Draft White Paper 

FOCUSED REVIEW OF “UNCERTAINTY AND VARIABILITY IN 

HISTORICAL TIME-WEIGHTED AVERAGE EXPOSURE DATA” 

(DAVIS AND STROM 2008) AND ITS APPLICATION IN 

DOSE RECONSTRUCTION UNDER EEOICPA

Contract No. 200-2009-28555 

Revision 1 

Prepared by 

John Stiver, MS, CHP 

Harry Chmelynski, PhD 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

 February 2011 

Disclaimer 

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

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

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

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

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

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

February 2, 2011 

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1 – Draft 

Document Description: White Paper: 

Focused Review of Davis and Strom 2008 

Page No. 

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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 

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Document Description: 

White Paper: Focused Review 

of Davis and Strom 2008 

Effective Date: 

Draft – February 2, 2011 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Revision No. 1 (Draft) 

Focused Review of “Uncertainty and Variability in 

Historical Time-Weighted Average Exposure Data” 

(Davis and Strom 2008) and its Application in Dose 

Reconstruction Under EEOICPA 

Page 2 of 35 

Task Manager: ___________________ Date: 

 John Mauro, PhD, CHP 

Supersedes: 

Rev. 0 – Draft 

Project Manager: _________________ Date: 

 John Mauro, PhD, CHP 

Reviewer: 

 John Mauro, PhD 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 11/04/2010 Initial issue 

1 (Draft) 02/01/2011 Revised and updated in response to Revision 3 of the NIOSH report, White Paper on 

the Use of FMPC DWE Reports for Estimation of Chronic Daily Intake Rate. 
Effective Date: 

February 2, 2011 

Revision No. 

1 – Draft 

Document Description: White Paper: 

Focused Review of Davis and Strom 2008 

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

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

TABLE OF CONTENTS 

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

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

2.0 Historical Milestones Leading Up to This Review..............................................................6 

3.0 Daily Weighted Exposure Description ................................................................................7 

4.0

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

Review – Uncertainty and Variability in Historical Time-Weighted Average 

Exposure Data

4.1 Sources of Variability and Uncertainty in DWE ...................................................10 

4.2 Constructing Uncertainty Distributions for DWEs................................................12 

4.2.1 Imputing Missing or Incomplete Data .......................................................13 

4.2.2

............................................................................................13 

DWA Distributions based on Sampling Discrete Concentration 

Measurements

4.2.3

.....................................................................14 

DWA Distributions based on Sampling Lognormal Fits to 

Concentration Measurements

4.3 ....................................................................................................................15 Results

4.3.1 Job-Specific DWE Distributions................................................................15 

4.3.2 Site-Wide AAC Distributions....................................................................18 

5.0

...........................................................................................................18 

Use of Davis and Strom (2008) in NIOSH Methodology for Estimating Intakes 

Based on AAC Data

5.1

...................................................................................................19 

White Paper on the Use of FMPC DWE Reports for Estimation of Chronic 

Daily Intake Rate

5.1.1 Sources of Variability and Uncertainty in the DWE Data.........................20 

5.1.2 DWE for a Facility in a Specified Year.....................................................22 

5.1.3 DWE for a Facility Based on Adjacent Years...........................................22 

5.1.4

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

Unweighted Air Concentration Data when Time-Weighted Data are 

Not Available

5.1.5 Thorium Exposures Not in Timeline .........................................................24 

5.2

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

Independent Audit of the Dose Reconstruction for an Energy Employee at 

the Uranium Mill in Monticello, Utah

6.0

...........................................................25 

Conceptual Consistency of SC&A-Suggested approaches for Estimating Intakes 

Based on AAC Data with Davis and Strom (2008)

6.1 Feed Materials Production Center (SC&A 2009)..................................................25 

6.2 Mallinckrodt Chemical Works Site Profile Review ..............................................27 

7.0 Summary of Findings and observations.............................................................................30 

7.1 Davis and Strom (2008).........................................................................................30 

7.2 Morris (2010).........................................................................................................31 

7.3 Monticello Uranium Mill DR Audit ......................................................................31 

7.4 SC&A Methods......................................................................................................31 

7.4.1 .........................................................................................................31 FMPC

7.4.2 Mallinckrodt...............................................................................................32 

8.0 References..........................................................................................................................33 
Effective Date: 

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ABBREVIATIONS AND ACRONYMS 

AAC Alpha Air Concentration 

ACGIH American Council of Governmental Industrial Hygienists 

Advisory Board 

or ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AM Arithmetic Mean 

BZ Breathing Zone 

cm3 cubic centimeters 

cpm counts per minute 

CV coefficient of variation 

dof degrees of freedom 

dpm disintegrations per minute 

DR Dose Reconstruction 

DWA Daily Weighted Average 

DWE Daily Weighted Exposure 

EE energy employee 

EEOICPA Energy Employees Occupational Illness Compensation Act of 2000 

FMPC Feed Materials Production Center 

GA General Area 

GM Geometric Mean 

GSD Geometric Standard Deviation 

HASL Health and Safety Laboratory 

ISO International Organization for Standardization 

MAC Maximum Allowable Concentration 

m3 cubic meter 

NIOSH National Institute for Occupational Safety and Health 

NLO National Lead of Ohio 

pCi picoCuries 

REQ Requisition 

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

SD Standard Deviation 
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NOTICE:

SEC Special Exposure Cohort 

TBD Technical Basis Document 

TWA Time-Weighted Average 

 
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1.0 STATEMENT OF PURPOSE 

The purpose of this revision is to update the findings presented in the SC&A white paper 

entitled, Focused Review Of “Uncertainty and Variability in Historical Time-Weighted Average 

Exposure Data” (Davis And Strom 2008) and Its Application in Dose Reconstruction under 

EEOICPA (SC&A 2010), to reflect recent changes in National Institute for Occupational Safety 

and Health (NIOSH) methodologies for using daily weighted exposure (DWE) data in the 

reconstruction of intakes of alpha-emitting airborne contaminants in cases where bioassay and/or 

in-vivo measurements are lacking. As part of that process, we identify aspects of that 

methodology that may require refinement to make it suitable for dose reconstruction (DR) under 

the Energy Employees Occupational Illness Compensation Act of 2000 (EEOICPA). 

SC&A (2010) was prepared under the Advisory Board on Radiation and Worker Health’s 

(Advisory Board or ABRWH) direction to determine the extent to which the concepts and 

methodology described in Uncertainty and Variability in Historical Time-Weighted Average 

Exposure Data (Davis and Strom 2008) have been adopted by NIOSH. A second aspect of that 

review was to ascertain whether alternative approaches recommended by SC&A in reviews of 

relevant NIOSH guidance documents are conceptually consistent with the methods outlined in 

Davis and Strom (2008). This report is particularly applicable to NIOSH’s proposed approach 

for reconstructing thorium-232 (Th-232) intake rates at Fernald based on air sampling data. 

2.0 HISTORICAL MILESTONES LEADING UP TO THIS REVIEW 

In April 2005, SC&A released a draft review of Revision 01 of ORAUT-TKBS-0005, the site 

profile [or technical basis document (TBD)] for the Mallinckrodt Chemical Works (ORAUT 

2005) entitled, Draft Preliminary Review (Partial) of the Mallinckrodt Site Profile Revision 1 

(Effective Date March 10, 2005) (SC&A 2005). In that review, SC&A identified three findings 

regarding time-weighted average air concentrations as used in the TBD. Those findings broadly 

encompassed claimant favorability, proper accounting for uncertainty and variability, and source 

data confirmation. In that review, SC&A demonstrated a method for quantifying and 

propagating uncertainty in the generation of distributions of weighted air concentrations suitable 

for DR. 

In March 2008, during a work group discussion on the Feed Materials Production Center 

(FMPC) Special Exposure Cohort (SEC), NIOSH was directed by the Advisory Board to post for 

review a large number of DWE reports, spreadsheets containing sample data derived from the 

reports, and a white paper describing NIOSH’s approach for using the data to reconstruct intakes 

of Th-232. The NIOSH white paper was entitled, White Paper on the Use of FMPC DWE 

Reports for Estimation of Chronic Daily Intake Rate, Revision 2 (Morris 2009). SC&A was 

tasked to review the white paper and spreadsheet data to determine if the proposed method and 

supporting data were sufficiently robust for DR. In July 2009, SC&A released the draft report, 

Draft Review of White Paper on the Use of FMPC DWE Reports for Estimation of Chronic Daily 

Intake Rate for Th-232 Internal Dose Reconstruction (SC&A 2009). That report contained 20 

findings, which were discussed at length at the January 2010 Fernald Work Group meeting. 
Effective Date: 

February 2, 2011 

Revision No. 

1 – Draft 

Document Description: White Paper: 

Focused Review of Davis and Strom 2008 

Page No. 

Page 7 of 35 

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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.

In September 2010, SC&A audited a NIOSH DR for an energy employee (EE) who worked at 

the uranium mill in Monticello, Utah, from 1948 to 1952. Because no external or internal 

dosimetry data were available and there was no site profile for this facility, NIOSH used a report 

prepared by the predecessor to DOE in lieu of a site profile. The report, Environmental Hazards 

Associated with the Mining of Uranium Ore, A Summary Report (HASL 1958), presents DWE 

data for 12 uranium mills, including Monticello, that were used to estimate the EE’s intake of 

airborne uranium dust. It is not clear from the DR Report, however, how the data were used to 

derive an air concentration for intake. 

The use of Alpha Air Concentration (AAC) data in internal DR was most recently discussed at 

the work group meeting for the Weldon Spring Plant (October 19, 2010). At that meeting, 

NIOSH indicated that they followed the methods described in Davis and Strom (2008) for 

reconstructing distributions of airborne alpha contamination for assessing intakes of alphaemitting radionuclides. Given the issues surrounding the applicability of AAC data for DR and 

unresolved questions regarding the credibility of the methods employed by NIOSH for using 

those data, the Advisory Board tasked SC&A to perform a focused review of Davis and Strom 

(2008), as described above in the Statement of Purpose. 

In November 2010, in accordance with the Advisory Board’s direction, SC&A submitted the 

draft white paper report referred to herein as SC&A (2010). That report focused on the 

methodologies in Revision 2 of the NIOSH white paper (Morris 2009). However, after the 

submission of SC&A (2010) and just prior to the November 9, 2010, Fernald Work Group 

meeting, NIOSH submitted a revision to their white paper on DWE entitled, White Paper on the 

Use of FMPC DWE Reports for Estimation of Chronic Daily Intake Rate, Revision 03 (Morris 

2010). SC&A’s initial review of Morris (2010) revealed that most of the 20 findings identified 

in SC&A (2009) had been addressed in a satisfactory manner, and that NIOSH appeared to have 

revised their white paper to be mostly in accordance with Davis and Strom (2008). After 

discussions held at the November 9 Work Group meeting, the Advisory Board asked SC&A to 

update our formal review to address the revisions in Morris (2010). This revised white paper 

comprises SC&A’s response to that request. 

3.0 DAILY WEIGHTED EXPOSURE DESCRIPTION 

The concept of the DWE was introduced into the Atomic Energy Commission (AEC) complex 

by the AEC’s Health and Safety Laboratory (HASL) staff beginning in the 1940s. Airborne 

activity concentration data were compiled from field surveys conducted by the Industrial 

Hygiene Branch of HASL. Data are presented, analyzed, and summarized in documents referred 

to as the “HASL reports.” The HASL reports were created to (1) evaluate exposure to 

employees from radioactive dust, (2) define the sources of exposure, (3) provide 

recommendations to decrease excess exposure, (4) provide an exposure history for the 

employees, (5) evaluate any direct exposure to radiation, and (6) acquire general knowledge of 

the plant to better understand hazards and ways of correcting them (Davis and Strom, 2008). 

Morris (2009) provides a detailed description of the HASL reports, which were fairly consistent 

among the different sites and over time. 
Effective Date: 

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Focused Review of Davis and Strom 2008 

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Air monitoring data were used to calculate an average airborne radioactive material 

concentration to which workers were exposed, based on the amount of time worked and the tasks 

performed. This time-weighted concentration is referred to as a “daily weighted average” 

(DWA) or “daily weighted exposure” (DWE), because it is the average of all exposure 

concentrations measured from random samples taken at short periods of time during a work day. 

Davis and Strom (2008) refer to the time-weighted average air concentration as the DWA, while 

the HASL reports and other historical documents refer to it as the DWE. For consistency with 

the historical record and previous SC&A and NIOSH reports, we use the term DWE in this 

review, except when quoting directly from Davis and Strom (2008) or describing their derived 

quantities. 

The DWE is an assessment of the exposure potential in terms of the time-weighted average AAC 

for a specific job description at a specific facility. The AAC was reported in units of dpm per 

cubic meter of air (dpm/m3

) for each task associated with a job description. The high, low, and 

average AAC for each task and the time required to complete each task were reported on a Job 

Exposure Evaluation card; general air (GA) and breathing zone (BZ) samples were reported. 

Most job-specific tasks were BZ samples. Typically, GA samples represented ambient exposure, 

such as would occur in non-production areas while engaged in activities such as smoking, using 

the washroom, eating in the cafeteria, or changing out in the locker room. These ambient 

exposure operations typically involved low concentrations and were minor contributors to the 

exposure for a given job description. The average AAC for each task was multiplied by the time 

required to complete the respective task on a daily basis. The “average × time values” were 

summed for all tasks and divided by the total time for all tasks to yield the DWE (daily weighted 

average alpha air concentration) for the job description. 

The DWE is typically expressed in units of dpm/m3 or in multiples of the Maximum Allowable 

Concentration (MAC), which at FMPC was 70 alpha dpm/m3

 of air until it was changed to 

100 alpha dpm/m3 of air in 1963. In modern practice, the average DWE concept is similar to the 

Time Weighted Average (TWA) exposure that is in current use (ACGIH 1996), except that the 

TWA assumes an 8-hour work day, while the DWE uses the actual work day duration. 

Descriptions of the tasks performed by employees of each site are laid out in job exposure 

evaluation sheets that are contained in an appendix to the HASL DWE reports. The sheets list 

job titles, number of employees per shift, number of shifts per day, and the total number of 

employees under that job title. Table 1 is an example of a job exposure evaluation sheet for a 

single job description—Chemical Process Area “Wet Area Helper”—from Building 9 of the 

FMPC in 1955, during a period of active thorium production (Stefanec 1955). This job category 

was assigned a DWE of 46.9 MAC (or 3,286 dpm/m3

 alpha). Note that the Job Exposure 

Evaluation card includes the time of the evaluated work shift. In almost all cases, the time 

represented on a job exposure evaluation sheet is 510 minutes or 8.5 hours. 
Effective Date: 

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Page No. 

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Table 1. Excerpted Job Exposure Evaluation, FMPC Plant 9 (1955) 

(Stefanec 1955) 

NATIONAL LEAD OF OHIO 

Job Exposure Evaluation 

Building 9 Process Area Chemical 

Operator: [Redacted] 1 men/shift 3 shifts/day 3 men/day 

Concentration (C) 

(dpm/m3

) Operation 

Operating Area 

Time per 

Shift (T) 

No. of 

Samples High Low Avg 

T × C 

BZ Dumping TNT into dissolving tank 60 3 1,088 395 774 46,440

BZ Cleaning predryer vents 16 5 1,876 1,040 1,532 24,512

BZ Dumping recycle oxide into predryer 15 8 125,061 5,239 54,960 824,400

GA Chemical area, upper deck 309 13 5,057 85 2,518 778,062

GA Smoking area 20 6 190 7 79 1,580

GA Washroom 10 4 68 22 54 540

GA Process locker room 20 15 51 5 15 300

GA Street locker room 10 20 25 1 6 60

GA Cafeteria 30 20 33 0 4 120

GA Travel time 20 4 3 0 1.2 24

∑T = 510 ∑ (T × C) = 1,676,038 



 

T

CT )(

= 3,286 dpm/m3 = 46.95 MAC

Inspection of Table 1 reveals that a total of 96 separate BZ and GA samples were used to 

construct the DWE for the Wet Area Helper in Building 9 in 1955. The data were sorted into 10 

different work categories, with each category assigned a number of minutes per shift. For 

example, in Table 1, “dumping TNT into dissolving tank” required 60 minutes per day, and there 

were three BZ air samples taken during that operation in that building in that year [sampling 

times from 4.8 to 12.4 minutes (NIOSH 2009)]. The results reveal a low value of 395 dpm/m3

, 

an average of 774 dpm/m3

, and a high value of 1,088 dpm/m3. The product of 774 dpm/m3 × 

60 minutes yields 46,440 dpm-minutes /m3

 (as indicated in the top line of the right-hand column 

in Table 1). This exercise was performed for each job category, resulting in a total of 

510 minutes (8.5 hours) of exposure during 1 work day for a Wet Area Helper in Building 9 in 

1955. The DWE for this category of worker in this building in 1955 is the sum of the values in 

the right-hand column, divided by 510 minutes per day; i.e., 3,286 dpm/m3 or 46.9 MAC. 

4.0 REVIEW – UNCERTAINTY AND VARIABILITY IN HISTORICAL TIMEWEIGHTED AVERAGE EXPOSURE DATA 

Davis and Strom (2008) reviewed six HASL reports covering five sites that were visited between 

1948 and 1955 to characterize radiological hazards arising from the processing of uranium (U), 

U ore, Th, or radium (Ra-226/Rn-222). Those five sites were Electrometallurgical Co. (HASL 

1948), Middlesex Sample Room (Klevin et al. 1950), and American Machine and Foundry Co. 

(HASL 1954; Klevin 1952) for exposure to uranium; Horizons, Inc. (Harris 1955) for exposure 

to thorium; and Lake Ontario Ordinance Works (Heatherton 1951) for exposure to radon and its 
Effective Date: 

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decay products. The site names, number of employees, and material processed at each site are 

listed in Table 2, which is extracted from Davis and Strom (2008). 

Table 2. Sites Studied and Relevant Parameters 

[Extracted from Table 1, Davis and Strom (2008)] 

Site Material Processed Date of Survey No. of Jobs No. of Employees 

Electrometallurgical Co. Uranium 1948 21 66 

American Machine and 

Foundry Co. Uranium 1952 6 7 

American Machine and 

Foundry Co. Uranium 1954 10 33 

Middlesex Sampling Plant Uranium ore 1950 14 31 

Horizons, Inc. Thorium 1954 11 18 

Lake Ontario Ordinance 

Works Ra-226, Rn-222 1951 1 8 

The HASL reports cover a total of 63 job titles for which DWEs were reported. Each job title 

was held by 1 to 12 employees from of a total of 165 employees across the sites. Job titles 

involved from 1 to 13 operations, and each operation is characterized by 1 to 27 air samples. A 

total of 428 air samples were reported. 

4.1 Sources of Variability and Uncertainty in DWE 

The DWE values from the HASL reports do not contain a quantitative expression of uncertainty. 

Because the uncertainty is necessary for DR, Davis and Strom (2008) outlined alternative 

methods for generating distributions of job-specific DWEs, based on the variability in the task 

AAC measurements. The authors utilized Monte Carlo methods to retrospectively assess the 

uncertainty and variability in DWE values for the 63 job titles. 

Davis and Strom (2008) identified three main sources of uncertainty in DWE values, 

(1) variability and uncertainty in air sample data, (2) uncertainties associated with measurement 

(counting statistics), (3) and spurious errors, such as mathematical errors and transcription errors, 

that the International Organization for Standardization (ISO) terms “blunders”1

 (ISO 1995). 

Variability in air sample data can be large and is associated with several factors that can occur 

during the sampling process. The authors identified the following five factors that contribute to 

air sample variability: 

(1) Changes in the way a task is performed 

(2) Where the sampler is placed during task performance 

(3) Consistency amongst staff while performing a task 

(4) Consistency in size of particulates being measured 

(5) Whether or not the sample represents the actual exposure experienced by the worker 

 1

 The ISO definition emphasizes that a blunder is a serious mistake caused by ignorance or confusion; 

stupidity, which is included in some U.S. English definitions of blunder, is not implied. 
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Observation #1: SC&A notes that the fifth item in the list of factors contributing to 

variability in the data, “whether or not the sample represents the actual exposure 

experienced by the worker,” is not a source of variability in the AAC data, but is an 

uncertainty in assessing worker exposure based on the data. This source of uncertainty is 

especially important for DR, due to limitations in the sampling performed by HASL, both in 

space and time, as discussed in greater detail later in this report. 

Because uncertainties associated with the counting statistics of measurement are generally small 

compared to the variability in the air sample data, they were not addressed in the study. 

Uncertainties arising from self-absorption for low specific activity materials like uranium and 

thorium were acknowledged to be potentially significant (Skrable et al. 1991), especially for 

large sample volumes or high concentrations or both, but were not addressed in the study. 

Uncertainties due to blunders were in some cases large and unexpected. 

Davis and Strom 2008 began their assessment of uncertainty in the AAC values by reviewing the 

raw air sampling measurement data contained in the HASL reports. They indicate that the raw 

data were recorded in an appendix of the HASL report under a requisition (REQ) number, 

sample number, time, date, and description of collection areas. Total alpha counts, counting 

times and counting rates for alpha particles, and background counting rates, as well as air flow 

rates for sampling, were recorded and calculated. For some of the samples, correction factors 

were also listed. 

Observation #2: It is noteworthy that the airborne dust reports (DWE reports) examined 

by SC&A in support of the review of Morris (2009) for its applicability in the 

reconstruction of Th-232 intakes did not contain the raw data (SC&A 2009). Those reports 

were prepared for FMPC by National Lead of Ohio (NLO). This aspect of the study 

continues to be important in light of revision 3 because the issue of availability of the raw 

data for use in assessing uncertainty in DWEs remains open. Note that this has been an 

ongoing topic of discussion for both Mallinckrodt and Fernald (see Finding #5, SC&A 

2009). 

To determine which air samples were used to calculate the DWE, the operations or operating 

area for each job title has to be matched to raw data in the HASL document. For BZ samples, it 

is fairly easy to match work descriptions with collection descriptions. The process for 

determining which samples were used to generate GA averages was considerably more complex 

and often required assumptions that introduced added uncertainty. 

In their analysis of the raw data in the HASL reports, Davis and Strom (2008) identified five 

types of human errors or “blunders” that could influence the integrity of the DWE values. 

According to the ISO (1995): 

Blunders in recording or analyzing data can introduce a significant unknown 

error in the result of a measurement. Large blunders can usually be identified by 

a proper review of all the data; small ones could be masked by, or even appear 
Effective Date: 

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as, random variations. Measures of uncertainty are not intended to account for 

such mistakes. 

The five types of blunders identified by the authors included: 

(1) Transcription errors (most of these were minor and occurred in only two places). 

(2) Calculation errors (occur in five cases). 

(3) Rounding errors (two occurrences). 

(4) Self contradictions (three occurrences). These are errors for which the data that are used 

do not support the statements that are made. 

(5) Data imputation required. These are situations where data are listed as “0” or as “< 1.” 

Although this study made no attempt to incorporate uncertainty due to blunders as a parameter in 

the DWE distribution, it did assess the impacts of such errors. 

4.2 Constructing Uncertainty Distributions for DWEs 

In developing distributions of DWE, Davis and Strom 2008 limited their analysis to variability in 

the air sample data. To assist the reader in understanding the methods employed in generating 

distributions of DWEs, the nomenclature and notation used in the report are first defined (the 

authors use the term DWA instead of DWE, though the terms mean the same thing). 

TS,i (min), is the total time to complete an operation [equivalent to Time per Shift (T) in Table 1]. 

Ci,k is the k

th air sample value for operation i in units of dpm/m3

. This value is the fundamental 

unit used to construct the DWE distribution. 

COA,i is the operation average concentration in units of dpm/m3 (equivalent to “Avg” in Table 1) 

of all air sample values (Ci,k) for each exposure. 

 Equation 1 

NS,i denotes the number of air samples representing the i

th operation. 

Equation 2 shows the method used by the HASL authors to calculate the DWA for the job title j 

having Nj operations: 

 Equation 2 

The numerator of Equation 2 is the sum of products of concentration and time, and the 

denominator is the total amount of time worked per shift. Davis and Strom (2008) refer to the 
Effective Date: 

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HASL-method DWE calculation in Equation 2 as DWAH. No variability or uncertainty is 

assumed or quantified for TS,I, the time to complete task i. 

DWAH is equivalent to 

 

T

CT )(

 in Table 1. 

4.2.1 Imputing Missing or Incomplete Data 

The first step undertaken by the authors in building DWE uncertainty distributions involved 

imputing concentration data for values recorded as “0” or “<1” (blunder Type 5). On some of 

the sites, samples taken between or outside buildings with operations had task average 

concentrations listed as zero. The authors indicated that, because it is unlikely that there would 

be no exposure, they substituted a nominal value of 1 dpm/m3 for the zero value. This 

adjustment was done under the assumption that the elevated dust concentration levels inside 

should have led to some exposure in the area outside. 

Many of the samples were recorded with exposure or count totals “<1.” For those values, Davis 

and Strom (2008) believed that it was necessary to use the data that were present to impute 

estimated concentrations for the “less than” values. The authors describe a method for imputing 

individual task concentration values (Ci,k) based on several assumptions and inferences: 

... a net counting rate was assumed by subtracting the inferred background rate 

of 0.2 cpm from 1.0 cpm to obtain a net counting rate of 0.8 cpm. This value was 

used to compute five concentration values based on the provided flow rate and 

inferred counting yield. Assuming that the values follow a lognormal distribution, 

they were run through the lognormal fitting utility [Strom 2006] to find the mean. 

Using a standard assumption documented by [Strom 2007], the calculated mean 

was divided by two and this imputed value entered into a program called 

LOGNORM4 [Strom and Stansbury 2000], with a GSD of 2 to produce five values 

from a lognormal distribution with these parameters. 

4.2.2 DWA Distributions based on Sampling Discrete Concentration Measurements 

The authors performed Monte Carlo simulations with Crystal Ball using the discrete Ci,k values 

to determine the distribution of DWAH values. For each job title j, and each operation i, one air 

sample concentration measurement Ci,m was randomly selected and multiplied by its 

corresponding TS,i. The value of the product Ci,m×(TS,i) was summed for all operations i in job j

and divided by the time worked per shift to obtain a single value: 

 

 Equation 3 

where m denotes a particular combination of Ci,k values (i.e., an index denoting the outcome of a 

single trial), so that the DWAj,m is considered to be the outcome of one trial. The simulation was 
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run for 10,000 trials for each job j. After all trials were run, all 10,000 DWAj,m realizations were 

extracted and summary statistics computed. The authors refer to the distribution of DWAj,m as 

the deterministic DWA, or DWAD. It is noteworthy that in Equation 3, the only modeled value 

is the concentration per task, Ci,m. 

4.2.3 DWA Distributions based on Sampling Lognormal Fits to Concentration 

Measurements 

In their literature review, Davis and Strom (2008) cite several references that recommend the 

lognormal distribution for modeling limited air sampling data: 

The NIOSH Occupational Exposure Sampling Strategy Manual suggests that 

DWA calculations are not the best way of measuring an eight-hour exposure 

[Leidel et al. 1977]. This recommendation is due to the large amount of 

variability in each air sample. ... When random grab samples are used, [Leidel 

et al. (1977)] suggest that a lognormal distribution be assumed. Variability will 

still remain high due to differences in work habits and the possibility of moving 

between numerous locations during a work day. Studies conducted by [Linkov 

and Burmistov (2001)] using 400 air sample measurements show that the 

between-area variability is not as great as the variability that exists in a single 

area on a month to month basis. They suggest that a single value should not be 

used to measure exposure. Rather a lognormal distribution should be used that 

will assign appropriate probability to all possible concentrations. The same 

conclusion was reached by [Nicas and Jayjock (2002)] where, in cases where only 

a few air samples can be taken, modeling the exposure using a lognormal 

distribution would give a more accurate estimate of the true exposure. 

The lognormal DWE distribution was constructed as follows: 

For each operation i, a lognormal distribution was fit to the Ci,k values. For those operations i 

where k = 1, or where the COA,i from the HASL report was used in place of missing data, the 

operational average concentration was assumed to be the arithmetic mean (Cavg) of a lognormal 

distribution with a GSD of 2. Based on examination of the data, the authors believed that a GSD 

of 2 was fairly representative of the average for most samples and state that the assumed GSD = 

2 is supported by Leidel et al. (1975), who analyzed sets of airborne chemical vapor and aerosol 

data. The value of the geometric mean (GM) was calculated by: 

/2] 

 Equation 4 

which amounts to dividing Cavg by 1.27. 

When the operation had two or more samples, the numbers were placed in a lognormal fitting 

utility (Strom 2006) to calculate the arithmetic mean, SD, coefficient of variation (CV), GM, and 

the GSD. For each job j and each operation i, a sample Ci,n was taken at random from a 

lognormal distribution fit to the Ci,k measurements, and Ci,n was multiplied by the corresponding 
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TS,i. The value of the product of Ci,n× (TS,i) was summed for all operations i in job j and divided 

by the time worked per shift to obtain a single value: 

 Equation 5 

where n denotes a particular sample from the lognormal distribution. The simulation was run for 

10,000 trials for each job title. After all trials were run, all 10,000 DWAj,n values were extracted 

and summary statistics computed. The DWA calculated using lognormal distributions is referred 

to as a DWAL. In Equation 5, the only modeled value is the concentration per task, Ci,m; TS,i is 

assumed not to vary. 

Finding #1: The formulations for DWAD and DWAL treat TS,i, the time required to complete 

task i, as a constant. Given that these are, in fact, average times to complete a task, they have 

associated variability (among workers) that should be addressed in generating uncertainty 

distributions of DWE. In the 2005 review of the Mallinckrodt report, SC&A noted that these 

uncertainties could be significant in high dust, short-duration operations that dominate timeintegrated exposure. 

To allow time periods to vary in length is a multivariate problem, since if one is made longer, 

some other(s) must be made shorter; times are mutually negatively correlated. We are really 

asking how to divide the day into percentage blocks, p1, ... pN, which always sum to 100%, yet 

are random. SC&A is aware of a distribution for this modeling task, which is the multivariate 

Dirichlet. The vector of specified times TSi are the expected values of this distribution. Dirichlet 

is the multivariate generalization of the beta distribution on interval [0,1]. In Crystal Ball, the 

multivariate Dirichet distribution is simulated as pi = Xi /∑(X1, ,XN), where Xi have 

independent gamma distributions. 

4.3 Results 

4.3.1 Job-Specific DWE Distributions 

For each job title j, 10,000 Monte Carlo trials were performed by Davis and Strom. In each trial, 

airborne radioactive dust concentrations were randomly sampled for each task i either from the 

discrete measurements reported by HASL (with blunders corrected) or from lognormal 

distributions fit to those measurements. The result of each trial was a DWAD or a DWAL. To 

demonstrate the characteristics of a DWAL distribution for a specific job type, Davis and Strom 

created a z-score plot of ranked DWAL values generated from 1,000 Monte Carlo trials for the 

“foreman” job title at Electrometallurgical Co. (Figure 3 of Davis and Strom 2008). The plot 

demonstrates that the simulated data are well described by the lognormal distribution. Figure 4 

of the report, which is reproduced below as Figure 1, depicts overlain distributions of simulated 

DWAD and DWAL for each of three job titles. 
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Figure 1. Distributions of Simulated DWA for Each of Three Job Titles 

[Extracted from Davis and Strom (2008)] 

In Figure 1, each histogram represents a different job title from Electrometallurgical Co. in 1948, 

which are (a) “Remelt Operator,” (b) “Bomb Unloader,” and (c) “Greenroom Operator.” It is 

noteworthy that the discrete distributions do not appear to be lognormal for any of the three job 

types displayed in Figure 1, though visual inspection suggests that the discrete distribution for 

the Greenroom Operator is the closest match to the lognormal. 

The authors indicate that the means calculated using the discrete method closely resemble those 

calculated using the HASL method for all sites. They go on to state that, for all three simulations 

in Figure 1, the means of the DWAD and DWAL distributions were consistent with one another, 

but that the standard deviations (SDs) for DWAL exceeded that for DWAD by factors of 1.4 

(Bomb Unloader) to 2.4 (Remelt Operator); for all datasets, the SDs for DWAL were higher or 

equal to those for DWAD. The upper tails of the DWAL distributions are higher because the 

lognormal allows for the possibility that exposures can be larger than those actually observed. 

Because BZ and GA sampling, as reported by HASL, was limited in space and time and may 

have missed some of the higher air concentrations, the use of DWAL may be more claimant 

favorable for DR. 

In summary, Davis and Strom (2008) state that for the HASL dataset, most groups of repeated air 

samples are well described by lognormal distributions, and that combining samples associated 

with different tasks often results in a reduction of the geometric standard deviation (GSD) of the 

job DWE to less than those GSD values typical of individual tasks. They indicate that their 

results support the assumption of a GSD value of 5, when information on uncertainty in DWE 

exposures is unavailable. 

Finding #2: The histograms in Figure 1 call into question the assumption of log-normality 

for the task AAC data. If the source data were lognormally distributed, as suggested by the 

authors and advocated in citations quoted in the literature review, one would expect that a 

DWE distribution constructed from those data would, in most cases, appear lognormal (as was 

true for DWAL, which was based on lognormal fits to the AAC data). 

SC&A believes that a careful review of the source data should be conducted prior to modeling to 

determine if a lognormal fit is appropriate, or if some other distribution is appropriate. For 
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source AAC that are not lognormal, another alternative would be to assign a percentile of the 

sorted DWED distribution. Notwithstanding unresolved issues regarding the completeness and 

applicability of the AAC data (SC&A 2009), SC&A believes that, for a credible dataset (i.e., 

sufficient number of samples that are free of blunders) that appears lognormal, the job-specific 

DWAL distributions provide a claimant-favorable construct that accounts to some extent for the 

possibility that exposures could have been larger than those actually observed. 

Impact of Blunders 

Some of the sites analyzed in this project reveal a high rate of blunders that add to the 

uncertainty in the DWE values. Davis and Strom 2008 note that the ratio of DWAD or DWAL to 

DWEH is a good index to the impact of blunders on DWE. Only those blunders that result in 

differences between DWAH and the two simulations of ± 20% were deemed to be significant. 

For the Electrometallurgical Co. site, at least 6 of the 21 job titles had errors that resulted in 

differences between the DWAD and DWAH of ≥20%. Less significant errors occur in nearly all 

the job titles, due to errors for general areas or tasks that recurred in most of the job titles. For 

American Machine and Foundry in 1952, imputed data lead to differences of ≥20% in two cases. 

For American Machine and Foundry in 1954, half of the job title worksheets contain errors that 

led to significant impacts on the DWAs. Significant errors also were present in half of the job 

titles for Horizons, Inc. Of all the sites, the HASL report for the Middlesex Sampling Plant 

contained the fewest errors, having only one that made a significant impact. 

One example of a blunder involves TS,i, the time required to complete task i. In one case, the 

time of work was not fully recorded; what was recorded was almost 50% less than the actual 

time. While variability in the time to complete a task is expected, SC&A did not expect major 

time exclusions. Note that this uncertainty in TS,i is due to blunders and is not the same as the 

variability/uncertainty in TS,i measurement, per Finding #1. 

Table 6 of Davis and Strom 2008 demonstrates that for those job titles in which significant 

blunders occurred (7 for DWAD and 16 for DWAL), average blunders cause a two-fold 

underestimate of exposure. Figure 5 of Davis and Strom (2008) illustrates that for 5 out of the 

63 jobs, blunders resulted in overestimates of DWA values by factors of 2 to 2.5, and in 2 cases, 

DWA values were underestimated by factors of 3 to 10. 

Davis and Strom conclude the discussion of blunders with the following statement: 

This work does not resolve the problem of how to handle the contribution to 

uncertainty in dose assessments of blunders in historical data analysis. In two 

cases, blunders are definitely unfavorable to the worker, had he or she been a 

claimant. [Emphasis added.] 

Finding #3: The impact of blunders on calculated air concentration values (AAC) was 

unexpected and in some cases significant. SC&A believes that this is a problem, even if it 

happened in only a few cases, and underscores the critical importance of validated source data 

in constructing uncertainty distributions for DWE. Note that this issue was raised in the 2005 

SC&A review of the Mallinckrodt TBD.
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4.3.2 Site-Wide AAC Distributions 

For the six HASL reports studied, the distributions for all the Ci,k data show a wide range of sitewide average values (Csite) among sites. The smallest Csite value is at American Machine and 

Foundry in 1954, at 117 ± 315 dpm m-3. Electrometallurgical has the highest Csite of 20,301 ± 

61,180 dpm m-3. Horizons had the highest GSD at 17.27 and the smallest is at American 

Machine and Foundry in 1954 with a GSD of 7.88. Amongst all sites, the BZ samples show the 

highest individual concentration (Ci,k ) values. For those BZ samples that had more than 3 

samples, the GSDs for the task averages (COA,i) were all less than 2. It is interesting that for the 

data evaluated for this study, the GA samples had the highest GSDs, with most greater than 2. 

Davis and Strom 2008 state that using the distribution of all air samples from a plant 

without time weighting or assignment to specific jobs does not produce a DWE or GSD that 

is representative of any individual worker for that site. They report that the means of sitewide average concentrations (Csite) exceed the DWAs for all workers in 60 of 63 cases, and in all 

but 1 case, the upper 95th percentile of the site-wide distribution exceeds the DWAs for all 

workers. For the three job titles for which Csite < DWEj, the ratios of DWE/Csite were 469%, 

198%, and 118%. The one job title for which the DWA exceeds the 95th percentile of the sitewide distribution did so by only 7%, and it is at the site with the smallest GSD of 7.88 (American 

Machine and Foundry in 1954). Csite exceeded the average DWAD at the site by factors of 8.0, 

6.7, 1.5, 6.1, and 10.8, respectively, for the first five sites listed in Table 1. The authors 

conclude that using the upper 95th percentile of site-wide air concentration data will almost 

always be favorable to the claimant, if unrealistically high for almost everyone. 

The authors note that on a site-wide basis, the job DWEs increase with the amount of time spent 

in direct contact with materials or time spent in processing areas and that, due to site-specific 

variation in the tasks associated with a given job title, the trend is more significant within a site 

than across sites. When viewed across all sites, administrative employees who spent no time in 

processing areas have DWEs of 0.39 to 0.45 MAC. Support staff, such as laundry workers, 

guards, and janitors, who spent limited to no time in processing areas, have DWEs of 1.09 to 

3.07 MAC. Foremen, supervisors, and maintenance personnel, who spent most of their time 

roaming the sites, have DWEs of 0.33 to 3.64 MAC. Laborers, who spent a majority of their 

shift in direct contact with materials or in the processing areas, have DWEs that range from 

0.007 to 594 MAC. Thus, it can be inferred that office workers and support staff did not 

experience large exposures. For construction workers and other employees considered to be 

“roamers,” the range of possible exposures is higher than that of the office and support staff, but 

does not exceed many of the exposures for laborers. It can be expected that the laborers ran the 

highest risk of large exposures. It is noteworthy that while the authors note a correlation 

between job type and exposure potential, they neither advocate nor present a method for 

estimating exposure by job type on a site-wide basis (Finding #8). 

5.0 USE OF DAVIS AND STROM (2008) IN NIOSH METHODOLOGY FOR 

ESTIMATING INTAKES BASED ON AAC DATA 

In this section, SC&A investigates the extent to which the methods outlined in Davis and Strom 

(2008) have been applied in a key NIOSH guidance document pertaining to the estimation of 
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intakes of airborne radioactive dusts based on AAC data. In October 2010, NIOSH released 

Revision 3 of their draft white paper entitled, White Paper on the Use of FMPC DWE Reports 

for Estimation of Chronic Daily Intake Rate (Morris 2010), which presented revised methods for 

using DWE data to reconstruct intakes of alpha-emitting radionuclides when bioassay and/or 

lung counting data are not available. NIOSH has indicated that Morris (2010) closely follows 

the methods in Davis and Strom (2008) and is intended as a generalized methodology to be 

applied in DR for Fernald and also for Weldon Spring and other sites. Accordingly, the 

discussion in this section focuses on those revised methods. Note that SC&A has recently 

audited a case for an EE who worked at the Monticello uranium mine in Utah in the late 1940s to 

early 1950s. Because that worker’s intakes were calculated from DWE, we include a brief 

comparison of the methods employed in that DR to Morris (2010) and Davis and Strom (2008). 

5.1 White Paper on the Use of FMPC DWE Reports for Estimation of Chronic Daily 

Intake Rate 

Morris (2010) describes a method for estimating chronic daily intake rates of uranium and 

thorium, their progeny, and other associated radionuclides using DWE data. The intent of that 

document is to demonstrate that DWE data may be used to estimate the daily intake rate when 

in-vivo data are unavailable or inadequate (e.g., the period prior to the introduction of in-vivo 

chest counting at FMPC). Morris (2010) has introduced significant changes from the previous 

version, most of which appear to be methodologically consistent with Davis and Strom (2008). 

The outline presented below contrasts the methods in Revision 2 and Revision 3 of the NIOSH 

white paper; a discussion of the revisions follows: 

Revision 2 (Morris 2009): 

 Proposes to use DWE data to estimate chronic daily intake rates for workers 

 Proposes to use job-specific data when data on job type are available in a worker’s file 

(not available in most cases) 

 For all others, seeks to construct log-normal facility (Plant) distributions of alpha air 

concentration 

o Assigns intakes to workers based on exposure potential using three quantiles of the 

facility distribution (low, medium, or high) 

 Low: admin, clerical, secretarial, managerial (up to GM - GSD) 

 Medium: not in low or high (maintenance, construction) (GM ± GSD) 

 High: process operators and helpers, machine operators/helpers, welders/helpers, 

furnace operators/helpers (GM + GSD) 
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Revision 3 (Morris 2010): 

 Proposes to use DWE data to estimate chronic daily intake rates for workers. 

 Proposes to assign the DWE value associated with the job title or job description with the 

highest DWE in the FMPC plant where thorium was handled for a specific year to every 

worker in that facility, with a GSD of 5. 

 Proposes to use the upper 95th percentile of the air sampling data for a facility when timeweighted average data are not available. 

 Proposes to assign a high DWE value from an adjacent year when neither DWE data nor 

air sampling data are available, or when they are judged to be inadequate or incomplete. 

A GSD of 5 is recommended. 

 If it is determined that thorium exposure may have occurred in a facility not shown in the 

thorium timeline (Morris 2010, Figure 1, p. 2), NIOSH recommends searching the SRDB 

for DWE data by using the keywords “exposure study.” A draft summary of the FMPC 

DWE data (Unknown 1990) can be used as an indicator of the data that are likely to be 

found in the SRDB. 

5.1.1 Sources of Variability and Uncertainty in the DWE Data 

A salient feature of Davis and Strom (2008) is the detailed discussion of the types of variability 

and uncertainty inherent in the DWE data and those sources addressed in their method, namely 

variability in the task AAC measurements. Their identification of human error (blunders) as a 

significant source of uncertainty in the AAC data and the need to carefully review those data is 

particularly relevant to DR under the EEOICPA (see Finding #3). 

Morris (2010) proposes to use an upper bound DWE or unweighted air concentration to account 

for sources of variability and uncertainty in the source data. The upper bound for a plant or 

building is to be based on the job with the highest DWE in the facility as a central estimate, with 

a GSD of 5. Regarding the GSD of 5, Morris (2010) states: 

Based on their analysis Davis and Strom state it is reasonable to conclude that 

the upper 95th percentile value of the GSD distribution is about 4 and the upper 

99th percentile is between 7 and 8. This lends support to their generalization of 

assuming a GSD of 5 when a DWE concentration value is available but there is 

no information on uncertainty. (Morris 2010, p. 11) 

 

This statement is consistent with Davis and Strom (2008), p. 15: 

By examining the data themselves rather than a fit, one can conclude that the 

upper 95th percentile of the GSD values is about 4, and the upper 99th percentile 

is between 7 and 8. This observation supports the practice of assuming a GSD of 

5 when a concentration measurement is available but there is no information on 

uncertainty. 
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By using a shortcut method that relies extensively on the analysis in Davis and Strom (2008), 

NIOSH can circumvent the need to generate a set of site-specific DWE fits from the Fernald 

source data. To help justify their reliance on Davis and Strom rather than site-specific data, 

NIOSH states the following: 

The sampling methods and data analysis used by the HASL staff were the same as 

those used at FMPC. The engineered controls in these AWE facilities were 

similar to, but likely inferior to those employed at FMPC, since FMPC was 

purpose-built in light of experience at earlier operating facilities. (Morris 2010, 

p. 10) 

Thus, NIOSH appears to believe that the data from Fernald are less variable and uncertain than 

those from the sites investigated by Davis and Strom because engineering controls had improved, 

based principally on experience gained from those earlier operations. However, NIOSH has not 

yet demonstrated that the data from Electrometallurgical Co., American Machine and Foundry 

Co., Middlesex Sampling Plant, Horizons, Inc., and Lake Ontario Ordnance Works collected 

from 1948 to 1955 can serve as a reasonable surrogate for bounding exposures in the Fernald 

thorium processing facilities during the proposed SEC period. That is, NIOSH has not analyzed 

the site-specific data to determine if a GSD of 5 is adequate for bounding Fernald DWEs. As 

noted in SC&A 2009, we have identified some of the raw air sampling data and matched it to 

DWE data for some plants and years. However, as stated in Observation #2, it is not clear to 

what extent the Fernald source data are available for analysis. Moreover, SC&A understands 

that NIOSH has not yet conducted a thorough investigation into the availability of the data. 

Finding #4: Morris (2010) has not demonstrated that the data analyzed in Davis and Strom 

(2008) constitutes a reasonable surrogate for bounding the Fernald DWEs during the 

proposed SEC period. SC&A believes that NIOSH should determine the extent of DWE 

source data availability for Fernald and perform an uncertainty analysis on those data to 

ascertain if a GSD of 5 is sufficiently bounding. 

As a corollary to Findings #3 and #4, NIOSH should review the available Fernald source data for 

blunders. As noted in the discussion leading to Finding #3, Davis and Strom demonstrated that 

for the subject datasets, blunders could result in underestimated intakes up to an order of 

magnitude. Furthermore, this type of uncertainty was not considered in their analysis. If 

blunders of this magnitude were found to exist at Fernald, upper-bound doses could potentially 

be underestimated (for example, a GSD of 5 combined with an underestimate of 10 from 

blunders would result in a factor of 2 underestimate of upper-bound dose). While SC&A 

understands the remote likelihood of such an occurrence, we believe it is incumbent upon 

NIOSH to provide reasonable documentation of the frequency and magnitude of blunders in their 

source data. 

Finding #5: Morris (2010) has not investigated the issue of blunders as a significant source of 

error in Fernald DWE source data. SC&A believes that NIOSH should determine the 

frequency and magnitude of blunders in their source data. If significant blunders are 

identified, their influence should be taken into account in uncertainty metrics (e.g., GSD). 
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5.1.2 DWE for a Facility in a Specified Year 

SC&A believes that once NIOSH has satisfied our concerns per Findings #4 and #5, the 

proposed method for bounding intakes based on the highest DWE in the FMPC plant where 

thorium was handled for a specific year, with a bounding GSD (nominally 5), is reasonable. 

5.1.3 DWE for a Facility Based on Adjacent Years 

SC&A believes that once NIOSH has satisfied our concerns per Findings #4 and #5, the 

proposed method of assigning a high DWE value from an adjacent year for bounding intakes 

when neither DWE data nor air sampling data are available, or when they are judged to be 

inadequate or incomplete, is reasonable. However, NIOSH should quantify what is meant by a 

“high DWE.” 

5.1.4 Unweighted Air Concentration Data when Time-Weighted Data are Not Available 

NIOSH proposes to use the upper 95th percentile of the air sampling data for a facility when 

time-weighted average data are not available. Morris (2010) draws from the following statement 

in Davis and Strom (2008) as the basis for this approach: 

Thus, using the upper 95th percentile of site-wide air concentration data will 

almost always be favorable to the claimant, if unrealistically high for almost 

everyone. Clearly, Csite is a biased estimator of exposure, but it can be used in 

making compensation decisions when it is required to be favorable to a claimant. 

(Davis and Strom 2008, p. 15) 

While there is no doubt that such a high intake assignment would be claimant favorable, the 

following statement from Davis and Strom (2008) suggests that it may not meet the plausibility 

requirement for DR under EEOICPA: 

Using the distribution of all air samples from a plant without time weighting or 

assignment to specific jobs does not produce a DWA or GSD that is 

representative of any individual worker for that site. (Davis and Strom, 2008, 

p. 15) 

Table 2 from Morris (2010) summarizes the recommended DWE values for years and facilities 

in which thorium work is known to have occurred. These values represent the job description in 

each facility with the highest DWE value for that year. That table is replicated below as Table 3, 

for convenience. “NA” indicates that thorium is not known to have been processed in that 

facility during that year. 
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Table 3. DWE Values, in Units of Multiples of the MAC, Recommended for use in 

Estimation of Thorium Intake Rates 

[From Table 2, Morris (2010)] 

Year 54 55 56 57 58 59 60 61 62 63 64 65 66 67 

Plant 1 a 16.4 4.3 1.5 1 2.1 0.5 0.6 1.1 0.6 0.7 0.6 1 1.2 

Plant 4 4.5 3.2 0.9 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 

Plant 6 N/A N/A N/A N/A N/A 0.8 4.3 1.6 2.8 17 N/A N/A N/A N/A 

Plant 8 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 7.1 N/A 

Plant 9 b 686 b N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 

Pilot Plant 5.9 c 2 N/A N/A N/A N/A N/A N/A N/A d d d 77 

Notes: 

a: Data are not available. Instead use the value for Plant 1, 1955. 

b: Data are not available. Instead use the value for Plant 9, 1955. 

c: Data are not available. Instead use the value for Pilot Plant 1954. 

d: DWE data are not available. The value for Pilot Plant 1967 is based on the 95th percentile value of 18 air samples 

taken during thorium operations. Use this value for Pilot Plant 1964 through 1966. 

NIOSH indicates that the proposed intake assignment of 77 MAC for the Pilot Plant for 1964–

1967 is based on the 95th percentile of 18 unweighted air samples taken in 1967. SC&A 

reviewed the raw air sampling data that were downloaded to support our review of Morris (2009) 

and found that NIOSH assigned the air concentration as described. However, we believe that an 

upper-bound AAC assignment without time weighting is unrealistic and highly implausible, due 

to the huge variability of such data in space and time. Moreover, we find it perplexing that 

NIOSH suggests using unweighted air sampling data when time-weighted data from the same 

plant for other years or from another plant are available. 

A closer inspection of the highest DWE for Plant 9 in 1955 helps illustrate our concerns 

regarding the assignment of unweighted AAC data. We note that the value of 686 MAC for 

Plant 9, while nearly an order of magnitude higher than the Pilot Plant assignment of 77 MAC, is 

nonetheless plausible, because it is based on a sufficiently robust set of time-weighted BZ and 

GA measurements for laborers involved in thorium metal production during that year. That is, it 

reflects actual exposure potential for a class of workers who were subject to heavy dust loading 

in the facility for the year in question. As an extreme example of NIOSH’s proposed approach, 

SC&A notes that the highest air concentration measured for Plant 9 in 1955 was a BZ sample for 

cleaning furnace pots inside an enclosure, a task that required about 75 minutes to complete. The 

highest measured concentration among 7 samples was 976,798 dpm/m3

 (9,768 MAC), though 

the samples were highly variable (low of 1,887 dpm/m3 and an average of 321,549 dpm/m3). 

Clearly, assigning the 95th percentile of these unweighted air concentrations to every worker in 

the plant that year would be claimant favorable, though not representative of reasonable exposure 

potential to any worker (nominally 13–14 times higher than the DWE for that job description). 

Finding #6: The use of the upper 95th percentile of the air sampling data for a facility when 

time-weighted average data are not available probably does not meet the plausibility 

requirement for DR under EEOICPA. SC&A finds it perplexing that NIOSH suggests using 

unweighted air sampling data, particularly when time-weighted data from other years or from 

another plant are available. 
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5.1.5 Thorium Exposures Not in Timeline 

SC&A believes that it is incumbent on NIOSH to locate and make available all AAC data that 

may be related to thorium exposure. A simple directive to the dose reconstructor to search the 

SRDB for such information if thorium exposure is suspected places an undue burden on the dose 

reconstructor and is likely to result in inconsistencies. SC&A’s concern regarding the 

completeness of the thorium timeline was identified as a finding (#8) in SC&A (2009) and is 

restated below: 

There are a number of years and plants in the thorium timeline that have no DWE 

reports. NIOSH has not provided a method for estimating thorium intakes in 

these cases. 

Finding #7: It is incumbent on NIOSH to update the thorium timeline and locate and make 

available all AAC data that may be related to thorium exposure. Reliance on the dose 

reconstructor to search the SRDB for such information if thorium exposure is suspected 

places an undue burden on the dose reconstructor and is likely to result in inconsistencies. 

5.2 Independent Audit of the Dose Reconstruction for an Energy Employee at the 

Uranium Mill in Monticello, Utah 

SC&A recently performed an independent audit of a DR performed by NIOSH for an EE who 

worked as a [redacted] at the Uranium Mill in Monticello, Utah, from October [redacted], 

through December [redacted]. Because NIOSH used DWE to assess the internal dose to this 

EE, SC&A believes that a comparison of the methods applied in this case to those in Morris 

(2009) and Davis and Strom (2008) is instructive. 

The DR Report explains that no external or internal dosimetry data are available for this EE. 

Also, there is apparently no site profile for this facility. However, NIOSH took advantage of 

material provided in a report prepared by the predecessor to DOE (HASL 1958). Because of the 

degree to which the DR for this EE is based on HASL (1958), we reviewed HASL (1958) as if it 

were a site profile. The DR Report states that it was not possible to determine whether the EE 

was in a position to experience internal exposures, and there are no air sampling or bioassay data 

for this facility. As a result, the data in HASL (1958) were used to assign internal exposures to 

this EE. HASL (1958) presents the results of a detailed investigation performed by HASL of the 

exposures of workers to internal emitters from 12 uranium mills operating in 1957. 

The emphasis of the HASL air sampling program was to determine the air concentration of 

alpha-emitting dust, its composition, particle size, and silica content (the latter for industrial 

hygiene reasons). The air samples consisted of GA samples collected in occupied areas, and a 

second set of BZ samples for employees engaged in specific potentially dusty operations. Many 

samples were replicates, and the average of the replicates was reported. The data were used to 

derive DWEs for different job categories using well established DWE techniques. 

Table 2 of the DR Report provides annual intakes in units of pCi/yr, but does not explain how 

the values in HASL (1958) were used to derive these intakes. Assuming the EE worked with 
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uranium ore, the total annual intake is estimated in Table 2 of the DR to be 2.1 × 104

 pCi/yr. If 

the EE worked with yellowcake, the total annual intake rate of long-lived alpha emitters is 5.1 × 

104

 pCi/yr. SC&A estimated the average airborne gross alpha activity (expressed in units of 

dpm/m3

) required to reach the stated intakes by applying a 2,000-hour work year and a breathing 

rate of 1.2 m3/hr. This results in average air concentrations of 19.44 and 47.21 dpm/m3 for 

uranium ore and yellowcake, respectively. 

Upon completion of SC&A’s review, it was determined that Mill A in HASL (1958) is the 

Monticello facility. A review of the air sampling data for Mill A reveals that it lies in the mid 

range of the levels observed among the 12 mills investigated by the HASL. Table II of HASL 

(1958) indicates that the DWE for Mill A was 12.5 × 10-11 μCi/cm3

, which converts to 

278 dpm/m3 (rounded): 

12.5 × 10-11 μCi/cm3

 × 106 cm3/m3 × 3.7 × 1010 d/s-106 μCi × 60 s/min = 278 dpm/m3

Therefore, the NIOSH values are equivalent to 7% and 17% of the average for Mill A for 

uranium ore and yellowcake, respectively. It appears from the limited information regarding the 

methods employed in this DR that the EE was assigned a “low” exposure, based on the EE’s 

[redacted] for the facility DWE (Mill A). This approach would be consistent with the NIOSH 

approach for assigning exposures based on job category in Morris (2009), to the extent that it is 

transparent to SC&A. SC&A understands that the DR Report was prepared prior to the issuance 

of Revision 3 of the NIOSH white paper and is, therefore, not consistent with the methods in 

Davis and Strom 2008. 

Finding #8: It appears that NIOSH has applied the methods described in Morris (2009) in 

assigning the intake to this EE as a percentile of the facility DWE based on job category. This 

approach is not consistent with Davis and Strom (2008) and does not appear to be a 

statistically valid method of using DWE data to estimate intake. 

6.0 CONCEPTUAL CONSISTENCY OF SC&A-SUGGESTED APPROACHES FOR 

ESTIMATING INTAKES BASED ON AAC DATA WITH DAVIS AND STROM 

(2008) 

In this section, SC&A ascertains whether alternative approaches we have recommended in 

reviews of relevant NIOSH guidance documents are conceptually consistent with the methods 

outlined in Davis and Strom (2008). 

6.1 Feed Materials Production Center (SC&A 2009) 

Attachment 1 of SC&A 2009 contains a detailed examination of the DWE data for one FMPC 

plant/year combination; Plant 1 in 1955. The DWE data for Plant 1 in 1955 are for 28 workers 

apportioned among 12 jobs that included a total of 95 separate tasks. The AAC data used to 

create the DWEs were transcribed by NIOSH from job evaluation sheets and compiled in 

spreadsheets. 
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med 

re as Figure 2. 

To verify the DWEH values generated from the NIOSH spreadsheets and also evaluate the 

degree to which the AAC data and job DWEs follow a lognormal distribution, SC&A perfor

a Monte Carlo simulation on the AAC data by task for 12 jobs for Plant 1 in 1955. We 

conducted a simulation using Crystal Ball with the exposures for each task being random, and a

weighted DWE for each job was calculated using the (fixed) time weights. To conduct the 

simulation, we constructed a separate lognormal distribution for each of the 95 tasks using the 

sample size and average, high, and low exposures taken from the spreadsheets. If the reported

low value was zero, a value equal to one-half of the smallest reported non-zero value was used. 

The means of the estimated lognormal distributions were plotted versus the spreadsheet averages 

for each task in Figure 1-1 of the report, as a check on the estimated parameters. That plot is 

replicated he

1

10

100

1,000

10,000

100,000

1 10 100 1,000 10,000 100,000

Average on Spreadsheet

Lognormal Mean

Figure 2: Scatter Plot - Lognormal Mean for Each Task versus Actual Average Exposure 

Figure 2 illustrates that SC&A’s Monte Carlo simulation yielded task averages that are 

consistent with the values calculated in the spreadsheets, which indicates that the task AAC 

distributions are well approximated by the lognormal. That this AAC dataset appears to be 

lognormal, while those from Figure 1 do not, underscores the wide variation in measurement 

distributions among job DWEs and across sites. 

Results of the Crystal Ball simulation are shown in Table 4 and compared to the DWEH values 

calculated from the NIOSH spreadsheets. Values are reported in units of dpm/m3. 

Table 4. Simulation Results for Job Descriptions and Facility Mean 

as Performed by SC&A 

Job Title DWEH Mean Median Standard 

Deviation 95th Percentile 

Sample Preparation Operations 1568 1,370.77 557.74 3,579.95 4,686.68 

General Plant Operations 468 530.49 448.71 397.25 1,014.13 

Leadman 97 82.22 47.20 130.75 263.61 

Production Foreman 38 33.30 22.13 38.95 89.06 

Sample Preparation Foreman 28 28.74 17.71 38.40 87.96 
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Table 4. Simulation Results for Job Descriptions and Facility Mean 

as Performed by SC&A 

Job Title DWEH Mean Median Standard 

Deviation 95th Percentile 

General Foreman 22 20.49 14.79 20.25 50.78 

Superintendent 15 14.10 10.39 13.18 35.98 

Storage Pad Foreman 12 12.42 12.23 1.92 15.78 

Storage Pad Operator 11 12.09 11.90 1.93 15.43 

Storage Pad Laborer 10 11.32 11.12 2.21 15.38 

Production Records Clerk 7.7 8.45 7.85 3.15 14.29 

The means resulting from the Crystal Ball simulation in Table 4 are consistent with the DWEH

calculated from the historical AAC data. Note that because this exercise was conducted to match 

the HASL DWEs, no attempt was made to account for variability in the time for each task. 

Finding #9: The method outlined above to generate distributions of job DWEs from 

lognormal fits to the task AAC data is practically identical to the DWAL distribution proposed 

in Davis and Strom (2008), and is presented in SC&A (2009) as a statistically credible 

alternative to the methods that were presented in Morris (2009). The SC&A approach seeks to 

account for the sources of variability and uncertainty in the raw data that were identified in 

Davis and Strom (2008), as summarized in Findings 1–6, 8, and 18 from SC&A (2009). 

Overall, SC&A believes that this method is conceptually consistent with Davis and Strom 

(2008). 

6.2 Mallinckrodt Chemical Works Site Profile Review 

SC&A’s review of ORAUT-TKBS-0005 (Rev. 01), Draft Preliminary Review (Partial) of the 

Mallinckrodt Site Profile Revision 1 (Effective Date March 10, 2005) (SC&A 2005), raises 

several concerns regarding the use of time-weighted averages for assigning intakes of airborne 

uranium dust. Those concerns are summarized in Finding 5.5 and are reproduced below: 

 The TBD’s use of time-weighted averages to quantify uranium dust inhalation 

dose does not take into account a number of variables, such as variation of 

the air concentration experienced by individual workers from the average, 

high episodic dust concentrations, the representativeness of measurements 

being taken over short periods of time, and uncertainties about job categories. 

The last problem would disproportionately affect survivor claimants. 

 Time-weighted averages as presented in Rev. 00 cannot be used to reliably 

estimate anything other than minimum doses. 

 Additional raw data confirmation, determination of uncertainties, and use of 

the upper 95th percentile values, estimated by sampling the various locations, 

are needed in order to provide a more claimant-favorable dose 

reconstruction. 
Effective Date: 

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SC&A (2005) makes the following observation regarding Rev. 01 of the TBD: 

Rev. 01 does not contain any analysis or indication that NIOSH has examined the 

raw data and evaluated the uncertainties so as to develop a claimant-favorable 

approach to estimating time-weighted averages. This is necessary in view of the 

small number of measurements that were made at each station. 

In order to illustrate the importance of uncertainty in the raw AAC data, SC&A was able to 

obtain the data for the job title of “[redacted]” and evaluated it for the tasks “mixing and 

charging,” the two tasks with the highest exposure potential. BZ samples were collected for 

these operations, which were done 12 times per shift, with the time estimate for the 2 operations 

being 1.5 minutes and 5 minutes, for total times of 18 and 60 minutes, respectively, as illustrated 

in Table 5 (from SC&A 2005). Note that uncertainties in the time for each operation were not 

indicated, and are therefore ignored in this computation (Finding #1). Note also that the original 

time-weighted average contains a typographical error in one value, indicating the need for 

checking the original calculations (Finding #3). 

Table 5. Time-Weighted Data for [Redacted], Plant [Redacted], September and October 

1948 

[From SC&A (2005)] 

Operation Total min. Avg 

dpm/m3

Time-integrated 

Avg dpm-min/m3 # Samples Range dpm/m3

 Mixing 18 3.53E+04 6.35E+05 3 12,000 to 62,600 

 Charging 60 4.97E+03 2.98E+05 3 1,920 to 6,680 

 Gen. air during operation 102 2.70E+03 2.75E+05 2 1,605 to 3,790 

 Gen. air when not 

operating 235 1.10E+03 2.59E+05 3 712 to 1,720 

 Gen. air, locker 35 6.10E+01 2.14E+03 4 39 to 110 

 Gen. air, lunch 45 2.62E+02 1.18E+04 2 262 to 272 

 Total 495 1.48E+06 

 Time-weighted Avg. 2.99E+03 

As stated in SC&A 2005, it is clear from the ranges reported in the far right column of Table 5 

that for each of the tasks/areas that make significant contributions to the total time-integrated 

concentration over the workday, there are significant uncertainties. For instance, the empirical 

lognormal 95th percentile value for the largest time-integrated item, mixing, is about 2 million 

dpm-min/m3 based on the 95th percentile value of the air concentration estimated from the three 

data points.2

 This is about 3.2 times larger than the value of 6.35 × 105 dpm-min/m3 derived 

from the average. This one uncertainty alone would increase the annual intake estimate by 

almost a factor of two. This estimate ignores the uncertainty in the variance due to the small 

number of measurements, as well as the fact that a worker would perform the operation many 

times. These two factors pull the 95th percentile estimate of an individual worker’s exposure in 

opposite directions. 

 2 The three measurements are 1.2 × 104

, 3.12 × 104 and 6.26 × 104 dpm/m3. The average of the natural 

logarithms is 10.26 and the estimate of the standard deviation is 0.829. This yields a 95th percentile value for air 

concentration of 1.12 × 105

 dpm/m3. Hence, the time integrated value = 18*112,000 = 2.02 × 106 dpm-min/m3.
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SC&A demonstrated a method to address both the small number of measurements and task 

repetition by using the Student’s t distribution to estimate the 95th percentile of the average of 

the task AAC distribution (still assuming the measurements themselves are lognormally 

distributed). This method could provide a claimant-favorable value for workers repeating 

the same operation in the same way, all other things being equal. The estimate of the 95th

percentile value of the average of the natural logarithms of the “mixing” AAC measurements is 

about 116,000 dpm/m3

, which is about 3.3 times the average value of the three measurements. 

The overall integrated exposure (95th percentile) goes up by a factor of about two as a result of 

the uncertainty in air concentration in this one operation alone.3

SC&A (2005) notes that the uncertainty from the other operations must also be taken into 

account and is expected to vary considerably. For example, the effect of the uncertainty in the 

lunchroom measurements on the time-integrated exposure will be relatively small, since the two 

measurements are close together and the total time-integrated value is low relative to the other 

operations. By contrast, the effect of the uncertainty in the general air concentration during 

operations will be considerable, because (1) there were only two measurements, (2) the spread 

between the measurements was large, and (3) the total time for the operation per day is large 

(102 minutes per day as opposed to 18 minutes per day for mixing). The 95th percentile value for 

the average air concentration at this station, using the t statistic (which is 6.314 in the case of 2 

measurements and a 5% tail) is about 37,000 dpm/m3, which is nearly 14 times the arithmetic 

average. As a result the uncertainty in this factor (air concentration for general air during 

operation) raises the total integrated exposure by a factor of about 3.4.4

The uncertainties in air concentration during various operations will have to be combined by an 

appropriate statistical method of propagation of errors, in order to develop an overall 95th

percentile value for the time-weighted job exposure.5 It is clear that in this example, the result 

would be several times greater than the time-weighted average value used by NIOSH. The effect 

in other cases will be different, depending on the number of measurements and the spread in the 

measurements. In cases where there is only one measurement of air concentration, a calculation 

of uncertainties is not possible for that task, since at least two measurements are needed to 

estimate a variance. 

Given the above issues, SC&A re-affirms that only minimum doses can be estimated based on 

the time-weighted averages in the TBD. Rather, an approach that takes into account the 

3

 The average is computed by the expression ŷ = μ + t*s/√n, where ŷ is the estimate of the average for the 

specified percentile, μ is the average, t is the t distribution statistic for the given number of measurements and 

percentile value, s is the estimate of the SD, and n is the number of measurements. The t statistic for 3 

measurements (2 degrees of freedom) and a 5% tail is 2.92. The average of the logarithms of the 3 measurements 

for the mixing operation is 10.26 and the SD is 0.829. Therefore, the 95th percentile estimate of the mean is = 10.26 

+ 2.92*0.829/√3 = 11.66. The corresponding value for the 95th percentile value of the average of the measurements 

= e11.66 = 116,000 dpm/m3

, where e is the base of natural logarithms. All values are rounded. Note that the 95th

percent upper confidence bound, which means a 2.5% tail on either side, would provide a higher estimate. 4

 The computation is done by using μ= 7.81, t= 6.314, s = 0.6076, and n = 2 in ŷ = μ + t*s/√n, which yields 

ŷ = 10.52, and the value for the air concentration of e10.52 ≈ 37,000 dpm/m3

. 5

 In Crystal Ball, the t random variable can be simulated by drawing an SD from a gamma distribution, then 

generating a normal random variable using the random SD. A word of warning though; when the degrees of 

freedom (dof) of the t distribution is 2 or less, the variance of the simulated values may be infinite (i.e., not defined). 

When dof is 1 or less, the mean is not defined. Therefore, the distribution must be artificially truncated. 
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sparseness of the data and the uncertainties that that creates for individual dose estimation is 

necessary to address the issue. 

Finding #10: The approach outlined above is conceptually consistent with Davis and Strom 

(2008), in that it seeks to account for the sources of variability and uncertainty in the raw data 

by generating probability distributions for each task and combining them in a statistically 

valid way to arrive at distributions of job-specific weighted exposure. In addition, SC&A 2005 

identified the problem of human error and the need to validate the raw data prior to use. This 

method, however, goes beyond the methods of Davis and Strom (2008), in that it seeks to 

account for the effects of task repetition by individual workers over time, which tends to 

narrow the uncertainty distribution. 

7.0 SUMMARY OF FINDINGS AND OBSERVATIONS 

7.1 Davis and Strom (2008) 

Observation #1: SC&A notes that the fifth item in the list of factors contributing to variability 

in the data, “whether or not the sample represents the actual exposure experienced by the 

worker,” is not a source of variability in the AAC data, but is an uncertainty in assessing worker 

exposure based on the data. 

Observation #2: It is noteworthy that the airborne dust reports (DWE reports) examined by 

SC&A in support of the review of Morris (2009) for its applicability in the reconstruction of 

Th-232 intakes did not contain the raw data (SC&A 2009). Those reports were prepared for 

FMPC by National Lead of Ohio (NLO). This aspect of the study is very important, because the 

issue of availability of the raw data for use in assessing uncertainty in DWEs has been an 

ongoing topic of discussion for both Mallinckrodt and Fernald (see Finding #5, SC&A 2009). 

Finding #1: The formulations for DWAD and DWAL treat TS,i, the time required to complete 

task i, as a constant. Given that these are, in fact, average times to complete a task, they have 

associated variability (among workers) that should be addressed in generating uncertainty 

distributions of DWE. In the 2005 review of the Mallinckrodt report, SC&A noted that these 

uncertainties could be significant in high dust, short-duration operations that dominate timeintegrated exposure. 

Finding #2: The histograms in Figure 1 call into question the assumption of log-normality for 

the task AAC data. If the source data were lognormally distributed, as suggested by the authors 

and advocated in citations quoted in the literature review, one would expect that a DWE 

distribution constructed from those data would, in most cases, appear lognormal (as was true for 

DWAL, which was based on lognormal fits to the AAC data). 

Finding #3: The impact of blunders on calculated air concentration values (AAC) was 

unexpected and in some cases significant. SC&A believes that this is a problem, even if it 

happened in only a few cases, and underscores the critical importance of validated source data in 

constructing uncertainty distributions for DWE. Note that this issue was raised in the 2005 

SC&A review of the Mallinckrodt TBD. 
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7.2 Morris (2010) 

Finding #4: Morris (2010) has not demonstrated that the data analyzed in Davis and Strom

(2008) constitute a reasonable surrogate for bounding the Fernald DWEs during the proposed 

SEC period. SC&A believes that NIOSH should determine the extent of DWE source data 

availability for Fernald and perform an uncertainty analysis on those data to ascertain if a GSD 

of 5 is sufficiently bounding. 

Finding #5: Morris (2010) has not investigated the issue of blunders as a significant source of 

error in Fernald DWE source data. SC&A believes that NIOSH should determine the frequency 

and magnitude of blunders in their source data. If significant blunders are identified, their 

influence should be taken into account in uncertainty metrics (e.g., GSD). 

Finding #6: The use of the upper 95th percentile of the air sampling data for a facility when 

time-weighted average data are not available probably does not meet the plausibility requirement 

for DR under EEOICPA. SC&A finds it perplexing that NIOSH suggests using unweighted air 

sampling data, particularly when time-weighted data from other years or from another plant are 

available. 

Finding #7: It is incumbent on NIOSH to update the thorium timeline and locate and make 

available all AAC data that may be related to thorium exposure. Reliance on the dose 

reconstructor to search the SRDB for such information if thorium exposure is suspected places 

an undue burden on the dose reconstructor and is likely to result in inconsistencies. 

7.3 Monticello Uranium Mill DR Audit 

Finding #8: It appears that NIOSH has applied the methods described in Morris (2009) in 

assigning the intake to this EE as a percentile of the facility DWE based on job category. This 

approach is not consistent with Davis and Strom (2008) and does not appear to be a statistically 

valid method of using DWE data to estimate intake. 

7.4 SC&A Methods 

7.4.1 FMPC 

Finding #9: The method outlined above to generate distributions of job DWEs from lognormal 

fits to the task AAC data is practically identical to the DWAL distribution proposed in Davis and 

Strom (2008), and is presented in SC&A (2009) as a statistically credible alternative to the 

methods that were presented in Morris (2009). The SC&A approach seeks to account for the 

sources of variability and uncertainty in the raw data that were identified in Davis and Strom 

(2008), as summarized in Findings 1–6, 8, and 18 from SC&A (2009). Overall, SC&A believes 

that this method is conceptually consistent with Davis and Strom (2008). 
Effective Date: 

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

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

NOTICE:

7.4.2 Mallinckrodt 

Finding #10: The approach outlined above is conceptually consistent with Davis and Strom 

(2008), in that it seeks to account for the sources of variability and uncertainty in the raw data by 

generating probability distributions for each task and combining them in a statistically valid way 

to arrive at distributions of job-specific weighted exposure. In addition, SC&A (2005) identified 

the problem of human error and the need to validate the raw data prior to use. This method, 

however, goes beyond the methods of Davis and Strom (2008), in that it seeks to account for the 

effects of task repetition by individual workers over time, which tends to narrow the uncertainty 

distribution. 
Effective Date: 

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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.

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1 – Draft 

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Focused Review of Davis and Strom 2008 

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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.

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February 2, 2011 

Revision No. 

1 – Draft 

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Focused Review of Davis and Strom 2008 

Page No. 

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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:

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