Review of NIOSH’s Program Evaluation 

Report DCAS-PER-067, “Allegheny 

Ludlum Appendix Q Revision”

Amy Mangel, MS, CHP, SC&A, Inc.

Advisory Board on Radiation and Worker Health, 

Subcommittee for Procedure Reviews

November 16, 2023
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DCAS-PER-067 purpose

Address the impacts of issuing revision 1 of Appendix Q to 

Battelle-TBD-6000 (TBD-6000) for Allegheny Ludlum Steel Plant 

(AL) on previously completed cases
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AL background

 AL rolled solid uranium rods for AEC in 1951 and 1952

 Additional metalworking activities included straightening, lathe 

work, cutting with shears, and stamping

 Total of 16 discrete rolling campaigns

 A salt bath furnace was introduced December 1, 1951

– reduced oxidation of the uranium

– reduced the amount of airborne uranium
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AL timeline

 EEOICPA covered period from 1951 to 1952

 No residual period after 1952
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Observation 1

Incorrect date for end of Atomic Weapons Employer (AWE) 

operational period

 When discussing the lack of a residual period, section Q.6 of 

Appendix Q, rev. 1, appears to incorrectly give the date of the 

end of operations as 1951 when it should be 1952.
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Subtask 1: Changes necessitating PER

 Revision 1 of Appendix Q eliminated job categories so that the 

same estimate is used for all employees

 More details about rolling campaigns included in revision 1

 Inhalation intakes increased for many of the former job 

categories

 Ingestion intakes and external dose estimates increased for all 

former job categories
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Subtask 2: Assess corrective action methods

 SC&A’s review of PER-067 focused on the changes in rev. 1 of 

Appendix Q

 The review included an evaluation of Appendix Q guidance on 

internal and external dose reconstruction

– Neither version of Appendix Q had been previously evaluated by SC&A
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Additional rolling campaign information

 NIOSH located additional dates and information for uranium 

rolling campaigns in 1951 and 1952

– Rolling campaign information is summarized in table Q.1 of 

Appendix Q, revision 1
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SC&A comments on rolling campaigns

 Table Q.1 of Appendix Q states that the first rolling campaign 

on January 20, 1951, rolled 25 ingots

 SC&A reviewed SRDB document 10885 and found information 

to suggest that a total of 40 ingots were rolled on this campaign

 Dose estimate calculations in Appendix Q are based on air 

concentration data and are not dependent on the number of 

ingots rolled on a given workday, so this potential discrepancy 

does not affect the dose estimates
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Observation 2

Discrepancy in the number of ingots rolled during 

January 20, 1951, campaign

 There appears to be a discrepancy in the number of ingots 

rolled during the first rolling campaign. However, it is SC&A’s 

understanding that this does not affect the intake estimates.
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Uranium air concentration data

Pre-salt-bath time period

 Before 12/1/1951

 Based on air monitoring data 

from rolling campaigns on 

1/21/1951 and 7/22/1951

 Geometric mean (GM) of 

291 dpm/m3

Post-salt-bath time period

 12/1/1951 and after

 Based on air monitoring data 

from one rolling campaign on 

2/9/1952

 GM of 20.5 dpm/m3
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Calculating inhalation intakes

 Job categories eliminated, inhalation intake rate the same for 

all workers

 NIOSH assumed 8.8-hour workday

 For non-rolling days, NIOSH assumed the higher airborne 

activity concentration of 291 dpm/m3 was allowed to deposit for 

30 days at a rate of 0.00075 m/s, with a resuspension factor of 

1E-05. 
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SC&A comments on inhalation intakes

 Confirmed that inhalation intake rate is not dependent on claimant’s 

job title

 Unclear how inhalation intakes would have been assigned using 

rev. 0 of Appendix Q; therefore, it is difficult to determine if the 

inhalation intakes using rev. 1 are, in fact, higher for most of the 

former job categories

 SC&A able to match NIOSH’s calculations for the GM uranium air 

concentrations

 SC&A also confirmed NIOSH used the guidance from section 3.4.2 

of TBD-6000 to calculate deposited surface contamination
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Consistency with air concentration data

SC&A searched for other AWE sites with a similar operational 

history as AL to determine if uranium air monitoring data are used 

consistently between similar AWE sites

 Bliss and Laughlin Steel is a similar site
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Uranium air concentration data – comparison 

to Bliss and Laughlin

 Bliss and Laughlin (BL) also performed uranium rod machining and 

straightening from 1951 to 1952

– Appendix D of TBD-6000

 Appendix D analyzed 13 breathing zone (BZ) samples and 7 

general area air samples for intake calculations

– GM of 2,602 dpm/m3

 GM of 2,602 dpm/m3 much lower than 5,480 dpm/m3 from TBD6000, table 7.5

 Because of the limited number of air samples, NIOSH used the air 

concentration from TBD-6000 to determine inhalation and ingestion 

intakes for BL, as it was determined to be more claimant favorable
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Representativeness of AL air monitoring data

 Smaller proportion of AL air monitoring samples were BZ

– 5 out of 43 samples in 1951 

– 0 out of 48 samples in 1952

 Unclear if available samples represent the full range of uranium 

air concentrations encountered by AL workers

 AL values of 291 dpm/m3 and 20.5 dpm/m3 are significantly 

lower than values in TBD-6000 and those used for BL
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Observation 3

Inconsistency with NIOSH’s approach to calculating uranium 

intakes from air sampling data

 The methods to utilize air sampling data for the purpose of 

reconstructing uranium intakes are different between two 

uranium rolling sites (AL and BL)

 SC&A requests clarification on the different approaches
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Calculating ingestion intakes

 PER-067 states ingestion intakes in rev. 1 increased for all 

former job categories

 NIOSH used OCAS-TIB-009 to calculate ingestion intakes

– Stated that this approach would likely overestimate the actual ingestion 

intake, as TIB-009 assumes operations occurred often enough for 

airborne contamination levels to reach a maximum

 NIOSH calculated an ingestion intake of 39.9 dpm/calendar 

day

– Used air concentration of 291 dpm/m3, factor of 0.2 from TIB-009, and 

converted to per calendar day
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SC&A comments on ingestion intakes

 Confirmed rev. 1 ingestion intakes are higher than those for 

various job categories in rev. 0

 0.2 adjustment factor from TIB-009 assumes an 8-hour work 

day

– AL inhalation intake calculations assume an 8.8-hour work day

– SC&A believes ingestion and inhalation intake assumptions should be 

consistent

 Correcting for an 8.8-hour work day results in a 

1.7 dpm/calendar day increase in ingestion intake rate
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Observation 4

Assumed work day length for ingestion calculations 

inconsistent with assumed work day length for inhalation 

calculations

 TIB-009 factor is based on an 8-hour day and that it would be 

appropriate for consistency to modify the TIB-009 factor to the 

8.8 hours per day assumed for AL

 However, the slightly lower calculated intake is offset by the 

other conservative assumptions in the ingestion model
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External dose estimate

 PER-067 states external dose estimates increased in rev. 1

 No external dosimetry records found for AL

 Rev. 1 uses TBD-6000 to estimate external dose at AL from U metal

– Assumes operators exposed to TBD-6000 1-foot dose rates 50% of the time

– Assumes hands and forearms exposed to TBD-6000 contact dose rates 50% 

of the time

 Also includes external dose from deposited residual contamination

– Uses conversion factors from TBD-6000, workers exposed 100% of each 

work day
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SC&A comments on external dose

 Confirmed that external dose increased in rev. 1

 Confirmed NIOSH used the 1-foot photon dose rate from a 

rectangular ingot from TBD-6000, table 6.1

– Assumed the beta dose rate is 10 times higher, per section 6.3 of TBD-6000

 Confirmed the contact beta dose rate came from section 6.3 of 

TBD-6000

 Confirmed the assumed fractions of time workers exposed to 1-foot 

and contact dose rates from metal are consistent with TBD-6000 

guidance

 Confirmed the calculations for exposure to deposited contamination

– Used factors from table 3.10 of TBD-6000 and assumed workers exposed for 

8.8-hour days
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Occupational medical dose

 No information specific to AL was found in rev. 1 of Appendix Q

 Unchanged guidance to refer to ORAUT-OTIB-0006, rev. 04, 

for assigning occupational medical dose in dose 

reconstructions

 SC&A agrees with the guidance to use OTIB-0006 in the 

absence of AL-specific information
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Subtask 3: PER selection criteria

 All completed claims with verified employment at AL with a 

probability of causation (POC) less than 50%

– 26 claims

 One claim used rev. 1 of Appendix Q already and was removed 

from further evaluation

– 25 claims
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NIOSH’s evaluation of impacted claims

25 claims reevaluated using rev. 1 of Appendix Q

 23 claims POC below 45%

 2 claims POC greater than 52%

 NIOSH requested the return of the 2 claims from 

U.S. Department of Labor
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Subtask 4: Audit of reevaluated DRs

SC&A recommends that the Board select two cases of the 25 

evaluated by NIOSH 

1. One case involving a worker whose employment includes 

rolling campaigns with and without a salt bath

2. One case involving a worker whose previous job category 

(such as administrative) in the old dose reconstruction (DR) 

led to a lower intake
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Questions?