Draft Report 

A FOCUSED REVIEW OF THE NORTON COMPANY SEC 

PETITION EVALUATION REPORT SEC-00173 CONCERNING 

THE USE OF ORAUT-OTIB-0070 FOR THE 

RECONSTRUCTION OF DOSES FROM 

RESIDUAL/POST-OPERATIONAL CONTAMINATION 

Contract No. 200-2009-28555 

Prepared by 

U. Hans Behling, PhD 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

July 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 pre-decisional and has not been reviewed by the Board for factual accuracy or applicability 

within the requirements of 42CFR82. 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: 

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

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Document No. 

Focused Review of SEC-00173 

Effective Date: 

 Draft – July 7, 2010 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 0 (Draft) 

A Focused Review of the Norton Company SEC Petition 

Evaluation Report SEC-00173 Concerning the Use of 

ORAUT-OTIB-0070 for the Reconstruction of Doses 

from Residual/Post-Operational Contamination 

Page 2 of 14 

Task Manager: 

______________________________ Date:____________ 

U. Hans Behling, PhD 

Supersedes: 

N/A 

Project Manager: 

______________________________ Date:____________ 

John Mauro, PhD 

Reviewer: 

 William C. Thurber

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 07/07/2011 Initial issue 

08/16/2011 Privacy Act-cleared as written. 
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TABLE OF CONTENTS 

1.0 Relevant Background Information.......................................................................................4 

1.1 A Timeline for the Norton Company.......................................................................4 

1.2 Petition for SEC Status............................................................................................4 

1.3 Availability of Data Used to Define/Limit the Time Period for the Proposed 

SEC Class.................................................................................................................4 

2.0 Dosimetry/Survey Data Used by NIOSH for Dose ReconstructIon During the 

Residual Contamination Period Between October 11, 1962 and October 31, 2009............6 

3.0 Data and Method Selected by NIOSH to Derive Bounding Estimates of Exposure ...........7 

3.1 Internal Exposure.....................................................................................................7 

3.2 External Exposure..................................................................................................10 

4.0 SC&A’s Comments and Associated Findings...................................................................11 

5.0 Summary Conclusions.......................................................................................................13 

6.0 References..........................................................................................................................14 
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1.0 RELEVANT BACKGROUND INFORMATION 

On January 24, 2011, NIOSH issued its Evaluation Report (ER) (NIOSH 2011) in behalf of the 

SEC Petition-00173 for the Norton Company located on New Bond Street, Worcester, 

Massachusetts. Due to the fact that NIOSH employed guidance contained in ORAUT-OTIB0070 in modeling internal and external dose estimates, the Advisory Board (during a full Board 

meeting held on February 23–25, 2011) directed the Subcommittee on Procedures Review to 

look into the use of ORAUT-OTIB-0070 at a time when select issues had not been resolved. In 

response to the Board’s directive, the Subcommittee, on March 22, 2011, requested SC&A to 

conduct a focused review of ER SEC Petition-00173. 

1.1 A TIMELINE FOR THE NORTON COMPANY 

The following provides a timeline for the Norton Company’s operational and post-operational 

periods: 

 Between 1945 and 1957, the Norton Company conducted Atomic Weapons Employer 

(AWE) radiological operations that involved the use of unspecified quantities of UO2, 

U3O8, and thorium. 

 From January 1, 1958, through October 7, 1962, Norton Company employees performed 

tear-down and removal of materials/equipment that had been used in AWE processes. 

 Between October 8 and October 10, 1962, Norton Company employees transported 

decontamination and decommissioning (D&D) wastes to a Norton Company landfill. 

 Following the decommissioning of the AWE operations, Norton Company continued to 

conduct commercial (i.e., non-AWE) thorium operations through 1967 under the Atomic 

Energy Commission (AEC) material license STB-00770. Contamination and resultant 

doses from Norton Company’s commercial thorium activities were not considered in 

NIOSH’s ER. 

1.2 PETITION FOR SEC STATUS 

In Petition SEC-00173, the petitioner requested that NIOSH consider the inclusion of all 

employees who worked at the New Bond Street facility from 1960 through 1972. Based on 

available data for dose reconstruction, NIOSH defined a single SEC class of employees with 250 

work-days for the period between January 1, 1958, and October 10, 1962. 

1.3 AVAILABILITY OF DATA USED TO DEFINE/LIMIT THE TIME PERIOD FOR 

THE PROPOSED SEC CLASS 

Based on the availability/suitability of data needed for dose reconstruction, NIOSH stated the 

following in its ER in behalf of two discrete post-operational time periods: 

 For the Proposed SEC Class that Covers the Post-Operational Time Period of January 1, 

1958, through October 10, 1962
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NIOSH has determined that, although AWE operations were not performed at 

Norton Co. after 1957, Norton Co. performed decontamination and 

decommissioning of AWE materials and wastes from January 1, 1958 through 

October 10, 1962, which potentially exposed Norton Co. workers to internal and 

external radiation. ... 

[However,] NIOSH finds it is not feasible to estimate internal and external 

exposures with sufficient accuracy for all workers at the site from January 1, 

1958 through October 10, 1962, due to decontamination and decommissioning 

activities conducted during that period for which NIOSH has insufficient source 

term and monitoring data to bound potential doses. [Emphasis added.] 

 For the Reconstruction of Worker Doses for the Remaining Portion of the PostOperational/Residual Radiation Period of October 11, 1962, through October 31, 2009, 

NIOSH Stated the Following:

Information available to NIOSH is sufficient to document or estimate the 

maximum internal and external potential exposure to members of the evaluated 

class under plausible circumstances during the period from October 11, 1962 

through October 31, 2009. [Emphasis added.] 
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2.0 DOSIMETRY/SURVEY DATA USED BY NIOSH FOR DOSE 

RECONSTRUCTION DURING THE RESIDUAL CONTAMINATION 

PERIOD BETWEEN OCTOBER 11, 1962 AND OCTOBER 31, 2009 

Due to the fact that no Site Profile has been written for the Norton Company that might provide 

supportive data/information for dose reconstruction, NIOSH identified the following two 

documents used to support dose reconstruction for the residual radioactivity period of October 

11, 1962, through October 31, 2009: 

 Technical Basis Document Battelle-TBD-6000: Site Profiles for Atomic Weapons 

Employers that Worked Uranium and Thorium Metals, Battelle TBD-6000, Rev. F0, 

December 13, 2006. 

 Technical Information Bulletin ORAUT-OTIB-0070: Dose Reconstruction During 

Residual Radioactivity Periods at Atomic Weapons Employer Facilities.

In brief, the ER proposed the use of Battelle-TBD-6000 and ORAUT-OTIB-0070 to support the 

reconstruction of bounding external and internal exposure from residual contamination as 

summarized in Section 3.0. 
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3.0 DATA AND METHOD SELECTED BY NIOSH TO DERIVE 

BOUNDING ESTIMATES OF EXPOSURE 

3.1 INTERNAL EXPOSURE 

The ER identified the following air sampling data used by NIOSH for determining bounding 

estimates for internal dose: 

 From Section 6.1, p. 20 of the ER

Forty-two sample results (short-lived and long-lived alpha-emitters) were 

reported for 21 samples collected on May 13, 1958 by the Massachusetts 

Department of Labor and Industries. Sixteen of the sample results (from eight 

samples) could be associated with the thorium processing area; six of the sample 

results (from three samples) could be associated with the uranium processing 

area. The system’s counting efficiency and MDA are not indicated. Results are 

listed in units of μCi/ml. [Emphasis added.] 

 From Section 7.2.2, p. 27 of the ER

NIOSH evaluated air monitoring data in the form of long-lived gross-alpha 

results obtained on May 13, 1958 (reported on May 28, 1958) by the 

Massachusetts Department of Labor and Industries to derive the air 

concentration starting on October 11, 1962 through the end of the residual 

radiation period, October 31, 2009. The average of the long-lived alpha results 

was calculated from the data shown in Table 7-1 to estimate the starting air 

concentration (4.662 dpm/m3) on October 11, 1962. 

Table 7-1: Air Monitoring Results, Long-Lived Alpha Emitters 

Sample 

Number 

Time 

Sampling 

Complete 

(hours) 

Location 

Long-Lived Alpha 

Emitters 

(μCi/mL) 

Thorium Air 

Concentration 

(dpm/m) 

1M 9.2 End of hood – thoria area 4E-13 – 

7M 2.5 End of hood – thoria area 4E-13 – 

13 2.5 End of hood – thoria area 2E-12 – 

5M 1.15 Thoria processing area 2E-12 – 

3 10 General area on bench 2E-12 – 

7 11.2 Hood – thoria area 1E-12 – 

11 2 Bench near thoria area 2E-12 – 

14 2.5 By glass cutting wheel 7E-12 – 

Average – thoria area samples 2.1E-12 4.662 

Average daily intake rates for inhalation and ingestion were calculated based on 

an inhalation rate of 1.2 m3/hr, 8-hour workday, and 250 workdays per year, 

resulting in a value of 30.654 dpm/day for the period from October 11, 1962 

through December 31, 1963. Intake rates for the following years through 

October 31, 2009 have been adjusted due to source term depletion per guidance 
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NOTICE:

in ORAUT-OTIB-0070 [see Table 7-2 below]. The air monitoring results are 

reported in units of gross alpha and are not isotopic-specific; therefore, the most 

claimant-favorable radionuclide and solubility class will be assigned by NIOSH. 

The Norton Co. processed both uranium oxide and thoria. Because Norton Co. 

processed both uranium and thorium oxides, uranium can be assumed to be 

U-234 (Types M and S) and thorium can be assumed to be Th-232 (Types M and 

S). [Emphasis added.] 

Table 7-2: Intake Rates for Uranium or Thorium 

Applicable Period ORAUT-OTIB-0070 

Adjustment 

Inhalation 

(dpm/day) 

Ingestion 

(dpm/day) Distribution 

01/1958 not feasible not feasible not feasible N/A 

10/11/1962 – 12/31/1963 1 30.654 0.747 Constant 

01/01/1963 – 12/31/1964 0.03 0.920 0.022 Constant 

1965 and later 0.0007 0.021 0.001 Constant 

Note: Not included for discussion herein is NIOSH’s model for bounding internal exposures 

from airborne alpha emitters associated with thoron-220 and its short-lived daughters (see Tables 

7-3 and 7-4 in SEC Petition Evaluation Report SEC-00173). Here too, data for the eight samples 

reported by Pagnotto and Bavley 1958 were used and adjusted using the identical ORAUTOTIB-0070 adjustment factors cited in Table 7-2 above. 

For convenience to the reader and verification of data, data for the eight air samples reported by 

Pagnotto and Bavley 1958 are enclosed below as Exhibit 1. 
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Exhibit 1: Results of Eight Air Samples from Pagnotto and Bavley 1958 
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3.2 EXTERNAL EXPOSURE 

To derive bounding external doses, NIOSH assumed that exposures would have resulted from

residual surface contamination and from immersion of resuspended surface contamination. By 

means of the same eight air samples reported by Pagnotto and Bavley 1958 (see Exhibit 1 above) 

and the methods cited in Battelle-TBD-6000, NIOSH derived post-1962 external doses using the 

following assumptions: 

 In order to determine the feasibility of bounding potential external doses received 

from exposures to residual radiation, NIOSH evaluated air monitoring data 

obtained during the operations period. The 95th percentile of the gross alpha air 

dust results was calculated to estimate the highest contamination levels present 

after the AWE materials had been buried starting on October 11, 1962. It is 

assumed that the material deposited on the floor with a deposition velocity of 

0.00075 m/s from October 11, 1962 through December 31, 1963. This results in 

a maximum contamination level of 1.83×106

 dpm/m2. Using these assumptions, 

daily doses can be calculated based on the maximizing potential radionuclide. 

The external doses are from penetrating photons with energies between 30 and 

250 keV and electron energy range of >15 keV for penetrating exposures. 

Table 7-5 shows the external dose rates for the residual radiation period 

adjusted for source term depletion per the guidance provided in ORAUT-OTIB0070 and Battelle-TBD-6000. ... [Emphasis added]

Table 7-5: External Dose Rates for the Residual Radiation Period 

Applicable Period ORAUT-OTIB-0070 

Adjustment 

Gamma 

(rem/year) 

Beta 

(rem/year) 

01/1958 – 10/10/1962 not feasible not feasible not feasible 

11/11/1962 – 12/1963 1 0.026 0.233 

01/1964 – 12/1964 0.03 0.001 0.007 

1965 onward 0.0007 <0.001 <0.001 
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4.0 SC&A’S COMMENTS AND ASSOCIATED FINDINGS 

For the reconstruction of bounding internal and external dose estimates from residual 

contamination for the period of October 11, 1962, to October 31, 2009, NIOSH employed air 

sampling data taken at the Norton Company on May 13, 1958, and guidance contained in 

Battelle-TBD-6000 and ORAUT-OTIB-0070. 

Finding 1: Both the internal and external dose estimates are based on a single set of air 

samples taken on May 13, 1958, which has limited credibility.

Exhibit 1 above and Table 7.1 of the ER (reproduced herein in Section 3.1) identify the eight air 

samples that form the basis of derived internal and external doses. The credibility of derived 

doses that are based on this data set may be questioned for the following reasons: 

 Limited Number of Air Samples. The Norton Company facility is principally defined by 

Building 112, which the ER describes as “. . . 50,000 square-feet building where Norton 

Company conducted AWE radiological operations from 1945 through 1957.” [Emphasis 

added.] 

 Restricted Air Sampling Time. For the eight air samples, Exhibit 1 identifies air 

sampling times that ranged from 1.15 hour to 11.2 hours. While Exhibit 1 provides no 

specific information regarding air flow rates for this data set, the ER references two other 

air sampling surveys on page 20: (1) 20 liters/minute for air samples collected by the 

Liberty Insurance Company in 1955; and (2) 19.8 liters/minute for air samples collected 

in a 1958 survey also performed by the Liberty Mutual Insurance Company. 

If the flow rate of 20 liters/minute may be assumed to apply to the 8 air samples taken on 

May 13, 1958, then air volumes ranging from 1.4 m3 to 13.4 m3 can be estimated. These 

low air volumes should be compared to conventional volumes of 160 to 320 m3 taken by 

a standard air sampler with a flowrate of 4 ft3

/minute and sampling times of 24 to 

48 hours. 

 No Data are Provided Regarding the Counting Efficiency, Counting Time(s), Background 

Count Rates, or MDA Values for the Analyses of Air Samples. As acknowledged in the 

ER “...The system’s counting efficiency and MDA are not indicated.” Thus, the 

standard error/uncertainty of individual activity levels can not be assessed. For example, 

Exhibit 1 identifies Sample 5M as having an activity level of 0.2 × 10-11

μCi/ml. With 

an air sampling time of 1.15 hours and an assumed airflow of 20 liters/minute, the total 

volume of collected air of ~1.4 m3 would have produced an activity level of 5 dpm on the 

filter. Assuming a 10-minute count and a maximum counting efficiency (i.e., cpm/dpm) 

of 50%, a total observed net count of about 25 would have been expected (or about 2.5 

cpm). 

In the absence of knowing the background count rate, neither the MDA nor the 

standard error of cited activity levels can be estimated in behalf of the eight air 

samples. 
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Finding 2 (Conditional): To derive both external and internal bounding dose estimates, 

NIOSH employed a source term depletion factor that is a simplified version of the default 

value of 0.01 day-1 (or 1% per day) as defined in ORAUT-OTIB-0070. 

Dose estimates from residual contamination used time-dependent adjustment factors of (1) 0.03 

for the year 1964, and (2) 0.0007 for 1965 through 2009 (see Tables 7.2 and 7.5 in the ER and 

reproduced here in Sections 3.1 and 3.2). These adjustment factors represent a simplified 

version of the 0.01 day-1 source term depletion factor recommended in ORAUT-OTIB-0070. 

The use of this default source term depletion factor has been cited by SC&A in its review of 

ORAUT-OTIB-0070 (SC&A 2008) as Finding #2. To date, this finding has not been resolved. 

The adjustment factors cited above in Table 7-2 were based on guidance provided in Table 3-1 of 

OTIB-0070. Table 3-1 is reproduced below with an additional column (K=1E-06/m) added for 

reasons discussed below: 

Table 3-1. Adjustment Factors to Account for Depletion of Source Term during 

Residual Contamination Period 

Year Factor 

(K=8E-05/m) 

Factor 

(K = 1E-06/m) 

1 1 1 

2 0.03 0.96 

3 on 0.0007 0.92 

The factors for year 2 and year 3 in Column 2 are based on a source depletion rate of 1% per day 

(e.g., exp(-0.01*365 = 0.026). The source term is assumed to remain constant after 3 years. The 

depletion rate of 1% per day is calculated in Section 2.6 of OTIB-0070 as follows: 

λ = 24KnH 

 where 

K – resuspension factor (8E-05/m) 

n – air change rate (1/hr) 

H – room height (5 m) 

If the resuspension rate were 1E-06/m as been suggested by NRC for cleaned-up facilities (AbuEid et al. 2002), the source term half-life would be reduced to 1.2E-02%/day and, as shown in 

the 3rd column of Table 3-1, intakes would be substantially higher. 

As SC&A has discussed in the past, use of an exponentially decaying source term is a reasonable 

concept. However, the depletion rate must be based on a resuspension rate, which is consistent 

with site conditions. A one-size-fits-all approach is not scientifically justified and may not be 

bounding. In the case of Norton, a resuspension factor of 1E-06/m seems more appropriate, 

given the clean-up activities undertaken at the beginning of the residual period. This would 

result in higher source term adjustment factors than used in the ER. 
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5.0 SUMMARY CONCLUSIONS 

In its SEC Petition ER for the Norton Company (Petition SEC-00173), NIOSH stated that it has 

sufficient data to bound internal and external doses associated with residual contamination for 

the period from October 11, 1962, through October 31, 2009. SC&A critically evaluated the 

quality and quantity of survey data, as well as applied model parameters used by NIOSH for 

deriving bounding internal and external doses. 

As stated in Finding 1, SC&A concludes that the air sampling data that represent the basis for 

deriving internal and external doses suffer from multiple deficiencies. Deficiencies include 

(1) the limited number of air samples, (2) the restricted number of sample locations, (3) short 

duration(s) of air sampling and (assumed) low air flow rate, and (4) lack of critical data 

surrounding the analyses of air samples (i.e., sample counting times, background count levels, 

counting efficiency, etc.). 

Finding 2 is a conditional finding that centers around the use of the default source term depletion 

factor of 0.01 day-1 (or 1% per day) recommended in ORAUT-OTIB-0070. Use of this default 

has been questioned by SC&A and discussed by the Advisory Board’s Subcommittee on 

Procedures Review. To date, however, use of this source term depletion remains an unresolved 

finding. Use of a source term depletion factor of 1% per day does not appear to be consistent 

with the expected resuspension factors for post-clean-up contamination at Hooker. 
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6.0 REFERENCES 

Abu-Eid, R. M., R. B. Coddell, N. A. Eisenburg, T. E. Harris, and S. McGuire, 2002. Reevaluation 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] 

Battelle-TBD-6000. 2006. Site Profiles for Atomic Weapons Employers that Worked with 

Uranium and Thorium Metals, Rev. F0, Battelle Team Dose Reconstruction Project for NIOSH. 

December 13, 2006. 

NIOSH. 2011. SEC Petition Evaluation Report for Petition SEC-00173 (January 1, 1958 

through October 31, 2009), Norton Company, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. January 24, 2011. 

ORAUT-OTIB-0070. 2008. Dose Reconstruction During Residual Radioactivity Periods at 

Atomic Weapons Employer Facilities, Rev. 00. Oak Ridge Associated Universities Team: 

Cincinnati, Ohio. March 10, 2008. 

Pagnotto, L. and H. Bavley, 1958. Study of Air Samples and Urinalysis Data (From May 13, 

1958 Visit) in Regards to Thoria Handling, correspondence to Harvey Elkins, May 28, 1958.

SC&A. 2008. Review of ORAUT-OTIB-0070: Dose Reconstruction During Residual 

Radioactivity Periods at Atomic Weapons Employer Facilities. SCA-TR-TASK3-0009, Rev. 0. 

SC&A, Inc.: Vienna, Virginia.