Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

A REVIEW OF NIOSH’S PROGRAM EVALUATON REPORT 

DCAS-PER-059, “NORTON COMPANY” 

Contract No. 211-2014-58081 

SCA-TR-2017-PR002, Revision 0 

Prepared by 

U. Hans Behling, PhD, MPH 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, Virginia, 22201

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

May 2017 

DISCLAIMER 

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

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

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

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

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

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

issues.

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

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

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: A Review of NIOSH’s Program Evaluation Report DCAS-PER-059, 

“Norton Company”

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2017-PR002 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: May 22, 2017

TASK MANAGER: U. Hans Behling, PhD, MPH [signature on file]

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

DOCUMENT 

REVIEWER(S): John Stiver, MS CHP [signature on file] 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 5/22/2017 Initial issue
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TABLE OF CONTENTS

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

1.0 Statement of Purpose .......................................................................................................... 5

2.0 Relevant Background Information ...................................................................................... 7

3.0 Subtask 1: Identify the Circumstances that Necessitated DCAS-PER-056 ........................ 8

4.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ............................. 10

4.1 Annual External Exposure Rates .......................................................................... 10

4.1.1 Summary of Operational Survey Data ...................................................... 11

4.1.2 Summary Post-Operational Survey Data .................................................. 14

4.2 Residual Period Internal Dose .............................................................................. 17

4.3 Annual Thoron Exposure Rates ............................................................................ 19

5.0 Subtask 3: Evaluate the PER’s Stated Approach for Identifying the Universe of 

Potentially Affected Dose Reconstructions.................................................................................. 21

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

DCAS-PER-059 ............................................................................................................................ 22

7.0 References ......................................................................................................................... 23
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ABBREVIATIONS AND ACRONYMS

Advisory Board 

or Board Advisory Board on Radiation and Worker Health 

AEC U.S. Atomic Energy Commission 

AWE Atomic Weapons Employer 

Bi bismuth 

cpm counts per minute

DCAS Division of Compensation Analysis and Support 

D&D decontamination and decommissioning 

dpm disintegrations per minute

DR dose reconstruction 

μc/cc microcuries per cubic centimeter

μCi/cm3 microcuries per cubic centimeter

μCi/ml microcuries per milliliter

MeV mega-electron volts 

mrem millirem

NIOSH National Institute for Occupational Safety and Health

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team

pCi picocurie 

pCi/L picocuries per liter

Pb lead

PER program evaluation report

Po polonium 

POC probability of causation

R&D research and development

SEC Special Exposure Cohort 

SRDB Site Research Database

TIB technical information bulletin

WL working level 

WLM working level month 
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1.0 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, Preparation of Program Evaluation Reports 

and Program Evaluation Plans (NIOSH 2006), Revision 2, dated December 6, 2006. This 

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

evaluation report (PER) and a program evaluation plan. 

A PER provides a critical evaluation of the effects that a given issue/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 impact on the probability of 

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

During a teleconference of the Advisory Board on Radiation and Worker Health (Advisory 

Board or Board) on January 26, 2017, the Board tasked SC&A to conduct a review of DCASPER-059, Norton Company (NIOSH 2015; hereafter “PER-059”). In conducting a PER review, 

SC&A is committed to perform the following five subtasks, each of which is discussed in this 

report: 

Subtask 1: Assess NIOSH’s evaluation/characterization of the “issue” and its potential impacts 

on DR. SC&A’s assessment intends to ensure that the “issue” was 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), 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 and conclusion 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 for the completion of the PER.
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Subtask 4: Conduct audits of DRs affected by the PER under review. The number of DRs 

selected for audit for a given PER will vary. (It is assumed that the selection of the DRs 

and the total number of DR audits per PER will be made by the Advisory Board.) 

Subtask 5: Prepare a written report that contains the results of DR audits under Subtask 4, along 

with SC&A’s review conclusions. 
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2.0 RELEVANT BACKGROUND INFORMATION

DCAS-PER-059 states that the Norton Company, located in Worcester, Massachusetts, began as 

an Atomic Weapons Employer (AWE) facility in September 1944 by working with beryllium 

under contract to the Manhattan Engineering District through 1956. For the year 1957, the 

company also worked with thorium and uranium. 

Starting in 1958, continued contracts involved non-radioactive materials, which no longer 

qualified the Norton Company as an AWE facility. However, it was not until 1962 that the 

Norton site performed decontamination and decommissioning (D&D) of equipment and 

materials. Thus, the period of residual contamination, which extends from January 1, 1958, 

through October 2009, represents the following two discreet time periods for worker exposure to 

residual contamination that is covered under the Energy Employees Occupational Illness 

Compensation Program Act: 

1) Period of residual contamination prior to D&D that extends from January 1, 1958, to 

October 10, 1962.

2) Period of residual contamination post D&D that corresponds to October 1962 through 

October 2009. 
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3.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED DCAS-PER-056

No technical basis document has been developed for DRs of workers at the Norton Company; 

however, a “previous” template had been developed for guidance to assess exposures in behalf of 

claimants. The issue date of the “previous” template is unknown to SC&A, and SC&A had no 

prior knowledge of its existence. 

The “previous” template of Norton Company was revised on September 16, 2011 (NIOSH 

2011a), primarily due to the following two reasons: 

1) The addition of a second class of employees to the Special Exposure Cohort (SEC-00173), 

which corresponds to a portion of the residual contamination of January 1, 1958, to 

October 10, 1962.

2) The revision to ORAUT-OTIB-0070, Revision 00, which was originally issued on March 

10, 2008 (NIOSH 2008). A key change made in Revision 01 to ORAUT-OTIB-0070 

(NIOSH 2012) was the adoption of a lower depletion rate of 0.067% per day for residual 

contamination starting October 10, 1962, and extending to 2009.

SC&A’s Comments 

Programmatic revisions that may affect the outcome of previously completed DRs and mandate 

the need for a PER include the addition of a new class of workers to the SEC and any revisions 

to guidance documents that may result in the assignment of a higher dose. 

SC&A regards (1) the addition of the SEC-00173 class and (2) the adoption of a reduced 

depletion rate during the residual period as justification for the revision of the Norton Company 

template and the need for the reevaluation of worker doses as defined in PER-059. 

SC&A concurs with NIOSH’s decision to issue PER-059, and there are no findings. 

Important to note, however, is that SC&A’s approach for its review of PER-059 is affected by 

the following facts:

1) The aforementioned two principal reasons that required the revision of the Norton 

template, which in turn necessitated issuance of DCAS-PER-059, pertain to the following 

procedural documents that have already been reviewed by SC&A: 

– On August 29, 2008, SC&A issued its draft report, Review of ORAUT-OTIB-0070: 

Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities. 

– On July 7, 2011, SC&A issued its draft report, A Focused Review of the Norton 

Company SEC Petition Evaluation Report SEC-00173 Concerning the Use of ORAUTOTIB-0070 for the Reconstruction of Doses from Residual/Post-Operational 

Contamination. 
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2) SC&A has reviewed neither the “previous” nor the revised Norton Company templates. 

Therefore, SC&A’s review of DCAS-PER-059 will include an evaluation of the Norton 

Company template for its guidance of internal and external dose reconstruction. 
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4.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

Due to SEC-00148 and SEC-00173 class designations, no internal or external doses can be 

derived with sufficient accuracy for the years 1945 through October 10, 1962. Thus, the principal 

changes for the reevaluation of dose in behalf of DCAS-PER-059 involves the use of the revised 

contamination depletion rate of 0.067% per day for claimants excluded from SEC status and with 

employment during the residual period after October 10, 1962. 

SC&A Comments

Because the principal justification for the reevaluation of doses pertaining to the revised 

contamination depletion rate (adopted in ORAUT-OTIB-0070, Revision 01) was previously 

assessed and approved by the Subcommittee for Procedure Reviews, there are no findings 

regarding its use for the reevaluation of worker doses affected by DCAS-PER-059. However, as 

mentioned above, there is a need to assess the application of the revised contamination depletion 

factor as part of SC&A’s review of the Norton Company template. 

A review of the template identifies use of the revised depletion factor of ORAUT-OTIB-0070 for 

deriving the following doses during the residual period for years 1962 through 2009: 

• Annual external exposure rates 

• Annual uranium intake rates 

• Annual thorium intake rates 

• Annual thoron exposure rates 

4.1 ANNUAL EXTERNAL EXPOSURE RATES

The revised template provides the following information: 

Individual external monitoring data is [sic] not readily available during the 

residual period. A limited amount of air dust results during the operational 

period (SRDB RefID 10412, 32669, 32687, 78700, 78702, 78720, 78722, 78724, 

and 78725). The 95th percentile of the gross alpha air dust results was calculated 

to estimate the contamination levels for the start of the residual period (1958) 

through the decontamination and decommissioning of AEC equipment and 

materials (1962). It is assumed that the material deposited on the floor with a 

deposition velocity of 0.00075 m/s for a period of one year without cleanup and 

then remained at that level of contamination for the duration of operations and 

through the cleanup done in 1962. This would be a contamination level of 

1.83×106

 dpm/m2. Using these assumptions, the daily doses can be calculated 

based on the maximizing potential radionuclide. [emphasis added]
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SC&A’s Comments

In an attempt to verify the derived surface contamination level at the 95th level of 

1.83×106 disintegrations per minute per square meter (dpm/m2), SC&A reviewed the above-cited 

Site Research Database (SRDB) references for data pertaining to air monitoring data for uranium 

and thoron. Based on the exact wording above, all nine referenced documents would be expected 

to contain air monitoring data from the operational period prior to 1958. 

4.1.1 Summary of Operational Survey Data 

SC&A’s review of the nine documents, however, shows that only four documents (i.e., SRBD 

Ref. IDs 10412, 78702, 78720, and 78725) contain survey data taken prior to 1958 during the 

operational period.

SRDB Ref. ID 10412 (AEC 1957) contains a total of twelve handwritten survey sheets 

representing about 70 air samples. A significant fraction of samples indicate high alpha air 

concentrations greater than 100,000 dpm/m3. However, due to the poor quality of these 

handwritten air survey measurements, a quantitative assessment of these data is not possible.

For illustration, Figure 1 identifies 12 “air dust” samples taken on March 31, 1954, in areas 

where ThO2 sorting was performed. While some of the data are legible, other are not. 
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Figure 1. Air Dust Samples Taken March 31, 1954 

(Source: AEC 1957; SRDB Ref. ID 10412)

Among the legible samples shown in Figure 1 is the first sample, N493, which involves the 

sorting of ThO2 and represents the following information: 

• Air sampling rate: 20 liters/minute 

• Air sampling time: 3 minutes

• Total volume of air sample: 0.06 m3

• Background α counts: 7.4 counts per minute (cpm/min) 

• Total sample count for 2 minutes: 4,062 counts/0.06 m3

• Total net sample count rate: 2,024 cpm/0.06 m3

• Total net sample count rate per m3: 33,733 cpm 

• Counting efficiency: 4.8 dpm/cpm
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 Air concentration corresponding to data for Sample N493 = 61,918 dpm/m3 of air

= 0.162×10-1 dpm/cm3

Sample N493 air concentration = 7.29×10-8 μCi/cm3

Important to note is that the air concentration for Sample N493 of 7.29×10-8 microcuries 

per cubic centimeter (μCi/cm3) (and a significant, but unknown, number of others among 

the ~70 air samples cited in SRDB Ref. ID 10412) are several orders of magnitude higher 

than air sample concentrations cited in the other eight references summarized below.

SRDB Ref. ID 78720 (dated June 1955) is a typewritten letter forwarded to the Atomic Energy 

Commission [AEC], which identifies two “general room” air samples with modest alpha 

activities of ~4.5×10-13 μCi/cm3 (Harris 1955). 

This letter contains survey data taken on June 3, 1955, which included two general area “air 

dust” samples taken in the manufacturing and research and development (R&D) facilities. These 

yielded air concentrations of 4.5×10-13 μCi/cm3

 and 4.0×10-13 μCi/cm3, respectively.

SRDB Ref. ID 78725 contained subsequent survey data, which included three pairs of air 

samples taken in July, August, and October 1955 for the Norton Company’s Manufacturing and 

R&D facilities. Air concentrations remained largely unchanged and ranged from 4×10-

14 μCi/cm3

 to 5.5×10-13 μCi/cm3 (Norton 1955). 

SRDB Ref. ID 78702 (Elkins 1957) cites air survey data taken on July 11, 1957, near the end of 

the AWE operational time period. This survey identifies long-lived alpha activity levels at 14 

different locations (see Figure 2). With the exclusion of air Sample 6, air concentrations within 

work areas ranged from 0.3×10-11 microcuries per milliliter (μCi/ml) to 51×10-11 μCi/ml, with an 

average value of 11.9×10-11 μCi/ml. 
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Figure 2. Air Sampling Data Taken July 11, 1957 

(Source: Elkins 1957; SRDB Ref. ID 78702) 

4.1.2 Summary Post-Operational Survey Data 

Summarized below are post-1957 air dust survey data in chronological order for the remaining 

five documents referenced in the Norton Company template. (Note: These documents and their 

data are referenced below in Finding 1.) 

SRDB Ref. ID 78700 (Pagnotto 1958): Conducted on May 13, 1958, this survey assessed “the 

atmosphere in the areas where uranium and thorium are handled” (emphasis added) and 

yielded the following values for long-lived alpha emitters:
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• Average of 7 thoria area samples: 0.21×10-11 μCi/ml

• Average of 2 uranium area samples: 0.1×10-11 μCi/ml

• Average of 10 screening and crushing samples: 1.1×10-11 μCi/ml

SRDB Ref. ID 78724 (Liberty Mutual 1958): This document cites airborne radioactivity 

representing two breathing zone values for employees engaged in the following activities on 

 1958: 

• 1.5×10-11 μCi/ml for employee weighing and mixing 

• 8.2×10-12 μCi/ml for employee weighing in

SRDB Ref. ID 32669: On February 2, 1962, two effluent air samples were assessed for alpha 

activity along with the following explanation:

1. One effluent air sample was taken from the exhaust duct discharging effluent 

air from Laboratory Bench #24181, as Thoria was being milled through a 

100 mesh screen. The reading obtained was 5.0 × 10-11 μc/cc of air. 

2. One effluent air sample was taken from the exhaust duct discharging air from 

Aeroturn Duct Collector #24528, as Thoria was screened in the box 

screener. The reading obtained was 2.5 × 10-12 μc/cc. [Norton 1962; 

emphasis added]

SRDB Ref. ID 32687: On , 1963, a single breathing zone air sample was taken in 

behalf of an operator weighing and pressing . Each brick weighed approximately 

1.5 pounds. The operator’s breathing zone air concentration was 9.5×10-13 microcuries per cubic 

centimeter (μc/cc) (Norton 1963). 

SRDB Ref. ID 78722: On , 1964, a survey was conducted of the Thoria handling 

operations of the Norton Company’s Industrial Building. The survey included two air samples 

that were identified and described as follows (Liberty Mutual 1964). 

Sample 1: 

General area, breathing zone level – sample taken of operator scooping and 

crushing . Also included in this sample is screening 

operation which is in an enclosed and exhausted screen box.

The air concentration was given as “1.6 × 10-11 μc/cc.” 

Sample 2: 

General room area sample – North of Thoria bench #24181. 

The air concentration was given as “5.4 × 10-11 μc/cc.” 
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Note: Based on dates and described operational activities, these five data sets do not appear 

to correspond to the residual period.

From air survey data assumedly contained in these nine referenced documents, NIOSH derived 

the 95th percentile values and applied a deposition value of 0.00075 m/s for a year in order to 

arrive at a surface contamination of 1.83×10-6 dpm/m2 for the start of the residual period of 1962. 

Annual external penetrating and shallow doses were based on this initial surface contamination 

using the “maximizing potential radionuclide.”

For the first year of the residual period (i.e., 1962), NIOSH identified an annual deep dose of 

26 millirem (mrem) and a shallow dose of 233 mrem.

SC&A’s Comments and Findings 

The limited and ambiguous wording regarding the use of air dust samples in the nine referenced 

documents cited in the Norton Company template raise multiple questions about their use for 

defining the 95th percentile air concentration.

For example, the largest number of available air samples are those in SRDB Ref. ID 10412. Even 

more important is the fact that this data set includes air concentrations that are several orders of 

magnitude higher than those cited in any other survey documents. Unfortunately, a significant 

fraction of this sample set is illegible (see Figure 1).

The potential inclusion of other air samples may be inappropriate based on sample location 

and/or time. For example, based on location, air Sample No. 6 shown in Figure 2 above, as well 

as “effluent air samples” cited in SRDB Ref. ID 32669, should clearly not be included. Equally, 

air samples taken after 1962 (NIOSH’s designated beginning of the “Residual Period”), which 

include air samples cited in SRDB Ref. ID 32687 and SRDB Ref. ID 78722, may not be 

appropriate.

In the absence of additional data, SC&A is unable to identify air dust data used by NIOSH in 

order to calculate the 95th percentile air concentration, which, in turn, NIOSH used to determine 

the starting “residual” surface contamination of 1.83×10-6 dpm/m2 and the resulting external 

deep dose of 26 mrem/yr and shallow dose of 233 mrem/yr for 1962.

By simple back-calculation of the 1.83×10-6 dpm/m2 surface contamination, NIOSH would have 

identified a 95th percentile air concentration of 3.48×10-11 μCi/cm3

, as demonstrated below:

95th % air concentration = 

1.83 × 10−6 dddddd/ 2

(0.00075mm

ss )(3.15 × 107 ss

yyyy)

= 77.372 dpm/m3

= 3.48 × 10-11 μCi/cm3

Finding 1. There is insufficient information in the Norton Company’s template for 

identifying critical data and parameters needed to (1) duplicate and/or (2) confirm 

NIOSH’s model for the estimation of external deep and shallow doses starting with the 

residual period of 1962.
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Under the template’s “Time Period” and “Facility Description” sections, NIOSH states the 

following: 

Time Period:

BE 1944 – 1956; AWE 1945 – 1957; Residual Radiation 1958 – 2009 

Facility Description

...Work with thorium and uranium continued through 1957 at Norton’s Worcester 

location. 

Norton continued to manufacture refractory products until at least 1965 for the 

AEC weapons complex, including Rocky Flats, Hanford and Y-12. However, after 

1957 these contracts specified that the refractory products were to be made out of 

magnesium oxide. Since magnesium oxide is not radioactive, Norton's work with 

it does not qualify it as an Atomic Weapons Employer for these years. 

Finding 2. Our review of the template’s cited references for “air dust” survey data 

identifies five of the nine references containing “operational” thoria and uranium data with 

dates starting in 1958 and continuing through 1964 (see the preceding discussion). 

Operational survey data for thoria/uranium after 1957 are in contradiction with the 

template’s designated “operational” time period that ends in 1957.

4.2 RESIDUAL PERIOD INTERNAL DOSE

NIOSH’s protocol for the assignment of internal dose from the inhalation/ingestion of uranium 

and thorium is described as follows (NIOSH 2011a): 

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

from exposures to residual radiation received after the burial of AWE materials, 

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

results obtained on May 13, 1958 by the Massachusetts Department of Labor and 

Industries (Pagnotto, 1958) to derive the air concentration starting on October 

11, 1962 through the end of the residual radiation period, October 31, 2009. The 

average of the long-lived alpha results was calculated from the data shown to 

estimate the starting air concentration on October 11, 1962. This resulted in an 

air concentration of 2.96 dpm/m3

 and 4.66 dpm/m3 for the for the uranium and 

thorium areas, respectively. 

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

an inhalation rate of 1.2 m3

/hr, 8-hour workday, and 250 workdays per year, 

resulting in a value of 19.463 dpm/day for the uranium areas and 30.654 

dpm/day for the thorium areas. Intake rates for the following years through 

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

in ORAUT-OTIB-0070. Ingestion intakes are calculated based on OCAS-TIB-009. 

[emphasis added] 
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SC&A’s Comments

The above-cited air concentrations of 2.96 dpm/m3 and 4.66 dpm/m3 for uranium and thorium 

areas, respectively, are values reported by Pagnotto (1958) and reproduced here as Figure 3. 

Figure 3. Pagnotto Memo (Source: SRDB RefID 78700) 

Figure 3 shows that for the eight thoria air samples, the average air concentration for long-lived

alpha emitters was 0.21×10-11 μCi/ml. This converts to an air concentration of 4.66 dpm/m3 with

a corresponding daily inhalation value of 30.654 dpm/day for thorium. 

For uranium air samples, Figure 3 identifies three sample locations (by numbers 3M, 4M, and 

6M) with long-lived alpha activities of 0.1×10-11 μCi/ml, 0.00×10-11 μCi/ml, and 0.1×10-11

μCi/ml, respectively. The average air concentration value for the three uranium air samples is
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0.067×10-11 μCi/ml, which converts to the air concentration of 1.49 dpm/m3 and a daily 

inhalation values of 9.80 dpm/day for uranium. 

Finding 3. While SC&A’s 1962–1963 air concentration and daily intake values for thorium 

match those derived by NIOSH, corresponding values for uranium derived by SC&A are a 

factor of two lower than values derived/assigned for uranium air concentration and 

intakes.

Note: SC&A realizes that the authors of this survey ignored the “0.00×10-11 μCi/ml” value of 

sample No. 4M and derived the average value of 0.1×10-11 μCi/ml based only on samples 3M 

and 6M. However, NIOSH’s value of 0.1×10-11 μCi/ml is still in error. (For Pagnotto’s average 

value of 0.1×10-11 μCi/ml, the correct air concentration corresponds to 2.22 dpm/m3.) 

4.3 ANNUAL THORON EXPOSURE RATES

For deriving potential inhalation exposure to thoron gas, NIOSH provided the following 

explanation in the revised Norton Company template: 

NIOSH does not consider radon as an exposure source, as Norton Co. only had 

uranium metals and associated dust onsite. NIOSH has identified thoron 

monitoring data in the form of short-lived thoria results obtained on May 13, 

1958 (Pagnotto, 1958). NIOSH used the reported average short-lived values as 

actual values of thoron, as provided in Table 7-3 to calculate the intake rate of 

thoron from the end of the burial operation through December 31, 1963. Working 

level months (WLM) were calculated for each result and for the average of the 

reported short-lived results. Intake rates for the following years have been 

adjusted due to source term depletion as described above. [emphasis added]

The above reference to the “reported average short-lived values as actual values for thoron as 

provided in Table 7-3” is puzzling because there is no Table 7.3 in the revised template. 

However, SC&A concluded that this value refers to the average of the eight short-lived alpha 

emitters identified as samples numbers 1M, 7M, 13, 5M, 3, 7, 11, and 14 in Figure 3. 

Thus, NIOSH assumed a thoron air concentration value of 6.26×10-11 μCi/ml as a starting air 

concentration in 1962. By means of this air concentration value, NIOSH derived a yearly thoron 

exposure rate of 0.0932 WLMs for the first year of the residual period (1962–1963). No further 

explanation or data were provided in deriving this value. 

SC&A Comments/Findings

SC&A derived the working level (WL) of thoron based on first principles. By definition, a WL is 

defined as any combination of short-lived radon or thoron decay products in 1 liter of air that 

will result in the ultimate emission of 1.3×105 mega-electron volts (MeV) of potential alpha 

energy. For thoron, short-lived daughters include polonium-216 (Po-216), lead-212 (Pb-212), 

bismuth-212 (Bi-212), and Po-212. The assessment of total potential alpha energy that may be 

released requires the determination of the total number of atoms for each of the short-lived 

daughters (that are assumed to exist in full equilibrium with thoron) and are assumed herein to 

have a concentration of 6.26×10-11 μCi/ml or 6.26×10-2 picocuries per liter (pCi/L). Table 1 
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summarizes the calculation that converts the assumed thoron concentration of 6.26×10-11 μCi/ml 

to the potential alpha energy of 1105.4 MeV per liter of air. This implies that, for thorium-220 

(in secular equilibrium with its short-lived daughters), a WL corresponds to a concentration of 

7.4 pCi/L. The potential alpha energy of 1105.4 MeV per liter of air corresponds to 8.50×10-3

WL and for a 2,000-hour per year exposure yields an annual thoron exposure of 0.100 WLM. 

SC&A’s value of 0.100 WLM is virtually identical to NIOSH’s derived value of 0.0982 WLM. 

Applying first principles, SC&A matched NIOSH’s calculation of potential thoron exposures 

during the residual period at the Norton Company. There are no findings associated with 

assigned exposures to thoron. 

Table 1. Estimate of Thoron Working Level for Year 1962 

Nuclide Half-life No. of Atoms per 

6.26 × 10-2 pCi/L

Potential Alpha 

Energy 

(MeV per Atom)

Total Potential 

Energy 

(MeV/6.26×10-2 pCi)

Po-216 0.158 sec ~ 0 14.8* ~ 0

Pb-212 10.64 hours 127.8 7.9** 1009.5

Bi-212 60.6 min 12.2 7.9** 95.9

Po-212 3×10-7 sec ~ 0 8.78 ~ 0

* 14.8 MeV is the combined α energy of 6.9 MeV for Po-216. 

** 7.9 MeV is the weighted sum of the α decay energy of Bi-212 and Po-212: 

(0.337)(6.206 MeV) + (0.663)(8.78 MeV) = 6.9 MeV
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5.0 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE UNIVERSE OF POTENTIALLY AFFECTED 

DOSE RECONSTRUCTIONS

Selection of cases requiring reevaluation of dose by NIOSH was based on the following criteria: 

• A total of 54 previously completed claims with POC values ≤50% were identified for 

further evaluation. 

• Nine of the 54 claims had employment periods that were confined to years prior to 1962 

and were therefore not impacted by PER-059. 

• Two additional claims were removed: one claim had recently been completed using the 

revised template and the other had been returned by DOL and was reevaluated by NIOSH 

as required by PER-059. 

• The remaining 43 claims have been reevaluated by NIOSH in accordance with the 

revised Norton Company template and all applicable/approved dose reconstruction 

protocols. All 43 revised dose reconstruction yielded POC values of below 45%. 

SC&A’s Comments

SC&A concurs with NIOSH’s selection criteria for defining the 43 claims requiring reevaluation 

of dose. There are no findings under Subtask 3. 
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6.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DOSE 

RECONSTRUCTIONS AFFECTED BY DCAS-PER-059

SC&A’s assessment suggests that the impact of DCAS-PER-059 and the implementation of DR

under the revised template issued September 16, 2011, involves assignment of the templateprescribed annual values for (1) external doses and (2) internal intake rates for uranium, thorium, 

and thoron for each year of employment after 1961. 

Pending the resolution of Findings 1, 2, and 3, and given the template’s prescriptive assignments 

of external doses and internal intakes for each specific year of employment post-1961, SC&A 

recommends that only a single claim from among the 43 cases be selected for audit. 
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7.0 REFERENCES

AEC 1957. Air Dust Samples. U.S. Atomic Energy Commission, Health and Safety Division. 

3/24/195–4/3/1957. March 24, 1954–April 3, 1957. [SRDB Ref. ID 10412] 

Elkins. 1957. Correspondence from Harvey B. Elkins, Director, Division of Occupational 

Hygiene, Department of Labor and Industries, Commonwealth of Massachusetts, to Karl T. 

Benedict, Norton Company. July 30, 1957. [SRDB Ref. ID 78702] 

Harris 1955. W.B. Harris, U.S. Atomic Energy Commission, Urinalysis and Wipe Sample

Results from Norton Company, Worcester, Massachusetts, report written by R.G. Gallaghar and 

R.G. McAllister, Norton Company. June 1955. [SRDB Ref. ID 78720] 

Liberty Mutual 1958. Norton Company Worcester, Massachusetts: Thoria-Urania, report written 

by R. Renzi, Loss Prevention Department, Liberty Mutual Insurance Company, Worcester, 

Massachusetts. October 28, 1958. [SRDB Ref. ID 78724] 

Liberty Mutual 1964. Industrial Hygiene Survey – Thoria-in-Air, survey conducted by Liberty 

Mutual Insurance Company, report written by R.L. Renzi. August 19, 1964. [SRDB Ref. 

ID 78722] 

NIOSH 2006. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

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

Compensation Analysis and Support, Cincinnati, Ohio. December 6, 2006. 

NIOSH 2008. Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0070, Revision 00, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. March 10, 2008. 

NIOSH 2011a. Dose Reconstruction Methodology for Norton Co., Template, National Institute 

for Occupational Safety and Health, Cincinnati, Ohio. September 16, 2011. 

NIOSH 2011b. SEC Petition Evaluation Report, Petition SEC-00173, Rev. 0, Norton Company, 

January 24, 2011.

NIOSH 2012. Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0070, Revision 01, National Institute for Occupational 

Safety and Health, Cincinnati, Ohio. March 5, 2012 

NIOSH 2015. Norton Company, Revision 0, DCAS-PER-059, National Institute for 

Occupational Safety and Health, Division of Compensation Analysis and Support, Cincinnati, 

Ohio. April 24, 2015. 

Norton 1955. Norton Company Worcester, Massachusetts: Thoria and Urania, report written by 

R.G. McAllister, Norton Company. November 16, 1955. [SRDB Ref. ID 78725] 

Norton 1962. Effluent Air Samples Results (February 19, 1962), survey conducted by Liberty 

Mutual, report written by R. S. Johnson. March 2, 1962. [SRDB Ref. ID 32669] 
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Norton 1963. Thorium Air Sample, Radiation Survey Thoria in the Air (February 26, 1963),

survey conducted by Liberty Mutual, report written by R. S. Johnson, Norton Company.

March 5, 1963. [SRDB Ref. ID 32687]

Pagnotto 1958. Correspondence from Leonard Pagnotto and Harold Bavley to Harvey B. Elkins, 

Director, Division of Occupational Hygiene, Department of Labor and Industries, 

Commonwealth of Massachusetts, Subj: “Norton Company, Worcester.” May 28, 1958. [SRDB 

Ref. ID 78700]

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

Periods at Atomic Weapons Employer Facilities, SCA-TR-TASK3-0009, Rev. 0, SC&A, Inc., 

Vienna, Virginia. August 29, 2008.

SC&A 2011. A Focused Review of the Norton Company SEC Petition Evaluation Report SEC00173 Concerning the Use of ORAUTI-OTIB-0070 for the Reconstruction of Doses from

Residual/Post-Operational Contamination, SC&A, Inc., Vienna, Virginia. July 7, 2011.

SEC 2011. Special Exposure Cohort Designation for a Class of Employees from Norton 

Company, Worcester, Massachusetts, Secretary of Health and Human Services. October 26, 

2011.