Draft

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

DCAS-PER-073, “BIRDSBORO STEEL AND FOUNDRY 

COMPANY” 

Contract No. 211-2014-58081 

SCA-TR-2018-PR003, Revision 0 

Prepared by

Robert Anigstein, PhD 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, VA 22201-3324 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

June 2018 

DISCLAIMER

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

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

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

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

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

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

issues.

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

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

Worker Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: A Review of NIOSH’s Program Evaluation Report DCAS-PER073, “Birdsboro Steel and Foundry Company”

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2018-PR003 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: June 7, 2018

TASK MANAGER Robert Anigstein, PhD [signature on file]

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

DOCUMENT 

REVIEWER(S):

John Mauro, PhD, CHP [signature on file]

Kathleen Behling [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date

Description of Revision

0 (Draft) 6/7/2018 Initial issue
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TABLE OF CONTENTS

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

1 Statement of Purpose ............................................................................................................. 6

2 Subtask 1: Assess NIOSH’s Evaluation and Characterization of the Issues that Necessitated 

DCAS-PER-073 and Its Potential Impacts on DR ................................................................. 8

2.1 Background ................................................................................................................. 8

2.2 Appendix B, Rev. 0 ..................................................................................................... 8

2.2.1 Name of Facility ............................................................................................ 8

2.2.2 Occupational Internal Dose ............................................................................ 9

2.2.3 Occupational External Dose ........................................................................ 10

2.3 Appendix B, Rev. 1 ................................................................................................... 10

2.4 DCAS-PER-073 ........................................................................................................ 11

2.5 Reviewer’s Comments .............................................................................................. 11

3 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ................................ 12

3.1 Site Activities............................................................................................................ 12

3.1.1 Reviewer’s Comments ................................................................................. 12

3.2 Revised Occupational Internal Dose ......................................................................... 13

3.2.1 Inhaled Intakes ............................................................................................. 13

3.2.2 Ingested Intakes ........................................................................................... 14

3.3 Revised Occupational External Dose ........................................................................ 16

3.3.1 Reviewer’s Comments................................................................................. 16

4 Subtask 3: Evaluate the PER’s Stated Approach for Identifying the Number of Dose 

Reconstructions Requiring Reevaluation of Dose ............................................................... 19

4.1 Reviewer’s Comments .............................................................................................. 19

5 Subtask 4: Conduct Audits of a Sample Set of Dose Reconstructions Affected by 

DCAS-PER-073 ................................................................................................................... 21

5.1 Selection of Dose Reconstructions ............................................................................ 21

6 References ............................................................................................................................ 22

Appendix A – Interview Report .................................................................................................... 25
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ABBREVIATIONS AND ACRONYMS

Board or 

ABRWH Advisory Board on Radiation and Worker Health

Co cobalt

DCAS NIOSH Division of Compensation Analysis and Support

DOL U.S. Department of Labor

dpm disintegrations per minute

DR dose reconstruction

DWA daily weighted average

EE energy employee

EEOICPA Energy Employees Occupational Illness Compensation Program Act

FMPC Feed Material Production Center

GSI General Steel Industries, Inc. 

H*(10) ambient dose equivalent

ICRP International Commission on Radiological Protection

IMBA Integrated Modules for Bioassay Analysis

kVp kilovolts peak

LOOW Lake Ontario Ordinance Works

mCi millicurie

MCNPX Monte Carlo N-Particle eXtended

mR milliroentgen

mrem millirem

MV megavolt

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH OCAS Claims Tracking System

OCAS Office of Compensation Analysis and Support

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT technical information bulletin

PA postero-anterior

pCi picocurie

PER program evaluation report
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PIC pocket ionization chamber

POC probability of causation

R roentgen

Ra radium

RF resuspension factor

SEC Special Exposure Cohort

TBD technical basis document

TIB technical information bulletin

U uranium
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1 STATEMENT OF PURPOSE

To support dose reconstruction (DR), the National Institute for Occupational Safety and Health 

(NIOSH) and the Oak Ridge Associated Universities Team (ORAUT) have assembled a large 

body of guidance documents, workbooks, computer codes, and tools. In recognition of the fact 

that all of these supporting elements in DR may be subject to revisions, provisions exist for 

evaluating the effect of such programmatic revisions on the outcome of previously completed 

DRs. Such revisions may be prompted by document revisions due to new information, 

misinterpretation of guidance, changes in policy, and/or programmatic improvements. 

The process for evaluating potential impacts of programmatic changes on previously completed 

DRs has been proceduralized in OCAS-PR-008, Revision 2, “Preparation of Program Evaluation 

Reports and Program Evaluation Plans” (NIOSH 2006), dated December 6, 2006. This procedure 

describes the format and methodology to be employed in preparing a program evaluation report 

(PER).

A PER provides a critical evaluation of the effects that a given issue or programmatic change 

may have on previously completed DRs. This includes a qualitative and quantitative assessment 

of potential impacts. Most important in this assessment is the potential effect on the probability 

of causation (POC) of previously completed DRs with POCs of <50%. 

During a meeting of the Advisory Board on Radiation and Worker Health (ABRWH) on 

December 14, 2017, in Albuquerque, New Mexico, SC&A was tasked by the Board to conduct 

reviews of two PERs, one of which is a Subtask 1–3 review of DCAS-PER-073, “Birdsboro 

Steel and Foundry Company” (NIOSH 2016). In conducting this PER review, SC&A is 

committed to perform the following three subtasks, each of which is discussed in this report: 

• Subtask 1: Assess NIOSH’s evaluation and characterization of the issues and their 

potential impacts on DR. Our assessment intends to ensure that the issues were fully 

understood and characterized in the PER. 

• Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where the 

PER involves a technical issue that is supported by documents (e.g., white papers, 

technical information bulletins [TIBs], and procedures) that have not yet been subjected 

to a formal SC&A review, Subtask 2 will include a review of the scientific basis and/or 

sources of information to ensure the credibility of the corrective action and its 

consistency with current/consensus science. Conversely, if such technical documentation 

has been formalized and previously subjected to a review by SC&A, Subtask 2 will 

simply provide a brief summary of this review process.

• Subtask 3: Evaluate the PER’s stated approach for identifying the universe of potentially 

affected DRs, and assess the criteria by which a subset of potentially affected DRs was 

selected for reevaluation. The second step may have important implications in instances 

where the universe of previously denied DRs is very large and, for reasons of practicality, 

NIOSH’s reevaluation is confined to a subset of DRs that, based on their scientific 

judgment, have the potential to be significantly affected by the PER. In behalf of 

Subtask 3, SC&A will also evaluate the timeliness of the completion of the PER.
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• Subtask 4: Conduct audits of DRs affected by the PER under review. 

The present review will encompass Subtasks 1–3, which have been authorized by the ABRWH. 

This review will also recommend criteria for selecting cases for future Subtask 4 audits.
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2 SUBTASK 1: ASSESS NIOSH’S EVALUATION AND

CHARACTERIZATION OF THE ISSUES THAT NECESSITATED 

DCAS-PER-073 AND ITS POTENTIAL IMPACTS ON DR

2.1 BACKGROUND

On December 13, 2006, Battelle (2006) issued TBD-6000, Rev. 0, a technical basis document 

(TBD) for use in reconstructing doses to workers at Atomic Weapons Employers that worked 

uranium and thorium metals. This was a generic document to be used in the absence of casespecific or site-specific data. Prior to that time, DRs for such workers utilized more generic 

documents and methods, such as ORAUT-OTIB-0004 (ORAUT 2003). 

To facilitate DRs for work sites for which more detailed information was required, NIOSH 

prepared or commissioned a series of appendices to TBD-6000. These appendices constituted 

site profiles, which supplemented or replaced the generic data and guidance provided by TBD6000. One such document was Appendix B, Rev. 0, a site profile of the Birdsboro Steel Foundry 

and Machine Company (Battelle 2007). 

On June 17, 2011, the NIOSH Division of Compensation Analysis and Support (DCAS) issued 

TBD-6000, Rev. 1 (NIOSH 2011). Subsequent to this revision, NIOSH revised some of the 

previously issued appendices to ensure consistency with the revised TBD. One such revision was 

Appendix B, Rev. 1 (NIOSH 2015). On August 1, 2016, NIOSH (2016) issued a program 

evaluation report (DCAS-PER-073) that examined the effects of the revised appendix on all 

previously completed claims. 

In order to assess the PER, we needed to review the changes implemented by Appendix B, 

Rev. 1. That, in turn, required an understanding of Appendix B, Rev. 0. Since neither document 

was previously reviewed by SC&A, we examined these reports in the course of our PER review. 

2.2 APPENDIX B, REV. 0 

We began our review with Appendix B, Rev. 0 (Battelle 2007). Appendix B, Rev. 0 (Battelle 

2007), described the shipment of 346 pounds of uranium waste from Birdsboro to the Lake 

Ontario Ordinance Works (LOOW) (mistakenly identified as “Lake Ontario Ordinance Waste”) 

in 1951, and the receipt by Birdsboro of four wafers cut from uranium rods, with a combined 

weight of 11.5 lb.1

1 This was actually the weight of five wafers received by Birdsboro (Smith 1952).

 Appendix B specified four job categories—“Plant Floor High,” “Plant Floor 

Low,” “Supervisor,” and “Clerk”—that corresponded to the four worker categories in TBD6000: “Operator,” “General Laborer,” “Supervisor,” and “Clerical.” Appendix B also specified 

that occupational medical dose be assigned according to ORAUT (2005), the same guidance that 

was provided by TBD-6000. 

2.2.1 Name of Facility

In reviewing contemporary and historical documents, we noted a change in the name used to 

refer to this facility. Historical documents contemporaneous with the operational period refer to 

 
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the facility as “Birdsboro Steel Foundry & Machine Company” (Smith 1952) or “Birdsboro Steel 

Foundry and Machine Company.” Young (1987) appears to be the earliest reference to call the 

site “Birdsboro Steel & Foundry,” while correctly referring to the owner as the “Birdsboro Steel 

Foundry & Machine Company.” This mistaken appellation of the site was perpetuated in later 

Department of Energy documents and was adopted by NIOSH in the titles of Appendix B, Rev. 0 

and Rev. 1. 

Observation 1 

We suggest that NIOSH refer to the site as the “Birdsboro Steel Foundry and Machine 

Company.” 

2.2.2 Occupational Internal Dose

To assess internal dose, Appendix B, Rev. 0 (Battelle 2007), assigned intakes of 234U per 

calendar day for each year of the operational period, assuming that operator exposures in 1951 

corresponded to those of a rolling operator and lasted 40 hours, while the 1952 exposures 

corresponded to those of a machining operator and lasted 8 hours. The inhaled intakes were 

calculated from the daily weighted average (DWA) air concentrations for rolling and machining 

operators listed in TBD-6000 (Battelle 2006, Tables 7.3 and 7.5). Intakes for the other job 

categories were based on the fractions of the exposure durations for these jobs: 

• Plant Floor High: 100% 

• Plant Floor Low: 50% 

• Supervisor: 25% 

• Clerk: 2.5% 

SC&A confirmed that the inhaled intakes tabulated in Appendix B, Rev. 0 (Battelle 2007, 

Table B.2), were derived according to the methodology described in that document. 

In Appendix B, Rev. 0, Battelle (2007, Table B.3) stated that it assigned daily ingested intakes of 

234U based on the “Generic Metal TBD” (i.e., TBD-6000, Battelle 2006). An explanatory note 

cited a conversion factor listed in TBD-6000, section 7.1.6. The latter document presented a 

formula for daily ingested intake to be entered into the Integrated Modules for Bioassay Analysis 

(IMBA). We applied this formula to derive the intakes of a rolling operator: 

IIMBA = 3.062 × 10-5 Ah

where

IIMBA = ingested intake

= 4.33 pCi/calendar day (1951) 

= 1.34 pCi/calendar day (1952) 

A = air concentration

= 3,533 dpm/m3 (rolling) 

= 5,480 dpm/m3 (machining)
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h = annual work hours 

= 40 h (1951) 

= 8 h (1952) 

Comparing our values with the ingested intakes of 234U listed in Appendix B, Rev. 0 (Battelle 

2007, Table B.3)—1.95 pCi/d in 1951 and 0.605 pCi/d in 1952—we find that both values were 

lower than the corresponding values derived above by a factor of 2.22, which is the factor for 

converting activities in disintegrations per minute (dpm) to picocuries (pCi). It would appear that 

Battelle (2007) mistakenly divided the derived results by 2.22 to convert to pCi, despite the fact 

that, as stated by Battelle (2006, section 7.1.6), the formula in TBD-6000 already incorporated 

that conversion factor to yield a result in pCi. Thus, the ingested intakes listed in Appendix B are 

less than one-half the values that would have been obtained by correctly applying the 

methodology in TBD-6000. 

2.2.3 Occupational External Dose 

According to Appendix B, Rev. 0 (Battelle 2007), external doses were calculated on the basis of 

the “Generic Metal TBD” (i.e., TBD-6000, Battelle 2006). Table B.4 of the former document 

listed external whole-body exposures to an operator as 0.0312 and 0.00625 mR per calendar day 

in 1951 and 1952, respectively. We attempted to confirm these values by using the value of 

6.27 mrem/d listed in TBD-6000 (Battelle 2006, Table 6.4) as the whole-body dose to an 

operator for 1951–1955. (The table listed the same value for all operations. The other 

contributions, from air submersion and exposure to a contaminated floor, are insignificant by 

comparison.) Since the listed value corresponds to a 2,200-h work year, we prorated the 

exposures to account for 40 h of work in 1951 and 8 h in 1952. We obtained values of 0.114 and 

0.0228 mrem per calendar day, almost 4 times higher than those in Appendix B, Rev. 0 (Battelle 

2007, Table B.4). We cannot explain this discrepancy. 

2.3 APPENDIX B, REV. 1 

Appendix B, Rev. 1 (NIOSH 2015) was issued on June 2, 2015. The new document was a 

complete rewrite of the original appendix and reflected a reappraisal of the site history and 

operations. We will briefly examine the differences between Appendix B, Rev. 0 and Rev. 1. 

A more detailed analysis of Rev. 1 was performed under Subtask 2 of the present review and 

reported in section 3. 

Table 1 presents a comparison of the exposure pathways in the two documents. For the purpose 

of this comparison, the intakes in Appendix B, Rev. 1, which were stated in terms of dpm per 

calendar day, but limited to the actual period of operations during 1951, are scaled to the entire 

year and displayed in pCi/d. As shown in the table, both the inhaled intakes and the external 

exposures are higher in Rev. 0 than in Rev. 1. However, the ingested intakes in Rev. 1 are higher 

by one to two orders of magnitude. 
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Table 1. Comparison of Exposure Pathways in Appendix B, Rev. 0 and Rev. 1 

Year Inhaled intake (pCi/d) Ingested intake (pCi/d) External exposure (mrem/y)

Rev. 0 Rev. 1 Rev. 0 Rev. 1 Rev. 0 Rev. 1

1951 209 42.93 1.95 30.68 11.42 10.4

1952 64.92 45.72 0.605 154.50 2.28 1.28

2.4 DCAS-PER-073 

It was not possible to determine ab initio whether the doses to a particular organ or tissue in a 

particular DR would go up or down as a result of the revision to Appendix B (NIOSH 2015). For 

cancers involving the respiratory tract, the time-dependent dose coefficients for inhaled 

particulates of 234U are three or more orders of magnitude higher than for the ingestion pathway 

(ICRP 2001). In such cases, the higher inhaled intakes prescribed by Appendix B, Rev. 0 

(Battelle 2007), would outweigh the effect of the lower ingested intakes, and the use of the 

earlier document would be more claimant favorable. However, this is not true for other tissues. 

Therefore, given the very large discrepancy between the ingested intake rates of Appendix B, 

Rev. 0 and Rev. 1, NIOSH needed to review any DRs that had been performed using the earlier 

methodology that had been denied because the POC was less than 50%. On August 1, 2016, 

NIOSH (2016) issued PER-073. 

2.5 REVIEWER’S COMMENTS

The operational period at Birdsboro spanned only two years: 1951 and 1952. In both years, the 

ingested intakes prescribed by Appendix B, Rev. 1 (NIOSH 2015), were significantly higher than 

those listed in Rev. 0 (Battelle 2007). Consequently, it was not possible to exclude any cases by 

period of employment. Given that DRs had been performed for only four former Birdsboro 

employees, NIOSH made the expedient decision to perform new DRs for all four cases under the 

PER.
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3 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

The reason stated by NIOSH (2015) for revising Appendix B was to conform to the revision to 

TBD-6000 (NIOSH 2011). A comparison of the revised TBD to the original version (Battelle 

2006) shows that there were no significant changes in the exposure pathways for organs other 

than skin that would affect the Birdsboro site profile. However, NIOSH did perform a 

fundamental revision of the exposure scenarios, based on a reassessment of the handling and 

working of uranium metal at Birdsboro, resulting in major changes in the exposure scenarios. 

Another fundamental change was in the methodology used to assess the ingestion pathway. 

3.1 SITE ACTIVITIES

Both Appendix B, Rev. 0 (Battelle 2007), and Appendix B, Rev. 1 (NIOSH 2015), cited the role 

of Birdsboro in designing a uranium rolling mill for use at the Feed Materials Production Center 

(FMPC) in Fernald, Ohio. As discussed in section 2.2 of the present review, Battelle cited the 

shipment of eight assorted pieces of uranium billets, weighing 346 lb, from Birdsboro to LOOW 

in 1951 and assumed that these uranium pieces had been rolled at Birdsboro. Battelle assumed 

that the work took one week (40 h). Battelle noted that, in a telephone interview, a claimant said 

that Birdsboro “built a press to crush and press uranium” (NIOSH 2003a). Battelle concluded 

that the 11.5 lb of uranium wafers received by Birdsboro in 1952 were used in the development 

of uranium slug design, and that the work took one day (8 h). 

In Appendix B, Rev. 1, NIOSH (2015) postulated that Birdsboro had received the uranium metal 

in order to perform microscopic analyses of the metal surfaces. NIOSH assumed that Birdsboro 

cut the pieces to prepare samples for the analyses, and that the work took one-fifth of the 44-h 

workweek assumed for this time period (NIOSH 2011). NIOSH (2015) postulated that Birdsboro 

received the billets on April 17, 1951, the earliest date that billets were produced at Simonds Saw 

and Steel Co. in support of the design of the FMPC rolling mill. The machining of the billets at 

Birdsboro was assumed to take place on the same day. The machining of the five wafers was 

assumed to take place on February 1, 1952, the day the pieces were shipped to Birdsboro. 

3.1.1 Reviewer’s Comments

The assumption in Appendix B, Rev. 0 (Battelle 2007), regarding the rolling of uranium billets, 

is reasonable, since Birdsboro was responsible for designing a uranium rolling mill for use at the 

FMPC. According to the Steel Founders’ Society of America (1961), Birdsboro operated a roll 

foundry in 1961. Detailed information for earlier years is not readily available, but it is 

reasonable to assume that the roll foundry was present during the covered period, which was why 

Birdsboro was selected to design the rolling mill at Fernald. The assumption that the rolling took 

one week is a claimant-favorable, high-end estimate. To cite a randomly selected example, 

Taussig (1948) stated that the Joslyn Manufacturing and Supply Co., then under contract to the 

Atomic Energy Commission, could roll 35 tons of uranium rods in 5 d. However, this was the 

capability of an experienced facility operating in production mode. The work at Birdsboro was 

developmental, so the throughput would likely have been much lower. Battelle (2007) described 

the shipment to LOOW as waste, although this designation does not appear in either Malone 

(1951a) or Malone (1951b), the only available references for this shipment. This description 
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most likely originated with the mistaken identification of the acronym as “Lake Ontario 

Ordinance Waste” rather than Lake Ontario Ordinance Works. Since eight billets could have 

been easily rolled in one day, the duration of work assumed in Appendix B, Rev. 1 (NIOSH

2015), is also reasonable and more likely than a 1-week duration. 

Observation 2 

The statement that TBD-6000 assumed that the standard workday was 8.8 hours is based on a 

misinterpretation. In fact, TBD-6000 assumed a 44-h week, which was based on working 8 h/d 

Monday–Friday and working half a day (4 h) on Saturday (Sopher 2014). 

It is more plausible and, as will be shown, claimant favorable, to assume that Birdsboro used the 

346 lb of billets for rolling than to assume it acquired these pieces, with an average weight of 

43 lb, for microscopic examination. However, that is a likely assumption for the wafers that were 

received in 1952. Smith (1952) stated that these samples, which were 1–2 inches thick and 

weighed between 1.9 and 2.6 lb, were cut from a rolling at the Bethlehem Steel plant in 

Lackawanna, New York. Such uranium pieces would have been between 1.3 and 2.2 inches in 

diameter, which is consistent with the reported diameter of 1.41 inches of rods rolled at 

Lackawanna (Kattner and Riches 1951). 

Although it would have a trivial effect on the estimated doses, we observe that the assumed dates 

of operations are implausible. If the billets were rolled at Simonds Saw and Steel in Lockport, 

New York, on April 17, 1951, it is implausible that they could have been machined on the same 

day at Birdsboro, which is over 300 miles away, especially since the machining was assumed to 

take an entire workday. A more likely date would be April 19, 1951, allowing one day for 

shipment after the rolling. Likewise, the wafers were shipped by Railway Express, a commercial 

carrier, from Model City, New York, also over 300 miles from Birdsboro, on February 1, 1952, 

which fell on a Friday. It is implausible that they could have been machined at Birdsboro on the 

same day. The earliest plausible date would be February 4, the following Monday. 

Observation 3 

We recommend that NIOSH adopt April 19, 1951, as the date for processing the 346 lb of billets 

and April 19, 1951, for working on the five wafers. 

3.2 REVISED OCCUPATIONAL INTERNAL DOSE

3.2.1 Inhaled Intakes

In Appendix B, Rev. 1, NIOSH (2015) assumed an air concentration with a geometric mean of 

3,160 dpm/m3

 during operations in both 1951 and 1952. This concentration was based on a 

review of the air sampling data tabulated in TBD-6000 (NIOSH 2011, section 7.1.2). Having 

dismissed both rolling and centerless grinding as operations that did not take place at Birdsboro, 

NIOSH (2015) selected the DWA for the surface grinder listed in TBD-6000, Table 7.5, the next 

highest DWA concentration listed in Tables 7.2–7.7. The inhaled intakes were based on exposure 

to this concentration for 8.8 h in each year. NIOSH (2015) also assumed that this airborne 

activity settled to the floor during this period of operations at a rate of 0.00075 m/s, resulting in a 

surface contamination of 75,082 dpm/m2

. This activity then became resuspended. Using a 

resuspension factor (RF) of 1 × 10-5 m/s, NIOSH derived an airborne activity of 0.751 dpm/m3, 
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which it used to calculate intakes during the working hours following the first operation in 1951 

until the second operation in 1952. The second surface grinding operation, assumed to have 

taken place on February 1, 1952, again generated airborne activity that settled to the floor, 

doubling the previous level of surface contamination, which in turn doubled the airborne activity 

due to resuspension during the remainder of the operational period (i.e., until the end of 1952). 

Reviewer’s Comments

NIOSH (2015, Table B.1) listed “other work hours,” the hours of exposure to resuspended 

airborne activities. According to Allen (2018), this value for 1951 was calculated by multiplying 

2,200, the work hours in the full year, by the fraction of the year the uranium was on site—from 

the time it was assumed to arrive until the end of the year. The “other work hours” in 1952 were 

calculated by using the ratios of the months—1 month before the wafers arrived and 11 months 

after they arrived—to 12 months in a year. This resulted in a slight double accounting: the 

workers were exposed to intakes of resuspended activities during the same time that the activities 

generated by the metal work were settling.

We performed a revised analysis of the inhaled intakes, assuming an airborne concentration of 

3,533 dpm/m3

, which is the DWA of a rolling operator that was used in Appendix B, Rev. 0, 

during an 8-h workday on April 19, 1951. We assumed that this activity settled out during an 8-h 

period, resulting in a surface contamination of 76,313 dpm/m2, which in turn resulted in a 

resuspended airborne concentration of 0.761 dpm/m3. The rest of the intake calculations 

paralleled those performed by NIOSH, except that we assumed that the surface grinding of the 

wafers took place on February 4, 1952, and that the workdays were 8 h on weekdays and 4 h on 

Saturdays. We calculated the actual workweeks following the rolling or machining of the 

uranium, based on the calendar, for assessing intakes of resuspended activities. The net result of 

this revision is an increase in the total intake in 1951 but a decrease in 1952, for a decrease of 

~3.4% in the total inhaled intakes for both years. 

Observation 4 

The methodology used by NIOSH had the net effect of slightly overestimating the inhaled 

intakes of uranium. 

3.2.2 Ingested Intakes

According to Appendix B, Rev. 1 (NIOSH 2015), OCAS-TIB-009 (NIOSH 2004) is not suitable 

for estimating ingested intakes because the uranium machining operations were of short duration, 

which did not allow the uranium airborne and surficial activities to achieve equilibrium. Instead, 

NIOSH estimated ingestion on the basis of the surface contamination levels cited in section 3.2.1

of the present review, assuming an ingestion rate of 1.1 × 10-4 m2

/h, citing NUREG/CR-5512 

(Kennedy and Strenge 1992) as a reference. The resulting ingested intakes are listed in Table 1 in 

the present review.
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Reviewer’s Comments

NIOSH (2004) cited three pathways that contribute to the ingested intakes. The first (Mode 1)—

the ingestion of material that is originally inhaled—is included in the inhalation pathway and 

needs not be considered further. The second (Mode 2) is the deposition of the airborne activity 

on a beverage cup, and the third (Mode 3) is the hand-to-mouth transfer from a contaminated 

surface. During a prolonged operational period, the latter two pathways make approximately 

equal contributions. During times when there are no uranium operations, the airborne uranium 

activity concentration is greatly reduced—0.751 vs. 3,160 dpm/m3, according to the NIOSH 

model cited in section 3.2.1 of the present review—so that the contribution of Mode 2 can be 

neglected. However, the Mode 3 pathway can be applied in the present case. 

NIOSH (2004) developed a method for calculating the Mode 3 contribution that assumed that 

each workday a worker ingested 10% of the activity on his hand, which was assumed to have an 

area of 4 × 6 inches, or 0.0155 m2. The surficial activity on the hand was equal to that on the 

surface contaminated by uranium aerosol deposition. Applying this method to the surface 

contamination level of 75,082 dpm/m2 derived by NIOSH, cited in section 3.2.1 of the present 

review, we obtained a daily ingestion rate of 116 dpm, or 14.5 dpm/h for an 8-h day during 1951, 

compared to 8.26 dpm/h listed by NIOSH (2015, Table B.2). 

There are several reasons for adopting this alternative methodology: 

• It is consistent with the model developed by NIOSH (2004), which has been reviewed by 

the ABRWH and cited in numerous site profiles. 

• It is consistent with assessments of ingestion rates during residual periods at other 

worksites (e.g., General Steel Industries [GSI], Carborundum, Hooker Electrochemical), 

where the ingestion rate during the operational period was assigned to the start of the 

residual period. (This actually resulted in overestimates, since the Mode 2 pathway 

should not be carried over when the airborne activity is greatly attenuated.) 

• It is claimant favorable, resulting in an intake rate that is 76% higher than the method 

employed by NIOSH (2015). 

Observation 5 

NIOSH used an ingestion rate that is inconsistent with rates used in exposure assessments for 

other worksites that were based on OCAS-TIB-009 and is not claimant favorable. This is an 

overarching issue that applies to other sites (e.g., the Evaluation Report on the Metals and 

Controls Special Exposure Cohort [SEC 236]) and should be addressed in a wider context. 

Observation 6 

NIOSH erroneously cited the source of the ingestion rate of 1.1 × 10-4 m2

/h as NUREG/CR5512, Vol. 1 (Kennedy and Strenge 1992). Kennedy and Strenge cited an approximate value of 

1 × 10-4 m2/h, based on four published results: two cited sources listed a value of 1 × 10-3 m2/h, 

while the other two cited 1 × 10-4 m2

/h. The value of 1.1 × 10-4 m2/h used by NIOSH was based 

on Beyeler et al. (1996), who performed a detailed study of ingestion rates and found this to be 

the average value of a derived probability density function. 
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3.3 REVISED OCCUPATIONAL EXTERNAL DOSE

In Appendix B, Rev. 1, NIOSH (2015) assumed that an operator handled uranium metal for 

1 week during 1951 and again in 1952—an exposure duration of 44 h, the assumed workweek 

during those years. The worker was assumed to be at a distance of 1 ft from the metal during 

one-half of this time. The external exposure of an operator handling uranium metal in 1951 was 

based on the dose rate from a short billet, as listed in TBD-6000 (NIOSH 2011, Table 6.1). The 

worker was thus assumed to receive this dose rate—0.469 mrem/h—during 22 h. During 1952, 

the dose rate was that from a slug—0.0524 mrem/h. NIOSH (2015, Table B.4) lists total photon 

doses of 10.3 and 1.15 mrem in 1951 and 1952, respectively. 

3.3.1 Reviewer’s Comments

We disagree with the choice of uranium shapes selected to assign doses to the operator. Since, as 

stated by NIOSH (2015), the billets were produced from 5-inch diameter ingots and were 

somewhere between the thickness of a rod and a 5-inch ingot, these billets are more properly 

represented by a long billet. The dose rates in TBD-6000 (NIOSH 2011, Table 6.1) are taken 

from Anderson and Hertel (2005). Table 1 of that paper describes the uranium metal shapes used 

in the dose rate calculations. The short billet has a radius of 7.62 cm, which is equal to a diameter 

of 6 inches, whereas the long billet has a radius of 6.35 cm, or a diameter of 5 inches. 

Furthermore, using the dimensions of the long billet listed by Anderson and Hertel, we calculate 

a mass of 170.7 kg (376 lb), close to the total reported weight of the uranium pieces: 346 lb. 

Thus, the long billet, for which Table 6.1 lists a dose rate of 0.703 mrem/h, is the more 

appropriate choice of the source of external exposure in 1951. The slug is described by Anderson 

and Hertel (2005, Table 1) as a hollow cylinder with an inner radius of 1.041 cm, an outer radius 

of 2.108 cm, and a length of 10.16 (4 inches). It is not a good representative of the wafers, which 

are described as cylindrical slices, 1–2 inches thick cut from rods. A better surrogate is the flat 

plate, which measured 3.1 × 18 × 0.18 inches. It had a dose rate at 1 ft of 0.231 mrem/h, more 

than 4 times higher than the slug. It weighs ~7 lb, which is consistent with the 11.5-lb weight of 

the five wafers. The operator might have been exposed to more than one wafer at the same time.

A much more serious issue arises from the fact that NIOSH ignored other sources of external 

exposure that were present at Birdsboro at the time of the uranium work. According to records of 

telephone interviews with the survivors of one energy employee (EE) (NIOSH 2003b), the EE 

worked as an who operated various , 

including a . According to the interview report: “

.” Furthermore, “ 

 from a bucket lifting out a source 

with a pole from the bucket. There is a radioactive sign next to it. In another photograph, 

.” These accounts match the use of 226Ra sources using the 

“fishpole” technique illustrated by Anigstein (2010, Figs. 3 and 4). A recent interview with a 

former Birdsboro employee, reported in Appendix A of the present review, confirms the 

information on radiographic sources. 

Records obtained from the archives of the University of Illinois at Urbana–Champaign include a 

list of Allis-Chalmers betatrons dated December 26, 1952, which includes “Birdsboro Foundry” 

that had a 22-MV betatron installed in 1952. According to the Steel Founders’ Society of 
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America (1961), Birdsboro had nondestructive test facilities comprising a 24-MV betatron, a 

300-kVp x-ray machine, 200 mCi of 60Co, and 500 mg of radium in 1961.2

2 Five hundred milligrams of 226Ra is approximately equal to 500 mCi.

Detailed information 

for earlier years is not readily available; however, the cited data are consistent with the 

information cited previously. 

The available information is entirely consistent with the information on radiographic operations 

at GSI. Since the greatest source of external photon exposure at GSI was the use of 226Ra 

employing the fishpole technique, a strong case can be made for using the external exposure 

scenarios developed for GSI as surrogate data for Birdsboro. We recommend that NIOSH assign 

external exposures to operators as a triangular distribution, with a minimum, mode, and 

maximum of 6.279, 11.345, and 15 R/y, respectively, during 1951 and 1952, as listed by NIOSH

(2017, Table 8). These are based on the use of 500-mCi 226Ra sources, as reported at both 

Birdsboro and GSI. Because these are limiting values, there is no need to include the small 

external exposures from the handling of uranium metal, which were also omitted at GSI. Since 

the betatron was installed at Birdsboro in 1952, an additional exposure in 1952 should include 

5.112 rad/y air kerma as a constant distribution, consisting of 30 keV photons in a posteroanterior (PA) geometry. 

The operator should be assumed to also spend 50% of the time performing steel radiography 

using the betatron in addition to performing radiography with 226Ra sources. (Unlike GSI, there 

is no evidence that Birdsboro performed radiography of uranium.) The operator would receive a 

neutron dose of 0.857 mrem ambient dose equivalent (H*[10]) per 8-h shift (Anigstein and 

Mauro 2014). Assuming a 2,200-h work year, his annual neutron dose would be 117.8 mrem 

(0.857 mrem/shift × 2,200 h/y ÷ 8 h/shift = 117.8 mrem). 

Administrative personnel who are defined as anyone normally working in an office environment 

not routinely entering the production areas should be assigned external photon exposures of 

571.5 mR/y. All other employees should be assigned the dose estimates for operators. 

Finding 1: NIOSH neglected the external exposure to documented radiographic sources in 

assigning photon doses to Birdsboro workers. 

Beta doses to the skin of operators from handling uranium metal should also be assigned for 

1951 and 1952. We recommend that the beta dose rate to skin other than that of the hands and 

forearms in 1951 be based on the long billet, as described by TBD-6000 (NIOSH 2011, 

Table 6.1). Assigning a beta skin dose rate of 7.03 mrem/h, which is 10 times the photon dose 

rate from this shape, would be consistent with the results of an earlier SC&A analysis of the beta 

dose rate from a similar shape, using the Monte Carlo radiation transport code MCNPX. The 

beta dose rate to skin other than that of the hands and forearms in 1952, prescribed in 

Appendix B, Rev. 1 (NIOSH 2015), is consistent with the MCNPX analysis of a uranium wafer, 

using a model based on the description by Smith (1952), that was performed as part of the 

present review.

 
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Observation 7

The beta dose rate to skin other than that of the hands and forearms in 1951 should be based on 

the long billet, as described by TBD-6000 (NIOSH 2011, Table 6.1). We make this an 

observation rather than a finding, since the change in the skin dose would be small compared to 

the much larger dose from radiographic sources cited in Finding 1.
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4 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DOSE RECONSTRUCTIONS 

REQUIRING REEVALUATION OF DOSE

According to DCAS-PER-073 (NIOSH 2016), 

In order to evaluate the effect of revision 1 of the Appendix on all previously 

completed claims, a search was conducted for all completed claims with verified 

employment at the Birdsboro site during the covered period and that had a 

probability of causation (POC) of less than 50%. This search identified 4 claims. 

4.1 REVIEWER’S COMMENTS

We verified the results of the search conducted by NIOSH (2016) by viewing the Birdsboro web 

page of the U.S. Department of Labor (DOL 2018), which stated that five cases were referred to 

NIOSH for DR. In all five cases, the POC was less than 50% and the final decision was to deny 

compensation. We next searched for Birdsboro cases in the NIOSH OCAS Claims Tracking 

System (NOCTS) and found five cases. On reviewing these cases, we found that 

Therefore, NIOSH was correct in reporting that four claims were within the scope of PER-073. 

We also confirmed that all four claims had POCs of less than 50%, resulting in the claims being 

denied. 

To determine the potential impacts of the changes discussed in section 3 of the present review, 

we examined the DR reports for these four cases. Given the small number of cases, it was 

simplest to perform a cursory inspection of the reports to determine the extent to which the DRs 

would be affected by the PER. 

The earliest DR was performed prior to the issuance of TBD-6000, Rev. 0, so it relied on generic 

guidance, such as that provided by OTIB-0004 (ORAUT 2003). That document specified the 

maximum plausible intakes of radioactive materials and external exposures, resulting in intakes 

and doses that were orders of magnitude greater than those in Appendix B, Rev. 1. A second DR 

report was issued after TBD-6000, Rev. 0, but prior to Appendix B, Rev. 0. That DR relied on 

TBD-6000 for data on external exposure while basing intakes on data from Simonds Saw and 

Steel, scaled to the ratio of the masses of uranium handled at Birdsboro and Simonds Saw. 

Another DR, although performed after the issuance of Appendix B, Rev. 0, also relied on TBD6000 for data on external exposure while basing intakes on data from Simonds Saw and Steel. In 

these two cases, the intakes were orders of magnitude lower than either Appendix B, Rev. 0, or 

Rev. 1. Only one DR was based on the intakes and external exposures in Appendix B, Rev. 0. 

Therefore, except for the earliest of the four DRs discussed above, it was necessary for NIOSH 

to revise the DRs. Issuing DCAS-PER-073 provided a procedure and mechanism for performing 

these revisions. The earliest of the four DRs, , could have been excluded from the 

process due to the large overestimates of assigned doses and intakes, which nevertheless resulted 

in a denial of the claim. However, it was probably simpler to repeat the DR rather than justify 

excluding this one case from the PER. We therefore have no findings pertaining to the 

identification of claims that were impacted by DCAS-PER-043.
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We observe that Appendix B, Rev. 1, was issued on June 2, 2015, while DCAS-PER-073 was 

issued August 1, 2016, 14 months later. SC&A does not have a basis for judging the timeliness 

of this PER. 
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5 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DOSE 

RECONSTRUCTIONS AFFECTED BY DCAS-PER-073

5.1 SELECTION OF DOSE RECONSTRUCTIONS

In order to complete our evaluation of DCAS-PER-073, we need to audit cases that represent a 

range of parameters that adequately characterize the cases evaluated by NIOSH for the present 

PER. In other PER reviews, SC&A typically cited case selection criteria, such as cancer type, job 

category, and period of employment. Following approval of the criteria by the ABRWH, NIOSH 

would select cases from a given site, based on these criteria. In the present circumstances, we 

had already performed a cursory examination of these reports to determine the extent to which 

they depended on earlier NIOSH guidance documents. Given that the cancer site and period of 

employment are listed on the cover page of each DR report, it was simplest to use the actual 

cases to determine the selection criteria that would enable us to perform an adequate review. 

• . Doses to the , which are part of the respiratory tract, represent a 

unique exposure pathway. The review should 

 to gauge the maximum effect of the additional sources of 

external exposure discussed in section 3.3.1 of the present review. The 

; a substantial increase in the external dose 

from radiographic sources could have a significant impact on the outcome. 

We note that the POC is not necessarily part of the selection criteria. In the present 

instance, however, we need an opportunity to evaluate the impact of the increased 

external exposure that we have proposed under Finding 1. The impact would be greatest 

on the case that has the highest POC, as revised under the PER.

• . A combined dose assessment of the 

requires the analyst to select the correct clearance type of uranium compounds to 

maximize doses to simultaneously. The is unusual in that, 

although it is a nonmetabolic organ, the presence of uranium in the urine following intake 

leads to a unique pathway. Reviewing such a combined assessment will also allow us to 

verify the calculation of the POC for .

• . Because of the increased intake of ingested uranium, which was the 

primary motivation for this PER, organs that are part of the alimentary tract are of special 

interest. Furthermore, the additional sources of external exposure discussed in 

section 3.3.1 of the present review would represent a significant dose pathway for this 

organ, which has a higher dose conversion factor for external exposure than any other 

 site among the four cases evaluated by NIOSH, according to OCAS-IG-001 

(NIOSH 2007). 

• . The has a higher dose coefficient for intakes of 234U via the 

ingestion pathway than any other cancer site among the four cases evaluated by NIOSH, 

according to the ICRP (2001). 
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6 REFERENCES

Allen, D. (NIOSH/DCAS). 2018. “RE: Appendix B, TBD-6000,” personal email to Robert 

Anigstein, SC&A, Inc. May 24, 2018.

Anderson, J. L., and N. E. Hertel. 2005. “Bremsstrahlung doses from natural uranium ingots.” 

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Anigstein, R. (SC&A, Inc.) 2010. “Review of NIOSH White Paper on Portable Radiography 

Sources at GSI.” September 23, 2010.

Anigstein, R., and J. Mauro. 2014. “Review of ‘Site Profiles for Atomic Weapons Employers 

that Worked Uranium Metals Appendix BB – General Steel Industries,’ Revision 1,” 

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Thorium Metals,” Battelle-TBD-6000, PNWD-3738 Rev. 0. Battelle Team, Dose Reconstruction 

Project for NIOSH. December 13, 2006.

Battelle. 2007. “Site Profiles for Atomic Weapons Employers that Worked Uranium and 

Thorium Metals, Appendix B: Birdsboro Steel & Foundry Company,” Battelle-TBD-6000, 

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tm. Accessed June 6, 2018.

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Kattner, W. T., and J. W. Riches. 1951. “Trip Report: Visits Pertaining to Metal Fabrication and 

Canning.” October 17, 1951. SRDB Ref. ID: 16127, PDF pp. 2–7.

Kennedy, W. E., Jr., and D. L. Strenge. 1992. “Residual Radioactive Contamination from 

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Effective Dose Equivalent,” NUREG/CR-5512. Vol. 1. Washington, DC: U.S. Nuclear 

Regulatory Commission.
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Malone, F. W. 1951a. “Weekly Production Report November 15th 1951,” excerpt from memo to 

R. J. Smith, Chief, Operations Branch, Production Division, NYOO, November 11, 1951. SRDB 

Ref. ID: 61144, PDF p. 3. 

Malone, F. W. 1951b. “Monthly Progress Report for November,” United States Government 

Office Memorandum to R. J. Smith, Chief, Operations Branch, Production Division, NYOO, 

November 26, 1951. SRDB Ref. ID: 9545, PDF pp. 13–19. 

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(EEOICPA) Dose Reconstruction Telephone Interview, NIOSH Claimant ID: .” NIOSH 

OCAS Claims Tracking System: Online.

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(EEOICPA) Dose Reconstruction Telephone Interview, NIOSH Claimant ID: .” NIOSH 

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OCAS-PR-008, Rev. 2. National Institute for Occupational Safety and Health, Office of 

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and Support, Cincinnati, OH. November 21, 2007. 

NIOSH. 2011. “Site Profile for Atomic Weapons Employers that Worked Uranium Metals,” 

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NIOSH. 2016. “Program Evaluation Report: Birdsboro Steel and Foundry Company,” DCASPER-073, Rev. 0. National Institute for Occupational Safety and Health, Division of 

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Taussig, W. A. 1948. “Facilities for Rolling Uranium,” memo to W. E. Kelley, Manager, New 

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APPENDIX A – INTERVIEW REPORT

REPORT OF INTERVIEW WITH , FORMER EMPLOYEE OF BIRDSBORO STEEL 

FOUNDRY AND MACHINE COMPANY

Robert Anigstein, SC&A task manager for the review of DCAS-PER-073, contacted former 

Birdsboro employee by telephone at approximately 2 PM on May 9, 2018. 

name and phone number had been furnished during the Dose Reconstruction Telephone 

Interviews by the (NIOSH 2003b). 

 worked at Birdsboro for years, starting in the . 

and also used 60Co and radium sources. the radium source had a strength of 500 mCi, 

while the 60Co had decayed to 200 mCi. that the workers performing this work wore film 

badges as well as pocket ionization chambers (PICs).