Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE NIOSH SITE PROFILE FOR THE W. R. 

GRACE AND COMPANY IN ERWIN, TENNESSEE 

Contract No. 200-2009-28555

SCA-TR-SP2013-0041

Prepared by 

Ron Buchanan, PhD, CHP 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755

January 2013 

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: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

2 of 39 

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. 

Document No. 

SCA-TR-SP2013-0041 

Effective Date: 

Draft – January 16, 2013 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 – Draft 

REVIEW OF THE NIOSH SITE PROFILE 

FOR THE W. R. GRACE AND COMPANY 

IN ERWIN, TENNESSEE 

Page 2 of 39 

Task Manager: 

________________________ Date: ___________ 

Ron Buchanan, PhD, CHP 

Supersedes: 

N/A 

Project Manager: 

________________________ Date: ___________ 

John Stiver, CHP 

Peer Reviewer(s): 

 Joe Fitzgerald 

 John Mauro, PhD, CHP 

Record of Revisions 

Revision 

Number Effective Date Description of Revision 

0 (Draft) 01/16/2013 Initial issue 

02/14/2013 Privacy Act-cleared, 508 compliance version released. Note: One section of 

this report containing the authors’ interpretation of a section of the Code of 

Federal Regulations, which does not affect the intent of this report, has been 

deleted in this version in its entirety. A minor format issue was also addressed 

that does not affect the technical validity of the document. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

3 of 39 

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. 

TABLE OF CONTENTS 

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

1.0 Executive Summary.............................................................................................................6 

1.1 Summary of Primary Findings.................................................................................9 

1.2 Summary of Strengths............................................................................................11 

1.3 Opportunities for Improvement .............................................................................11 

2.0 Scope and Introduction ......................................................................................................13 

2.1 Review Scope.........................................................................................................14 

2.2 Assessment Criteria and Methods..........................................................................15 

2.2.1 Objective 1: Completeness of Data Sources.............................................15 

2.2.2 Objective 2: Technical Accuracy..............................................................15 

2.2.3 Objective 3: Adequacy of Data.................................................................15 

2.2.4 Objective 4: Consistency among Site Profiles..........................................16 

2.2.5 Objective 5: Regulatory Compliance........................................................16 

2.3 Dose Reconstruction under EEOICPA..................................................................16 

2.4 Report Organization...............................................................................................17 

3.0 Vertical Issues....................................................................................................................18 

3.1 ..................................................................................................................18 Findings

3.1.1 Occupational Internal Dose, Section 3 of ORAUT-TKBS-0043...............18 

3.1.2 Occupational External Dose, Section 4 of ORAUT-TKBS-0043 .............25 

3.1.3 Occupational Medical Dose, Section 4 of ORAUT-TKBS-0043..............30 

3.1.4

............................................................................................................31 

Occupational Environmental Dose, Section 6 of ORAUT-TKBS0043

4.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................33 

4.1 Satisfying the Five Objectives...............................................................................33 

4.1.1 Objective 1: Completeness of Data Sources.............................................33 

4.1.2 Objective 2: Technical Accuracy..............................................................34 

4.1.3 Objective 3: Adequacy of Data.................................................................34 

4.1.4 Objective 4: Consistency Among Site Profiles.........................................34 

4.1.5 Objective 5: Regulatory Compliance........................................................34 

4.2 Usability of Site Profile for Intended Purposes .....................................................35 

4.2.1

.....................................................................................35 

Lack of Defined AEC Weapons and Research Activities During 

Operational Period

4.2.2 Lack of Defined Use of Plutonium During Operational Period ................35 

4.2.3 Incomplete Information and DR Recommendations for Neutrons............35 

4.2.4 Location of X-ray Examinations Not Sufficiently Addressed...................35 

4.3 Unresolved Policy or Generic Technical Issues....................................................35 

5.0 References..........................................................................................................................37 

Attachment 1: Site Expert Interview Summary............................................................................39 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

4 of 39 

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. 

ACRONYMS AND ABBREVIATIONS 

Advisory Board Advisory Board on Radiation and Worker Health 

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

BZ Breathing zone 

CDC Centers for Disease Control 

CFR Code of Federal Regulations 

D&D Decontamination and Decommissioning 

DCAS Division of Compensation Analysis and Support 

DHHS U.S. Department of Health and Human Services (DHHS) 

DOE U.S. Department of Energy 

dpm disintegrations per minute 

DR Dose Reconstruction or Dose Reconstructor 

DU depleted uranium 

DWE Daily Weighted Exposures 

EE Energy Employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ERDA Energy Research and Development Agency 

HEU Highly Enriched Uranium 

keV kilo electron volt 

L Liter 

LEU Low Enriched Uranium 

LOD Limit of Detection 

m

2

 square meter 

m3 cubic meter 

MDA Minimum Detectable Activity 

MDL Minimum Detectable Level 

μg Microgram 

MOX Mixed Oxide 

mrem millirem 

mR milli roentgen 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

5 of 39 

 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:

NFS Nuclear Fuel Services 

NIOSH National Institute for Occupational Safety and Health 

n/p neutron-to-photon dose ratio 

NRC Nuclear Regulatory Commission 

NU natural uranium 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team 

OTIB ORAUT Technical Information Bulletin 

pCi picocuries 

POC probability of causation 

rem roentgen equivalent man 

RU recycled uranium 

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

SEC Special Exposure Cohort 

SRDB Site Research Database 

TBD Technical Basis Document 

TIB Technical Information Bulletin 

V&V verification and validation 

WRG W. R. Grace and Company 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

6 of 39 

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. 

1.0 EXECUTIVE SUMMARY 

This report provides the results of a review conducted by S. Cohen and Associates (SC&A) of 

the site profile for the W. R. Grace and Company (WRG), in Erwin, Tennessee, developed by the 

National Institute for Occupational Safety and Health (NIOSH). This review was conducted 

during the period from July 2012–November 2012, in support of the Advisory Board on 

Radiation and Worker Health (Advisory Board) in the latter’s statutory responsibility under the 

Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA) to 

conduct such reviews and advise the Secretary of Health and Human Services on the 

“completeness and adequacy” of the EEOICPA program. 

The site profile for the WRG site consists of one document (with 7 sections), ORAUT-TKBS0043 (ORAUT 2011a). This document will be referred to in this review as the Technical Basis 

Document (TBD). 

In this review, unless specified otherwise, the term “WRG site” will be used to refer to the W. R. 

Grace and Company’s Erwin, Tennessee, site in general, to include the later period when the 

name was changed in 1964 to Nuclear Fuel Services (NFS). This includes all the facilities, 

ponds, burial site(s), and grounds located within the approximate 58 acres, with 21 acres located 

inside the security fence. 

The term “Navy” in this report refers to the WRG/NFS program to supply reactor fuel for use by 

the U.S. Navy. 

The WRG site was constructed in 1957 to convert highly enriched uranium (HEU) and lowenriched uranium (LEU) from UF6 (or to recover uranium from scrap) to a product that met 

customer requirements. Thorium, depleted uranium (DU), U-233, recycled uranium (RU), and 

plutonium have also been processed at various times to oxides or metals with subsequent 

processing into the form necessary for the manufacture of nuclear fuel (ORAUT 2011a). A list 

of some of the important dates at this facility is provided in Table 1 below. 

Table 1. WRG Timeline of Events 

1957: Construction of WRG facilities at Erwin, TN. 

1958–1970: Operational period. WRG processed uranium, plutonium, and thorium for the Atomic Energy 

Commission (AEC) weapons program, AEC research, commercial reactors, and the Navy. 

Which radioactive materials were involved in which programs is not well defined. 

March 1958: WRG received first material as an AEC licensee. 

1958–1978: Ponds 1, 2, 3, and 4 used for liquid waste disposal. 

May 1959: WRG received first material as an AEC contactor. 

1964: Nuclear Fuel Services (NFS) formed from merger of WRG and American Machine and 

Foundry Company. 

October 1964: Uranium bioassays began. 

1965–1970: Southwest Trench used for disposal of solid radioactive waste. 

1966: Plutonium processing began. 

1966–1977 Low-level waste disposed in north burial grounds. 

1971–Present: Residual period. Processing of materials continued for commercial and Navy purposes. No 

material received for weapons. Decontamination and decommissioning (D&D) of some 

buildings. Cleanup of ponds and burial sites. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

7 of 39 

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. 

Table 1. WRG Timeline of Events 

1975: AEC split into NRC and Energy Research and Development Agency (ERDA). 

1977: Department of Energy (DOE) replaced ERDA. 

1990–present Plutonium building (#234) D&D. Called the “PU” building. 

1997–2010: NFS removed waste material from Ponds 1, 2, 3, and 4 and soil decontaminated. 

1997–2010: NFS excavated waste and soil from north burial grounds and soil decontaminated. 

1999–2000: Excavation of Southwest Trench. 

The WRG facility essentially had three major phases of operations: 

 AEC weapons/research and commercial/Navy operational period, 1958–1970. 

 AEC/DOE non-weapons, commercial/Navy operational period, 1971–present. 

 Cleanup of ponds, burial sites, and some buildings, 1991–present. 

A brief outline of these three major periods at WRG follows. 

(1) AEC weapons/research and commercial/Navy operational period, 1958–1970: During 

this era, activities included receiving, processing, and shipping uranium, plutonium, and thorium 

for use in weapons and reactor fuel elements. Additionally, recovery processes were conducted 

to extract uranium from scrap materials. Some unwanted materials were discharged or buried in 

the onsite ponds and burial grounds. 

To date, documentation has not been located that provides a clear description of what radioactive 

materials were used only for AEC weapons or research activities, and what was used only for 

commercial and/or Navy purposes. In the TBD, it is assumed that uranium, thorium, and some 

plutonium were used during the operational period (1958–1970), and only residual uranium 

contamination has the potential to cause exposure during the residual period (1971–present). It 

appears that thorium was not actually used in AEC-related work, although there were indications 

that it was contemplated according to the following communication of June 2006 (NFS 2006), in 

which it is stated that: 

The thorium orders at NFS (W.R. Grace from 1957–1964) were related to USAEC 

weapons program work (Th metal powder/pellets for Union Carbide Nuclear 

Corp., for example)... [Emphasis added.]

However, it appears that the orders were not carried through, according to the following later 

information (Leiton 2011): 

None of the evidence suggests that W.R. Grace's work with thorium was part of 

their AWE efforts. 

However, there is no supporting documentation that indicates that plutonium was not involved 

in the AEC weapons work at WRG during the operational period; this will be outlined further in 

Section 3 of this report as a finding. 

(2) AEC/DOE non-weapons and commercial/Navy operational period 1971–present: 

During this era, activities included receiving, processing, and shipping uranium, plutonium, and 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

8 of 39 

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. 

thorium for use in reactor fuel elements. Additionally, recovery processes were conducted to 

extract uranium from scrap materials. The TBD lists the residual period as 1971–2009; however, 

the exposure to residual radioactive materials extends up through the present time. 

(3) Cleanup of ponds, burial sites, and some buildings, 1991–present: During this era, the 

ponds, burial sites, and some buildings were decommissioned (or are presently being 

decommissioned) and the radioactive material removed, processed/concentrated, packaged, and 

shipped offsite for disposal. 

SC&A’s Evaluation 

A list of some of the important dates concerning the TBD and related issues is provided in Table 

2 below. 

Table 2. Timeline of TBD and Related Events 

7/21/2005: Worker Outreach meeting held.

2006: ORAUT-TKBS-0043, Rev. 00 issued. Residual period section reserved.

2007: WRG SEC-00082 based on lack of thorium bioassay data for 1958–1970 approved. 

2008: ORAUT-TKBS-0043, Rev. 01 issued. Residual external and internal doses based on all radioactive 

materials used during 1958–1970. 

4/06/2011: Worker Outreach meeting held. 

2011: ORAUT-TKBS-0043, Rev. 02 issued. Residual external and internal doses based on 1961 uranium in 

air measurements only, except for burial ground workers. 

SC&A reviewed the WRG site TBD for the following attributes, in accordance with Site Profile 

Review Procedures (SC&A 2004): 

 Completeness of Data Sources 

 Technical Accuracy 

 Adequacy of Data 

 Consistency Among Site Profiles 

 Regulatory Compliance 

In preparation for this report, SC&A reviewed the WRG site TBD in detail, along with many 

WRG site-related documents located in the Site Research Data Base (SRDB) on the Center for 

Disease Control (CDC) server. SC&A also conducted an onsite visit and interviews with current 

and former WRG site workers in October 2012. From these reviews, SC&A developed a 

number of issues regarding the WRG site profile. These issues were identified, consolidated, 

and grouped into findings. Findings that have the potential to significantly impact the results of 

at least some dose reconstructions (DRs) are listed as Primary Findings, and those that are 

important, but may have less impact on the results of DRs, are listed as Secondary Findings. 

Additionally, items in the TBD that could potentially lead to incorrect dose assignments, because 

of errors, lack of clarity, inconsistencies, omissions, etc., are listed as text items that need to be 

addressed in Section 1.3 of this report. 

In this section, a brief summary of the issues are presented, followed by a summary of the 

primary findings. (Primary Findings, along with Secondary Findings, are further detailed in 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

9 of 39 

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. 

Section 3 of this report). SC&A then provides a discussion of the strengths of the TBD, 

followed by recommendations for improvement at the end of this section, and a list of text items 

that need to be addressed by NIOSH. 

Summary of Issues 

SC&A found that there was some documentation available describing the plant’s operations and 

cleanup activities. External dose and bioassay records are available for most workers; however, 

the accuracy and completeness of these records has not been addressed in detail at this point by 

SC&A, NIOSH, or DOE. The TBD for the WRG site incorporated some of this material and 

makes recommendations for its use in performing DRs. However, SC&A has identified some 

shortcomings in the TBD that may lead to dose assignments during DR that are not necessarily 

adequate and/or accurate and employ some questionable assumptions. These concerns are 

summarized below, with detailed discussions provided in Section 3 of this report. 

1.1 SUMMARY OF PRIMARY FINDINGS 

Finding 1: Accuracy and completeness of bioassay records not addressed 

The accuracy and completeness of the recorded bioassay data have not previously been 

addressed by either DOE or NIOSH as part of a routine “verification and validation” (V&V) 

database review. SC&A performed a preliminary scan of the WRG DOE files for a small 

sampling of claimants and did not identify any outstanding issues. However, a broader and more 

detailed survey should be conducted that would determine if workers who should have been 

monitored because of job title (i.e., chemical operator, production-line operator, etc.) and/or 

location (i.e., production buildings, waste facilities, burial grounds, etc.) have recorded bioassay 

data for the corresponding periods when working in these areas. 

Finding 2: Insufficient uranium bioassay/intake data 

If a worker’s uranium bioassay data are not available, the TBD recommends on page 25 that the 

intake values in Table 3-15 be used to assign unmonitored dose during the operational period 

1958–1970. There has been no documentation or substantiation of the appropriateness of using a 

1961 air concentration data point for operating conditions at WRG during the entire operational 

period. Additional investigation of the use of the 1961 data for 1958–1970 is needed. 

Finding 3: Use of operational-period plutonium results but not residual-period plutonium 

results, and not estimating non-bioassayed workers’ plutonium doses during either period, 

are not consistent with the Special Exposure Cohort (SEC) 

The SEC was not based on lack of plutonium data, and it has not been documented that 

plutonium was not AEC weapons-related (and indications are that it could have been, in any 

case). Therefore, plutonium DR during the operational period should be included in the DR 

protocol, as it was for uranium, with provisions (such as using a coworker model) to bridge gaps 

in bioassays, or to compensate for lack of bioassays. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

10 of 39 

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. 

Additionally, not assigning plutonium dose during the residual period assumes that all legacy 

plutonium from the operational period is still undisturbed in storage, burial grounds, ponds, 

buildings, duct work, etc., and creates no significant exposure hazard. However, this is not the 

situation during the residual period. Therefore, it appears that to substantiate that plutonium 

processed at WRG was not used in the AEC weapons program (and hence not to be included in 

the residual period as recommended in the TBD), NIOSH would need to locate government 

documents outside of the WRG/NFS company that would verify the origin, destination, and 

ultimate use of the plutonium material processed at the WRG facility during the operational 

period. 

Finding 4: Lack of neutron dose assignment 

SC&A did not locate any recorded neutron doses in the claimants’ files reviewed to date. The 

TBD concludes (page 28) that there were potential neutron exposures, but “No attempt should be 

made to estimate neutron dose for workers not monitored for neutrons during the operational 

period.” Site profiles for other uranium- and plutonium-handling facilities incorporate neutron 

doses in the DR process, usually using the neutron-to-photon ratio (n/p) method, for workers 

potentially exposed to neutrons. Further investigation of the potential neutron exposures and 

methods to assign appropriate neutron doses is needed for the WRG facility. 

Finding 5: Lack of dosimetry calibration knowledge 

Because of the lack of information indicating otherwise, it appears that the dosimeters for WGR 

workers were read and recorded by outside vendors, with WRG depending on the processing 

companies to provide the correct correlation between the various radiation fields at WRG and the 

vendor’s calibration. It needs to be determined if any field measurements of the radiation energy 

spectra were made, and what calibration source(s) were used by the vendors. Dosimeters 

calibrated using higher-energy sources, such as Co-60, may not have correctly responded to the 

lower-energy photons from the various radionuclides present at WRG. Therefore, a correction 

factor may be needed, especially for determining the dose to skin and shallow organs. 

Finding 6: Onsite medical x-ray exams not substantiated 

It has not been substantiated that x-ray exams were performed onsite at the WRG facility during 

the AEC operational period of 1958–1970. Therefore, assigning offsite x-ray exams may not be 

consistent with ORAUT-OTIB-0079 (ORAUT 2011d) if the exams were performed offsite. 

While the TBD recommendations are claimant favorable, to ensure consistency with other site 

profiles, this is an area that needs further verification. 

Finding 7: The 2011 TBD does not adequately cover environmental doses 

The methods for estimating dose in the TBD do not account for airborne radioactive materials 

that were generated by the cleanup and processing of waste from the ponds and burial grounds 

during the residual period to which monitored, as well as unmonitored, non-burial ground 

workers may have been exposed. These non-burial grounds workers may still have been 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

11 of 39 

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. 

exposed to environmental radioactive materials from the cleanup operations during the residual 

period. 

The internal and external environmental exposures throughout the site during both the AEC 

period (1958–1970) and from the cleanup of the AEC legacy materials during the period 1971–

present are not adequately addressed. 

1.2 SUMMARY OF STRENGTHS 

The WRG site TBD was written in one volume, containing seven sections, which assist the 

reader in accessing and analyzing the information in an orderly fashion. The TBD addressed the 

different time periods (operations, residual, and cleanup) relevant to the WRG site in a consistent 

manner. Section 2 of the TBD provided a description of the site’s history from its origin in 1958 

to its present-day status. The uranium intake methodology used in Section 5 was well done and 

followed proper protocol using appropriate methods, as recommended in TBD-6000 (NIOSH 

2008). 

References were well documented and editorial errors were kept to a minimum. (See 

Section 1.3, “Opportunities for Improvement,” for text items that need to be addressed 

concerning some of the errors that were located during this review.) The information presented 

was fairly consistent across the different sections of the TBD. The current TBD is useful in the 

DR process, but needs to be revised to address the concerns described in the following section 

and the findings in Section 3 of this report. 

1.3 OPPORTUNITIES FOR IMPROVEMENT 

There are numerous opportunities for the TBD to be further developed, so that it would be more 

useful and accurate in DR by building on the basic information provided in the current version. 

Most of the major issues are identified in the findings described in Section 3 of this report. 

Additionally, SC&A has identified some areas where changes in the TBD would be beneficial to 

the claimant by preventing possible mistakes during DR or clarifying items to make them less 

ambiguous. The text items that need to be addressed by NIOSH are as follows: 

Item 1 – Incomplete text

In the first paragraph on page 27 of the TBD, “1970” needs to be inserted: 

As such, before [1970], the total shallow dose is best estimated by summing the reported 

skin (i.e., non-penetrating dose) and whole-body (i.e., penetrating dose component) 

doses. 

Item 2 – Incorrect footnote notation 

The last footnote for Table 4-2 on page 29 of the TBD should be labeled as c, not b: 

c. MDL information communicated by Landauer. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

12 of 39 

 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:

Item 3 – Incomplete reference 

Although the minimum detectable level (MDL) values listed in Table 4-2 on page 29 of the TBD 

are consistent with other DOE sites, a check of the reference (Tester 2005) in the footnote (b) 

indicates that the person in the reference only states a reporting level of 10 mR, 1 mrem, and 

10 mrem, not an MDL of 40 mrem, as indicated by the TBD.

Item 4 – Incorrect section number 

The last row in Column 6 of Table 4-3 on page 31 of the TBD should read “See Section 4.6,” not 

“See Section 4.4.5.” 

Item 5 – Missing reference 

The last sentence of the next-to-the-last paragraph on page 31 of the TBD references (EPA 

1993a); however, this reference is not listed in the references on page 39 of the TBD.

Item 6 – Incorrect units in equation on page 32 

The equation on page 32 of the TBD reads: 

air concentration pCi/m3 × 31,536,000 s/yr × 0.00075 m/s = surface activity dpm/m2

 (Eq.1) 

when it should read: 

air concentration dpm/m3 × 31,536,000 s/yr × 0.00075 m/s = surface activity dpm/m2 (Eq.1) 

Item 7 – Missing text on page 35 

The end of the first sentence in the next to the last paragraph on page 35 of the TBD needs the 

word “electrons” added to it as follows: 

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

and 250 keV and electrons >15 keV...
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

13 of 39 

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. 

2.0 SCOPE AND INTRODUCTION 

The review of the WRG site profile was conducted during the period July 2012–November 2012 

by an SC&A senior health physicist. WRG, located near Erwin, Tennessee, was considered a 

“job shop” and as such, received, processed, and shipped material without many details 

concerning its origin, properties, and end use; therefore, most work was not classified. 

SC&A understands that site profiles are living documents, which are revised, refined, and 

supplemented with NIOSH technical information bulletins (TIBs) as required to help dose 

reconstructors. Site profiles are not intended to be prescriptive or necessarily complete in terms 

of addressing every possible issue that may be relevant to a given DR. However, future revisions 

of the WRG site TBD would serve to mitigate some of the gaps and issues raised in this report. 

It is noteworthy that the WRG facility was granted an SEC for January 1, 1958, through 

December 31, 1970. Section 1.3 of the TBD defines the SEC as follows: 

NIOSH has determined, and the Secretary of the U.S. Department of Health and 

Human Services (DHHS) has concurred, that it is not feasible to reconstruct 

internal radiation dose for (Leavitt 2007): 

Atomic Weapons Employer (AWE) employees who were monitored or 

should have been monitored for potential exposure to thorium while 

working in any of the 100 series buildings or Buildings 220, 230, 233, 

234, 301, or 310 at the W. R. Grace site at Erwin, Tennessee, for a 

number of work days aggregating at least 250 work days from January 1, 

1958, through December 31, 1970, or in combination with work days 

within the parameters established for one or more other classes of 

employees in the Special Exposure Cohort. 

Therefore, only internal dose from uranium and plutonium is considered in 

Section 3.0 of this site profile. Because of the identified dose reconstruction 

infeasibility, all dose reconstructions for all workers having employment during 

the SEC class period are considered partial dose reconstructions. If monitoring 

data are available for workers included in the SEC class, this data may be used to 

refine the dose reconstruction; however, such dose reconstructions are still 

considered partial dose reconstruction 

SC&A’s understanding of the current NIOSH policy is that, although thorium intakes during the 

operational period (1958–1970) were not AEC weapons work-related, thorium must be taken 

into consideration; and therefore, the SEC is applicable. However, during the residual period 

(1971–present), thorium intakes are not required to be included in DR, because it was not AEC 

weapons-related material. 

Given the SEC, this review focuses on those portions of the site profile where the TBD claims it 

can reconstruct doses, namely internal and external exposures to uranium and plutonium during 

the operations and residual periods. In addition, as will be discussed, the TBD appears to 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

14 of 39 

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. 

indicate that external exposures could also be reconstructed during the operational and residual 

period; however, the definition of the SEC is silent regarding this matter. 

2.1 REVIEW SCOPE 

Under the EEOICPA, the Advisory Board is mandated to conduct an independent review of the 

methods and procedures used by NIOSH and its contractors for DR. As a contractor to the 

Advisory Board, SC&A has been charged to support this effort by independently evaluating a 

select number of site profiles that correspond to specific facilities at which energy employees 

worked and were exposed to ionizing radiation. 

This report provides a review of the site profile document, ORAUT-TKBS-0043 (ORAUT 

2011a), for the WRG site in Erwin, Tennessee. To date, this document has not been 

supplemented by site-specific TIBs, but there are several generic TIBs that provide additional 

guidance to the dose reconstructor. 

Implementation guidance is also provided by so-called “workbooks,” which have been 

developed by NIOSH for selected sites to provide more definitive direction to the dose 

reconstructors on how to interpret and apply the TBD, as well as other available information. To 

date, no WRG site-specific workbooks have been developed. 

SC&A, in support of the Advisory Board, has critically evaluated the WRG site TBD for the 

following: 

 Determine the completeness of the information gathered by NIOSH in behalf of the site 

profile, with a view to assessing its adequacy and accuracy in supporting individual DRs

 Assess the technical merit of the data/information

 Samples of some of the internal and external data in the claimant files that will be used 

for DR purposes

SC&A’s review of this site profile document focuses on the quality and completeness of the data 

that characterized the facility and its operations, and the use of these data in DR. The review was 

conducted in accordance with Site Profile Review Procedures (SC&A 2004), which was 

approved by the Advisory Board. 

The review is directed at “sampling” the site profile analyses and data for validation purposes. 

The review does not provide a rigorous quality control process, whereby actual analyses and 

calculations are duplicated or verified. The scope and depth of the review are focused on aspects 

or parameters of the site profile that would be particularly influential in deriving DRs, bridging 

uncertainties, or correcting technical inaccuracies. 

The WRG site TBD serves as a site-specific guidance document used in support of DRs. These 

site profiles provide the health physicist who conducts DRs on behalf of NIOSH with consistent 

general information and specifications to support their individual DRs. This report was prepared 

by SC&A to provide the Advisory Board with an evaluation of whether and how the TBD can 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

15 of 39 

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. 

support DR decisions. The criteria for evaluation include whether the TBD provides a basis for 

scientifically supportable DR in a manner that is adequate, complete, efficient, and claimant 

favorable. Specifically, this review was conducted using the criterion of whether DRs based on 

the TBD would provide for robust compensation decisions. 

The basic principle of DR is to characterize the radiation environments to which workers were 

exposed, and determine the level of exposure the worker received in that environment through 

time. The hierarchy of data used for developing DR methodologies is dosimeter readings and 

bioassay data, coworker data and workplace monitoring data, and process description 

information or source term data. 

2.2 ASSESSMENT CRITERIA AND METHODS 

SC&A is charged with evaluating the approach set forth in the site profiles that is used in the 

individual DR process. These documents are reviewed for their completeness, technical 

accuracy, adequacy of data, consistency with other site profiles, and compliance with the stated 

objectives, as defined in SC&A’s Site Profile Review Procedures (SC&A 2004). This review is 

specific to the WRG site profile and supporting TIBs; however, items identified in this report 

may be applied to other facilities, especially facilities with similar source terms and exposure 

conditions. The review identifies a number of issues and discusses the degree to which the site 

profile fulfills the review objectives delineated in SC&A’s Site Profile Review Procedures. 

2.2.1 Objective 1: Completeness of Data Sources 

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify 

principal sources of data and information that are applicable to the development of the site 

profile. The two elements examined under this objective are (1) determining if the site profile 

made use of available data considered relevant and significant to DR, and (2) investigating 

whether other relevant/significant sources are available, but were not used in the development of 

the site profile. 

2.2.2 Objective 2: Technical Accuracy 

Objective 2 requires SC&A to perform a critical assessment of the methods used in the site 

profile to develop technically defensible guidance or instructions, including evaluating field 

characterization data, source term data, technical reports, standards and guidance documents, and 

literature related to processes that occurred at the WRG site. The goal of this objective is to 

analyze the data according to sound scientific principles, and then evaluate this information in 

the context of DR. 

2.2.3 Objective 3: Adequacy of Data 

Objective 3 requires SC&A to determine whether the data and guidance presented in the site 

profile are sufficiently detailed and complete to conduct DR, and whether a defensible approach 

has been developed in the absence of data. In addition, this objective requires SC&A to assess 

the credibility of the data used for DR. The adequacy of the data identifies gaps in the facility 

data that may influence the outcome of the DR process. For example, if a site did not monitor all 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

16 of 39 

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. 

workers exposed to neutrons who should have been monitored, this would be considered a gap, 

and therefore an inadequacy in the data. An important consideration in this aspect of our review 

of the site profile is the scientific validity and claimant favorability of the data, methods, and 

assumptions employed in the TBD to fill in data gaps. 

2.2.4 Objective 4: Consistency among Site Profiles 

Objective 4 requires SC&A to identify common elements within site profiles completed or 

reviewed to date, as appropriate. In order to accomplish this objective, the WRG site TBD was 

compared to other TBDs previously reviewed. This assessment was conducted to identify areas 

of inconsistencies, and determine the potential significance of any inconsistencies with regard to 

the DR process. 

2.2.5 Objective 5: Regulatory Compliance 

Objective 5 requires SC&A to evaluate the degree to which the site profile complies with stated 

policy and directives contained in 42 CFR Part 82. In addition, SC&A evaluated the TBD for 

adherence to general quality assurance policies and procedures utilized for the performance of 

DRs. 

2.3 DOSE RECONSTRUCTION UNDER EEOICPA 

SC&A’s draft report and preliminary findings will undergo a multi-step resolution process. Prior 

to and during the resolution process, the draft report is reviewed by the DOE Office of Health, 

Safety, and Security to confirm that no classified documents or information have been 

incorporated into the report. Resolution includes a transparent review and discussion of draft 

findings with members of the Advisory Board Working Group, petitioners, claimants, and 

interested members of the public. This resolution process is intended to ensure that each finding 

is evaluated on its technical basis in a fair and impartial basis. A final report will then be issued 

to the Advisory Board for deliberation and a final recommendation. 

All review comments apply to Rev. 02 of the WRG site TBD, which is the most recently 

published version (ORAUT 2011a), unless otherwise stated. 

In October 2012, site expert interviews were conducted with current and former WRG site 

workers to help SC&A obtain a comprehensive understanding of the radiation protection 

program, site operations, and historic exposure experience. The interviewees included a good 

cross-section of current and former WRG site workers, including production, maintenance, 

safety, office, and radiological safety personnel that worked at the WRG/NFS site at some point 

during the operational and/or the residual period. The interviews were conducted at the NFS 

training center in Erwin, Tennessee, and the United Steelworkers of America Local 5-3677 union 

hall in Erwin, Tennessee. Each interview session was summarized by SC&A, and then reviewed 

by the interviewee before including the summary in an amendment to this report; the amendment 

will be issued later to prevent delaying the release of this evaluation report in a timely manner. 

Documents pertinent to the WRG site and its operations were reviewed at the NFS in Erwin, 

Tennessee, prior to release. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

17 of 39 

 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:

Because of the singularity of purpose, limited operating period, and relatively small size of the 

WRG site (as opposed to other DOE sites or national laboratories), SC&A did not submit a list of 

questions to NIOSH as part of its evaluation of the WRG site TBD. SC&A believed that the 

resources and time that would have been involved in submitting questions and obtaining 

responses could be more effectively spent in performing document research, site interviews, and 

other tasks for this site profile review. 

2.4 REPORT ORGANIZATION 

In accordance with directions provided by the Advisory Board and with Site Profile Review 

Procedures (SC&A 2004) prepared by SC&A and approved by the Advisory Board, this report 

is organized into the following sections: 

(1) Executive Summary 

(2) Scope and Introduction 

(3) Vertical Issues 

(4) Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

18 of 39 

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. 

3.0 VERTICAL ISSUES 

SC&A developed the issues for the WRG site profile document using the five objectives defined 

in SC&A’s review procedures (SC&A 2004). The issues were identified, consolidated, and 

grouped into findings. Findings that could substantially impact the results of DR for some 

workers are listed as Primary Findings, and those that are important, but may have less impact on 

the results of DR, are listed as Secondary Findings. SC&A has also identified some areas where 

changes in the TBD would be beneficial to the claimant by preventing possible mistakes during 

DR, or where clarification of items would make them less ambiguous; these were listed as text 

items that need to be addressed in Section 1 of this report. 

3.1 FINDINGS 

3.1.1 Occupational Internal Dose, Section 3 of ORAUT-TKBS-0043 

Background and Introduction 

Section 3 for internal dose, pages 16–26, was written to provide the dose reconstructor with 

recommendations concerning internal DR at the WRG site during the period of AEC/ 

commercial/Navy operations (1958–1970), and also during the AEC/DOE residual period and 

commercial/Navy operations (1971–present). This section provides some information 

concerning: 

 Internal exposure from uranium, RU, plutonium, and thorium

 1959 and 1961 uranium air measurements

 Uranium and plutonium bioassay urinalyses

 Internal DR assumptions

In addition to the operational period (1958–1970) covered by Section 3, Section 5 (pages 31–34) 

covers internal dose during the residual period of 1971–present. The following is a brief outline 

of the contents of Section 3 and Section 5 for internal dose:

Section 3 Internal – AEC Operational Period 1958–1970

1. Internal Exposure Potential – 

 1958–1970: During the AEC operational period, the main source of internal exposure 

was from uranium, RU, thorium, and plutonium (starting in 1966) dust. 

 There was DU, NU, uranium enriched from 3.5% (LEU) to 93% (HEU) in U-235; 

there were also U-232 and U-233 present. Recycled uranium potentially contained 

Tc-99, Np-237, Th-232, Ru-106, and Pu-238. These are summarized in Table 3-1, 

page 17 of the TBD. Table 3-2 on page 17 of the TBD lists the uranium types and 

activity fractions. Table 3-3 on page 18 of the TBD lists the Shippingport U-233 

activity fractions. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

19 of 39 

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. 

2. Uranium Air Samples – 

 AEC 1959: Air samples were taken during the recovery of 93% HEU from scrap. 

The average daily weighted exposures (DWE) in dpm/m3 for different 

operators/operations/areas are listed in Tables 3-4, 3-5, and 3-6 on pages 18–19; 

additionally, the geometric means and other statistics are provided in each table. 

 AEC 1961: Air samples were taken during the recovery of 3.6% LEU from scrap. 

The average DWE in dpm/m3

 for different operators/operations/areas are listed in 

Tables 3-7, 3-8, and 3-9 on pages 19–20; additionally, the geometric means and other 

statistics are provided in each table. 

 The maximum DWE of 578.38 dpm/m3 [at the 95% confidence level from Table 3-8 

for the 1961 breathing zone (BZ) samples] was used by NIOSH in the remainder of 

this TBD to derive potential intakes and exposures. 

 These air samples were analyzed by determining the total alpha activity; therefore, 

knowledge of the uranium enrichment is not necessary to assign intake and doses, 

using the default radionuclide of U-234 to be claimant favorable. 

 Table 3-10 on page 22 lists the derived annual uranium inhaled intakes using the 

DWE of 578.38 dpm/m3, 2,000 hours/year, and a breathing rate of 1.2 m3/hr. 

 Table 3-11 on page 22 lists the derived annual uranium ingested intakes using the 

DWE of 578.38 dpm/m3

, 2,000 hours/year, and a factor of 0.2 (as recommended in 

OCAS-TIB-009 (NIOSH 2004). 

3. Recycled Uranium – 

 Table 3-12 on page 23 provides a list of the radioactive contaminants associated with 

RU at WRG. 

4. Uranium Bioassays – 

 Urinalysis for uranium began in October 1964. 

 A uranium minimum detectable activity (MDA) of 2 dpm/L or 10 dpm/L should be 

used. 

 Uranium lung counts began in 1970. An MDA value of 120 μg should be used. 

Table 3-13 on page 23 provides chest count conversions for uranium. 

5. Plutonium Exposures – 

 Plutonium may have arrived in 1966. 

 Plutonium could have been reactor, fuel, or weapons grade. NIOSH selected 12% 

fuel-grade Hanford plutonium to be used in the DR process; Table 3-14 on page 24 

lists the activity of this plutonium. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

20 of 39 

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. 

6. Plutonium Bioassay – 

 Plutonium urinalysis was performed for Pu-239 during the time period 1967–

February 1973. 

 The TBD states on page 24: 

The bioassay data should be used for assessing a worker’s plutonium 

dose. No attempt should be made to estimate plutonium dose for 

unmonitored workers during the operational period. [Emphasis added.] 

 A plutonium MDA of 0.06 dpm/L should be used. 

 Pu-239 chest counts started at WRG around 1987. The MDAs for this system were 

large; therefore, urinalysis results should be used if possible. 

7. Uranium-233 – 

 U-233/Th-232/Th-228 was used in the production of the Mixed Oxide (MOX) fuel. 

8. Internal DR Assumptions – 

 According to the WRG SEC, it is infeasible to reconstruct internal thorium dose 

adequately during the AEC operational period January 1, 1958, through December 

31, 1970; dose estimates for this period are considered partial dose estimates (NIOSH 

2007), as stated in the TBD. 

 Use uranium, thorium, and plutonium bioassays if available. If uranium bioassays are 

not available, use the intakes derived in Table 3-15. If thorium bioassays results are 

or are not available, it will be considered a partial DR because of the SEC. If an 

individual was not monitored for plutonium exposures through bioassay, no attempt

should be made to estimate plutonium dose during the operational period, and the DR 

is to be considered a partial internal assessment. 

 Table 3-15 on page 26 lists the uranium exposure summary for the AEC operational 

period of 1958–1970. This includes inhaled and ingested uranium and RU 

components. Table 3-15 is based on the information in Tables 3-10 and 3-11, and 

365 day/year intake. 

Section 5 Internal – Residual Period 1971–2009

1. Remediation –

 Ponds 1, 2, 3, and 4, and the burial grounds were remediated during the time period of 

1991–2009. 

2. Assignment of Internal Intakes – Non-Burial Grounds Workers 

 According to page 32, the TBD recommends: 

During the residual radioactivity period at W.R. Grace (1971 through 

October 2009), personnel might have been internally exposed to uranium in 

the workplace. Internal monitoring data could exist for plutonium or thorium 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

21 of 39 

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. 

3.1.1.1

during the residual period; however, only operations involving uranium

were part of the nuclear weapons-related program. [Emphasis added.] 

 If the uranium bioassay data are available, it may be used, but must be adjusted 

downward by the source term depletion rate of 0.00067/day, as listed in Table 5-1 on 

page 32 (this is according to SC&A’s present understanding of the recommendations 

of the TBD on page 32). 

 If uranium bioassay data are not available, the intakes from inhaled uranium and RU 

are obtained from Table 5-2 on page 33. This table is based on the 1961 DWE data. 

Additionally, intakes from ingested uranium and RU are listed in Table 5-3 on page 

34; this table is based on the 1961 DWE data and OCAS-TIB-009, Estimation of 

Ingestion Intakes (NIOSH 2004). 

3. Assignment of Internal Intakes – Burial-Grounds Workers 

According to page 34 of the TBD, remediation activities at the burial grounds should be 

assessed based on individual bioassay records. It is not stated if this is to include 

plutonium bioassays along with uranium (however, it is stated on page 32 that only 

uranium is to be considered in assigning dose from AEC activities); what areas the term 

“burial grounds” includes, or how burial grounds workers are to be identified. 

SC&A reviewed Sections 3 and 5 of the TBD in accordance with the guidance provided 

in Site Profile Review Procedures (SC&A 2004) and has the following findings. 

Internal Dose Primary Findings 

Finding 1: Accuracy and completeness of bioassay records not addressed 

The accuracy and completeness of the recorded bioassay data have not previously been 

addressed. SC&A performed a preliminary scan of the WRG DOE files for several of the 

claimants and found some recorded bioassay data for uranium in urine (in units of dpm/L) 

starting in 1964, plutonium in urine (in units of dpm/L) starting in 1968, and in-vivo chest counts 

for U-235 (in units of microgram U) starting in 1974. There may have been early start dates for 

these bioassays, but these are the earliest listed in the claims scanned to date by SC&A; the 

recorded bioassays located appeared legible. 

SC&A performed a preliminary scan of 25 WRG claims for energy employees (EEs) that worked 

at WRG sometime during the period 1957–1970, and had job titles that would indicate the 

potential need for bioassays (such as operator, chemical operator, production, etc.). A qualitative 

review indicated that bioassays were not performed before 1964 (which concurs with the 

evaluation given in the TBD), and that a relatively small fraction of the workers were 

bioassayed, mostly for uranium by urinalyses. SC&A found that, on the average, approximately 

17% of the 25 workers were bioassayed each year for the total time period of 1957–1970, and 

37% were bioassayed during the time period 1964–1970 (a partial year of employment was 

counted as a year worked in this qualitative analysis). These results are summarized in Figure 1 

below. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

22 of 39 

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. 

WRG - Number of Bioassayed Years & Number 

of Worked Years Vs. Year 

(17% average bioassayed for 25 workers)

0

2

4

6

8

10

12

14

19571958195919601961196219631964196519661967196819691970

Year

# of Bioassayed 

years & # of worked 

years per year

# of bioassyed-years # of worked-years

Figure 1. Number of Uranium Bioassayed Years and Number of 

Years Worked vs. Year 

A more detailed survey may need to be conducted that would determine if workers who should 

have been monitored because of job title (i.e., chemical operator, production line operator, etc.) 

and/or location (i.e., production buildings, waste facilities, burial grounds, etc.) have recorded 

bioassay data for the corresponding periods when working in these areas. 

Scanning the same claimant files for plutonium bioassays indicates that they were not evident 

until after the operational period ended (1970). 

Given the fact that the bioassay data appear to be incomplete for both uranium and plutonium 

during the operational period, coworker models are needed. This issue is examined in more 

detail in the following two findings. 

Finding 2: Insufficient uranium bioassay/intake data 

In reviewing the claimant files, SC&A concurs with NIOSH that it appears uranium urinalyses 

did not start until late in 1964 at WRG (page 22 of the TBD). If a worker’s uranium bioassay 

data are not available, the TBD recommends on page 25 that the intake values in Table 3-15 be 

used to assign unmonitored dose during the period 1958–1970. The intake values in Table 3-15 

are based on values listed in Tables 3-8, 3-10, and 3-11, which basically were derived from the 

578 dpm/m3

 maximum measured DWE value in 1961. The use of this one data point would 

mostly impact the 1958–1964 time period when no uranium bioassays were obtained. There has 

been no documentation or substantiation of the appropriateness of using a 1961 air concentration 

data point for operating conditions at WRG prior to 1961, nor after 1961. Operating conditions 

and health regulations may not have remained relatively constant during the entire 1958–1970 

period, and the 1961 measurement may not have been representative of this entire operational 

period. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

23 of 39 

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. 

Additional investigation of the use of the 1961 data for 1958–1970 is needed. 

Finding 3: Use of operational-period plutonium results, but not residual-period plutonium 

results, and not estimating non-bioassayed workers’ plutonium doses during either period 

is not consistent with SEC 

Operational Period (1958–1970)

The lack of plutonium data was not stated as a part of the basis for the SEC (only the lack of 

thorium data, according to NIOSH 2007). The TBD, page 25, recommends using plutonium 

bioassay results if available for DR purposes during the operational period; an excerpt from 

page 25 of the TBD is as follows: 

Uranium and plutonium (and associated radionuclides) intakes during the 

operational period (1958–1970) should be based on actual bioassay monitoring 

results for the individual. 

Additionally, page 11 of NIOSH’s SEC Evaluation Report for WRG (NIOSH 2007) states: 

Plutonium operations at W. R. Grace began in 1966. All AEC weapons-related 

work (including work with plutonium) ended in 1970.

This statement indicates that AEC weapons work at WRG included plutonium. However, on 

page 25 of the TBD, it is also stated: 

In addition, if an individual was not monitored for plutonium exposures through 

bioassay, no attempt should be made to estimate plutonium dose during the 

operational period, and the dose reconstruction is to be considered a partial 

internal assessment. [Emphasis added.] 

As previously stated, the SEC was not based on lack of plutonium data, and it has not been 

documented that plutonium was not AEC weapons-related (and indications are that it could have 

been); therefore, plutonium DR during the operational period should be included in the DR 

protocol (as it was for uranium) with provisions (such as using a coworker model) to bridge gaps 

in bioassays, or to compensate for lack of bioassays. 

Residual Period (1971–present)

On page 32 of the TBD, it is stated: 

During the residual radioactivity period at W.R. Grace (1971 through October 

2009), personnel might have been internally exposed to uranium in the 

workplace. Internal monitoring data could exist for plutonium or thorium during 

the residual period; however, only operations involving uranium were part of the 

nuclear weapons-related program, and are covered during the residual period for 

dose reconstruction under EEOICPA (Leiton 2011). 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

24 of 39 

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. 

Although it is not explicitly stated that the plutonium was used in the AEC weapons/research 

activities, the following excerpt, shown below in Exhibit A, confirms plutonium from Hanford 

was processed during the AEC weapons era at WRG (AEC 1966): 

Exhibit A. Plutonium Contract Between AEC and NFS 

As previously pointed out, there are indications that there was use of plutonium in the AEC 

weapons programs at WRG during the operational period; therefore, not assigning plutonium 

dose during the residual period assumes that all legacy plutonium from the operational period is 

still undisturbed in storage, burial grounds, ponds, buildings, duct work, etc., and creates no 

significant exposure hazard. However, it is known that this material has been disturbed, dug up, 

handled, processed, packaged, and shipped, and buildings have been decommissioned during the 

residual period, resulting in potential plutonium exposures to workers. 

The results of SC&A’s investigation of the use of radioactive materials besides uranium (i.e., 

plutonium and thorium) in the AEC weapons program during the operational period indicates 

that for many contracts, neither the company (WRG) nor the workers were privileged to the 

origin, destination, or ultimate use of the materials that passed through the WRG facility. The 

WRG facility was a “job shop” that performed a service for various government agencies and 

commercial sectors. Therefore, it appears that to substantiate that the plutonium processed at 

WRG was not used in the AEC weapons program (and hence not to be included in the residual 

period as recommended in the TBD), government documents outside of the WRG/NFS company 

would have to be obtained to verify the origin, destination, and ultimate use of the plutonium 

material processed at the WRG facility during the operational period. 

Burial Grounds Workers and Definition Issue 

On page 34 of the TBD, it is stated: 

Remediation of the Burial Grounds 

Remediation activities of the burial grounds should be assessed based on 

individual bioassay records per guidance in Section 3. 

However, it is not clear if this is to include plutonium bioassay results or only uranium. 

Additionally, since many workers changed job locations/duties frequently (an “operator” at 

WRG could be doing anything from mixing chemicals, pressing pellets, digging a ditch, or 

operating a bulldozer), it would be difficult for the dose reconstructor to determine if a specific 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

25 of 39 

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. 

3.1.1.2

worker was involved in burial grounds activities. Also, it is not clear if the term Burial Grounds

includes the trenches and ponds, where a large of amount of the cleanup took place in the 

residual period, or just the North Burial site, as indicated in Figure 2-2 of the TBD. 

Internal Dose Secondary Findings 

Secondary Finding A: Table 3-15, Table 5-2, and Table 5-3 based on 365 days instead of 

250 days per year 

SC&A found that Tables 3-10 and 3-11 on page 22 of the TBD are based on 250 days/year (i.e., 

2,000 hours/year × 1 day/8 hours = 250 days/year); However, Table 3-15 on page 26, Table 5-2 

on page 33, and Table 5-3 on page 34 are all based on 365 days/year, but use the data from

Tables 3-10 and 3-11 that are based on 250 days/year. Therefore, the values in Table 3-15, 

Table 5-2, and Table 5-3 are too small by a factor of 365/250 = 1.46, and need to be revised 

upward in value by a factor of 1.46 to be correct. 

Secondary Finding B: AEC material buried and removed from ponds and grounds not 

documented or accounted for 

SC&A has not found sufficient documentation of the materials that were buried and then 

removed from the ponds, burial grounds, and trenches to allow for the determination of the 

potential exposure to workers, especially the ability to separate the AEC legacy weapons/ 

research-related materials from the other materials. Although it is stated on page 31 of the TBD 

that, “The contents and locations of most disposal pits are well documented,” there are no 

references provided. 

3.1.2 Occupational External Dose, Section 4 of ORAUT-TKBS-0043 

Background and Introduction 

Section 4 for external dose, pages 26–31, was written to provide the dose reconstructor with 

recommendations concerning external DR at the WRG site during the period of AEC/ 

commercial/Navy operations (1958–1970), and also during the AEC/DOE residual period and 

commercial/Navy operations (1971–2009). This section provides some information concerning 

external non-penetrating, penetrating, neutron, extremity, and missed doses, and external DR 

recommendations. In addition to the operational period (1958–1970) covered by Section 4, 

Section 5 (pages 35–36) covers external exposures during the residual period of 1971–2009. The 

following is a brief outline of the contents of Section 4 and Section 5 for external dose:

Section 4 External – AEC Operational Period 1958–1970

1. Badging – 

 At one time, all WRG workers were badged 

 Later, office workers were not badged 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

26 of 39 

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. 

2. Reporting – 

 Before 1970, the reported skin dose represented only the non-penetrating dose 

component; therefore, the total shallow dose is best estimated by summing the 

reported skin (i.e., non-penetrating dose) and whole-body (i.e., penetrating dose 

component) doses. 

 Beginning January 1, 1970, the reported skin dose included the shallow dose from 

both the non-penetrating and penetrating dose components. 

 Table 4-1 on page 27 lists the dosimetry characteristics for WRG badges. 

 Photon dose should be assigned as 30–250 keV photons, and plutonium doses are to 

also include <30 keV photons. 

3. Neutrons – 

Page 28 of the TBD states: 

There were no documented neutron exposures at W.R. Grace. However, the 

use of uranium hexafluoride and uranium fluoride, and the possible presence 

of plutonium can generate neutrons through an alpha-neutron reaction 

between the uranium and the fluorine (DOE 2004). Neutrons can also arise 

from HEU and during plutonium processing operations (DOE 2006). 

Personnel exposure records are used to evaluate radiation exposure. No 

attempt should be made to estimate neutron dose for workers not monitored 

for neutrons during the operational period. 

4. Extremity Doses – 

Extremity doses while working in gloveboxes are addressed on page 28. 

5. Missed Dose – 

Table 4-2 on page 29 provides a summary of the types of dosimeters used at WRG, their 

period of use, MDL values, and maximum annual missed doses. 

6. External DR Assumptions –

 Non-penetrating dose should be assigned as >15 keV electrons or <30 keV photons 

for plutonium workers with non-skin cancers 

 Photon dose is to be assigned as 30–250 keV photons, and exposure dose conversion 

factors are to be used 

 DCAS-TIB-0010 (NIOSH 2010) recommendations should be used for glovebox 

workers at WRG 

 For U-233 workers, use dose as recorded 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

27 of 39 

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. 

Section 5 External – Residual Period 1970–2009

1. Non-Burial Grounds Workers –

 Use the dosimetry parameters listed in Table 5-4, page 35 

 Records may be used to limit dose 

 Otherwise, use doses listed in Table 5-5, page 36, which is derived from the DWE of 

578.38 dpm/m3, settling rates, Table 5-1 depletion rate, surface contamination, and 

resuspension factors 

2. Burial-Grounds Workers –

 Use the dosimetry parameters listed in Table 5-4, page 35 

 Dose may be assessed based on individual monitoring records 

 It is not stated what areas the term burial grounds includes, or how burial grounds 

workers are to be identified 

SC&A reviewed Sections 4 and 5 of the TBD in accordance with guidance provided in Site 

Profile Review Procedures (SC&A 2004) and has the following findings. 

3.1.2.1 External Dose Primary Findings 

Accuracy and completeness of external exposure records not addressed 

The accuracy and completeness of the recorded external doses have not previously been 

addressed. SC&A performed a preliminary scan of the WRG DOE files for several of the 

claimants and found some external dose records available, and those located were generally 

legible. Gamma doses (in units of rem) were recorded on a varying frequency (i.e., weekly, 

biweekly, monthly, etc.). Beta doses (in units of rem) were sporadically recorded, as if on an asneeded basis. No neutron doses were recorded in the files scanned by SC&A. 

SC&A’s performed a preliminary scan of 25 WRG claims for EEs that worked at WRG 

sometime during the period 1957–1970 and had job titles that would indicate the potential need 

for external monitoring (such as operator, chemical operator, production, etc.). A qualitative 

review indicated that external monitoring was implemented for most of the operational years for 

production workers. This was only a qualitative analysis, in that any external monitoring during 

a calendar year was counted as monitoring for that year, and any portion of a year worked was 

counted as a full year. SC&A found that, on average, approximately 97% of the 25 workers 

were monitored for external exposure (badged) each year for the period of 1957–1970. These 

results are summarized in Figure 2 below. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

28 of 39 

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. 

WRG - Number of Badged Years & Number 

of Worked Years Vs. Year 

(97% average badged for 25 workers)

0

2

4

6

8

10

12

14

19571958195919601961196219631964196519661967196819691970

Year

# of Badged years 

& # of worked years

per year

# of badged-years # of worked-years

Figure 2. Number of Badged Years and Number of Years Worked vs. Year 

This was only a qualitative review of 25 potentially exposed workers; a more detailed survey 

(expand workers’ job categories, investigate months monitored during each year, etc.) may need 

to be conducted that would determine if workers who should have been monitored because of job 

title and/or location have recorded external dose data entries for the corresponding periods of 

time worked in areas with potential exposures. However, at this time, SC&A has no indication 

that external dose records are not reasonably accurate and complete for DR purposes. 

Finding 4: Lack of neutron dose assignment 

The TBD mentions neutron doses on pages 9, 26, and 28, and concludes on page 28 that there 

were potential neutron exposures, but no neutron dose will be assigned: 

There were no documented neutron exposures at W.R. Grace. However, the use 

of uranium hexafluoride and uranium fluoride, and the possible presence of 

plutonium can generate neutrons through an alpha-neutron reaction between the 

uranium and the fluorine (DOE 2004). Neutrons can also arise from HEU and 

during plutonium processing operations (DOE 2006). 

Personnel exposure records are used to evaluate radiation exposure. No attempt 

should be made to estimate neutron dose for workers not monitored for neutrons 

during the operational period. 

SC&A did not locate any recorded neutron doses in the claimants’ files reviewed to date. 

Section 2.3.1 of DOE 2004 provides an outline of the neutron doses from uranium, which 

indicates that there are measurable neutron exposures for workers spending a reasonable amount 

of their work time near uranium fluoride compounds, or container storage facilities, and states on 

page 2-20: 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

29 of 39 

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. 

Neutron sensitive personnel monitoring badges are recommended for operations 

dealing with uranium fluoride compounds. 

This statement indicates that neutron exposures should be considered for uranium facilities. 

Also, site profiles for other uranium- and plutonium-handling facilities incorporate neutron doses 

in the DR process, usually using the n/p method, for workers potentially exposed to neutrons. 

Further investigation of the potential neutron exposures and methods to assign appropriate 

neutron doses is needed for the WRG facility. 

Finding 5: Lack of dosimetry calibration knowledge 

Because of the lack of information indicating otherwise, it appears that the dosimeters for WGR 

workers were read and recorded by outside vendors, with WRG depending on the processing 

companies to provide the correct correlation between the various radiation fields at WRG and the 

vendor’s calibration. This is also indicated in the communication between NFS and OCAS in 

2005 (Tester 2005). However, the operations at WRG resulted in varying radiation fields of 

photon, beta, and neutron energies, as indicated on page 27 of the TBD: 

The W.R. Grace/NFS distribution of low-energy photons is dependent on the 

amounts, separation and enrichments of uranium, and the age and type of 

plutonium used at the site. 

Additionally, a number of different radionuclides are listed on page 16 of the TBD that would 

encompass a variety of photon and beta energy ranges: 

Uranium enrichment levels included DU, natural uranium (NU), LEU (3.5%), 

and HEU (93%) as well as 232U and 233U. Uranium-233 contains 232U as an 

impurity due to nuclear reactions from the neutron irradiation of 232Th. The 232U 

impurity results in elevated gamma and beta dose rates due to the ingrowth of 

232U progeny (228Th and its progeny). Uranium from recycling operations would 

have included small activities of non-uranium isotopes such as 99Tc, 237Np, 232Th, 

106Ru, and 238Pu. There was one indication of RU processing in the case of a 

recycled 233U pellet. 

It needs to be determined if any field measurements of the radiation energy spectra were made, 

and what calibration source(s) were used by the vendors. Dosimeters calibrated using higherenergy sources, such as Co-60, may not have correctly responded to the lower-energy photons 

from the various radionuclides present at WRG. Therefore, a correction factor may be needed, 

especially for determining the dose to skin and shallow organs. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

30 of 39 

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. 

3.1.2.2 External Dose Secondary Findings 

Secondary Finding C: Burial Grounds workers and definition issue

On page 36 of the TBD it is stated: 

Remediation of the Burial Grounds 

Remediation activities of the burial grounds should be assessed based on 

individual monitoring records per guidance in Section 4 and Table 5-4. 

Because many workers changed job locations/duties frequently (an “operator” at WRG could be 

doing anything from mixing chemicals, pressing pellets, digging a ditch, or operating a 

bulldozer), it would be difficult for the dose reconstructor to determine if a specific worker was 

involved in burial grounds activities. Also, it is not clear if the term Burial Grounds includes the 

trenches and ponds, where a large of amount of the cleanup took place in the residual period, or 

just the North Burial site, as indicated in Figure 2-2 of the TBD. 

Secondary Finding D: Methods used to derive Table 5-5 not provided 

External annual exposure rates for the residual period (1971–present) are provided on page 36 of 

the TBD. Presumably, the data in this table were derived from the maximum DWE of 

578 dpm/m3

 coupled with the average depletion rate of 0.00067/day from Table 5-1. However, it 

is not stated how the values in Table 5-5 were calculated; i.e., what resuspension rate was used, 

how the penetrating versus non-penetrating doses were derived, or whether rather this residual 

contamination is on the floor, work surfaces, ground, etc., and if this includes components of 

RU. 

3.1.3 Occupational Medical Dose, Section 4 of ORAUT-TKBS-0043 

Background and Introduction 

The current version of the WRG site TBD contains a relatively short section (one paragraph on 

page 30) concerning occupational medical doses. This section recommends the use of ORAUTOTIB-0006 (ORAUT 2011b) for occupational medical dose assignment. 

Finding 6: Onsite medical x-ray exams not substantiated 

It has not been substantiated that x-ray exams were performed on site at the WRG facility during 

the AEC operational period of 1958–1970. On page 18 of the worker outreach meeting notes of 

April 2011 (ORAUT 2011c), it states: 

After some discussion, the attendees agreed that X-rays are done annually at the 

hospital in Erwin... 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

31 of 39 

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. 

SC&A’s interviews conducted in October 2012 confirmed this statement. Therefore, assigning 

offsite x-ray exams may not be consistent with ORAUT-OTIB-0079 if the exams were 

performed offsite, because ORAUT-OTIB-0079 (ORAUT 2011d), Section 2.0, page 5, states: 

If it is known that occupational medical X-ray dose was received at a location 

other than a covered facility (i.e., an offsite physician’s office, clinic, or local 

community hospital), it shall not be included in dose reconstruction. If there is 

doubt about where the X-ray exposure was received, dose reconstructors should 

assume that the dose was received at a covered facility. [Emphasis added.] 

The TBD states on page 30 that: 

To date, no site-specific information is available for W.R. Grace workers in 

relation to the type or frequency of occupationally required medical X-ray 

examinations. 

In the preliminary scanning of the DOE files for WRG claimants, SC&A has not located any 

files concerning x-ray exams, either at onsite or offsite locations. While the TBD 

recommendations are claimant favorable, to ensure consistency with other site profiles, this is an 

area that needs further verification. 

3.1.4 Occupational Environmental Dose, Section 6 of ORAUT-TKBS-0043 

Background and Introduction 

The current version of the WRG site TBD contains a relatively short section (one paragraph on 

page 37) concerning occupational environmental doses. 

Finding 7: The 2011 TBD does not adequately cover environmental doses 

Section 6 of the TBD, page 37, states: 

It is not necessary to include an environmental dose component for W.R. Grace 

worker dose because all workers are assumed to have been exposed to 

operational conditions, and dose has been assigned accordingly. 

For internal dose assignments, this statement apparently refers to: 

 Operational period – The use of the uranium intake values as listed in Table 3-15 

(derived from the 1961 air samples) for assigning unmonitored doses. The dose 

reconstructor is not to attempt to assign any dose from thorium or plutonium if the 

worker was not bioassayed (pages 10 and 25, respectively, of the TBD). 

 Residual period – The use of the uranium intake values as listed in Tables 5-2 and 5-3 

(derived from the 1961 air samples, uranium settling and resuspension factors, and 

modified by the depletion rate from Table 5-1) for assigning internal doses [for both 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

32 of 39 

 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:

bioassayed and unmonitored workers; i.e., do not use the uranium, plutonium or thorium 

bioassays (page 32), unless the worker was involved in burial ground activities, then 

apparently the DR is to only use the uranium bioassays (page 34)]. The DR may use 

uranium bioassays if adjusted by the depletion factor in Table 5-1 (page 32). 

However, these methods do not account for airborne uranium materials that were generated by 

the cleanup and processing of waste from the ponds and burial grounds during the residual 

period to which monitored, as well as unmonitored, workers may have been exposed; although, 

these workers may not be considered to have been directly involved in the cleanup activities. 

Additionally, as pointed out in a previous finding (assuming that plutonium was used in the 

weapons program), the methods recommended do not account for intakes of plutonium for 

unmonitored workers during the operational period, or plutonium during the residual period for 

both monitored and unmonitored workers. 

For external dose assignments, this statement is apparently based on: 

 Operational period – Page 26 of the TBD states: “Claimant-specific data should be used 

for analysis of the external radiation dose,” and “At one time, everyone in the W.R. 

Grace plant was badged.” 

 

 Residual period – The use of the external dose from residual uranium contamination as 

listed in Table 5-5 (derived from the 1961 air samples, uranium settling and 

resuspension factors, and modified by the depletion rate from Table 5-1) for assigning 

external doses [for both monitored and unmonitored workers; i.e., do not use external 

dose records (page 35), unless the worker was involved in burial ground activities and 

only then use the recorded external dose (page 36)]. 

However, in contrast to this, page 26 also states, “No attempt should be made to estimate 

external radiation doses for unmonitored workers during the operational period,” [emphasis 

added] and “At a later time, office workers were not assigned dosimeters.” These statements 

indicate that some workers may not have been monitored for external exposure during the 

operational and residual periods; hence, requiring coworker or environmental external dose 

assignments. 

The internal and external environmental exposures throughout the site during both the AEC 

period (1958–1970) and from the cleanup of the AEC legacy materials during the period 1971–

present are not adequately addressed.
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

33 of 39 

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. 

4.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR 

DOSE RECONSTRUCTION 

The SC&A procedures call for both a “vertical” assessment of a site profile for purposes of 

evaluating specific issues of adequacy and completeness, as well as a “horizontal” assessment 

pertaining to how the site profile satisfies its intended purpose and scope. This section addresses 

the latter objective in a summary manner by evaluation of (1) how, and to what extent, the site 

profile satisfies the five objectives defined by the Advisory Board for ascertaining adequacy; 

(2) the usability of the site profile for its intended purpose (i.e., to provide a generalized technical 

resource for the dose reconstructor when individual dose records are unavailable); and 

(3) generic technical or policy issues that transcend any single site profile that need to be 

addressed by the Advisory Board and NIOSH. 

4.1 SATISFYING THE FIVE OBJECTIVES 

The completeness, accuracy, and adequacy of data (to include data to be used for monitored 

workers’ individual DRs and data to be used in deriving coworker databases for unmonitored 

workers) should be validated to demonstrate its usefulness. SC&A has performed extensive 

document searches and found approximately 400 WRG documents. SC&A also reviewed some 

of the approximately 200 WRG claims to assess the information available in the energy 

employees’ dose records and their applicability to DR and coworker databases. In addition, 

SC&A conducted 2 days of onsite interviews with current and former WRG site workers to 

obtain information concerning working conditions and exposure potentials that may impact the 

completeness and usefulness of dose records. The following is a summary of SC&A’s 

evaluation of the present resources available (TBD, dose records, site documents, etc.) to the 

dose reconstructor for reconstruction of dose to WRG site workers with reasonable completeness 

and accuracy. 

4.1.1 Objective 1: Completeness of Data Sources 

During the review of the WRG site TBD and associated documents, SC&A found that the 

bioassay records used for DR have not been analyzed to determine that they are sufficiently 

complete and accurate for DR purposes. SC&A has not found documented evidence that there 

are missing bioassay records, but neither has this issue been addressed by NIOSH for the WRG 

site. Additionally, NIOSH has not addressed the need for creating coworker models for uranium 

and plutonium intakes in view of the lack of complete bioassay monitoring during the 

operational period. 

Because WRG was mostly a “job shop” operation (i.e., basis material in, processed, material 

out), there is not a large number of operational documents and other WRG-related documents 

available for the AEC operational period (1958–1970), especially documents detailing the 

radioactive materials used, source terms, handling, and operating conditions for AEC 

weapons/research-related activities. What information is available for the 1958–1970 

operational period does not sufficiently differentiate the AEC weapons/research processes and 

materials from the AEC non-weapons/research, commercial, and Navy processes/materials to 

allow assessment of doses related to only AEC weapons/research activities. Therefore, it 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

34 of 39 

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. 

appears that to substantiate that plutonium processed at WRG was not used in the AEC weapons 

program (and hence, not to be included in the residual period as recommended in the TBD), 

NIOSH would need to obtain government documents outside of the WRG/NFS company to 

verify the origin, destination, and ultimate use of the plutonium materials processed at the WRG 

facility during the operational period. 

4.1.2 Objective 2: Technical Accuracy 

SC&A found that the WRG TBD generally presents technically accurate information. However, 

as described in the findings in Section 3 of this report, there are numerous situations where there 

is a lack of sufficient information or investigation of an issue. As addressed in detail in the 

findings in Section 3 of this report, there is a lack of technical details concerning the accuracy of 

the recorded doses, investigation of dosimetry calibration factors, lack of neutron monitoring, 

and other recorded dose-related issues. The TBD assumes that the dose of record is complete, 

accurate, and applicable without the need for further verification or adjustments; this opens up 

the potential for incorrect and/or incomplete dose assignments. 

4.1.3 Objective 3: Adequacy of Data 

There appears to be some information concerning operating conditions and potential exposure 

conditions at WRG for use in DR. The individual dose data records are apparently available 

from NFS and the workers’ personnel files. However, as discussed in Section 3 of this report, 

there has not been any verification of the individual dose records to ensure that they are 

complete, and therefore, adequate for DR. SC&A’s preliminary review of some of the claims 

indicates that there are external and bioassay monitoring records, although some individual 

records show sporadic monitoring results, especially for internal monitoring. This indicates that 

WRG coworker models for uranium and plutonium internal intakes need to be considered for DR 

purposes. 

4.1.4 Objective 4: Consistency Among Site Profiles 

When compared to other site profiles, SC&A’s review of the WRG site profile TBD did not find 

major inconsistencies that would significantly impact DR or create claimant-unfavorable 

situations. However, SC&A did find that the WRG TBD did not recommend a method for 

assigning neutron doses, although neutron fields were listed as a potential radiation exposure 

source. On the other hand, the TBD recommended assigning occupational medical dose when it 

has not been confirmed that the x-ray examinations were conducted onsite. These 

recommendations are inconsistent with protocol for most other uranium/thorium/plutoniumhandling sites. 

4.1.5 Objective 5: Regulatory Compliance 

No regulatory compliance issues were identified by SC&A in the WRG site TBD. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

35 of 39 

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. 

4.2 USABILITY OF SITE PROFILE FOR INTENDED PURPOSES 

Because the purpose of a site profile is to support the DR process, it is critical that the site profile 

assumptions, analytic approaches, and procedural directions be clear, accurate, complete, and 

auditable (i.e., sufficiently documented). The WRG site TBD generally provided some methods 

of assessing workers’ external, internal, and occupational medical dose; however, SC&A has 

some concerns in the use of this TBD for DR as follows: 

4.2.1 Lack of Defined AEC Weapons and Research Activities During Operational Period 

What activities were considered AEC weapons- or research-related compared to the commercial 

and Navy activities at WRG during the operational period of 1958–1970 has not been well 

defined, nor does this appear to be well documented. AEC-related source terms during the 

operational period that could cause exposures in the residual period (1971–present) have not 

been sufficiently defined to ensure claimant-favorable DR. 

4.2.2 Lack of Defined Use of Plutonium During Operational Period 

To date, documentation has not been located that provides a clear description of what radioactive 

materials were used only for AEC weapons or research activities, and what was used only for 

commercial and/or Navy purposes. This information is necessary if plutonium is to be correctly 

accounted for during both the operational and residual period; this is especially applicable if 

plutonium intakes are not to be assigned during the residual period, as recommended in the 

current TBD. 

4.2.3 Incomplete Information and DR Recommendations for Neutrons 

The TBD does not sufficiently investigate the potential neutron exposures at WRG, nor does it 

make claimant-favorable recommendations to the dose reconstructor concerning assigning 

neutron doses. 

4.2.4 Location of X-ray Examinations Not Sufficiently Addressed 

The WRG site TBD does not provide any verification that the occupational medical x-ray 

exposures received by WRG workers occurred on the WRG property in order to recommend 

assigning dose according to ORAUT-OTIB-0006 (ORAUT 2011b). This is in conflict with 

recommendations in ORAUT-OTIB-0079 (ORAUT 2011d) that recommends not assigning 

occupational medical dose if it is known that the exams were performed offsite. 

4.3 UNRESOLVED POLICY OR GENERIC TECHNICAL ISSUES 

A number of issues identified in the WRG site TBD review represent potential generic policy 

issues that transcend other individual site profiles. These include a lack of analyses of recorded 

dose and bioassay data for adequacy/accuracy, lack of sufficient environmental data for onsite 

unmonitored workers, insufficient knowledge/documentation of some source terms and radiation 

fields (especially neutrons), lack of dosimetry geometry factors, and lack of addressing the need 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

36 of 39 

 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:

for coworker models for uranium and plutonium intakes. Additionally, there is a lack of 

information concerning the types, frequency, doses, and location of occupational medical x-ray 

exams. These issues are discussed in detail as findings in Section 3 of this report.
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

37 of 39 

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. 

5.0 REFERENCES 

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction under the Energy Employees 

Occupational Illness Compensation Program Act of 2000, Code of Federal Regulations, May 2, 

2002. 

AEC (U.S. Atomic Energy Commission) 1959. Davison Chemical Company, Nuclear Reactor 

Materials Plant, Erwin, Tennessee: Occupational Exposure to Radioactive Dust, HASL-75, 

Health and Safety Laboratory, Environmental Sciences Division, Field Services Branch, 

November. [SRDB Ref ID: 11771] 

AEC (U.S. Atomic Energy Commission) 1961. Davison Chemical Company, Nuclear Reactor 

Materials Plant, Erwin, Tennessee: Occupational Exposure to Radioactive Dust, HASL 

Technical Memorandum 61-9, Health and Safety Laboratory, Health Protection Engineering 

Division, August. [SRDB Ref ID: 11771] 

AEC 1966. Annual Report to Congress of The Atomic Energy Commission, 1965. Atomic 

Energy Commission, Washington, D.C. January 1966. 

DOE 2004. Guide of Good Practices for Occupational Radiological Protection in Uranium 

Facilities, DOE-STD-1136-2000, U.S. Department of Energy, Washington, D.C., December 

2004. [SRDB Ref ID: 4617] 

DOE 2006. Guide of Good Practices for Occupational Radiological Protection in Plutonium 

Facilities, DOE-STD-1128-98, Change Notice 2, U.S. Department of Energy, Washington, D.C., 

December 2006. [SRDB Ref ID: 34061] 

Leavitt 2007. Leavitt, M. (Secretary of HHS), HHS Designation of Additional Members of the 

Special Exposure Cohort under the Energy Employees Occupational Illness Compensation 

Program Act, Designating a Class of Employees, W. R. Grace, Erwin, Tennessee, U.S. 

Department of Health and Human Services, Office of the Secretary, Washington, D.C., June 22, 

2007. [SRDB Ref ID: 97820] 

Leiton 2011. Leiton, R. (U.S. Department of Labor) untitled letter to Hinnefeld, S. (National 

Institute for Occupational Safety and Health, Division of Compensation Analysis and Support), 

U.S. Department of Labor, Office of Workers’ Compensation Programs, Washington, D.C., 

April 20, 2011. [SRDB Ref ID: 94298] 

NFS 2006. E-mail exchanges between OCAS Health Physicist (Nelson, C.) and Nuclear Fuel 

Services (NFS) (Tester, M.) regarding thorium work at W. R. Grace; June 13, 2006. [SECIS ID: 

128] 

NIOSH 2004. OCAS-TIB-009 Estimation of Ingested Intakes, Rev. 0, National Institute for 

Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. April 13, 2004. 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

38 of 39 

 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:

NIOSH 2007. SEC Petition Evaluation Report SEC-00082, Office of Compensation Analysis 

and Support, National Institute for Occupational Safety and Health Cincinnati, Ohio, March 26, 

2007. [SRDB Ref ID: 41324] 

NIOSH 2008. Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Appendix C - Dow Chemical Co. (Madison Site), Battelle-TBD-6000 Appendix C, Rev. 

0, Office of Compensation Analysis and Support, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio, September 8, 2008. 

NIOSH 2010. DCAS-TIB-0010, Technical Information Bulletin: Best Estimate External Dose 

Reconstruction Considerations for Glovebox Workers, Rev. 3, National Institute for 

Occupational Safety and Health, Division of Compensation Analysis and Support, Cincinnati, 

Ohio. June 18, 2010. 

ORAUT 2006. Technical Basis Document – An Exposure Matrix for the W. R. Grace and 

Company in Erwin, Tennessee, Rev. 00, ORAUT-TKBS-0043. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. February 14, 2006. 

ORAUT 2008. Technical Basis Document – An Exposure Matrix for the W. R. Grace and 

Company in Erwin, Tennessee, Rev. 01, ORAUT-TKBS-0043. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. July 16, 2008. 

ORAUT 2011a. Technical Basis Document – An Exposure Matrix for the W. R. Grace and 

Company in Erwin, Tennessee, Rev. 02, ORAUT-TKBS-0043. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. September 16, 2011. 

ORAUT 2011b. ORAUT-OTIB-0006, Technical Information Bulletin: Dose Reconstruction 

from Occupationally Related Diagnostic X-Ray Procedures, Rev. 04, Oak Ridge Associated 

Universities, Cincinnati, Ohio. June 20, 2011. 

ORAUT 2011c. Public Outreach Meeting with United Steelworkers of America Minutes, Oak 

Ridge Associated Universities Team, Oak Ridge, Tennessee. April 6, 2011. 

ORAUT 2011d. ORAUT-OTIB-0079, Technical Information Bulletin: Guidance on Assigning 

Occupational X-Ray Dose Under EEOICPA for X-Rays Administered Off Site, Rev. 00, Oak 

Ridge Associated Universities Team: Cincinnati, Ohio. January 3, 2011.

SC&A 2004. Site Profile Review Procedures, Prepared for the Advisory Board on Radiation and 

Worker Health by S. Cohen and Associates, McLean, Virginia. May 13, 2004. 

Tester 2005. Tester, M. (NFS), “OCAS conference call,” documented conference call between 

Nuclear Fuel Services and the Office of Compensation Analysis and Support, National Institute 

for Occupational Safety and Health Cincinnati, Ohio. August 11, 2005. [SRDB Ref ID: 18803] 
Effective Date: 

 January 16, 2013 

Revision No. 

0 

Document No. 

SCA-TR-SP2013-0041 

Page No. 

39 of 39 

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: SITE EXPERT INTERVIEW SUMMARY 

(The site interview summary will be provided as an amendment to this report)