Draft White Paper 

Resolution of SC&A Findings on Appendix C (Dow Madison) 

of Battelle-TBD-6000 

Contract No. 200-2009-28555 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

 March 2010 

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.
Draft White Paper – Dow Madison 2 SC&A – March 12, 2010 

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. 

INTRODUCTION 

At the February 5, 2010, meeting of the SEC Issues Work Group, SC&A was tasked by 

Chairman Melius to prepare an outline to insure that all the relevant points related to Special 

Exposure Cohort (SEC) issues at Dow Madison have been addressed. Based on the discussions 

at the meeting, SC&A determined that this request has two parts. The first was to delineate the 

extent to which surrogate data are used for dose reconstruction, based on the most recent NIOSH 

position presented in Appendix C of Battelle-TBD-6000, and the second is to summarize the 

extent to which SC&A’s findings [based on its August 24, 2009, review of Appendix C (SC&A 

2009a)] have been addressed by NIOSH. These two items are covered in separate brief white 

papers. This white paper describes SC&A’s understanding of the extent to which its findings 

from a review of Appendix C have been resolved. 

RESOLUTION ON SC&A”S APPENDIX C FINDINGS 

Subsequent to the publication of the three petition evaluation review reports (NIOSH 2007a, 

2007b, and 2008), NIOSH released Appendix C to TBD-6000 (Battelle 2006) on September 8, 

2008, which specifically deals with the Dow Madison site. Appendix C tabulates and 

consolidates data and guidance that can be used to calculate internal (inhalation and ingestion) 

and external doses from uranium exposures during both the operating and residual periods. 

Appendix C also provides data that can be used to calculate external thorium exposures during 

the operating period, and both external and internal (inhalation, ingestion, and thoron) exposures 

during the residual period. NIOSH determined that it was not feasible to reconstruct internal 

thorium doses during the operating period. 

Each of SC&A’s Findings from its review of Appendix C is listed below, together with NIOSH’s 

comments made at the February 5th meeting (Transcript 2010) and additional input by SC&A for 

this white paper. In summary, SC&A believes that all issues have been resolved or have been 

transferred for review as generic issues. 

Finding 1: NIOSH has proposed the use of geometric mean data to calculate internal uranium 

exposures during the operating period. The geometric mean is based on only two measurements 

and, since NIOSH’s stated goal is to estimate maximum doses, we believe that use of the 95th

percentile is a more appropriate metric for this situation. 

NIOSH pointed out that this is not an SEC issue, since workers exposed during the operating 

period have already been added to the SEC. Therefore, the finding only relates to dose 

reconstruction for non-presumptive cancers. NIOSH thought that the POC might actually go 

down when using the 95th percentile, as compared to using the estimated geometric mean (GM) 

and an assumed geometric standard deviation (GSD) of 5 proposed by NIOSH (Transcript 2010, 

p. 23). 

The question of the proper metric to be used for bounding calculations has been discussed on 

many occasions in the past. The question was recently considered by the TBD-6000 Work 

Group at its December 16, 2009, meeting, where NIOSH adopted the position that use of the 
Draft White Paper – Dow Madison 3 SC&A – March 12, 2010 

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. 

GM/GSD approach was claimant favorable, and SC&A felt that use of the 95th percentile was 

more appropriate for bounding calculations. At that meeting, the Work Group requested that 

SC&A make some hypothetical Interactive RadioEpidemiological Program (IREP) calculations 

to clarify the situation. SC&A modeled two hypothetical external exposure cases; in one, the 

POC was >50% for both approaches, and in the other, the POC was >50% using the 95th

percentile and <50% using GM/GSD (SC&A 2009b). So the question remains unanswered. 

Perhaps, the matter could be resolved for Dow by some hypothetical IREP modeling of internal 

dose. 

NIOSH was also of the opinion that use of the 95th percentile would result in implausible 

uranium intakes during the operation period (Transcript 2010, p. 24). The uranium operation 

with the highest dust level modeled in Appendix C involved rod straightening, with a GM daily 

weighted average value of 1,690 dpm/m3 (Battelle 2006, Table 7.7). Assuming a GSD of 5, the 

95th percentile value would be 23,860 dpm/m3

. The maximum dust exposure reported in TBD6000 for any uranium fabrication operation is 13,700 dpm/m3 (for a roughing roll operator). 

Based on that information, we agree that NIOSH’s approach to bounding internal uranium 

exposures during the operating period is reasonable. Hence, SC&A recommends closing this 

issue. 

Finding 2: The resuspension factor used by NIOSH for estimating uranium dust concentrations 

in air could be low by 1 to 2 orders of magnitude. NIOSH should revisit the use of a value of 1 × 

10-6/m. 

NIOSH and SC&A agreed that this was an overarching issue that needs to be resolved in a 

broader context than just Dow, since it affects a number of different appendices and approaches 

(Transcript 2010, p. 24). Hence, SC&A believes that this issue is being addressed as a generic 

issue and will be held in abeyance as it applies to Dow, until this issue is resolved generically. 

Finding 3: NIOSH should consider developing an exponential decay function for uranium 

removal during the residual period based on guidance in ORAUT-OTIB-0070 [ORAUT 2008].

NIOSH indicated that a better approach would be one which is consistent with the approach used 

for thorium; namely, using an exponential decay function. NIOSH said that they would look into 

changing the uranium modeling approach to be similar to thorium (Transcript 2010, p. 25). 

Finding 4: There appear to be data entry errors in Table C.2 for the residual period. 

NIOSH agreed that the last line in Table C.2 was incorrect (Transcript 2010, p. 25). In a March 

10th e-mail from LaVon Rutherford of NIOSH to W.C. Thurber of SC&A, Rutherford stated that 

the correct values for uranium exposure during the residual period were 0.86 mr/yr for the 

photon dose, 8.6 mrem/yr for the shallow dose to the skin other than the hands and arms, and 

8.6 mrem/yr to the hands and arms. The skin dose was independent of body location, because 

workers would not be handling uranium during the residual period. 
Draft White Paper – Dow Madison 4 SC&A – March 12, 2010 

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. 

 

We presume that the photon dose is based on information in Table 6.4 of TBD-6000 for a “scrap 

recovery” operator1 who received a dose of 2.358E-03 mr per calendar-day, or 0.86 mr/yr from a 

contaminated floor surface. We further presume that the shallow dose was assumed to be 

10 times the deep dose. This is consistent with the guidance in Section 6.3 of TBD-6000, which 

states that, “For dose to other skin on the worker’s body that is not in direct contact with uranium 

metal, but is nearby (for example, a worker’s neck and face when the hands are in contact with 

metal), a dose relation can be used that estimates this dose to be 10 times the photon dose rate at 

1-foot. This relation, [is] based on a review of film badge data, ...” 

Based on the information provided by NIOSH, SC&A believes that this finding is appropriately 

resolved. SC&A recommends closing this issue. 

 

Finding 5: NIOSH should focus additional attention on insuring the transparency of the dose 

reconstruction guidance. 

This finding was not discussed, nor was discussion necessary. The development of dose 

reconstruction parameters is often complex and this finding is simply intended to reflect the fact 

that, with minimal additional effort, the dose reconstruction guidance could be clarified. It is 

often difficult to trace the assumptions to their source or to understand how the cited assumptions 

were actually implemented. In some cases, units of measurement are not clear. 

 

REFERENCES 

Battelle 2006. Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals. Battelle-TBD-6000. Battelle Team Dose Reconstruction Project for NIOSH.

NIOSH (National Institute for Occupational Safety and Health) 2007a. SEC Petition Evaluation 

Report Petition SEC-00079. April 13, 2007; SRDB Ref ID: 39873. 

NIOSH (National Institute for Occupational Safety and Health) 2007b. Addendum 1 to SEC 

Petition Evaluation Report Petition SEC-00079. August 6, 2007. 

NIOSH (National Institute for Occupational Safety and Health) 2008. Addendum 2 to SEC 

Petition Evaluation Report Petition SEC-00079. June 3, 2008. 

ORAUT (Oak Ridge Associated Universities Team) 2008. Dose Reconstruction During 

Residual Radioactivity Periods at Atomic Weapons Employer Facilities. ORAUT-OTIB-0070, 

Revision 00. Cincinnati, Ohio. 2008. 

SC&A 2009a. Focused Review of Appendix C to TBD-6000 – Dow Chemical Company 

(Madison Site). SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. August 

24, 2009. 

1

 This job description included rod straightening. 
Draft White Paper – Dow Madison 5 SC&A – March 12, 2010 

 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:

SC&A 2009b. Review of NIOSH Issue 1 White Paper Dated December 10, 2009. Prepared for 

the TBD-6000 Work Group by SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. December 23, 2009. 

Transcript 2010. Transcript of SEC Issues Work Group Meeting, February 5, 2010. 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2010/wgtr020510.pdf.