Memo to PRSC 1 SC&A – March 24, 2015 

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. 

MEMO 

DATE: March 24, 2015 

TO: Subcommittee on Procedures Review, NIOSH, Ted Katz, DFO 

FROM: U. Hans Behling 

SUBJECT: Review of NIOSH’s Response to DCAS-PER-045 Findings 

Relevant Background Information 

On April 16, 2014, SC&A was tasked by the Advisory Board’s Subcommittee on Procedures 

Review to conduct reviews of three PERs, which included DCAS-PER-045, Aliquippa Forge 

TBD Revision (DCAS 2013). 

In August 2014, SC&A submitted its draft report, A Review of NIOSH’s Program Evaluation 

Report DCAS-PER-045, “Aliquippa Forge TBD Revision” (SC&A 2014). In the draft report, 

SC&A identified two observations and eight findings. 

In response to SC&A’s observations and findings, NIOSH prepared a document dated January 

23, 2015, which is enclosed herein as Attachment #1. 

During a teleconference meeting of the Procedures Subcommittee on February 18, 2015, SC&A 

was tasked to review and comment on NIOSH’s responses enclosed herein as Attachment #1. 

SC&A’s Response and Resolution to Findings 

A review of the eight (8) findings cited by SC&A identifies the fact that all findings relate to 

assumed model parameters/methodology used by NIOSH to derive annual internal exposures 

(from inhalation and ingestion) and external exposures (from penetrating and non-penetrating) 

exposures to residual radioactivity from 1950–1995, as defined in Table 5-1 of ORAUTTKBS-0021, Rev. 01 (ORAUT 2012) and reproduced in Table 3 of SC&A 2014. 

Relative to all of SC&A’s findings, with the exception of Finding #4, are the following two 

issues: (1) NIOSH’s derivation of the starting air concentration of 0.211 dpm/m3in 1950, and 

(2) the use of this value for deriving a source term depletion rate of 1.15 × 10-4 d

-1

, as given by 

the following explanation cited in Section 5.0 of ORAUT-TKBS-0021, Rev. 01 (ORAUT 2012) 

and reproduced in Section 4.2.2. of SC&A 2014:
Memo to PRSC 2 SC&A – March 24, 2015 

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. 

After the end of AEC rolling operations, a July 1949 survey was performed. 

The survey indicated that the maximum air dust concentration, taken during 

normal operations in the Furnace area, was 5.9 μg/m3or 8.94 dpm/m3

(assuming a specific activity of 1.516 dpm/μg for natural uranium) (Belmore 

1949b). 

To calculate internal exposure from residual activity the analysis assumed that 

all buildings had an air concentration of 8.94 dpm/m3in 1950. This operational 

air concentration was assumed to have occurred for 1 year with no cleanup. An 

indoor deposition velocity of 0.00075 m/s was applied to calculate a 2.11 × 

105 dpm/m2

surface contamination level at the end of operations/start of the 

residual period. A resuspension factor of 1 × 10-6 m-1 was applied to the surface 

contamination level, resulting in an air concentration of 0.211 dpm/m3. A source 

term depletion rate was calculated based on a starting air concentration in 1950 

and the air concentration calculated based on the 1992 survey data (ORAUT 

2012b). The 1992 calculated air concentration of 0.035 dpm/m3 was based on 

applying a resuspension factor of 1 × 10-6

m

-1 (Abu-Eid et al. 2002) to the 

maximum removable surface contamination of 350 dpm alpha/100 cm2. Using 

these two air concentrations, a source term depletion rate of 1.15 × 10-4 d

-1

was 

calculated. The ingestion intake rates were calculated using the method 

described in Section 3.0. The estimated daily inhalation and ingestion intake 

rates to residual radioactivity from AEC operations at the site (Table 5-1), were 

calculated by assuming that workers were exposed for 2,000 hr/yr. [Emphasis 

added.] 

SC&A’s Finding #5 (see Attachment #1) questioned NIOSH’s conversion of an empirical air 

concentration of 8.94 dpm/m3 for 1950 to a revised “modeled” dose that at 0.211 dpm/m3is 

42-fold lower. Upon review of SC&A’s Finding #5, NIOSH has agreed that “. . . the 1949 air 

sample itself [is] representative of the start of the residual period and will revise the site profile 

to use 8.94 dpm/m3as the starting point.” [Emphasis added.] 

NIOSH’s acceptance of 8.94 dpm/m3as the starting air concentration for 1950 would, therefore, 

also change the derivation of the source term depletion rate from 1.15 × 10-4 d

-1 to 3.58 × 

10-4 d

-1. In combination, acceptance of the empirical air concentration of 8.94 dpm/m3

and its 

use for deriving the source term depletion factor would not only impact all internal exposure 

estimates cited in Table 5-1 of the Aliquippa TBD, but also all external exposure estimates. To 

reconstruct penetrating external exposures from residual radioactivity, NIOSH employed the 

maximum reported exposure rate of 0.014 mR/hr for 1992 (Adams and Payne 1992) and backextrapolated dose rates by the 1.15 × 10-4 d

-1 source term depletion factor that had been derived 

inappropriately by means of the “modeled” 1949 air concentration value. Non-penetrating 

exposure estimates were determined by assuming a 5-to-1 ratio of non-penetrating to penetrating 

exposure rates during the residual exposure period. 
Memo to PRSC 3 SC&A – March 24, 2015 

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. 

In summary, it is SC&A’s opinion that the use of the empirical air concentration of 8.94 dpm/m3

as the starting value for the residual period and its use for deriving the source term depletion rate 

will claimant-favorably address SC&A’s concerns for Findings #1, #2, #3, #5, #6, #7, and #8. 

With regard to Finding #4, SC&A still maintains that the reported air sample of 180 dpm/m3for 

floor sweeping (enclosed herein as Exhibit #1) represents the highest empirically observed air 

concentration that is likely a bounding value. However, while “floor-sweeping” should not be 

considered an “unusual” activity, SC&A does agree that floor sweeping is likely a localized and 

episodic activity in day-to-day activities and may, therefore, not be representative of long-term 

steady-state conditions. 
Memo to PRSC 4 SC&A – March 24, 2015 

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. 

EXHIBIT #1: 1949 Belmore Memo (SRDB 9939) 
Memo to PRSC 5 SC&A – March 24, 2015 

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. 

References 

Abu-Eid, R.M., R.B. Codell, N.A. Eisenberg, T.E. Harris, and S. McGuire, 2002. Re-Evaluation 

of the Indoor Resuspension Factor for the Screening Analysis of the Building Occupancy 

Scenario for NRC’s License Termination Rule, NUREG-1720, Draft Report for Comment, U.S. 

Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, 

Washington, DC, June. [SRDB Ref ID: 22400] 

Adams, W. C., and Payne, J. L., 1992. Characterization Survey of Portions of Aliquippa Forge 

Site West Aliquippa, Pennsylvania, ORISE 93/A-6, Final Report, Oak Ridge Institute for Science 

and Education, Oak Ridge, Tennessee, December. [SRDB Ref ID: 6288] 

Belmore, F.M., 1949b. “Decontamination of Vulcan Crucible Steel Co at West Aliquippa, 

Penna.,” memorandum to M. Eisenbud, U.S. Atomic Energy Commission, July 28. [SRDB Ref 

ID: 9939] 

DCAS 2013. Aliquippa Forge TBD Revision 01, DCAS-PER-045, NIOSH’s Division of 

Compensation Analysis and Support, Cincinnati, Ohio. May 13, 2013. 

ORAUT 2012. Basis for the Development of an Exposure Matrix for Aliquippa Forge, 

Pennsylvania, Period of Operation: January 1, 1947 through February 28, Rev. 01, ORAUTTKBS-0021. Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 26, 2012. 

SC&A 2014. A Review of NIOSH’s Program Evaluation Report DCAS-PER-045 “Aliquippa 

Forge TBD Revision,” SCA-TR-PR2014-0092, Rev. 0, SC&A, Inc., Vienna, Virginia. August 

20, 2014. 
Memo to PRSC 6 SC&A – March 24, 2015 

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. 

ATTACHMENT #1: NIOSH’s Responses to SC&A’s Review of DCAS-PER-045 
Page 1 of 6 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor.

Responses to SC&A Review 

of DCAS-PER-045, 

Aliquippa Forge TBD Revision

Response Paper 

Rev. 0 

National Institute for Occupational 

Safety and Health 

January 23, 2015 

Mutty Sharfi 

Oak Ridge Associated Universities Team

- 

Reviewed by James W. Neton, Ph.D., CHP 

Division of Compensation Analysis and Support 

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. 
Response Paper: Responses to SC&A Review of DCAS-PER-045, Aliquippa Forge TBD Revision 

Page 2 of 6 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. 

OBSERVATION #1. NIOSH SHOULD REPHRASE THE ROLE OF ORAUT-OTIB-0070 

IN SECTION 2.0 OF DCAS-PER-045. 

NIOSH Response: NIOSH agrees that the revision to ORAUT-OTIB-0070 itself did not play a 

role in driving the PER; rather, it was the changes resulting from the incorporation of ORAUTOTIB-0070 into the residual period methodology. The previous version of ORAUT-TKBS-0021 

did not use ORAUT-OTIB-0070 in its assessment of the residual period for Aliquippa Forge 

because ORAUT-TKBS-0021 Rev 00 PC-1 was issued prior to the development of ORAUTOTIB-0070. However, the inclusion of ORAUT-OTIB-0070 into the residual period 

methodology did result in an increase in dose for the residual period, and therefore, is a factor in 

the PER. 

OBSERVATION #2. REVIEW OF RECORDS INDICATES THAT NEITHER REV. 00 

NOR REV. 01 OF THE ALIQUIPPA FORGE TBD (ORAUT-TKBS-0021) WAS EVER 

REVIEWED/AUDITED BY SC&A. 

NIOSH Response: No response needed. 

FINDING #1. FAILURE TO ACCOUNT FOR A PREVIOUS D&D EFFORT. 

NIOSH Response: The 1978 FUSRAP survey (SRDB 6325) reported all beta-gamma exposure 

levels at 1 meter as less than background (0.03 to 0.05 mR/hour). As this survey was performed 

prior to the 1988 interim remedial activities, it can be compared to the calculated 1978 residual 

annual external doses in ORAUT-TKBS-0021 Rev 01 to verify the impact of back-extrapolating 

a post-remediation result to prior years. For penetrating dose (gamma), the annual dose was 50 

mrem; for non-penetrating dose (beta), the annual dose was 252 mrem. This results in a total 

beta-gamma exposure rate of 302 mrem per 2000 hours or 0.151 mrem/hour. Therefore, NIOSH 

considers the approach of back-extrapolating the maximum 1992 dose rate to be bounding and 

favorable and not impacted by the 1988 interim remedial activities. 

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. 
Response Paper: Responses to SC&A Review of DCAS-PER-045, Aliquippa Forge TBD Revision 

Page 3 of 6 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. 

FINDING #2. BACKWARD EXTRAPOLATION BY MEANS OF THE NIOSHDERIVED SOURCE TERM DEPLETION FACTOR IS INAPPROPRIATE DUE TO 

IMPACTS ASSOCIATED WITH THE “INTERIM REMEDIAL ACTIVITIES” OF 1988. 

NIOSH Response: As shown in the response to Finding #1, NIOSH feels that the use of the 

source-term depletion factor (based on the internal data) applied to the external data results in a 

bounding and favorable estimate of external doses. In addition, the fact that the maximum dose 

rate from the 1992 survey was used (rather than the 95th percentile or mean dose rate) also adds 

to the favorability of the assessment. Because the internal source-term depletion factor results in 

a more favorable, but not unrealistic, estimate of external dose, NIOSH feels this is an acceptable 

approach. 

FINDING #3. USING NIOSH’S APPROACH FOR DERIVING INHALATION AND 

INGESTION RATES DURING THE RESIDUAL PERIOD, SC&A WAS UNABLE TO 

MATCH VALUES CITED IN TABLE 3 ABOVE (TABLE 5-1 OF ORAUT-TKBS-0021). 

NIOSH Response: SC&A was able to match the starting point of the residual period. As stated 

in the TBD, the actual starting point of the residual period for the calculations was 1951, not 

1950, because 1950 was a partial year, and therefore, just assumed to be equal to 1951. While 

SC&A used the 1992 data to calculate the inhalation intake rate for that year, the TBD only used 

the 1992 data to calculate the source-term depletion factor, then the 1992 source term depletion 

factor (0.179) was applied to the 1951 intake rate (0.627 pCi/d) to get the 1992 intake rate (0.112 

pCi/d). Therefore, the slight discrepancy is a rounding difference in the application of the 

source-term depletion factor. 

The difference in the ingestion intake rate is due to an error: the air concentration was not 

converted from dpm/m3

to pCi/m3. Therefore, NIOSH agrees that the ingestion intake rates in 

ORAUT-TKBS-0021 Rev 01 Table 5-1 are overestimated by a factor of 2.22 pCi/dpm. The 

TBD will be revised to correct this error. 

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. 
Response Paper: Responses to SC&A Review of DCAS-PER-045, Aliquippa Forge TBD Revision 

Page 4 of 6 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. 

FINDING #4. FAILURE TO ACKNOWLEDGE AND USE A REPORTED AIR SAMPLE 

THAT AT 180 DPM/M3 WAS ~20-FOLD HIGHER THAN THE CITED VALUE OF 8.94 

DPM/M3, WHICH NIOSH DESCRIBED AS “THE MAXIMUM AIR DUST 

CONCENTRATION TAKEN DURING NORMAL OPERATIONS.” 

NIOSH Response: NIOSH does not feel that the air samples associated with a short-term 

operation of sweeping is representative of the steady-state air concentration that would be 

applicable in estimating the routine conditions. This is further indicated in the cited report 

because the air sample associated with sweeping was the only sample in excess of the preferred 

level. Therefore, NIOSH does not believe that this sample should be considered when 

characterizing the general steady-state air concentration. 

FINDING #5. NIOSH’S “CONVERSION” OF THE EMPIRICALLY MEASURED AIR 

CONCENTRATION OF 8.94 DPM/M3 THAT WAS REDUCED MORE THAN 42-FOLD 

TO A “MODELED AIR CONCENTRATION” REPRESENTS A MAJOR ERROR AS 

THE STARTING POINT FOR DERIVING INTERNAL DOSE FOR THE INHALATION 

AND INGESTION AND FOR ALL YEARS FROM 1950 TO 1995. 

NIOSH Response: NIOSH agrees that the air samples taken in July of 1949 were collected after 

uranium rolling operations ceased and not during actual operations (even though the report states 

that it was taken during operations). The purpose of the visit was to evaluate the adequacy of the 

decontamination efforts that had already taken place. Therefore there is no need to settle an 

operational air concentration to calculate a residual surface contamination level and then 

resuspend that residual surface contamination level to estimate the starting residual air 

contamination levels. NIOSH considers the 1949 air samples itself representative of the start of 

the residual period and will revise the site profile to use 8.49 dpm/m3

as the starting point for the 

residual period. 

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. 
Response Paper: Responses to SC&A Review of DCAS-PER-045, Aliquippa Forge TBD Revision 

Page 5 of 6 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor.

FINDING #6. INAPPROPRIATE USE OF THE RESUSPENSION FACTOR 1×10-6 M-1

FOR POST-AEC WORK, BUT NEVERTHELESS ACTIVE OPERATIONS AT THE 

ALIQUIPPA FORGE FACILITY AS SPECIFIED IN THE FOOTNOTE OF TABLE 5-1 

IN ORAUT-OTIB-0070. 

NIOSH Response: As noted in FUSRAP report (SRDB 6325), a major decontamination effort 

was performed and was completed in 1950. In addition, as SC&A noted in its discussion of 

Finding #2, the contamination identified was overwhelmingly fixed contamination, not 

removable. Therefore, NIOSH feels that the re-suspension factor of 1×10-6 m

-1 for post-AEC 

work is consistent with the stated guidance and ORAUT-OTIB-0070. 

FINDING #7. NIOSH’S CHOICE OF THE 1992 SURVEY MEASUREMENT OF 350 

DPM/100 CM2 REMOVABLE ALPHA CONTAMINATION IS COMPROMISED BY 

THE FACT THAT IT POST-DATES THE “INTERIM DECONTAMINATION 

EFFORTS” CONDUCTED FROM OCTOBER TO DECEMBER 1988. 

NIOSH Response: The 1978 FUSRAP survey (SRDB 6325) reported the maximum smear result 

as 80 dpm/100cm2. Because this was performed prior to the 1988 interim remedial activities, it 

can be compared to the calculated 1978 residual annual internal intakes in ORAUT-TKBS-0021 

Rev 01 to verify the impact of back-extrapolating a post-remediation result to prior years. The 

1978 intake rate was 0.202 pCi/day. This would correspond to an air concentration of 0.0681 

dpm/m3. Applying the re-suspension factor of 1x10-6 m-1 to calculate the associated surface 

contamination levels, this results in a surface contamination level of 681 dpm/100cm2. Because 

this value exceeds the actual contamination levels prior to the 1988 interim remedial activities, 

NIOSH feels that the approach of back-extrapolating the maximum 1992 survey measurement to 

be bounding and favorable and not impacted by the 1988 interim remedial activities. 

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. 
Response Paper: Responses to SC&A Review of DCAS-PER-045, Aliquippa Forge TBD Revision 

Page 6 of 6 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor.

FINDING #8. NIOSH’S METHODOLOGY FOR DERIVING INTERNAL INHALATION 

AND INGESTION DOSE DOES NOT COMPLY WITH THE USE OF AVAILABLE 

DATA AND THE PRIORITIZATION OF RECOMMENDED METHODS DEFINED IN 

ORAUT-OTIB-0070, REV. 01. 

NIOSH Response: NIOSH believes that there are two errors in the methodology. The first error 

is the incorrect conversion of dpm to pCi for the ingestion intakes, as indicated in the response to 

Finding #3. Secondly, the misinterpretation of the 1949 air samples as an operational air sample, 

not a post clean up air sample, as indicated in the response to Finding #5. 

In addition, SC&A’s recommendation that a source-term depletion factor of 0.00067 d-1 should 

be used over the calculated source-term depletion factor of 0.00012 d-1 in ORAUT-TKBS-0021 

Rev 01 would only result in less-favorable exposure estimates. Therefore, NIOSH believes that 

the methodology in ORAUT-TKBS-0021 Rev 01 does comply with the use of available data and 

the prioritization of recommended methods defined in ORAUT-OTIB-0070 Rev. 01 and results 

in favorable exposure estimates, as indicated by the responses to the previous seven findings. 

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.