Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

SC&A’s Review of the NIOSH Document Issued March 3, 2016, 

Titled, Discussion of Ames Laboratory TBD Findings on 

External Dose 

Contract No. 211-2014-58081 

SCA-TR-2016-SP007, Revision 0 

Prepared by

Rose Gogliotti

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

June 2016 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

SC&A’s Review of the NIOSH Document Issued March 3, 2016, 

Titled, Discussion of Ames Laboratory TBD Findings on External 

Dose

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SP007 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: June 28, 2016

TASK MANAGER: Hans Behling [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file] 

DOCUMENT 

REVIEWER(S): Hans Behling [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 06/28/2016 Initial issue
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TABLE OF CONTENTS

1.0 Introduction and Background ............................................................................................. 5

2.0 Findings Related to Environmental Exposures Associated with the Operation of the 

Synchrotron......................................................................................................................... 5

2.1 NIOSH Response .................................................................................................... 5

2.2 Analysis of Proposed Solution................................................................................ 6

3.0 Finding 21 Issues Resolution.............................................................................................. 7

3.1 NIOSH Response .................................................................................................... 7

3.2 Analysis of Proposed Solution................................................................................ 7

3.2.1 Uranium Production Period Annual Doses, 1942–1945............................. 7

3.2.2 Post-Uranium Production Period Annual Doses, 1946–1952..................... 8

4.0 Finding 22 Issues Resolution............................................................................................ 10

4.1 NIOSH Response .................................................................................................. 10

4.2 Analysis of Proposed Solution.............................................................................. 10

5.0 References......................................................................................................................... 11
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ABBREVIATIONS AND ACRONYMS

AEC Atomic Energy Commission

ALRR Ames Laboratory Research Reactor

CTW construction trade worker 

dpm/m3

 disintegrations per minute per cubic meter 

EE energy employee

Electro Met Electro Metallurgical Company

ER evaluation report 

mrem millirem

NIOSH National Institute for Occupational Safety and Health

pCi picocurie 

SEC Special Exposure Cohort 

TBD technical basis document
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1.0 INTRODUCTION AND BACKGROUND

In response to SC&A’s 2013 review of ORAUT-TKBS-0055, Site Profile for Ames Laboratory, 

Revision 03 (ORAUT 2012; hereafter referred to as the “Ames technical basis document” or 

“TBD”), the National Institute for Occupational Safety and Health (NIOSH) issued Discussion of 

Ames Laboratory TBD Findings on External Dose, Revision 0, dated March 3, 2016 (NIOSH 2016). 

This report addressed 5 of the 22 findings in SC&A 2013: Findings 3, 4, 5, 21, and 22. A shared 

feature of these findings is that they pertain to external dose. Eleven findings from SC&A’s review of 

the TBD (SC&A 2013) were previously addressed by NIOSH’s report, NIOSH Response to SC&A 

Review of the Ames Site Profile Document Regarding Uranium Internal Exposures, Revision 0, dated 

July 29, 2015 (NIOSH 2015b). NIOSH has not yet responded to the remaining six SC&A 2013 

findings. 

2.0 FINDINGS RELATED TO ENVIRONMENTAL EXPOSURES 

ASSOCIATED WITH THE OPERATION OF THE SYNCHROTRON

2.1 NIOSH RESPONSE

In Section 2.0 of its response (NIOSH 2016), NIOSH responded to the following findings:

Finding #3: NIOSH’s selection of personnel at the ALRR Facility as the target 

population is inappropriate and results in dose estimates that are not claimant 

favorable. At a minimum, survey data/dose rates cited in Exhibit 4-2, which 

reflect Synchrotron fenceline measurements, should be considered.

Finding #4: NIOSH’s selection of data from the 1961 survey conducted at the 

Synchrotron Facility defines fenceline dose rates that are 1 to 2 orders of 

magnitude lower than other measurements reported in the survey when beam 

direction was shifted from westerly to easterly direction. For bounding estimates 

of environmental doses, fenceline data cited in Exhibit 4-3 should be considered.

Finding #5: SC&A concludes that the 1961 survey measurements, which were 

limited to gamma dose rates, were therefore incomplete and may have 

substantially underestimated total exposure by excluding the contribution of 

particulate radiation.

NIOSH stated that the ambient external dose values from the Ames TBD will be eliminated,

because the data currently available are limited. When there are insufficient individual 

monitoring data to complete a dose reconstruction, external coworker doses will be used.

NIOSH expanded on this response in Section 6.0 of the NIOSH 2016 external dose response:

For Ames, the ambient external dose should be considered the minimum dose to 

be assigned to an unmonitored worker from exposure to any source on site. The 

definition in TBD section 4.0 should be clarified and be consistent with 

instructions in section 6.3.1.2. That change should resolve some of the issues 

raised by SC&A. However, SC&A also had comments on the TBD’s estimate of 

dose rates at the Synchrotron facility perimeter fence...
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The selected data and method used in the TBD to estimate ambient doses at the 

Synchrotron boundary are arguable, and there does not appear to be a clear 

resolution to SC&A’s Findings 4 and 5 using the 1961 data....

In lieu of sufficient ambient dose data, 50th percentile coworker dose should be 

assigned to bound ambient dose for unmonitored workers for all years. Thus, all 

unmonitored workers should be assigned either the 50th percentile dose or the 

95th percentile coworker dose, as specified in TBD section 6.3.1.2. These 

changes will be included in a TBD revision. [Emphasis added.]

2.2 ANALYSIS OF PROPOSED SOLUTION

SC&A acknowledges that replacing the ambient dose with coworker dose is more claimant 

favorable than the model presented in the Ames TBD. SC&A’s review of the Ames TBD (SC&A 

2013) had no findings related to the unmonitored dose. SC&A accepts NIOSH’s proposed 

approach as favorable for energy employees (EEs) who worked at the main campus, but SC&A 

can find no justification for why it might be technically appropriate to apply unmonitored dose 

from the chemistry facilities to workers at the Synchrotron. It appears that some Synchrotron 

badge readings were incorporated into the coworker dose; however, most weekly Synchrotron 

dosimetry was omitted from the modelling. These facilities were located roughly 1.5 miles apart 

and performed very different research functions, such that the unmonitored dose at the facilities 

should not be representative of dose at the Synchrotron. It is unclear if Synchrotron workers 

spent all their time at that facility, or if they also worked at the main campus.

As was indicated in SC&A’s Review of the NIOSH Document Issued July 29, 2015, Titled, 

NIOSH Response to SC&A Review of Ames Site Profile Document Regarding Uranium Internal 

Exposure (SC&A 2015), the reported “background” 0.5–1 millirem per hour at the Synchrotron

facility (Ames 1961) was significantly larger than the national average (311 millirem per year). 

This would translate to a dose of 1–2 rem per year, assuming a 2,000-hour work year. In the 

Ames TBD NIOSH states, “apparently the background reading was taken near the synchrotron 

when the radiation level was slightly elevated above the normal background level.” Film 

dosimetry records from Synchrotron workers in 1952–1954 report weekly doses in the range of 

0–36 milliroentgen (Ames 1954a and 1954b). All of these doses are reported at levels that are 

below the detection limits of the film dosimeters used at the time. Although all Synchrotron 

workers should have been monitored for external exposure, accounting for missed dose, the 

minimum dose an EE should be assigned is 1 rem.

Additionally, replacing the ambient dose with unmonitored dose does not address the time period 

1949–1952. These years do not have monitoring records available to develop a coworker model, 

and no Synchrotron workers were monitored for external exposures before 1952.
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3.0 FINDING 21 ISSUES RESOLUTION

3.1 NIOSH RESPONSE

Finding 21 from SC&A’s 2013 review of ORAUT-TKBS-0055 (SC&A 2013) states:

Finding #21: SC&A’s concerns about the use of the same surrogate data sources 

and questionable assumptions for deriving external dose for Ames’ workers 

exposed to uranium closely parallel those related to uranium intakes as cited in 

Findings #10 and #13.

NIOSH responded to Finding 21 in Section 2.0 of NIOSH 2016:

NIOSH recommends changes to the surrogate dose data in the TBD, as discussed 

in section 5.3. As noted in related Finding #13, SC&A also questions the 

sufficiency of providing multiple building and multiple job category levels of 

exposure for external dose during the uranium production years. Based on review 

of available information on work locations for claimants, job categories, and the 

nature of work evolutions at the Ames facilities during the uranium production

years of 1942 through 1945, NIOSH is proposing a simpler approach that should 

be favorable to claimants and that can be implemented consistently.

For the years 1946–1952, NIOSH proposed the following change in Section 5.3:

External dose from uranium contamination is derived from the median Type S 

uranium intake of 6,932 pCi/day ([NIOSH 2015b]). This production era calendar 

day intake rate was derived from Ames bioassay data during uranium operations. 

An air concentration correlating to that intake rate was estimated by assuming an 

annual inhalation volume of 2,400 m3

. This results in an air concentration of 

2,340 dpm/m3

. An estimate of surface contamination was made using the methods 

specified in Battelle-TBD-6000 section 3.4.2. These assumptions provide a 

contamination level of 4.55 x 106 dpm/m2

. The dose rate factors from BattelleTBD-6000, Table 3.10, were then used to estimate a photon dose of 0.004 rem per 

year and a beta dose of 0.042 rem per year based on a 48 hour work-week.

3.2 ANALYSIS OF PROPOSED SOLUTION

3.2.1 Uranium Production Period Annual Doses, 1942–1945

NIOSH proposed replacing the surrogate data in the TBD with the coworker external doses from 

the Electro Metallurgical Company (Electro Met). The Electro Met data are more representative 

of potential exposures to uranium production workers at Ames than what is currently provided in 

the Ames TBD. The surrogate data come from Electro Met dosimeters worn June 1948 through 

September 1949. During these years, Electro Met’s uranium production facility used the “Ames 

process” to reduce uranium tetrafluoride (UF4) to uranium metal ingots (NIOSH 2015a). The 

Electro Met plant was built to mirror the Ames production process, and Electro Met engineers 

made trips to Ames in 1942 and 1943 to build their facility to mimic the process at Ames. 
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Although some minor process differences can be noted during early development work at Ames, 

overall surrogate dosimetry data from Electro Met make it an ideal candidate site to develop a 

surrogate model for Ames Laboratory during its uranium production period. 

Table 1. Proposed Uranium Production Period Annual Doses, 1942–1945 

Operators

Whole body, photons 4.403 rem 

Non-penetrating, skin of whole 

body 

44.03 rad 

Non-penetrating, hands and 

forearms

276 rad 

Administrative Workers

Whole body, photons 1.356 rem 

Non-penetrating, skin of whole 

body 

13.56 rem 

Source: Table 2 of Ames 2016. 

NIOSH’s response specifically defines “operator” as “anyone involved with research, 

production, labor, maintenance, or any non-administrative type of work.” Administrative 

workers “should be applied to secretaries, security personnel, managers, or other office 

personnel.” Administrative workers are workers that level of dose will allow for intermittent 

exposure in the production areas under the presumption that they could have intermittent 

exposure for a significant amount of time. 

SC&A recommends these definitions be expanded to include reference to construction 

trade workers (CTWs). Under the current definitions, CTW occupations could reasonably be 

interpreted to fall into both categories. Based on Attachment B of the NIOSH response, 5 of the 

15 workers referenced in Table B1 would fall into this category (NIOSH 2016). Provided the 

terms “operator” and “administrative worker” are adequately defined in the proposed revision 

such that there is no ambiguity for dose reconstructors, SC&A finds this approach appropriate 

for the years 1942–1945. Ames’ uranium production operations ceased by the end of 1945; other 

operations continued in Annex I and Annex II. After production ceased, surrogate data from 

Electro Met are no longer appropriate. 

3.2.2 Post-Uranium Production Period Annual Doses, 1946–1952 

The NIOSH response essentially proposes two intake models based on the EEs’ employment. 

The first, “Uranium Facility Workers,” is identical to the “Administrative category” workers 

from the 1942–1955 model. The “Uranium Facility Workers” dose model is to be applied to any 

worker in the Chemistry Building, Annex I, or Annex II, or to workers whose work locations 

cannot be determined. The second model, “Other Workers,” uses the median uranium intake 

distribution from NIOSH 2015b to estimate likely dose from surface contamination. The “Other 

Workers” category is for “all other workers, or for workers who had only occasional entries in 

those three facilities.” 
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Table 2. Proposed Post-Uranium Production Period Annual Doses, 1946–1952 

Uranium Facility 

Workers

Whole body, photons 1.356 rem

Non-penetrating, skin whole 

body

13.56 rem

Other Workers

Whole body, photons 0.004 rem

Non-penetrating, skin whole 

body

0.042 rem

Source: Table 3 of Ames 2016. 

SC&A agrees the model provided is appropriate for low- and medium-category workers; 

however, it does not appear to be claimant favorable for high-category workers. These categories 

are defined in NIOSH 2015b as: 

High (Assign 95th percentile intakes) – Individuals who operated the process 

equipment and/or routinely handled radiological materials. This category would 

include operators, maintenance workers, laboratory workers, health physics 

monitors, etc. Doses will be applied as a constant. 

Medium (Assign 50th percentile intakes) – Individuals who routinely worked in 

the production areas and may have been periodically in the vicinity of where 

processing was occurring. This includes supervisory staff, engineers, individuals 

who were not normally in contact with the radiological materials but who worked 

routinely in the production areas, etc. Doses will be applied as a lognormal 

distribution. 

Low – This category is for individuals exposed to ambient air in the environment 

outside of the uranium production areas who may have been incidentally exposed. 

This includes office workers or non-uranium workers who are documented to 

have been in a different location from the uranium work. These intakes allow for 

incidental exposures and will be applied as a constant. 

SC&A previously reviewed the uranium intake values presented in NIOSH 2015b. The values 

from Table 2 are based on the production model and the 50th percentile inhalation model; 

however, workers who operated the process equipment and/or routinely handled radiological 

materials were exposed to high levels of contamination. It is unclear that “Administrative” dose 

from production years bounds external dose to workers exposed to uranium during 1946 through 

1952. Although most production ceased in 1945, it appears there was still the potential for some 

workers to receive higher levels of exposure. Also, it is not known if, or when, these facilities 

were decontaminated. 

Restricting external exposure to the low- and medium-category workers is also not consistent 

with the dose reconstruction assumptions applied to internal exposure from these same years 

(NIOSH 2015b). Guidance on internal dose recommends the following (NIOSH 2015b, 

page 14): 
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To allow for potential intakes of uranium after the end of 1945, the production 

era intake rates are to be applied through 1953 for the Chemistry Building, 

Annex 1 and Annex 2.

This guidance allows the higher category worker to be assigned 95th percentile intakes. SC&A 

recommends that NIOSH consider a higher external dose category for workers who may have 

been involved in ongoing production activities.

4.0 FINDING 22 ISSUES RESOLUTION

4.1 NIOSH RESPONSE

Finding 22 from SC&A’s 2013 review of ORAUT-TKBS-0055 (SC&A 2013) states:

Finding #22: Given the availability of highly credible and site-specific data for 

deriving external doses from thorium exposure, NIOSH’s decision to exclude said 

exposure/doses is not justified.

NIOSH responded to Finding 22 as follows:

In the designation for the SEC class added via petition SEC-00185, the Secretary 

of Health and Human Services determined certain external doses cannot be 

reconstructed with sufficient accuracy from 1942 through 1954 (Sebelius, 2011). 

SC&A suggested radiation surveys taken in March 1952 are sufficient for 

estimating doses from 1942 – 1952. NIOSH does not consider those results 

sufficient to characterize external radiation exposures from thorium production, 

as indicated in the Evaluation Report for SEC-00038 (NIOSH, 2006). 

Additional review by NIOSH for this finding indicates some limited gamma dose 

results are available from film badges in late 1952, but these were reportedly for 

some Synchrotron workers. Regular dosimetry for beta-gamma exposures began 

at Ames Laboratory in 1953. Thorium production ended in April 1953. 

NIOSH has compiled dosimeter results and considers the available beta-gamma 

dosimetry data sufficient to use for unmonitored doses starting in 1953. Some 

neutron dosimeter data are available starting in 1954, and NIOSH intends to use 

that data to assign unmonitored dose for workers potentially exposed to neutrons 

starting in 1954.

4.2 ANALYSIS OF PROPOSED SOLUTION

The Special Exposure Cohort (SEC)-00185 petition evaluation report (ER) (NIOSH 2011) did 

not evaluate the ability to reconstruct external exposures from thorium for 1942–1952; instead, it 

deferred to a recommendation made in the SEC petition ER for SEC-00038 (NIOSH 2006). That 

ER did not attempt to evaluate external beta and gamma exposure from thorium and its progeny,

because it previously determined source term information was not adequate to reconstruct 

internal doses. SC&A reviewed this SEC ER in 2006 but did not evaluate the possibility of using 

the 1952 Atomic Energy Commission (AEC) study (Klevin 1952) to estimate external dose.
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SC&A does acknowledge that the SEC-00185 ER (NIOSH 2011) found that limited information 

was available on claimant-specific work locations, such that NIOSH was unable to eliminate a 

specific worker from potential exposure scenarios based on his or her assigned work location. 

This was the basis for the SEC class being granted that extended the Ames SEC classes already 

in effect to include all work locations. However, if it can be reasonably determined that an EE 

worked in a thorium area, a minimum exposure can easily be determined.

SC&A argues that external thorium exposures can be reasonably estimated by using the 1952 

study results for non-presumptive cancers (Klevin 1952). The current approach denies EEs who

worked in thorium areas with non-presumptive cancers (most notably skin cancers) an 

accounting of their external exposures despite the availability of task-specific thorium dose rate 

measurements. The lack of precise knowledge of the source term age is not necessary to 

reasonably estimate potential external exposures.

5.0 REFERENCES

Ames 1954a. External Exposure Results 1952–1954, Iowa State University, Ames, Iowa. [SRDB 

Ref. ID 18821]

Ames 1954b. Weekly Exposure and Film Badge Dosimetry Data 1953–1954. [SRDB Ref. ID 

18822]

Ames 1961. “Synchrotron Building Radiation Survey,” U.S. Atomic Energy Commission, Iowa State 

University, Ames, Iowa. May 16, 1961. [SRDB Ref. ID 25766]

Battelle 2011. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, BattelleTBD-6000, Revision 1, Battelle Pacific Northwest National Division, Richland, Washington. 

June 17, 2011.

Christofano and Harris 1960. E. Christofano and W. B. Harris, “The Industrial Hygiene of Uranium 

Refining,” Archives of Environmental Health, volume 1, pp. 438–460, November 1960. [SRDB Ref.

ID 15774]

Klevin 1952. Paul B. Klevin, Occupational Exposures to Thorium and Beryllium, AMES-1, U.S. 

Atomic Energy Commission (AEC), New York Operations Office, Health and Safety Division, New 

York, New York. July 14, 1952. [SRDB Ref. ID 18942]

Martin, J.B., 2006. “Unbadged Workers at the Synchrotron,” E-mail to D.B. Shipler (Pacific 

Northwest National Laboratory), Dade Moeller & Associates, Richland, Washington. November 1, 

2006. [SRDB Ref. ID 29256]

NIOSH 2006. SEC Petition Evaluation Report, Petition SEC-00038, Revision 0, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. April 10, 2006.

NIOSH 2011. SEC Petition Evaluation Report, Petition SEC-00185, Revision 1, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. July 14, 2011.

NIOSH 2015a. Technical Basis Document of the Electro Metallurgical Company, Revision 01, 

Division of Compensation Analysis and Support, Cincinnati, Ohio. September 24, 2015.
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NIOSH 2015b. NIOSH Response to SC&A Review of the Ames Site Profile Document Regarding 

Uranium Internal Exposures, Revision 0, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. July 29, 2015.

NIOSH 2016. Discussion of Ames Laboratory TBD Findings on External Dose, Revision 0, Division 

of Compensation Analysis and Support, Cincinnati, Ohio. March 3, 2016.

ORAUT 2012. Site Profile for Ames Laboratory, ORAUT-TKBS-0055, Revision 03, Oak Ridge 

Associated University Team, Cincinnati, Ohio. January 3, 2012.

SC&A 2006. Review of the Ames Laboratory Special Exposure Cohort (SEC) Petition, 

SEC-00038, SCA-SEC-TASK5-0031, SC&A, Inc., Vienna, Virginia. June 5, 2006

SC&A 2013. Review of the NIOSH Site Profile for the Ames Laboratory, Revision 0, SCA-TRSP2013-0044, S. Cohen and Associates, Vienna, Virginia. August 14, 2013.

SC&A 2015. SC&A’s Review of the NIOSH Document Issued July 29, 2015, Titled, NIOSH response 

to SC&A Review of Ames Site Profile Document Regarding Uranium Internal Exposure, Revision 0, 

S. Cohen & Associates, Vienna, Virginia. September 8, 2015.

Sebelius 2011. HHS Designation of Additional Members of the Special Exposure Cohort under the 

Energy Employees Occupational Illness Compensation Program Act of 2000, Designating a Class of 

Employees from Ames Laboratory at Iowa State University, Ames, Iowa. October 18, 2011. [SRDB 

Ref. ID 141455]