a data hierarchy standpoint, NIOSH should further justify the use of urinalysis sampling 

data in the context of developing an accurate and bounding approach to assign coworker doses, 

particularly to job titles with the highest exposure potential. The TBD would also benefit from a 

description of the upper quantiles of the DWE distributions in comparison to the urinalysis 

values. It should be noted that Davis and Strom (2008) recommends a standard deviation of 5 
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when using DWE data for dose reconstruction to account for the inherent uncertainty in this type 

of analysis. Davis and Strom 2008 was utilized by NIOSH in formulating a DWE model for the 

earlier years at Fernald (DCAS 2010). 

1.1.6 Finding 6: More Quantitative and Substantive Discussion of Available External 

Monitoring during Residual Period 

NIOSH should provide justification for the selection of certain parameters in developing external 

dose assignments for the residual period; for example, reducing the length of the workday from 

10 hours (assumed during the operational period) to 8 hours (assumed for the residual period). 

Also, a more quantitative discussion of the residual surveys that took place at Simonds Saw and 

Steel during the 1970s and 1980s would help to demonstrate the claimant favorability of the 

selected external dose assignments. Additionally, Strom 2007 recommends the use of a 

geometric standard deviation (GSD) of 5 when additional information used to characterize the 

distribution is absent. NIOSH should consider this methodology when formulating external dose 

assignments in the residual period. 

1.1.7 Finding 7: Appropriateness of Chosen Internal Methodology during Residual 

Period and Consistency with OTIB-0070 

NIOSH developed a coworker model for the uranium intake rate at the start of the residual 

monitoring period using the average of general air samples from 19481

–1953 during the 

operation of the plant. However, a large portion of the air samples available at Simonds Saw and 

Steel are from the middle years of operation when engineering controls were in place and being 

utilized, which would not be reflective of operations at the end of the operational period. 

Furthermore, NIOSH uses survey data taken in 2007 and assumes the same source term existed 

in 1983 when the plant was officially shut down. NIOSH should consider developing a 

correction factor to account for any degradation of the available source term during those 

24 years when the plant was closed. The approach proposed by NIOSH appears to differ with 

the established methodology developed in ORAUT-OTIB-0070 (ORAUT 2008). 

 

1.2 STRENGTHS 

The site profile does a good job of identifying available data sources, as well as documenting the 

changes in site policies and institutional controls that occurred during the operational period at 

Simonds Saw and Steel. Of particular note was NIOSH’s analysis of the DWE reports generated 

by the AEC during the first few years of the site’s uranium operations and using these reports to 

generate associated intake values. This analysis was in addition to the proposed internal 

coworker model, which utilized the available bioassay data. These extensive air sampling and 

monitoring programs were relatively unique at the time and have been used as surrogate data for 

other uranium milling sites, such as Bethlehem Steel. As such, it is important to describe and 

analyze the available air sampling/DWE data as was done in the current TBD. 

1 The text of the TBD states that it used data from 1949–1953, and not the 1948 data; however, the

references provided indicate that data from 1948 were included.  Data from 1954 were not included.
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NOTICE:

In addition, the TBD performs a detailed calculation using the MCNP code to characterize the 

external penetrating exposure potential from typical radiological operations at Simonds Saw and 

Steel. Surrogate external measurements taken at Aliquippa Forge during a survey in 1948 (AEC 

1949) were used to determine the non-penetrating external exposure potential. Also, general 

area film badge data measured by AEC at Simonds were used to develop ambient exposures to 

workers from general plant contamination. These measurements are presented in Table 19 of the 

TBD and shown here in Table 1. This analysis was used to reconstruct external exposures in the 

absence of sufficient external monitoring data, which are virtually nonexistent at Simonds Saw 

and Steel. External exposures during the residual period utilize maximum survey data collected 

at the end of the operational period, but before any significant cleanup activities had taken place. 

Table 1. 1948 Survey Measurements (mrep/hr)* taken at Aliquippa Forge 

Location of measurement Dose rate 

Billet assumptions 

Contact with floor next to the quench tank where oxide scale has collected 8 

Contact with floor in front of rolls where oxide scale has collected 5–10 

Same location but 18 in. high 2–5 

Rod assumptions 

4 ft above a pile of rods in the boxcar 20 

5 ft from the end of a pile of rods next to the door of the boxcar 5 

2 ft from the end of the same pile 13 

* These measurements are given in the units of “mrep,” which stands for milli-roentgen equivalent physical and is a 

historical unit that is approximately equal to the millirem (mrem). 

Source: ORAUT 2011, Table 19 
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2.0 SCOPE AND INTRODUCTION 

The review of the site profile for the Simonds Saw and Steel plant was authorized by the 

Advisory Board during the full Board meeting held in Niagara Falls, New York, on May 19–21, 

2010, and was conducted between August 2011 and May 2012 by SC&A’s team of health 

physicists and technical personnel. 

2.1 REVIEW SCOPE 

This report provides a review of the TBD related to historical occupational exposures at Simonds 

Saw and Steel, ORAUT-TKBS-0032, Rev. 01, Site Profile for Simonds Saw and Steel (ORAUT 

2011). 

To date, the site profile has not been supplemented by site-specific technical information 

bulletins (TIBs), but there are three generic TIBs that provide additional guidance to the dose 

reconstructor and are referenced in the TBD: 

 ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at 

Atomic Weapons Employer Facilities, Rev. 0, March 10, 2008 (ORAUT 2008) 

 OCAS-TIB-009, Estimation of Ingestion Intakes, Rev. 0, April 13, 2004 (NIOSH 2004) 

 ORAUT-OTIB-0060, Internal Dose Reconstruction, Rev. 0, February 6, 2007 (ORAUT 

2007) 

SC&A also reviewed other pertinent documents, including those cited on the NIOSH Site 

Research Database (SRDB). SC&A has critically reviewed the Simonds Saw and Steel TBD, as 

well as supplementary and supporting documents, against the following three evaluation criteria: 

 Determine the completeness of the information gathered by NIOSH, with a view to 

assessing its adequacy and accuracy in supporting individual dose reconstructions

 Assess the technical merit of the data/information

 Assess NIOSH’s guidelines for the use of the data in dose reconstructions

SC&A’s review of the Simonds Saw and Steel site profile and supplemental documentation 

focuses on the quality and completeness of the data that characterized the facility and its 

operations, and on the use of these data in performing dose reconstruction. The review was 

conducted in accordance with SC&A Standard Operating Procedure for Performing Site Profile 

Reviews (SC&A 2004), which was approved by the Advisory Board. 

The scope and depth of the review are focused on aspects or parameters of the site profile that 

would be particularly influential in dose reconstructions, bridging uncertainties, or correcting 

technical inaccuracies. The review includes an independent compilation and analysis of site 

monitoring data, including urinalysis, air monitoring (including general air, breathing zone and 

other samples), available DWE reports, and post-operational survey data. 
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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. 

The Simonds Saw and Steel site profile document serves as site-specific guidance to support 

dose reconstructions for EEOICPA claimants. It provides the health physicists who conduct 

dose reconstructions on behalf of NIOSH with consistent general information and specifications 

to support their individual dose reconstructions. This report was prepared by SC&A to provide 

the Advisory Board with an evaluation of whether and how the TBD can support dose 

reconstruction decisions. 

The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed, and to determine the levels of exposure the workers received in that 

environment through time. The hierarchy of data used for developing dose reconstruction 

methodologies gives the greatest weight to dosimeter readings and bioassay data, followed by 

coworker and workplace monitoring data, and then process description information or source 

term data. 

 

2.2 ASSESSMENT CRITERIA AND METHODS 

SC&A is charged with evaluating the approach set forth in the site profiles that is used in the 

individual dose reconstruction process. These documents are reviewed for their completeness, 

technical accuracy, adequacy of data, consistency with other site profiles, and compliance with 

the stated objectives, as defined in SC&A (2004). This review is specific to the Simonds Saw 

and Steel site profile; however, items identified in this report may be applied to other facilities, 

especially facilities with similar source terms, exposure conditions, and mobile workforces. The 

review identifies a number of issues and discusses the degree to which the site profile fulfills the 

review objectives delineated in SC&A’s site profile review procedure (SC&A 2004). 

2.2.1 Objective 1: Completeness of Data Sources 

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify 

principal sources of data and information that are applicable to the development of the site 

profile. The three elements examined under this objective are (1) determining if the site profile 

made use of available data considered relevant and significant to the dose reconstruction, 

(2) investigating whether other relevant/significant sources are available, but were not used in the 

development of the site profile, and (3) determining if worker input was considered in the 

development of the site profile. 

2.2.2 Objective 2: Technical Accuracy 

Objective 2 requires SC&A to perform a critical assessment of the methods used in the site 

profile to develop technically defensible guidance or instructions, including evaluating field 

characterization data, source term data, technical reports, standards and guidance documents, and 

literature related to processes that occurred at the Simonds Saw and Steel plant. The goal of this 

objective is to analyze the data according to sound scientific principles, and then evaluate this 

information in the context of dose reconstruction. 
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2.2.3 Objective 3: Adequacy of Data 

Objective 3 requires SC&A to determine whether the data and guidance presented in the site 

profile are sufficiently detailed and complete to conduct dose reconstruction, and whether a 

defensible approach has been developed in the absence of data. In addition, this objective 

requires SC&A to assess the credibility of the data used for dose reconstruction. The data 

adequacy analysis identifies gaps in the facility data that may influence the outcome of the dose 

reconstruction process. For example, if a site did not monitor all workers exposed to radioactive 

materials who should have been monitored, this would be considered a gap and thus an 

inadequacy in the data. An important consideration in this aspect of our review of the site profile 

is the scientific validity and claimant favorability of the data, methods, and assumptions 

employed in the site profile to fill in data gaps. 

2.2.4 Objective 4: Consistency among Site Profiles 

Objective 4 requires SC&A to identify common elements within site profiles completed or 

reviewed to date, as appropriate. In order to accomplish this objective, the Simonds Saw and 

Steel TBD was compared to other TBDs, particularly those referenced in the site profile and 

those related to frequently visited facilities. This assessment was conducted to identify areas of 

inconsistencies and determine the potential significance of any inconsistencies with regard to the 

dose reconstruction process. 

2.2.5 Objective 5: Regulatory Compliance and Quality Assurance 

Objective 5 requires SC&A to evaluate the degree to which the site profile complies with stated 

policy and directives contained in 42 CFR Part 82. In addition, SC&A evaluated the TBD for 

adherence to general quality assurance policies and procedures utilized for the performance of 

dose reconstructions. 

SC&A’s draft report and preliminary findings will subsequently undergo a multi-step resolution 

process. Resolution includes a transparent review and discussion of draft findings with members 

of the Advisory Board Work Group, petitioners, claimants, and interested members of the public. 

Prior to and during the resolution process, the draft report is reviewed by the DOE Office of 

Health, Safety, and Security to confirm that no classified information has been incorporated into 

the report. 

All review comments apply to Rev. 01 of the Simonds Saw and Steel site profile document 

(ORAUT 2011), which is the most recently published version. Site expert interviews were 

conducted with former Simonds Saw and Steel site workers to assist SC&A in obtaining a 

comprehensive understanding of the radiation protection program, site operations, and historic 

exposure experience. 

2.3 REPORT ORGANIZATION 

In accordance with directions provided by the Advisory Board and with site profile review 

procedures prepared by SC&A and approved by the Advisory Board (SC&A 2004), this report is 

organized into the following sections: 
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(1) Executive Summary 

(2) Scope and Introduction 

(3) Overview of TBD Dose Reconstruction Methods 

(4) Vertical Issues 

(5) Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction 

Based on the issues raised, SC&A prepared a summary list of findings, which is presented in the 

Executive Summary. Issues are designated as primary findings if SC&A believes they represent 

deficiencies that need to be corrected and pose the potential for substantial impact on at least 

some dose reconstructions. Issues can be designated as secondary findings if they simply raise 

questions, which, if addressed, would further improve the site profile and may possibly reveal 

deficiencies that will need to be addressed in future revisions of the site profile. Detailed 

analyses of the primary and secondary findings are provided in Section 4.0 of this report. 

Section 5.0 summarizes the evaluation of the TBD with respect to the stated objectives. 
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3.0 OVERVIEW OF NIOSH METHODOLOGIES 

3.1 RECONSTRUCTION OF EXTERNAL EXPOSURES DURING THE 

OPERATIONAL PERIOD 

Film badging of individual workers at Simonds Saw and Steel was restricted to one badging 

period of approximately 7 working days during a rolling period in 1949. Because external 

monitoring was so limited at the site, NIOSH has developed an alternate method for 

characterizing potential external doses during the operational period that combines area film 

badge measurements, instrument measurements, and computerized dose modeling. 

In 1949, the AEC used area film badges to characterize the general radiation environment in the 

plant. The results of this film badge study were used to develop the penetrating and nonpenetrating exposure from the contamination of plant surfaces and also submersion in 

contaminated air. The MCNP transport code was used to model external penetrating exposures 

to uranium billets and rods. Non-penetrating exposures from uranium billets and rods were 

estimated using beta measurements2

 taken at Aliquippa Forge, which had similar source terms 

and exposure scenarios. It is important to note that the TBD assumes that exposure to uranium 

billets and rods was not coincidental (i.e., workers were not exposed to both sources at the same 

time). The results of the modeling exercise are presented in Table 20 of the TBD and are 

recreated here in Table 2. It is important to note that medical x-rays were performed offsite at a 

non-covered commercial facility and so are not applicable to the dose reconstruction process. 

Table 2. Proposed External Exposure Model for Simonds Saw and Steel 

Exposure 

Mode 

Exposure 

Type 

Exposure or 

Dose Rate Basis Assumed 

Exposure Time Year Annual 

Exposure 

IREP 

Distribution 

1948 0.582 R 

1949 0.650 R 

1950 0.650 R 

1951 0.650 R 

1952 0.650 R 

1953 0.650 R 

1954 0.650 R 

1955 0.650 R 

1956 0.650 R 

Penetrating 0.26 mR/hr Film Badge 2,500 

workhours/yr 

1957 0.650 R 

Lognormal 

GSD 1.2 

1948 2.912 R 

1949 3.250 R 

1950 3.250 R 

1951 3.250 R 

1952 3.250 R 

1953 3.250 R 

1954 3.250 R 

1955 3.250 R 

1956 3.250 R 

Submersion/ 

area 

contamination 

Nonpenetrating 1.3 mR/hr Film Badge 2,500 

workhours/yr 

1957 3.250 R 

Lognormal 

GSD 2.3 

 2 These measurements are given in the units of “mrep” which stands for milli‐roentgen equivalent

physical and is a historical unit that is approximately equal to the millirem (mrem)
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Table 2. Proposed External Exposure Model for Simonds Saw and Steel 

Exposure 

Mode 

Exposure 

Type 

Exposure or 

Dose Rate Basis Assumed Exposure Time Year Annual Exposure 

IREP 

Distribution 

1948 

1949 

1950 

1951 

1952 

1953 

1954 

1955 

1956 

Medical x-ray 

1957 

Not Assigned 

1948 0.352 rem 

1949 0.384 rem 

1950 0.384 rem 

1951 0.384 rem 

1952 0.384 rem 

1953 0.384 rem 

1954 0.076 rem 

1955 0.076 rem 

1956 0.076 rem 

Penetrating 0.703 mrem/hr MCNP 

calculation 3.5 hr/rolling day 

1957 0.076 rem 

Lognormal 

GSD 4.3 

1948 2.503 rep 

1949 2.730 rep 

1950 2.730 rep 

1951 2.730 rep 

1952 2.730 rep 

1953 2.730 rep 

1954 0.543 rep 

1955 0.543 rep 

1956 0.543 rep 

U billets 

Nonpenetrating 5 mrep/hr Instrument 

measurement 3.5 hr/rolling day 

1957 0.543 rep 

Lognormal 

GSD 1.5 

1948 0.143 rem 

1949 0.156 rem 

1950 0.156 rem 

1951 0.156 rem 

1952 0.156 rem 

1953 0.156 rem 

1954 0.031 rem 

1955 0.031 rem 

1956 0.031 rem 

Penetrating 0.285 mrem/hr MCNP 

Calculation 3.5 hr/rolling day 

1957 0.031 rem 

Lognormal 

GSD 5.7 

1948 2.503 rep 

1949 2.730 rep 

1950 2.730 rep 

1951 2.730 rep 

1952 2.730 rep 

1953 2.730 rep 

1954 0.543 rep 

1955 0.543 rep 

1956 0.543 rep 

U rods 

Nonpenetrating 5 mrep/hr Instrument 

measurement 3.5 hr/rolling day 

1957 0.543 rep 

Lognormal 

GSD 2.3 

Source: ORAUT 2011, Table 20 
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3.2 RECONSTRUCTION OF INTERNAL EXPOSURES DURING THE 

OPERATIONAL PERIOD 

Urinalysis samples were taken at Simonds Saw and Steel from late 1948 through 1952. Many 

times samples were taken before and after a particular rolling period. NIOSH proposes to use 

these urinalysis samples to construct coworker intakes to unmonitored workers. A summary of 

available bioassay data is presented in Table 5 of the TBD and recreated here in Table 3 with the 

addition of the number of bioassay samples by date. Four intake periods were calculated using 

the data in Table 17 and are recreated here in Table 4. 

Table 3. Available Uranium Urinalysis Data at Simonds Saw and Steel 

Bioassay Date 

Number of 

Bioassay 

Results 

GM Bioassay 

(mg/L) 

84th-Percentile 

Bioassay (mg/L) 

Maximum 

Bioassay (mg/L) 

11/1/1948 12 0.021 0.045 0.140 

11/3/1948 12 0.022 0.042 0.090 

11/4/1948 11 0.022 0.043 0.070 

11/8/1948 11 0.011 0.018 0.030 

11/11/1948 10 0.016 0.031 0.050 

11/15/1948 11 0.016 0.035 0.050 

1/6/1949 11 0.006 0.016 0.018 

4/27/1949 12 0.017 0.028 0.036 

11/4/1949 16 0.016 0.036 0.272 

11/17/1949 52 0.001 0.010 0.164 

1/6/1950 49 0.002 0.009 0.026 

1/19/1950 49 0.010 0.024 0.035 

5/15/1950 25 0.005 0.014 0.022 

5/23/1950 25 0.008 0.019 0.034 

8/14/1950 20 0.027 0.041 0.102 

8/28/1950 18 0.016 0.022 0.033 

9/23/1950 20 0.002 0.009 0.020 

9/25/1950 19 0.011 0.018 0.024 

10/20/1950 19 0.006 0.026 0.067 

10/25/1950 19 0.005 0.016 0.043 

11/9/1950 19 0.003 0.010 0.030 

11/16/1950 40 0.005 0.014 0.028 

12/14/1950 40 0.006 0.015 0.080 

12/20/1952 62 0.016 0.035 0.066 

12/22/1952 62 0.015 0.033 0.054 

 Source: ORAUT 2011, Table 5 
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Table 4. TBD Derived Coworker Intake Values 

Radionuclide Start End Intake Route Absorption 

Type 

Intake 

(pCi/d) GSD 

2/24/1948 12/1/1948 Inhalation M 5.76E+02 3.0 

12/1/1948 12/15/1950 Inhalation M 2.36E+02 3.0 

12/15/1950 12/31/1952 Inhalation M 4.49E+02 3.0 

1/1/1953 12/1/1957 Inhalation M 5.76E+02 3.0 

2/24/1948 12/1/1948 Inhalation S 1.72E+04 3.0 

12/1/1948 12/15/1950 Inhalation S 2.40E+03 3.0 

12/15/1950 12/31/1952 Inhalation S 7.26E+03 3.0 

U-234 (Choose 

M or S intake 

scenario, not 

both) 

1/1/1953 12/1/1957 Inhalation S 1.72E+04 3.0 

1/1/1953 12/1/1957 Inhalation M, if U is M 1.05E+00 3.0 Np-237* 1/1/1953 12/1/1957 Inhalation S, if U is S 3.13E+01 3.0 

1/1/1953 12/1/1957 Inhalation M, if U is M 1.05E+00 3.0 Pu-239* 1/1/1953 12/1/1957 Inhalation S, if U is S 4.50E+01 3.0 

*Np and Pu intakes are based on the contaminant ratios of 0.00182 and 0.00261, respectively. 

Source: ORAUT 2011, Table 17 

It should be noted that bioassay data were only used to calculate intakes for the first 3 periods 

displayed (February 24, 1948–December 1, 1948; December 1, 1948–December 15, 1950; and 

December 15, 1950–December 31, 1952). From 1953 onward, the intake rates were assumed to 

be equal to those in the pre-December 1, 1948, intake period. This is reflective of the loss of 

engineering controls designed to reduce dust levels during this period, which would have been 

similar to the earlier period at Simonds. 

3.3 RECONSTRUCTION OF EXTERNAL EXPOSURES DURING THE POSTOPERATIONAL PERIOD 

To reconstruct external doses in the residual period, NIOSH utilizes a survey that was performed 

at Simonds Saw and Steel by National Lead of Ohio (NLO) prior to the closeout of its contract 

with NLO. The stated objective of the survey trip was described as follows: 

The purpose of this visit to Simonds was to make a preliminary radiation survey 

to determine if further clean-up or decontamination of those portions of the 

Simonds’ Plant, which had been used for work with radioactive materials under 

the National Lead contract, would be required before termination of the contract. 

(Heatherton 1957) 

It is not clear to what extent the plant had been decontaminated at that point. The results of 

external radiation levels found during the survey are presented in Table 5. 
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Table 5. Measurements Taken at Locations Higher than 0.2 mreps Combined 

Beta/Gamma 

Location 

Rough 

Dimensions of 

Contamination 

Beta-gamma 

Contact Readings 

(mreps/hr) 

Beta Readings 

at 3 ft 

(mreps/hr) 

Gamma 

Readings at 3 ft 

(mR/hr) 

10” Bar Mill Bed 75 ft2 × 1⁄2” thick 10–20 1.0–1.7 0.04, 0.05 

Front of Shear 10 ft2 × 1” thick 1–2 0.4 0.08 

Between Floor Plates on Mill 

Floor Unavailable 0.15 0.05 Not Detected 

Forge Area Unavailable 0.7–1.2 0.2 0.02 

Top of Furnace 150 ft2 × 2” thick 1.0 Not Measured Not Measured 

Source: Heatherton 1957, Table 1 

In order to reconstruct external doses during the residual period, the TBD states: 

To reconstruct external exposure to residual radioactivity after the end of AEC 

operations, this analysis assumed that workers were exposed to 0.08 mR/hr 

penetrating radiation, which was the upper end of the gamma exposure rate 

readings at 1 m in 1957. The residual penetrating radiation exposure was 

estimated by assuming that 0.08 mR/hr was the median rate and the beta/gamma 

exposure rate at 3 ft (0.4 mrep/hr) was the 95th-percentile rate, which yields a 

GSD of 3.5. A nonpenetrating external exposure was estimated by assuming that 

0.2-mrep/hr beta/gamma reading at 3 ft from the floor in the forge area was the 

median rate and that the 1-mrep/hr beta/gamma reading at contact was the 95th

percentile rate, which yields a GSD of 2.6. (ORAUT 2011) 

These external dose rates were converted to annual doses assuming an 8-hour workday and 

250 workdays per year (nominally 2,000 hours/year). 

3.4 RECONSTRUCTION OF INTERNAL EXPOSURES DURING THE POSTOPERATIONAL PERIOD 

To determine the internal exposure intake rate at the start of the residual period, NIOSH assumes 

that the average of general air samples taken at Simonds Saw and Steel from 19493

–1953 

represents a bounding value of the contamination present at the cessation of operations. This 

results in an airborne contamination level of 94 μg/m3

 and an associated intake rate of 

422 pCi/calendar day. 

To evaluate the intake rate at the end of the residual period, surface contamination (beta) 

measurements made during a 2007 remedial investigation were used (Earth Tech 2010). The 

TBD states: 

Surface contamination measurements performed during this investigation were 

used to derive Exposure Point Concentration (EPC) values to be used in exposure 

 3 Although the TBD states that it used general air samples starting in 1949, the references provided

indicate that samples from 1948 were also included.
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NOTICE:

and risk assessment studies. The EPC values represent the 95% upper confidence 

limit values for each particular parameter reported. (ORAUT 2011) 

These exposure point concentration values are reported in Table 22 of the TBD and recreated 

here in Table 6. 

Table 6. 2007 Exposure Point Concentration (EPC) Values at Simonds Saw and Steel 

(dpm/100 cm2 – beta) 

Building Maximum Average EPC Value 

1 21,000 300 600 

2 140,100 200 400 

3 145,900 3,500 4,600 

4/9 30,700 1,100 1,300 

5 2,200 1,000 1,200 

8 58,300 2,600 6,800 

24 124,200 5,400 9,300 

35 2,800 300 400 

 Source: ORAUT 2011, Table 22 

The TBD uses the highest EPC value (9,300 dpm/100 cm2 in Building 24) and assumes a 

resuspension factor of 10-6. Additionally, the assumption is made that the total uranium surface 

activity is 1.93 times the total beta value. This results in an intake rate of approximately 

5.5 pCi/d. This intake rate is assumed to be constant from 1982 through the present. An 

exponential decrease in intake rate is assumed from the initial intake rate (422 pCi/d in 1958) to 

the ending intake rate (5.5 pCi/d in 1982); this exponential rate constant is 0.18/yr. 

Thorium intake rates during the residual period are estimated by assuming that the thorium 

intake was 1% of the uranium intake, which is consistent with the relative level of production on 

a mass basis4

 of thorium versus uranium at Simonds Saw and Steel.

 4 The intake of thorium is based on 1% of the activity of uranium, not the mass, though historical

documentation indicates production of thorium was approximately 1% of the mass of uranium processed.
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4.0 VERTICAL ISSUES 

4.1 FINDING 1: MORE SUBSTANTIVE DISCUSSION OF THE PROPOSED 

OPERATIONAL EXTERNAL DOSE APPROACH IS NEEDED DUE TO 

LIMITED FILM BADGE DATA 

Worker film badging was not a regular practice at Simonds Saw and Steel; in fact, only one set 

of film badge data exists, which covers a period from October 11, 1949–October 19, 1949. 

Because of the severely limited external exposure records for workers, NIOSH adopted a 

combination of survey readings along with a modeling approach using MCNP to derive the 

following external exposures: 

 Submersion in air contaminated with uranium dust 

 Exposure from contaminated surfaces 

 Non-penetrating exposure (beta) at the surface of uranium billets and rods 

 Penetrating exposure (gamma) to uranium billets and rods 

The results of NIOSH’s analysis are shown in Table 20 of the TBD, which is recreated here in 

Table 7. It is important to note that the TBD assumes that workers were exposed to uranium 

rods for 3.5 hours per rolling day and uranium billets for 3.5 hours per rolling day. The TBD 

states: 

Several air exposure records were reviewed to estimate a worker’s time near a 

billet or rod versus being in the general area. The records indicated that for most 

workers the time near the uranium billet or rod was less than 5 hr/shift, but some 

workers could have spent 6.5 hours near the rods and billets. Because workers 

changed jobs, this analysis assumed that workers were near the billets for 

3.5 hr/rolling day and near the rods for 3.5 hr/rolling day. (ORAUT 2011, 

pg. 35) 

NIOSH should clarify why it is not plausible that workers could have been coincidentally 

exposed to uranium rods and billets, but rather that the two source terms represent separate 

exposure configurations (for example, process descriptions, special separation of the two source 

terms). It would also be instructive for NIOSH to provide specific examples of air exposure 

records that support the proposed exposure duration to each source term (billets versus rods), 

particularly those higher-risk jobs, such as the roughing and finishing roll operators. 
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Table 7. Derived External Exposure Values 

Year Exposure Scenario Exposure type Annual Exposure 

(Roentgen) 

Annual Total 

(Roentgen) 

Submersion, Penetrating 0.582 

contaminated surfaces Nonpenetrating 2.912 

Penetrating 0.352 U Billets Nonpenetrating 2.503 

Penetrating 0.143 

1948 

U Rods Nonpenetrating 2.503 

1.08 γ

7.92 β

Total: 9 

Submersion, Penetrating 0.650 

contaminated surfaces Nonpenetrating 3.250 

Penetrating 0.384 U Billets Nonpenetrating 2.730 

Penetrating 0.156 

1949–1953 

U Rods Nonpenetrating 2.730 

1.19 γ

8.71 β

Total: 9.90 rem 

Submersion, Penetrating 0.650 

contaminated surfaces Nonpenetrating 3.250 

Penetrating 0.076 U Billets Nonpenetrating 0.543 

Penetrating 0.031 

1954–1957 

U Rods Nonpenetrating 0.543 

0.76 γ

4.34 β

Total: 5.10 rem 

Source: ORAUT 2011, Table 20 

TBD-6000 (Battelle 2006, pg. 36) recommends using a 10:1 ratio for beta versus gamma dose to 

parts of the body other than the hands and arms. Based on the modeled gamma doses shown in 

Table 2 of Section 3.1, this would result in beta doses of approximately 2 mrep5

/hr for billets and 

7 mrep/hr for rods. This is consistent with the TBD assumed value of 5 mrep/hr for both 

exposure configurations. However, when workers directly handle the uranium billets and rods, 

the beta dose would increase to approximately 230 mrep/hr (Battelle 2006, pg. 36). NIOSH 

should explore the potential for workers to directly handle uranium materials at Simonds Saw 

and Steel, and how that may affect the assumed beta dose estimates. 

Table 8 shows the external film badge data taken in October of 1949 for comparison with the 

derived doses during that period (1.18 γ, 8.71 β). The film badge data were taken over a period 

of 9 days, which included a weekend (Tuesday to the following Wednesday). In order to 

extrapolate these recorded doses to a full year of work, it was assumed that the badges were worn 

for a 7-day rolling operation and extrapolated to 156 rolling days per year. For example, Badge 

Reference #1 showed 595 mR over an assumed 7 days of uranium rolling operations. This could 

then be extrapolated to an assumed full year of rolling by normalizing to a single day and 

multiplying by 156 rolling days per year: 

595 [mR/7days] / 7 [days] * 156 [rolling days/yr] / 1,000 [mR/R] = 13.26 [R/yr] 

 5 Unit of millirep is based on the rep (roentgen equivalent physical), which is a historical unit of

dose equivalence approximately equal to a rem
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This can then be compared with the TBD-assigned value of 9.90 R to show a difference of 

3.37 R (13.26 - 9.90 = 3.36) between the extrapolated film badge results and the MCNP-modeled 

external dose. 

Table 8. Film Badge Data from October 11, 1949–October 19, 1949 Extrapolated to a 

Full Year of Rolling 

Original values (milli-Roentgen) Extrapolated to 1 Year** (Roentgen) Badge 

Reference* 

No. Beta Gamma Total Beta Gamma Total 

Difference 

with TBDDerived 

Values (R) 

1 520 75 595 11.59 1.67 13.26 3.36 

2 300 50 350 6.69 1.11 7.80 -2.09 

3 160 0 160 3.57 0.00 3.57 -6.32 

4 310 55 365 6.91 1.23 8.13 -1.76 

5 400 75 475 8.91 1.67 10.59 0.70 

6 260 105 365 5.79 2.34 8.13 -1.76 

7 330 0 330 7.35 0.00 7.35 -2.54 

8 390 50 440 8.69 1.11 9.81 -0.08 

9 270 55 325 6.02 1.23 7.24 -2.65 

10 430 0 430 9.58 0.00 9.58 -0.31 

11 360 0 360 8.02 0.00 8.02 -1.87 

12 1250 105 1355 27.86 2.34 30.20 20.31 

13 520 75 595 11.59 1.67 13.26 3.37 

14 Lost Badge Lost Badge NA 

15 190 0 190 4.23 0.00 4.23 -5.66 

16 320 75 395 7.13 1.67 8.80 -1.09 

17 815 115 930 18.16 2.56 20.73 10.84 

18 370 95 465 8.25 2.12 10.36 0.47 

19 320 75 395 7.13 1.67 8.80 -1.09 

20 300 75 375 6.69 1.67 8.36 -1.53 

21 300 55 355 6.69 1.23 7.91 -1.98 

* Note: Actual badge numbers have been replaced with a random reference number for Privacy Act concerns. 

** A full year of rolling assumes that 156 days per year were spent processing uranium metal assumed in the TBD. 

As shown in Table 8, 6 of the 20 TBD-derived external values are lower than the corresponding 

values obtained by extrapolating the 7-day film badge readings to 156 days; those TBD values 

corresponding to badges #12 and #17 are lower by factors of 20 and 10, respectively. Note that 

the differences may be greater than indicated in Table 8, because the annual doses extrapolated 

from the film badge readings do not include any external doses accrued from contamination 

present in the plant during non-uranium rolling operations. Hence, for some workers, the 

coworker model may underestimate the annual dose to workers. However, it is not clear to what 

extent these numerical differences are significant, given the uncertainties inherent in 

extrapolating the badge readings and those related to modeling. NIOSH should perform a 

similar comparison in the TBD to demonstrate that their chosen methods for assigning external 

dose are bounding. 
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4.2 FINDING 2: REPRESENTATIVENESS OF AVAILABLE URINALYSIS DATA 

IN RELATION TO CHANGING INDUSTRIAL HYGIENE PRACTICES AND 

EXPOSURE POTENTIAL 

NIOSH proposes to use only the urinalysis results and not the DWEs in determining internal 

dose during the operational period. Figure 1 shows the distribution of the number of bioassay 

samples taken during the operational period. Table 9 shows an overview of the bioassay results 

based on SC&A’s independent compilation of the urinalysis data. The table also displays the 

TBD-proposed intake periods and specific intake rates (pCi/d) as seen in Table 17 of the TBD. 

Figure 1. Distribution of Urinalysis Results during the Operational Period (1948–1957) 
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Table 9. Overview of Urinalysis Data during the Operational Period 

Results (mg/l) Date of Samples 

Covering Period 

Number of 

Samples 

Pre-roll or 

Post-roll 

Designation Arithmetic 

Average Median Maximum

Proposed 

Intake Period 

Calculated 

Intake from 

TBD Table 17

(pCi/d) 

11/1/1948 12 Unknown 0.031 0.020 0.140 

11/3/1948 12 Unknown 0.028 0.020 0.090 

11/4/1948 11 Unknown 0.028 0.020 0.070 

11/8/1948 11 Unknown 0.012 0.010 0.030 

11/11/1948 10 Unknown 0.019 0.015 0.050 

11/15/1948 11 Unknown 0.018 0.020 0.040 

2/24/48–

12/1/48 

Type M: 

5.76E+02 

Type S: 

1.72E+04 

1/6/1949 11 Pre-roll 0.009 0.009 0.018 

4/27/1949 12 Pre-roll 0.019 0.019 0.036 

11/4/1949 16 Pre-roll 0.031 0.014 0.272 

11/17/1949 52 Post-roll 0.008 0.001 0.164 

1/6/1950 49 Pre-roll 0.005 0.002 0.026 

1/19/1950 49 Post-roll 0.013 0.015 0.035 

5/15/1950 25 Pre-roll 0.007 0.007 0.022 

5/23/1950 25 Post-roll 0.010 0.014 0.034 

8/14/1950 20 Pre-roll 0.030 0.028 0.102 

8/28/1950 18 Post-roll 0.017 0.017 0.033 

9/23/1950 20 Unknown 0.004 0.000 0.020 

9/25/1950 19 Post-roll 0.012 0.013 0.024 

10/20/1950 19 Pre-roll 0.014 0.004 0.067 

10/25/1950 19 Post-roll 0.009 0.006 0.043 

11/9/1950 19 Unknown 0.005 0.004 0.030 

11/16/1950 40 Unknown 0.008 0.006 0.028 

12/14/1950 40 Unknown 0.009 0.007 0.080 

12/1/48–

12/15/50 

Type M: 

2.36E+02 

Type S: 

2.4E+03 

12/20/1952 62 Unknown 0.020 0.017 0.066 

12/22/1952 62 Unknown 0.019 0.016 0.054 

12/15/50–

12/31/52 

Type M: 

4.49E+02 

Type S: 

7.26E+03 

Remaining 

Operational 

Period 

0 N/A Assumes 2/24/48–12/1/48 derived 

intake rates 

1/1/53–

12/31/57

Type M: 

5.76E+02 

Type S: 

1.72E+04 

Source: ORAUT 2011, Table 17 
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Section 3.1.1 of the TBD outlines how the bioassay data were interpreted and analyzed to obtain 

the intakes as described in Table 9 (see ORAUT 2011, Table 17). The TBD assumes a detection 

limit of 0.01 mg/L for uranium urine bioassay. This value is based on a reported sensitivity of 5 

to 10 μg/L for uranium fluorimetry urinalysis in the early years (Wilson 1958). In addition, 

several early Simonds bioassay reports noted that the results of less than 10 μg/L were 

insufficient for reliable detection (Author unknown 1948). Intake rates are adjusted from 

milligrams/day to picocuries/day by multiplying by 682.91 pCi/mg. 

It is not clear how accurately the urinalysis data and potential gaps in the data reflect the changes 

in exposure potential over the plant’s occupational history or whether a plausible upper bound 

intake can be derived from the data. There are documented changes in engineering controls and 

industrial hygiene practices that were implemented during the first few years of the AEC 

contract, but these were incrementally removed or no longer used during later years of operation. 

Attachment 1 displays a timeline of the use and removal of these controls. 

The air sampling data collected from 1948 to 1953 reflect changes in airborne dust levels that 

resulted from the implementation and subsequent removal of engineering controls. Figures 2 and 

3 are plots of the number of urinalysis samples and the average and median DWE data by job 

category for the intake periods proposed by NIOSH.6

 The vertical black lines on Figures 2 and 3 

delineate the intake periods as outlined in Table 9 (see ORAUT 2011, Table 17). 

Figure 2. Chronological Plot of the Uranium Urinalysis Sampling versus the Average 

Daily Weighted Exposure over the same Timeframe 

 6 Note:  this is not reflective of the DWEs for all workers included in the sample.  Each job title is given

equal weight.
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Figure 3. Chronological Plot of the Uranium Urinalysis Sampling versus the Median 

Daily Weighted Exposure over the same Timeframe 

The sharp reduction in average and median DWEs between the first intake period (1948) and 

second intake period (1949 to 1951) demonstrates the large-scale improvements in radiological 

control practices that were introduced during that timeframe. The first DWE report was for 

operations on October 27, 1948, and the first urinalysis samples were taken a few days later 

(November 1, 1948), with follow-up samples taken over the next 2 weeks Also, as noted in 

Table 9, the derived Type S average annual intake rates based on bioassay data decline from 

1.72E4 pCi/y in the first period to 2.4E3 pCi/d in the second time period. 

Most of the AEC-recommended radiological controls had not been in use during the October 27, 

1948, rolling, with the exception of the use of a central vacuum, instead of standard broom 

sweeping. There are no DWE reports prior to the October rolling. Though records indicate a 

gradual introduction of other radiological safety improvements, such as the issuance of two sets 

of protective clothing for a rolling in late July of 1948 (previously, workers only wore protective 

gloves and were responsible for washing their own clothes), those improvements did not include 

respiratory protection and would therefore not be expected to have mitigated inhalation intakes 

by workers. Thus, while the urinalysis samples taken in November 1948 are probably 

representative of intakes that occurred during the October rolling, it is not clear that extrapolating 

these results to earlier rollings before dust control measures (e.g., vacuum cleaning) were 

employed will result in bounding intakes. 

The continuing downward trend in average DWEs during the second intake period (December 1, 

1948–December 15, 1950) is indicative of more improvements in radiological control as 

additional precautions were taken, such as: 
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 Ventilation installed over the rolls, vacuum cleaner and pressure quencher exhausted 

through the roof (January 20, 1949) 

 Exhaust over the descaler installed (February 15, 1949) 

 Partial installation of floor grating to decrease the resuspension of dusts (April 5, 1949) 

 Lucite plastic sheeting installed over the rolling ventilation hoods (June 7, 1949) 

 Improvement in dust collection efficiency for the finishing rolls exhaust system 

(September 7, 1949) 

 Installation of the rest of the floor grating (sometime after September 7, 1949) 

 Improvement of the quencher exhaust system, elimination of rod shearing operation, 

exclusive use of the lead bath furnace instead of gas fired furnace system (April 14, 1950) 

The median urine concentrations and NIOSH-derived intakes for the second intake period are 

substantially lower than for the first period. While urinalysis samples during the second period 

were taken as early as January 6, 1949, all were designated as pre-roll samples until after the 

November rolling (November 17, 1949) (Table 9). It is not clear to what extent they reflect the 

retention of insoluble forms of uranium from internal exposures accrued during first period 

rolling operations (when radiological controls were incrementally being installed). For the 

remainder of the period, urinalysis samples were taken before and after rolling operations in 

January, May, August, September, and October of 1950.7 Samples were also taken on December 

14, 1950, though it is unknown whether they represent pre- or post-roll samples. 

The bioassay results for the third intake period (December 15, 1950–December 31, 1952) are 

higher than for the previous period and likely reflect increased dust levels that resulted from less 

effective institutional controls, notably: 

 Pressure quenching changed to dip quenching, which left more scale on the rods; use of a 

continuous water stream on some rods, which caused higher localized air contamination; 

removal of the plexiglass (Lucite) shields over the rolling ventilation hoods8

 (January 10, 

1951) 

 Intermittent use of the floor grating (March 8, 1951) 

 Grating directly in front of the rolls had been removed, broom sweeping was regularly 

being employed with only ‘intermittent’ use of the vacuum cleaner, lack of adequate 

protective clothing (August 15, 1951) 

 Floor grating had been pounded flat by continued pounding by the weight of the rods; 

vacuum cleaner still not being used (December 9, 1952) 

7 While not specifically labeled as pre‐roll or post‐roll, it is likely that samples taken on November 9, 1950,

and November 16, 1950, represent pre‐ and post‐roll samples. 8 The AEC report states, “It was learned that the omission of shields on the hoods in the beginning was

through oversight.  After that, no one bothered to put them on” (Heatherton 1951a).  Plexiglass shields were not

reinstalled until August 21, 1951.
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Despite the removal and degradation of radiological control practices as described above, the 

DWE data for the third period remain fairly consistent with the previous intake period. The lack 

of an apparent upward trend in DWE data during this time may indicate incomplete air 

concentration measurements in the affected rolling and quench areas. That is, the highest 

concentrations may have been missed due to the timing of air sampling measurements relative to 

uranium rolling operations. Davis and Strom (2008) demonstrated that the general air and 

breathing zone air samples that comprise DWE data are highly variable due to spatial and 

temporal fluctuations in air concentrations, and recommend a GSD of 5 be applied to such data 

for the purposes of coworker modeling. 

There appears to be a brief spike in the DWE data in late 1952 (third from last measurement); 

however, this is reflective of a thorium operation that occurred on the unventilated 10” bar mill, 

as opposed to the normally ventilated 16” bar mill. Specifically, the AEC report for this 

operation (Klevin and Weinstein 1953b) notes: 

Aside from the lack of suitable dust control measures for this operation which 

include local exhaust ventilation over the three rolls, floor gratings in front of the 

rolls and a central vacuum cleanup system, there were malpractices of good 

industrial hygiene procedures which contributed to the high alpha concentrations. 

These were: 

1 – No cleanup during the entire rolling operation 

2 – Sweeping of steel plate floor are [sic] with brooms after 

completion of rolling 

3 – Stamping of thorium rods on flat steel bed of conveyor 

4 – Tracking of dust from the rolls to the rest areas 

Though this thorium rolling may not directly reflect the type of exposures encountered during 

uranium rolling, they are likely indicative of the type of practices occurring at the site during that 

time. 

The last DWE point represents the rolling of “Special E” or enriched material. The AEC report 

for this rolling (Heatherton 1953) states: 

Ventilation on the 16" mill was the same as normally used in uranium rollings at 

the Simonds plant. No ventilation was provided for work on the 10” mill. Air 

dust results indicate that workers on the 10” mill had weighted exposures while 

rolling ranging from 5.4 to 130 MAC. The operation was a one-time operation 

and was not meant to be repeated... General air results indicate an overall 

contamination of the building as a result of performing the operation without 

ventilation. A repetition of this operation could seriously contaminate the whole 

building and result in immediate and prolonged exposure of building occupants to 

concentrations in excess of the maximum allowable amount. 

Thus, the high median DWE for the “Special E” rolling was due not only to the higher specific 

activity of enriched versus natural uranium, but also to the lack of ventilation on the 10” mill. 
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NOTICE:

The only urinalysis samples taken during this intake period were at the very end of the period 

(December 20–22, 1952), though it is not clear whether these represent pre-roll or post-roll 

samples (or both). Considering the degradation of radiological controls throughout the defined 

intake period and the insoluble nature of the uranium metal and oxides, these urinalysis samples 

can probably be assumed to reflect a bounding intake scenario for the rolling operations during 

intake period 3. 

Figure 4 depicts the timeline of changes in industrial hygiene practices in relation to the number 

of urine bioassay samples. Figures 5 and 6 plot the median DWE values for the proposed intake 

periods and the proposed NIOSH intakes based on bioassay (Types M and S respectively) for the 

defined intake periods and include the timeline of industrial hygiene changes. 
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Figure 4. The Number of Uranium Urinalysis Results Plotted versus the Timeline of Significa

in Industrial Control 

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0

200400600800

10001200140016001800

1948 1949 1950 1951 1952 1953 

MedianDWE Result

Year

Median DWE Result TypeM Intake based on Bioassay

Vacuumused

intermittently

Main ventilationinstalled overrolls

Floorgratingspartiallyinstalled

Floor gratingscompletely installed

Practice of broomsweeping ceases

Lucite shielding installed

around ventilation

Lucite shieldingremoved from

ventilation hoods

Vacuumcleaningdeemed

"infrequent", lucite shields

reinstalled

Practice of broomsweepin

Floor gratingbeen pound

Floorgratings only

used intermittently

Figure 5. Median Daily Weighted Exposure and Proposed Type M Intakes based on Bioassay Data 

Timeline of Significant Changes in Industrial Control 

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0

200400600800

10001200140016001800

1948 1949 1950 1951 1952 1953 

MedianDWE Result

Year

Median DWE Result Type S Intake based on Bioassay

Vacuumusedintermittently

Main ventilation

installed overrolls

Floorgratingspartiallyinstalled

Floor gratingscompletely installed

Practice ofbroom sweepingceases

Lucite shielding installedaround ventilation

Lucite shieldingremoved fromventilation hoods

Vacuumcleaningdeemed

"infrequent", lucite shieldsreinstalled

Practice of broomsweeping 

Floorgratinbeen poun

Floor gratings onlyused intermittently

Figure 6. Median Daily Weighted Exposure and Proposed Type M Intakes based on Bioassay Data 

Timeline of Significant Changes in Industrial Control 

NOTICE

wever, th
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It is evident from Figures 4–6 that the bioassay and DWEs trend together, though the strongest 

correlation is seen in the first and second intake periods. It is also evident that the installation 

of main ventilation hoods and vacuum cleaning in late 1948 had the biggest impact on reducing 

air dust concentrations for the second intake period. NIOSH should analyze the available 

bioassay data in the context of industrial changes and observed DWE data to ensure that the 

derived intake values are representative of the changing exposure potential at Simonds Saw 

and Steel. 

4.3 FINDING 3: FURTHER DISCUSSION ON “PRE-ROLL” VERSUS “POSTROLL” URINALYSIS SAMPLING AND 1ST VERSUS 2ND SHIFTS 

As shown in Table 9, there are several instances where urinalysis samples were collected 

before and after a specific uranium rolling operation. It is not clear how these different types 

of samples may have been interpreted in developing coworker intake values. 

Of the 25 separate days when uranium samples were taken: 

 6 sampling days were designated as “post-roll” 

 7 sampling days were designated as “pre-roll” (2 of which did not have a corresponding 

“post-roll” sampling) 

 12 sampling days were not specifically labeled 

Notably, the 12 sampling days that were not specifically labeled as “pre-roll” or “post-roll” 

occurred either at the beginning of urinalysis sampling (first 6 sampling events) or at the end 

of urinalysis sampling (last 6 sampling events). These periods generally correspond with the 

decreased use of radiological engineering controls over the operational period of the plant. 

A comparison of pre-roll and post-roll samples for five pairs of urinalysis data is presented in 

Table 10; the first column provides a number for reference. The average pre-roll samples are 

higher than the average post-roll samples for three of the five pairs (#1, #4, and #5) and all 

samples overall.9

 When comparing the median values, this was the case for two of the five 

pairs (#1 and #4). For more highly soluble compounds, one would expect the post-roll 

urinalysis results to universally be higher than the pre-roll samples. However, it is likely the 

uranium inhaled by workers at Simonds Saw and Steel was in the form of metal and uranium 

oxide, both of which are Type S (insoluble) materials. Thus, as time went on, one would 

expect to see increasing urine concentrations, because the body burden should be increasing, 

even though engineering controls were changing. Therefore, short-term (i.e., pre- versus postroll) fluctuations in urine concentration would not necessarily be discernible through urine 

bioassay with Type S materials. However, it is not clear what circumstances might cause the 

urinalysis results to decrease during a rolling period, and a more detailed statistical analysis of 

these results may be warranted. 

9 The ‘All Post‐roll’ and ‘All Pre‐roll’ categories in Table 10 include all samples designated as post‐ or

pre‐roll, not just the pairs.
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Table 10. Comparison of Pre-Roll and Post-Roll Sampling 

Reference # Date # Percentage of Total Average Median Maximum 

11/4/1949 16 - 0.031 0.014 0.272* 1 

11/17/1949 52 - 0.008 0.001 0.164 

1/6/1950 49 - 0.005 0.002 0.026 2 

1/19/1950 49 - 0.013 0.015 0.035 

5/15/1950 25 - 0.007 0.007 0.022 3 

5/23/1950 25 - 0.010 0.014 0.034 

8/14/1950 20 - 0.030 0.028 0.102 4 

8/28/1950 18 - 0.017 0.017 0.033 

10/20/1950 19 - 0.014 0.004 0.067 5 

10/25/1950 19 - 0.009 0.006 0.043 

All Post-roll** 182 28% 0.011 0.010 0.164 

All Pre-roll** 152 24% 0.014 0.009 0.272 

Unknown 310 48% 0.016 0.011 0.140 

* Though there is no information in the source documentation (Author Unknown 1949–1951) that would 

invalidate the sample, the value of 0.272 on November 4, 1949, may have been due to a contaminated sample 

and could be considered an outlier. The worker in question gave a sample prior to a rolling period that was 

0.272 mg/l; 2 weeks later (presumably after the rolling period), the same worker sampled at 0.010 mg/l. 

When that data point is removed, the average drops to 0.015 and the median to 0.013, and the average for all 

Pre-roll samples drops to 0.012. 

** The ‘All Post-roll’ and ‘All Pre-roll’ categories in Table 10 include all samples designated as post- or pre-roll, 

not just the pairs. 

Additionally, it has been suggested in source documentation for Simonds that there may have 

been differences in the exposure potential between the first and second shift. One radiological 

monitoring report in particular (Heatherton 1950b, covering the rolling period from August 14, 

1950 to August 28, 1950) sampled workers both before and after the rolling operation. Worker 

samples that were taken ‘post-roll’ were actually lower than the ‘pre-roll’ samples for 14 of the 

18 workers. The reference states the following possible reasons: 

It is difficult to single out a reason for the results of urine samples collected in 

August. Possible explanations are: 

1 – The group sampled work the second shift which has less 

supervision and consequently there are higher exposures

[Emphasis added] 

2 – There was an error in the analysis 

3 – All or most of the samples were contaminated 

4 – The group received a very high exposure a few hours before the preroll samples were collected and large amounts of uranium were still 

being excreted at the time of the post-roll sampling.

It is not clear under what conditions scenario 4 could be a viable explanation, given that 

inhaled materials were predominantly insoluble Type S. Scenarios 2 and 3 would seemingly 
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invalidate this particular batch of bioassay data. If scenario 1 is correct, then it is important to 

establish which shifts were sampled for uranium. SC&A attempted to compile data to tie 

specific workers to the first or second shift, so that the urinalysis results of the two groups 

could be compared; the results of the comparison are shown in Table 11. As seen in the table, 

the average and median values for the first and second shift are comparable. The highest value 

for the two groups occurred for the second shift. This does not appear to support the notion 

that the exposure potential was significantly greater for the second shift; also it does not appear 

that one shift was sampled more frequently than the other. 

Table 11. Comparison of Urinalysis Samples for the Two Different Shifts 

Shift Designation Number of 

Samples 

Percentage 

of Total 

Percentage of 

Zero Samples Average Median Max 

First 93 14% 10% 0.017 0.015 0.066 

Second 114 18% 15% 0.016 0.016 0.102 

Unknown 437 68% 20% 0.013 0.009 0.272 

4.4 FINDING 4: REPRESENTATIVENESS OF PROPOSED INTAKE MODEL 

FOR DIFFERENT JOB TYPES AND EXPOSURE POTENTIAL 

Based on the DWE data collected, it is apparent that different job classifications had 

significantly different exposure potential, particularly in the early years. Table 12 presents 

DWE data collected by the AEC for the main job titles at Simonds Saw and Steel. For the job 

titles designated as ‘rollers,’ even the position on a particular roll has a significant impact on 

the exposure potential. For example, workers on the east side of the roughing roll had DWEs 

that were between 2 and 12 times higher than the west side of the roll (on average, the 

exposures are about 5 times higher). On any given sampling date, the ratio of the highest DWE 

to the lowest DWE ranged from ~2.7 to as high as ~27. On average, the ratio from the highest 

DWE to the lowest DWE was approximately 10. It is also important to note that the DWEs 

represent snapshots in time that may well have missed some of the highest air concentrations. 

The high variability and uncertainty in the DWE data is the reason why Davis and Strom 

(2008) recommend a GSD of 5 be applied to DWE data for use in dose reconstruction. 

With such diverse exposure potential within the same plant, it is important that the proposed 

intake model does not underestimate unmonitored doses to higher-risk job classifications. 

SC&A compiled job title information, where available, in order to compare the urinalysis 

results for the most common job titles found in the DWE reports. Approximately 25% of the 

urinalysis results could be matched to one of these job titles. An overview of these urinalysis 

results is found in Table 13. Not surprisingly, the roughing and finishing rollers had the 

highest average and median urinalysis results, with the east side of the rolls generally higher 

than the west.10 It has not been established that the proposed intake values properly bound 

exposures to the job titles with higher exposure potential.

 10 The furnace man shows the highest average results in Table 13; however, once the value of 0.272

μg/l is removed, the average drops significantly, as noted.
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Table 12. Daily Weighted Exposures (dpm/m3) for the Most Common Job Categori

Date Drag Down Operator Finishing Roll - East Finishing Roll - West Foreman Furnace Man Pressure Quencher Rod Stamper Roughing Roll - East Roughin

Roll - We

10/27/1948 620 8394 797 1760 527 1471 1944 13700 1620 

12/1/1948 732 2496 1028 908 274 477 826 1574 826 1/10/1949 105 1010 290 320 96 2580 1870 693 263 

4/5/1949 180 400 430 220 150 260 590 470 92 

5/10/1949 370 470 200 290 122 360 840 390 170 

1/9/1950 70 145 310 135 61 370 258 185 85 

1/10/1950 310 214 96 90 135 208 108 385 90 

4/1/1950 60 215 75 50 45 40 90 200 30 5/1/1950 131 232 120 110 17.6 39.4 111 195 33.2 

10/1/1950 55.5 96.2 72.4 58.8 58 35.9 34.2 112 61.5 

1/9/1951 90.4 945 53.5 81.5 81.5 91.7 82.3 622 48.5 

8/21/1951 116 175 114 149 99 91 75 124 132 12/9/1952 60 96.5 286 97.4 76.7 230 297 120 162 1/17/1953 - - - 701 - - 2041 1061 372 

Average 223.1 1145.3 297.8 355.1 134.1 481.1 654.8 1416.5 284.7 

Median 116.0 232.0 200.0 142.0 96.0 230.0 277.5 387.5 112.0 

Max 732 8394 1028 1760 527 2580 2041 13700 1620 
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Table 13. Urinalysis Results for the Most Common Job titles Identified in DWE 

Reports 

Job title # Samples Percentage of total Samples Average Median Maximum 

Dragdown Operator 8 1% 0.009 0.009 0.017 

Finishing Roll - East 20 3% 0.020 0.022 0.048 

Finishing Roll - West 16 2% 0.015 0.015 0.041 

Foreman 15 2% 0.011 0.003 0.066 

Furnaceman 8 1% 0.043 0.012 0.272* 

Pressure Quencher 21 3% 0.011 0.003 0.046 

Rod Stamper 13 2% 0.010 0.011 0.023 

Roughing Roll - East 13 2% 0.017 0.017 0.033 

Roughing Roll - West 19 3% 0.016 0.016 0.044 

Shear Man/ Straightener 28 4% 0.010 0.009 0.031 

* If the outlier value of .272 is omitted, the average and median values for the furnace man drop to 0.01 and the 

maximum value to 0.027.

4.5 FINDING 5: ESTABLISH CLAIMANT FAVORABILITY OF URINALYSIS 

COWORKER MODEL VERSUS DAILY WEIGHTED EXPOSURE (DWE) 

DERIVED COWORKER MODEL 

The TBD presents derived inhalation intake values based on both the DWE reports (ORAUT 

2011, Table 11) and urinalysis data (ORAUT 2011, Table 17). A comparison of both calculated 

intakes are recreated below in Table 14 and shown visually in Figures 7–9. SC&A notes that no 

statistical parameters were provided for the DWE-based intakes. Therefore, it is not possible to 

compare upper quantiles of the DWE distribution to the urinalysis-based values. As previously 

noted, Davis and Strom (2008) performed an uncertainty analysis on DWE data for prospective 

use in coworker model development and recommends a GSD of 5. A comparison of intakes at 

Simonds Saw and Steel based on DWE data versus urine bioassay might benefit from an 

evaluation of upper quantile values. It is noteworthy that NIOSH has accepted the Davis and 

Strom analysis for their thorium coworker model at Fernald (DCAS 2010) 

Since the last identified DWE report was issued in January 1953, it is not clear how the intakes 

for the latter periods were calculated. Also, the current TBD methodology using urinalysis 

assumes that the internal exposures after 1952 are equivalent to those in 1948. Figures 8 and 9 

show how the DWE-derived intakes would change if this same methodology had been applied. 

It is generally accepted that bioassay data are a preferable basis for developing coworker intakes 

when compared with other monitoring data, such as air sampling. However, given the large 

differences in Type M intakes between the DWE-derived intakes and urinalysis-derived intakes 

for certain periods, NIOSH should further demonstrate that the urinalysis model is reflective and 

bounding to the highest-exposed worker populations and represents a more accurate basis for the 

development of coworker intakes. 
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It should be noted that if Type S intakes based on bioassay data are applied, then the DWE-based 

intakes become less favorable to the claimant than bioassay-based intakes. The comparison of 

bioassay Type S intakes to DWE-based intakes is shown in Figure 9. 

Table 14. Comparison of TBD-Derived Intake Values based on Daily Weighted 

Exposure Reports and Urinalysis Samples 

Urinalysis Derived Inhalation Intakes* DWE Derived Inhalation Intakes 

Intake Period Absorption 

Type 

Urinalysis 

Derived Intake 

(pCi/d) 

Intake Period Absorption 

Type 

DWE Derived 

Intake (pCi/d) 

M 576 2/24/48–12/1/48 S 17,200 2/24/48–12/1/48 M, S 5,040 

M 236 12/1/48–12/15/50 S 2,400 12/1/48–4/5/49 M, S 2,290 

M 449 4/5/49-4/13/50 M, S 605 

12/15/50–12/31/52 

S 7,260 4/13/50–1/1/54 M, S 387 

M 576 1/1/53–12/1/57 S 17,200 1/1/54–12/31/57 M, S 153 

*TBD recommended coworker intakes 

Source: ORAUT 2011, Table 11 (DWE data) and Table 17 (urinalysis data) 

Figure 7. Comparison of Derived Intake Values based on Urinalysis and DWE Data 
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Source: ORAUT 2011, Table 11 (DWE data adjusted) and Table 17 (urinalysis data adjusted) 

Figure 8. Comparison of Derived Intake Values (Type M) based on Urinalysis and 

DWE Data Adjusted for Later Year Methodology 

Source: ORAUT 2011, Table 11 (DWE data adjusted) and Table 17 (urinalysis data adjusted) 

Figure 9. Comparison of Derived Intake Values (Type S) based on Urinalysis and 

DWE Data Adjusted for Later Year Methodology 
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4.6 FINDING 6: MORE QUANTITATIVE AND SUBSTANTIVE DISCUSSION OF 

AVAILABLE EXTERNAL MONITORING DURING RESIDUAL PERIOD 

In order to reconstruct external doses for workers during the residual period of operation, NIOSH 

proposes to use values identified during a survey of the Simonds plant immediately preceding the 

termination of their contract with NLO (Heatherton 1957). The purpose of the 1957 survey was 

to determine whether further cleanup operations would be needed subsequent to the contract 

closeout. Although much of the actual measurement data is not provided, the survey document 

makes the statement: 

With the exception of two small areas, the radiation readings at 3 feet above the 

floor never exceeded 0.2 mreps/hr combined beta and gamma radiation. 

(Heatherton 1957) 

The measurements of the “two small areas” are then presented here in Table 15 (see Heatherton 

1957, Table I). To assign penetrating dose, NIOSH proposes to use the gamma reading of 

0.08 mR/hr (as shown for the “Front of Shear”) as the median exposure and assume the value of 

0.4 mreps/hr-beta as representative of the 95th percentile exposure, which results in a GSD of 

3.5.11 It should be noted that Strom 2007 recommends using a GSD of 5 in the absence of other 

information. 

Also, it is not clear why a beta measurement would be used to represent external penetrating 

dose. However, it is possible that the source documentation is mislabeled and that this in fact 

represents a combined beta/gamma measurement instead of strictly beta. The TBD would 

benefit from a more substantive discussion as to why the specific penetrating dose values were 

chosen for the residual period. 

Table 15. Measurements Taken at Locations Higher than 0.2 mreps Combined 

Beta/Gamma 

Location 

Rough 

Dimensions of 

Contamination 

Beta-gamma 

Contact Readings 

(mreps/hr) 

Beta Readings 

at 3 Feet 

(mreps/hr) 

Gamma 

Readings at 

3 Feet (mR/hr) 

10” Bar Mill Bed 75 ft2 × 1⁄2” thick 10–20 1.0–1.7 0.04, 0.05 

Front of Shear 10 ft2 × 1” thick 1–2 0.4 0.08 

Between Floor Plates on 

Mill Floor Unavailable 0.15 0.05 Not Detected 

Forge Area Unavailable 0.7–1.2 0.2 0.02 

Top of Furnace 150 ft2 × 2” thick 1.0 Not Measured Not Measured 

Source: Heatherton 1957, Table I 

As seen in Table 15, the highest beta measurements were taken for the 10” Bar Mill Bed. It 

would be important to establish whether residual workers might have regularly worked on, or in 

close vicinity of, the 10” Bar Mill Bed in order to ensure that the external doses assigned using 

this survey data are favorable to the highest potentially exposed workers. It should also be noted 

 11 It appears, based on the values selected, that the GSD should be 2.65 (0.08*GSD^1.65=0.4 therefore

GSD=(0.4/0.08)^(1/1.65)=2.65)
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that these values are extrapolated to annual doses assuming an 8-hour workday in the TBD, 

though during the operational period, a 10-hour workday was assumed. NIOSH should provide 

the basis for this assumed reduction in hours worked per day during the residual period. 

Finally, a more quantitative discussion of residual surveys undertaken since the end of 

radiological operations at Simonds would help to demonstrate the claimant favorability of the 

proposed external dose assignments. Specifically, a discussion on the amount of available data 

that was collected and analyzed, and its relative magnitude compared to the assumed external 

dose values for the residual period would help strengthen the proposed approach. 

4.7 FINDING 7: APPROPRIATENESS OF CHOSEN INTERNAL METHODOLOGY 

DURING RESIDUAL PERIOD AND CONSISTENCY WITH OTIB-0070 

For internal doses associated with the start of the residual period, NIOSH proposes to use the 

average of the general air samples measured at the plant from 1949–1953 (listed as 94 μg/m3) to 

establish a daily intake rate of 422 pCi/day. Specific criteria for how air sampling data were 

identified and compiled were not provided in the TBD, so it is not clear what sampling data were 

included and what were discarded. Also, it is not clear why air sampling data from 1954 were 

not included in the analysis. Similar to the external dose methodology, the TBD assumes an 

8-hour work day for the residual period, though a 10-hour work day was assigned for the 

operational period. 

SC&A independently compiled available air sampling reports for comparison with the stated 

airborne contamination levels; the total number of records identified for the sampling types is 

shown in Table 16. As shown in the table, air sample results often were not labeled as 

specifically being “general air” or “breathing zone,” and it is not known if these samples (which 

were not specifically labeled) were included in NIOSH’s compilation. Also, many individual 

samples contained in the hardcopy records were repeat measurements of the same location, 

activity, and work day. It is not clear whether these repeat measurements were treated as 

individual results or were combined into a single average result in NIOSH’s data analysis. In 

SC&A’s analysis presented here, repeat samples were combined into a single average result to 

avoid biasing the available data with repeated measurements of the same activity/timeframe. 

Table 16 also shows that a large proportion of the general air samples identified were taken in 

1949–1950 when institutional controls and associated contamination levels would be the lowest. 

Tables 17-19 present the average, median, and geometric mean results for the different 

categories of air samples by year. Figure 10 plots the number of general air samples versus the 

average annual result; the years with higher numbers of air sampling results generally had lower 

average contamination results. As shown in Table 17, the average general air sample for all 

years was approximately 479 dpm/m3

. Assuming natural uranium, this would roughly translate 

to 316 μg/m3

, which is significantly higher than the number quoted in the TBD (94 μg/m3). 

However, it is also worth noting that the median and geometric mean results from 1948–1954 are 

significantly less than 94 μg/m3

 (48 and 50 μg/m3, respectively). 

Because operations at the end of the operational period would likely have been similar to those in 

1954 and are not necessarily reflective of earlier years when institutional controls were in place, 
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it may be more appropriate to only consider samples from 1954. This would be in accordance 

with the methodology presented in ORAUT-OTIB-0070, which utilizes air monitoring data at 

the end of the operational period to represent the airborne contamination at the very beginning of 

the residual period. 

Table 16. Total Number of Air Samples by Year 

Year General 

Air 

Breathing 

Zone 

Not Specifically Labeled 

GA or BZ 

1948 37 3 50 

1949 174 32 96 

1950 225 84 92 

1951 56 25 44 

1952 53 45 11 

1953 49 30 46 

1954 16 13 10 

Table 17. Average Air Sampling Results by Year (dpm/m3) 

Year General 

Air 

Breathing 

Zone 

Not Specifically 

Labeled 

All Air 

Samples 

1948 1794.1 878.0 5603.3 3879.8 

1949 680.1 1378.4 592.7 726.3 

1950 177.1 539.7 2020.6 676.0 

1951 148.7 309.3 156.3 183.5 

1952 272.1 5712.0 316.1 2522.4 

1953 705.2 306.3 210.7 427.5 

1954 633.7 635.6 5732.7 1941.8 

All Sampled Years 478.7 1613.4 1720.2 1063.5 

Table 18. Median Air Sampling Results by Year (dpm/m3) 

Year General 

Air 

Breathing 

Zone 

Not Specifically 

Labeled 

All Air 

Samples 

1948 325.0 630.0 1691.0 861.7 

1949 95.0 520.0 270.0 150.3 

1950 50.0 112.5 154.0 75.3 

1951 91.0 100.0 104.2 91.0 

1952 78.0 176.0 226.0 140.0 

1953 83.0 108.2 27.0 61.0 

1954 97.5 15.0 2290.0 100.0 

All Sampled Years 72.5 150.0 209.0 106.0 
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Table 19. Geometric Mean Air Sampling Results by Year (dpm/m3) 

Year General 

Air 

Breathing 

Zone 

Not Specifically 

Labeled All Samples 

1948 332.3 716.6 2036.0 933.3 

1949 103.8 627.1 208.6 159.0 

1950 52.0 126.5 221.7 86.8 

1951 80.7 137.7 110.9 100.4 

1952 97.4 430.0 229.9 196.0 

1953 106.0 124.7 35.2 73.4 

1954 191.2 43.7 1760.5 207.4 

All Sampled Years 84.9 193.5 228.8 133.7 

Figure 10. Comparison of the Number of Air Samples to the Average Air 

Sample Value by Year 

To determine the internal dose at the end of the residual period, NIOSH proposes to use EPCs 

developed from a comprehensive 2007 survey of the site. The TBD states: 

Surface contamination measurements performed during this investigation were 

used to derive Exposure Point Concentration (EPC) values to be used in exposure 

and risk assessment studies. The EPC values represent the 95% upper confidence 

limit values for each particular parameter reported. (ORAUT 2011) 
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The TBD would benefit from a more substantive discussion as to how EPC values were 

calculated and what “parameters” were used in developing the 95th percentile value. 

Additionally, the assumption is made that the source term as measured in 2007 is the same 

source term that would have been observed in 1982. This assumption is not likely to be claimant 

favorable, as one would expect the source term to decrease over the 25-year span from 1982 to 

2007 by means such as weather removal. A 2010 walkthrough of the Simonds plant revealed 

that the operational areas were essentially “open air,” as there were holes in the roof and many 

broken windows. Figures 11 and 12 illustrate the condition of the plant during that walkthrough. 

According to ORAUT-OTIB-0070, the date of the measurement during the residual period 

(2007) should be used to develop an exponential interpolation factor for evaluating internal 

doses. The TBD should justify why an alternate method than that presented in ORAUT-OTIB0070 is preferable for Simonds Saw and Steel. 

It should be noted that thorium intakes during the residual period are applied as 1% of the 

uranium activity intake. The assumption of 1% is based on historical estimates on the ratio (by 

weight) of thorium to uranium processing at Simonds. The specific activity of natural uranium is 

approximately six times the specific activity of thorium, so the assignment of this thorium intake 

is a conservative and claimant-favorable assumption. 

Figure 11. Photo of the Main Operational Area of the Simonds Plant in 2010 
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Figure 12. Photo of the Condition of the Roof at the Simonds Plant in 2010 

NOTICE:
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5.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR 

DOSE RECONSTRUCTION 

The SC&A procedures call for both a “vertical” assessment of a site profile for evaluating 

specific issues of adequacy and completeness, and a “horizontal” assessment considering how 

effectively the profile satisfies its intended purpose and scope. This section addresses the latter 

objective in a summary manner by assessing: 

(1) How, and to what extent, does the site profile satisfy the five objectives defined by the 

Advisory Board? 

(2) How usable is the site profile as a generalized technical resource for the dose 

reconstructor when individual dose records are unavailable? 

(3) Have generic technical or policy issues been identified that transcend any single site 

profile and need to be addressed by the Advisory Board and NIOSH? 

5.1 OBJECTIVE 1: COMPLETENESS OF DATA SOURCES 

NIOSH analyzed both DWE data and available urinalysis data when characterizing the internal 

dose potential at Simonds Saw and Steel. Daily weighted exposure (DWE) data exist from early 

on in the site’s operational history (October 1948) into early 1953. Urinalysis data are available 

over a similar timeframe (November 1948 to December 1952). Internal monitoring studies/data 

do not exist past this timeframe, though some air sampling data do exist as late as October 1954. 

Individual external monitoring data rarely existed at Simonds Saw and Steel and were restricted 

to only 21 workers for a period of approximately 9 days. NIOSH utilizes a combination of onsite 

measurements (area film badges), surrogate data (survey measurements at Aliquippa Forge), and 

computerized models (MCNP) in order to develop an external dose coworker model. 

Finally, the ever-changing industrial hygiene controls at Simonds were well documented in the 

available SRDB documentation. These changes were thoroughly represented in the TBD, which 

gave a generally complete and accurate characterization of operations at Simonds based on 

available records. 

 

5.2 OBJECTIVE 2: TECHNICAL ACCURACY 

NIOSH has performed a comprehensive search of available documentation on the SRDB relating 

to Simonds Saw and Steel, including a series of available reports titled, Occupational Exposure 

to Radioactive Dust, which document internal exposure potential, via both urinalysis and air 

sampling, at various times during Simonds Saw and Steel’s operation. Intakes based on bioassay 

data were analyzed using the Integrated Modules for Bioassay Analysis (IMBA) Expert OCASEdition Version 3.2.20 and assumes a uniform error of 1 and normal error distributions for each 

result. Intakes based on DWE data use site-specific information on the number of rolling 

periods, worker exposure times, and typical breathing rates for light work based on ICRP 60 

(ICRP 1991). 
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External exposures were characterized by a combination of general area film badge 

measurements for exposures from general plant contamination, as well as surrogate data from 

Aliquippa Forge to develop non-penetrating radiation dose assignments for uranium operations. 

Due to the general absence of operation-specific external exposures, NIOSH has adopted a 

modeling approach using MCNP to determine the potential external dose to Simonds workers 

during radiological operations. It would be beneficial for NIOSH to provide more specific 

descriptions of the parameters and assumptions used in the MCNP model to characterize 

operational external exposures. 

Residual exposures are based on site-specific data taken at the end of the period (in the case of 

external exposure), and a combination of operational data and survey data from the end of the 

residual period for the site. Because these approaches utilize real data from the site, they are 

deemed technically accurate. 

5.3 OBJECTIVE 3: ADEQUACY OF DATA 

As stated previously in Sections 5.1 and 5.2, NIOSH has performed a detailed and thorough 

review of available documentation for Simonds Saw and Steel and has analyzed available 

internal exposure data to develop plausible intakes. As stated in the TBD, the latter years of the 

site had less detailed and complete records on plant conditions and operations. However, given 

that available records from earlier in the period represent a cross section of different levels of 

industrial control and operations, SC&A believes the available data are sufficient and adequate to 

be used as a surrogate for periods where records are unavailable or missing during the 

operational period. 

Data to characterize external exposures were generally incomplete at Simonds Saw and Steel. 

Ambient external exposure potential was able to be characterized by a single general area film 

badge study performed by AEC to determine the levels of contamination and resulting external 

doses in the plant. Film badging at Simonds was restricted to a single short-term badging period 

and may not be representative of typical operations. Despite this absence of data, SC&A 

believes that sufficient information exists in the form of source characterization, computer 

modeling, and surrogate data to overcome this deficiency. 

Residual external exposures are based on site survey data taken at the end of the operational 

period, and we believe that they are adequate for dose reconstruction purposes. Internal 

exposures at the start of the residual period are based on operational survey data and may not 

reflect the condition of the plant at the end of operations. However, SC&A believes that 

sufficient data exist towards the end of the operational period that could feasibly be used to 

develop a reasonable characterization of the plant at the end of operations. 

5.4 OBJECTIVE 4: CONSISTENCY AMONG SITE PROFILES AND OTHER 

NIOSH DOCUMENTS 

In evaluating external exposures during the operational period, NIOSH used a combination of 

site-specific data, surrogate data from similar uranium processing sites, and computer modeling 

using the MCNP software. Surrogate data and exposure models are only preferable in the 
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absence of site-specific data, as was the case with external exposures during radiological 

operations; though it is important to note that there was a limited set of film badge data from 

which meaningful comparisons could likely be made. 

Internal dose was evaluated using available bioassay data, which is preferable to other sources of 

data, such as air monitoring, surrogate data, or other source-based modeling and characterization. 

This is consistent with standard dose reconstruction procedures and approaches taken at other 

AWE sites. It should be noted, however, that there was also an extensive DWE program that 

was analyzed by NIOSH and produced significantly higher intakes for soluble forms of uranium. 

It is recommended that NIOSH re-examine the differences in the two intake models and assure 

that their chosen internal dose assignments are sufficiently bounding. 

External dose during the residual period was based on site-specific measurements taken at the 

end of the operational period at Simonds, which is consistent with established procedures. 

Internal dose during the residual period deviated slightly from the established procedures in 

ORAUT-OTIB-0070 (ORAUT 2008). Specifically, the starting intake values are based on 

general air samples taken during the middle of the operational period and not the end of the 

period,12 which would be more reflective of residual operations. Also, the intakes for the very 

end of the residual period were based on survey data from 2007, which would normally be 

consistent with OTIB-0070. However, the 2007 data were assumed to be reflective of the 

condition of the plant in the early 1980s, which differs from the methods described in OTIB0070. 

5.5 OBJECTIVE 5: REGULATORY COMPLIANCE AND QUALITY ASSURANCE 

SC&A performed a comprehensive data compilation of urinalysis and air sampling data for 

comparison with the NIOSH results. SC&A found no issues with the urinalysis data 

compilation. SC&A could not exactly match the results of the air sampling analysis presented in 

the TBD; however, the results were reasonably consistent and within the range of expected 

uncertainty in that type of data compilation and analysis. 

5.6 INCONSISTENCIES AND EDITORIAL ERRORS IN THE SITE PROFILE 

(1) Pg. 10: SC&A could not verify the start date based on the reference provided in the TBD 

(AEC 1948a) 

(2) Pg. 11: “The process generated a considerable amount of waste, as evidenced from a 

1952 Tonawanda Progress Report (AEC 1952a): ‘Approximately fifty drums of 

[uranium contaminated] scrap and oxide were received from Simonds at the completion 

of the January rolling.’” SC&A could not find the provided reference based on the 

SRDB REF ID. SC&A found an equivalent document (AEC 1952b), but could not find 

mention of the ‘fifty drums’ therein. 

(3) Pg. 11: “Information on material processing was compiled from all available Simondsrelated documents and places the total quantities of uranium and thorium processed at 

12 Actual general air samples are not available in the final few years of operation at Simonds; however, air

sampling was performed as late as 1954 which was not used in developing residual intakes.
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11,500 tons and 114,000 pounds respectively [NIOSH 2010]. These values exceed the 

amounts stated in various documented historical narratives by about a factor of three.” It 

appears the factor of 3 only applies to the amount of thorium processed. 

(4) Pg. 17: Paragraphs one and three are essentially identical. 

(5) Pg. 20: “It was assumed that operations in 1953 continued at the same level as those in 

1952, although the available records indicate significant curtailment at the end of 1953.” 

Table 3 shows the number of rolling days in 1953 as 20% of the load in 1952 – this 

assumption (per the text) shouldn’t be applied until January 1, 1954. The title for Table 3 

should be clarified to number of uranium rolling days per year. 

(6) Pg. 20: Table 4 only extends to January 1, 1957, and should be December 31, 1957. 

(7) Pg. 22: “In addition, some postrolling samples might have been collected at the rolling 

day’s end (i.e., at the very end of rolling, not after rolling).” It is unclear what this 

sentence is meant to convey and should be clarified. 

(8) Pg. 27: “Several assumptions included in the dose reconstruction are likely to be 

overestimating assumptions, which increase the estimate of the median intakes from air 

concentrations.” These assumptions should be described and some idea of the 

quantitative effect on the dose reconstruction discussed. 

(9) Pg. 32: Table 16 displays assumed contaminant ratios for Np, Pu and Tc; however, the 

intakes displayed in Table 17 only display intake rates for Np and Pu. 

(10) Pg. 33: Row for Np-237 instructs to use absorption Type M “if U is S.” This is likely a 

typo and should be Type S “if U is S.” 

(11) Pg. 39: “The average of general area air sample results reported during air monitoring 

studies conducted between 1949 and 1953 was used as an estimate of the air 

concentration at the start of the residual period [AEC 1948b and 1949; Heatherton 1950a, 

1950b, 1951b, and 1953; Klevin 1948a, 1949a, 1949b, 1949c, 1950; and 1951, Klevin 

and Weinstein 1953a and 1953b].” Sentence should likely say it used the average of 

general area air samples reported from 1948–1953. 

(12) Pg. 39: The text shows the intake rate starting in 1982 as 5.5 pCi/d; however, the table 

on the following page lists it as 5.4 pCi/d. 

(13) Pg. 41: Column 3 of Table 24 appears to have the wrong footnote. 
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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. 

6.0 REFERENCES 

42 CFR Part 82. Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal Register/Vol. 67, 

No. 85/Thursday, May 2, 2002, p. 22314. 

AEC 1948a. Monthly Status and Progress Report for February 1948, Office of New York 

Directed Operations, New York, New York, March 1948. SRDB REF ID: 6257. 

AEC 1948b. Simonds Saw and Steel Occupational Exposure to Radioactive Dust Visit of 

December 1, 1948. New York Operations Office, Medical Division, New York, NY. SRDB 

REF ID: 12442. 

AEC 1949. Simonds Saw and Steel Company – Summary Report of Three Surveys (October 27, 

1948 to February 15, 1949). Atomic Energy Commission. SRDB Ref ID: 11996, pp. 249-254. 

AEC 1952a. Monthly Progress Report for January 1952. Atomic Energy Commission, SRDB 

REF ID: 6867. 

AEC 1952b. Monthly Progress Report for January 1952. Atomic Energy Commission. SRDB 

REF ID: 75071. 

Author Unknown 1948. Uranium Content of Urine Samples from Simonds Steel Mills, Lockport, 

N.Y. SRDB REF ID: 11227. 

Author Unknown 1949–1951. Urine Air Dust Sample Reports 1949–1951. Simonds Saw and 

Steel Company. 1/1/49–12/31/51. SRDB REF ID: 10219. 

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

Metals. Battelle-TBD-6000, PNWD-3738 Rev. 0. Battelle Team Dose Reconstruction Project 

for NIOSH. December 13, 2006. 

Belmore, F.N., and B.S. Wolf, 1949. Results of Dust Samples Collected at Rolling Mill Area, 

SImonds Saw &Steel Co., July 6, 1949. Simonds Saw and Steel – Production Division, Medical 

Division. August 26, 1949. SRDB REF ID: 11225. 

Davis, A.J., and D.J. Strom 2008. Uncertainty and Variability in Historical Time-Weighted 

Average Exposure Data. Health Physics, Volume 94, Number 2, pp. 145–160. 

DCAS 2010. White Paper on the Use of FMPC DWE Reports for Estimation of Chronic Daily 

Intake Rate, Rev. 03, Robert Morris, Division of Compensation Analysis and Support – National 

Institute for Occupational Safety and Health. October 2010. 

Earth Tech 2010. Remedial Investigation Report, Former Guterl Specialty Steel Corporation 

FUSRAP Site, Lockport, New York. July 2010. 
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

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

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

Harris, W.B., 1950. Simonds Saw and Steel Co. – Visits of February 13, 14, 17, and 20, 1950. 

Office Memorandum – United States Government. April 16, 1950. SRDB REF ID: 11224. 

Hayden, R.E., 1948. Contamination of the Simonds Saw and Steel Company at Lockport, New 

York. Office Memorandum – United States Government. May 19, 1948. SRDB REF ID: 

11229. 

Heatherton, R.H., 1950a. Simonds Saw and Steel Company – Occupational Exposure to 

Radioactive Dust. U.S. Atomic Energy Commission – New York Operations Office, Medical 

Division. June 21, 1950. SRDB REF ID: 16310. 

Heatherton, R.H., 1950b. Simonds Saw and Steel Company – Occupational Exposure to 

Radioactive Dust. U.S. Atomic Energy Commission – New York Operations Office, Medical 

Division. October 24, 1950. SRDB REF ID: 17024. 

Heatherton, R.H., 1951a. Simonds Saw and Steel Company – Occupational Exposure to 

Radioactive Dust. U.S. Atomic Energy Commission – New York Operations Office, Medical 

Division. March 20, 1950. SRDB REF ID: 16353. 

Heatherton, R.H., 1951b. Simonds Saw and Steel Company – Occupational Exposure to 

Radioactive Dust. U.S. Atomic Energy Commission – New York Operations Office, Medical 

Division. March 20, 1951. SRDB REF ID: 10881. 

Heatherton 1953. Air Survey of Special Rolling “E” Material on 10” Mill – Simonds Saw and 

Steel Company, Lockport, New York. Atomic Energy Commission, April 30, 1953. SRDB REF 

ID: 14150. 

Heatherton, R.C., and W.B. Harris, 1951. Trip Report – Visits to L.O.O.W. and Simonds Saw 

and Steel – March 7 and 8, 1951. March 14, 1951. SRDB REF ID: 81453. 

Heatherton, R.C., 1957. Trip Report to Simonds Saw and Steel Company, Lockport, New York, 

July 10, 1957. National Lead Company of Ohio, Cincinnati, Ohio. July 12, 1957. SRDB REF 

ID: 11996. 

ICRP 1991. 1990 Recommendations of the International Commission on Radiological 

Protection, ICRP Publication 60. Annals of the ICRP Volume 21 (1-3). 1991. 

Klevin, P.B., 1948a. Simonds Saw and Steel - Occupational Exposure to Radioactive Dust – 

Visit of October 27, 1948. U.S. Atomic Energy Commission – New York Operations Office, 

Medical Division. Document Date: Unknown. SRDB REF ID: 10883. 

Klevin, P.B., 1948b. Simonds Saw and Steel Co. – Occupational Exposure to Radioactive Dust 

– Visit of December 1, 1948. U.S. Atomic Energy Commission – New York Operations Office, 

Medical Division. Document Date: Unknown. SRDB REF ID: 10167. 
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

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

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

Klevin, P.B., 1949a. Simonds Saw and Steel Co. – Occupational Exposure to Radioactive Dust – 

Visit of January10-21, 1949. U.S. Atomic Energy Commission – New York Operations Office, 

Medical Division. Document Date: Unknown. SRDB REF ID: 10908. 

Klevin, P.B., 1949b. Simonds Saw and Steel Co. – Occupational Exposure to Radioactive Dust 

– Visit of April 5, 1949. U.S. Atomic Energy Commission – New York Operations Office, 

Medical Division. Document Date: Unknown. SRDB REF ID: 16230. 

Klevin, P.B., 1949c. Simonds Saw and Steel Co. – Occupational Exposure to Radioactive Dust – 

Visit of May 2-20, 1949. U.S. Atomic Energy Commission – New York Operations Office, 

Medical Division. July 8, 1949. SRDB REF ID: 4609. 

Klevin, P.B., 1950. Simonds Saw and Steel Co. – Occupational Exposure to Radioactive Dust – 

January 6, 9, and 10, 1950. Industrial Hygiene Branch – Health and Safety Division. 

February 1, 1950. SRDB REF ID: 10184. 

Klevin, P.B., 1951. Simonds Saw and Steel Company – Occupational Exposure to Radioactive 

Dust. Industrial Hygiene Branch – Health and Safety Division. October 12, 1951. SRDB REF 

ID: 16314. 

Klevin, P.B., and M.S. Weinstein, 1953a. Simonds Saw and Steel Company – Occupational 

Exposure to Uranium. Industrial Hygiene Branch – Health and Safety Division. February 18, 

1953. SRDB REF ID: 17017. 

Klevin, P.B., and M.S. Weinstein, 1953b. Simonds Saw and Steel Company – Occupational 

Exposure to Thorium. Industrial Hygiene Branch – Health and Safety Division. February 20, 

1953. SRDB REF ID: 17025. 

NIOSH 2004. Estimation of Ingestion Intakes. OCAS-TIB-009, Rev. 00. National Institute of 

Occupational Safety and Health – Office of Compensation Analysis and Support. April 13, 

2004. 

NIOSH 2010. Special Exposure Cohort Petition Evaluation Report Petition SEC-00157. 

Division of Compensation Analysis and Support, Cincinnati, Ohio. December 2010. 

ORAUT 2007. Internal Dose Reconstruction. ORAUT-TIB-0060, Rev. 00. Oak Ridge 

Associated Universities Team. February 6, 2007. 

ORAUT 2008. Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities. ORAUT-OTIB-0070, Rev. 00. Oak Ridge Associated Universities Team. 

March 10, 2008. 

ORAUT 2011. Site Profile for Simonds Saw and Steel. Gubin, S.L., Vogel, R., Oak Ridge 

Associated Universities Team. ORAUT-TKBDS-0032, Rev. 01. Oak Ridge Associated 

Universities Team. April 18, 2011. 
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 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

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

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

NOTICE:

Polson, C.E., 1954. Contamination – Simonds Steel Company, Lockport, New York. November 

22, 1954. SRDB REF ID: 14154. 

Reichard, H.F., 1949. Trips to Simonds Saw and Steel Company and Lake Ontario Ordnance 

Works. Office Memorandum – United States Government. June 13, 1949. SRDB REF ID: 

10876. 

SC&A 2004. Standard Operating Procedure for Performing Site Profile Review, Sanford Cohen 

& Associates, 2004. 

Strom 2007. Default Assumptions and Methods for Atomic Weapons Employer Dose 

Reconstructions. Battelle-TIB-5000 PNWD-3741. Technical Information Bulletin. April 2007. 

Wilson 1958. The Hanford Uranium Bio-Assay Program: Symposium on Occupational Health 

and Experience and Practices in the Uranium Industry. HASL-58, U.S. Atomic Energy 

Commission, New York, New York, October 1958. SRDB REF ID: 7886. 
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ATTACHMENT 1: TIMELINE OF THE IMPLEMENTATION AND USE OF RADI

CONTROLS AT SIMONDS SAW AND STEEL 

Date Description of Engineering Controls 

5/19/1948 Workers are only provided with gloves and are responsible for doing their own laundry. 7/30/1948 Two sets of clothing per man provided by AEC. Ventilation and vacuum plans have been made, but not yet installed. Installation of floor grating deferred until it can be determined if frequent vacuuming can keep the dust levels down. 

10/27/1948 Vacuum cleaner had been installed, but was used only intermittently; reports indicate the vacuum discharge was simpl

re-entering the plant. 

12/1/1948 

Vacuum cleaner set to discharge outside and exhausts for rolls installed, temporary enclosure over the descaler installe

It is recommended that exhaust ventilation be installed over the descaler and floor gratings be installed on the mill floo

1/20/1949 

“The present study was made after complete ventilation had been installed, vacuum exhaust vented outside the mill are

and exhaust fan from pressure quencher exhausted through roof. All the original recommendations of the Health and Safety Branch had been complied with except for the placement of gratings on each side of the roller floor.” 

2/15/1949 Exhaust for descaler installed. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Date Description of Engineering Controls 

4/5/1949 

Floor gratings partially installed on the mill area floor: “it was noted that the gratings used on the date of the survey dinot cover an area large enough to prevent uranium dust from being kicked up by the personnel in areas directly adjacento the rolls.” (pg. 4) Pedestal fan installed by the pressure quencher to decrease exposures to operators and rod stampers; however, this 

increased exposures to workers downstream of the fan – recommend that they cease using the pedestal fan and instead increase the ventilation hood over the quenching area. H&S recommend stamping rods after they are descaled; otherwise the installation of a hood over the stamping area should be undertaken. 

5/20/1949 Floor gratings were still only partially installed. 

6/7/1949 

Lucite plastic sheeting to be installed onto rolling ventilation hoods. Floor gratings only partially installed. Ventilated housing for stamping operations or an exhaust hood is recommended. 

7/6/1949 Recommendations made to add floor grating to pressure quencher and rod stamping area. 9/7/1949 

Exhaust fans over finishing rolls operating speed increased, which will increase the dust collection efficiency. All floogratings have been received at Simonds; however, had not been installed yet as they were being outfitted with rollers. 

is assumed all will be in service by the end of the rolling period. 

1/10/1950 Recommends adding a ventilated conveyor; no additional controls appear to have been implemented. 2/20/1950 

No additional controls have been implemented. Recommended that all broom sweeping cease; report directs Simonds personnel to refer to previous recommendations 

made. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Date Description of Engineering Controls 

4/14/1950 

Increased airflow on the quencher exhaust system lowered the general air concentrations in the plant. Exclusive use of the lead bath furnace for heating the billets. Rod shearing operation has been eliminated. 

8/14/1950 Notes that continuous water stream is used in the quenching area, which sprays directly onto the floor; recommends extending quenching hood to cut down on the spray and improve ventilation. 1/10/1951 

Pressure quenching operation changed to dip quenching, which left more scale on the rods when removed from the quenching tank causing higher exposures to rod stampers and workers in the quench tank area. Continuous water stream used to wet 2 of the 7 rolls, which caused a higher air contamination from increased carry off fine fumes in the steam cloud. Plexiglass shields had been removed from the ventilation hoods over the rolls: “It was learned that the omission of 

shields on the hoods in the beginning was through oversight. After that, no one bothered to put them on.” (pg. 5) 

3/8/1951 Noted that the plexiglass shields were still removed from the rolls and that the floor grating was only used intermittent

8/21/1951 

Grating directly in front of the rolls was moved to 2 feet west of the rolls; broom sweeping was employed in most area

instead of vacuum cleaning, which was deemed ‘infrequent.’ Plexiglass shields have been reinstalled. Recommends using a more powerful vacuum to remove dust from in between grates. “The practice of flinging small rshearings (6" to 8" long) across the West rolling area to the pressure quencher should be eliminated as it creates both a health and a safety hazard... Common sanitary considerations dictate that two sets of coveralls should be issued to eacman on the rolling crews for any rolling longer than 5 days. A uniform change every four days would eliminate the present practice of changing into their own clothes during the uranium rolling operation.” 

11/22/1952 

“Aside from lack of suitable dust control measures for this operation which include local exhaust ventilation over the three rolls, floor gratings in front of the rolls and a central vacuum cleanup system, there were malpractices of good industrial hygiene procedures which contributed to the high alpha concentrations. These were: 1 - No cleanup during entire rolling operation, 2 - Sweeping of steel plate floor area with brooms after completion of rolling, 3 - Stamping of thorium rods on flat steel bed of conveyor, 4 - Tracking of dust [f]rom the rolls to the rest areas.” 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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

June 13, 2012 

Revision No. 

0 

Document No. 

SCA-TR-SP2012-0013 

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61 of 61 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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

Date Description of Engineering Controls 

NOTICE

wever, th

12/9/1952 

Similar conditions found in August 1951; gratings were noted to have been pounded flat by the weight of the rods; recommendations made in August (including consistent use of the vacuum cleaner and elimination of broom sweepingwere not implemented. 

1/17/1953 Special 'E' material processed on the 16" and 10" bar mill – no ventilation was available on the 10" mill. 

8/6/1954 

Operators wear coveralls and a cape supplied by NLO; shoe covers were supplied but not worn. It appears the floor 

grating has been replaced with steel sheeting. “[The Plant Manager] told me that radioactive material had been procesfor many years without any adverse effects. He also intimated that if it became necessary to install elaborate dust eliminating equipment, further work of this nature would have to be abandoned.” 

10/11/1954 

“Doubtful practices” noted by NLO H&S: 1- Dropping of billets on floor prior to rolling, 2 - Wire brushing billets to observe temperature, 3 - Sweeping of floor instead of vacuum cleaning, 4 - Use of cloth gloves... “These practices habeen going on for as long as anyone connected with the operations can remember. Many attempts have been made to caution the operators about the dust contamination. There appears to be no fear on the part of most of the personnel at Simonds as to the toxicity of the normal uranium and thorium dust created during fabrication.”