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Resolution of Site Profile Issues for the 

Carborundum Company

Niagara Falls, New York

White Paper

National Institute for Occupational 

Safety and Health

August 16, 2018

Thomas P. Tomes 

Division of Compensation Analysis and Support

Reviewed by: James W. Neton, Ph.D., CHP

Division of Compensation Analysis and Support

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

Page 2 of 11

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

INTRODUCTION

The S. Cohen & Associates (SC&A) review of SEC Petition 225 of January 27, 2016, identified 

seven Issues (Anigstein, 2016). All the Issues were either closed or considered site profile issues. 

In addition, SC&A also identified several other Issues/Findings during the review of NIOSH’s 

use of surrogate data and review of NIOSH responses and updated methods (NIOSH, 2017) and 

draft example dose reconstructions provided to the Carborundum Work Group (Work Group) on 

March 2, 2017. The additional issues were identified in memoranda to the Carborundum Work 

Group on November 16, 2016, March 12, 2017, and June 30, 2017 (Anigstein and Mauro, 2016; 

2017a; 2017b). 

Some of the site profile issues were discussed and closed by the Work Group during meetings 

held on August 18, 2016, November 17, 2016, and March 13, 2017 (Work Group 2016a, 2016b, 

2017). The resolution of some site profile issues remain unresolved by NIOSH and the Work 

Group. Table A-1 in Attachment A lists the various issues and findings and the status of each, 

including those already closed (or with agreed resolutions). Table 1 below lists nine 

Issues/Findings/Observations whose resolution has not previously been agreed to by NIOSH and 

the Work Group. Note that final resolution on a number of the issues will be implemented by 

NIOSH in an updated site profile document once agreement is reached on resolution of the 

remaining open issues. The issues that NIOSH intends to resolve by changes to doses or intakes 

specified in the site profile are identified with the “Update site profile” phrase in the third 

column of the tables. 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

Page 3 of 11

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Table 1: Open Site Profile Issues

Open site profile Issues Reference Resolution/Status

Dose from X ray Diffraction SC&A January 27, 2016

 March 12, 2017 

June 30, 2017

See NIOSH response below 

in text. 

Use of surrogate external 

dose data in 2nd Operational 

Period

SC&A November 10, 2016

NIOSH October 27, 2016

Work Group 

 March 13, 2017 

transcripts

See NIOSH response below 

in text. 

Update site profile.

Finding 4.1.1

Inconsistent work-hours used 

in residual dose calculations 

SC&A June 30, 2017 NIOSH has updated all the 

site profile calculations to 

agree with work-hours in 

Battelle-TBD-6000. The 

following number of workhours per year are used in 

updated calculations: 2,400 

for 1943-1950, 2,200 for 

1951-1955, and 2,000 for 

1956 to end. 

Update site profile.

Finding 4.1.2

Incorrect distribution type 

used for external doses in 

example DR for 1959 and 

1960.

SC&A June 30, 2017 NIOSH corrected an error in 

a table in the draft site profile 

spreadsheet.

Update site profile.

Finding 4.1.3

Incorrect source term and 

glovebox model used to 

model dose from plutonium 

SC&A June 30, 2017 

January 27, 2016

A white paper with revised 

dose estimates was provided 

to Work Group in August 

2018 (NIOSH, 2018). 

Update site profile.

Finding 4.1.5

Workers exposed to glovebox 

operations should be assigned 

intakes of both uranium and 

plutonium

SC&A June 30, 2017 See NIOSH response in text 

of this memo. 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Open site profile Issues Reference Resolution/Status

Finding 4.1.6

Incorrect worker intake 

category used in one of the 

Example DRs. 

SC&A June 30, 2017 NIOSH agrees with the 

SC&A comment. There was 

an error in the intake value 

used in the draft Example 

DR. 

No action needed by NIOSH.

Observation 4.2.1

SC&A commented that the 

methods to assign residual 

external dose using only the 

30-250 keV energy band in 

the Example DRs resulted in 

a small overestimate of dose

SC&A June 30, 2017 NIOSH used the method to 

simplify dose calculations. As 

indicated in the SC&A memo 

the dose difference is 

favorable to the claimant, but 

not significant. In the 

example mentioned by 

SC&A, the simplified 

calculation resulted in about a 

0.1% overestimate of total 

dose. 

No action needed by NIOSH.

Observation 4.2.2

SC&A commented that the 

method NIOSH used to 

calculate ingestion intakes in 

the 2nd Operational Period 

resulted in a slightly lower 

dose as opposed to the 

methods described in OCASTIB-009. 

SC&A June 30, 2017 The total dose difference is 

insignificant; however, 

NIOSH updated the 

spreadsheet used for the site 

profile to agree with the 

SC&A comment.

Update site profile.

Three of the issues in Table 1 referred to the text for response. Those three issues are discussed 

below. 

ISSUE: DOSE FROM X-RAY DIFFRACTION

SC&A commented on the need for NIOSH to make adjustments in the calculations of external 

dose from X-Ray Diffraction (XRD). Comments included the recommendation to increase workhour estimates of exposure in proximity to the XRD unit, application of a 2.48 factor to the dose 

rates proposed by NIOSH to adjust dose rates for instrument efficiency for the 8.0 keV and 8.9 

keV characteristic photons from the copper target used by the Carborundum XRD unit. SC&A 

also commented that organ doses should be calculated using more appropriate dose conversion 

factors (DCFs) than the 30-250 keV DCFs NIOSH used in the draft Example DRs.
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Resolution: NIOSH agrees to adopt the more favorable assumptions recommended by 

SC&A for exposure time and to apply the 2.48 factor to adjust the dose rate for instrument 

response to the low energy photons. These adjustments result in an annual exposure of 1.033 R 

to the XRD operator, as recommended by SC&A in their March 12, 2017, memorandum to the 

Work Group. 

NIOSH also agrees that more appropriate organ DCFs should be applied. SC&A suggested 

NIOSH use the mode value of the <30 keV DCF category. However, NIOSH performed organ 

dose calculations using more precise organ dose conversions for the characteristic photons (8.0 

keV and 8.9 keV). Factors for <0.010 MeV photons from ICRP Publication 74 (ICRP, 1996) 

were used to estimate organ doses. The 1.003 R/yr exposure was converted to air kerma (0.00877 

Gy/R), resulting in an annual dose of 0.008796 Gy/yr. Organ doses, in Gy, were then calculated 

using the ICRP 74 factors for 10 keV photons (organ dose per unit kerma free-in-air) found in 

Tables A.2 through A.20. The organ doses were then converted to units of rem. The various 

organ doses ranged from zero rem to a maximum of 0.267 rem. NIOSH then compared the organ 

doses from an XRD Operator to doses from a Laborer (support worker) in the uranium 

fabrication area. The uranium area work assumption provides the larger dose and will be used for 

dose reconstructions because NIOSH cannot determine precise work locations for all workers at 

all times. 

ISSUE: USE OF SURROGATE EXTERNAL DOSE DATA IN 2ND OPERATIONAL PERIOD

The Work Group discussed NIOSH’s use of surrogate data during the November 17, 2016, 

meeting (Work Group, 2016b); it was agreed that NIOSH needed to revise the external dose rate 

values. In the February 22, 2017, response paper to the Work Group, NIOSH presented updated 

dose estimates from exposure to uranium using surrogate data, and the updated doses were 

discussed during the Work Group meeting on March 13, 2017. At that time concurrence was 

reached on the updated photon dose rates; however, SC&A commented that the beta dose rates 

provided by NIOSH may underestimate actual dose rates at one foot from the source and 

overestimate the contact dose rate. The beta dose rate issue was determined to be a site profile 

issue and referred back to NIOSH for further evaluation. Subsequently, SC&A provided copies 

of their MCNP files and calculations of beta dose rates. 

NIOSH Resolution:

NISOH reviewed the calculations provided by SC&A and agrees that the beta dose rates 

modeled by SC&A are appropriate. Those calculations indicate a contact beta dose rate of 77.6 

mrem/hour and a one foot dose rate of 4.05 mrem/hour. NIOSH plans to use those dose rates in 

an updated site profile. For an Operator, those dose rates result in an annual whole body beta 

dose of 4.05 rem per year and a beta dose of 77.6 rem per year to the hands and forearms. Doses 

to other workers will be adjusted accordingly. 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ISSUE: FINDING 4.1.5, WORKERS EXPOSED TO GLOVEBOX OPERATIONS SHOULD BE 

ASSIGNED INTAKES OF BOTH URANIUM AND PLUTONIUM

SC&A commented that plutonium workers should be assigned intakes of both uranium and 

plutonium during the 2nd Operational Period in 1961 through 1967, a period during which both 

uranium and plutonium were used to fabricate mixed carbide fuel pellets. SC&A concluded it is 

“illogical to assume that a worker who was externally exposed to the fabrication of uraniumplutonium pellets would be assigned intakes that consisted only of uranium aerosols.” SC&A 

further noted that “plutonium can make significant contributions to internal doses.”

NIOSH Response: 

The intake methods described by NIOSH in the response paper of February 22, 2017, that were 

the subject of SC&A Finding 4.1.5, are favorable, and NIOSH proposes no changes to the intake 

methods presented in that paper. The rationale is provided below.

Uranium work in the 2nd Operational Period started in 1959. The plutonium work started in 1961 

and involved both uranium and plutonium in the fabrication of mixed carbide fuel pellets. There 

was a separate uranium laboratory used for experiments and fabrication of uranium (only) 

experimental pieces and fuel pellets. NIOSH estimated intake rates in the uranium laboratory 

based on measured alpha air concentrations in the uranium laboratory. The plutonium laboratory 

was an isolated cell in the same building; operations with plutonium started in 1961. NIOSH 

estimated intake rates from the plutonium cell based on measured alpha air concentrations in the 

plutonium laboratory. In the absence of definitive work locations for all workers, NIOSH intends 

to assign intakes from whichever work area provides the higher dose. The choice of using one or 

the other areas of exposure, but not both, is based on the assumption that a worker is not 

simultaneously exposed in two different areas of the Carborundum facility. The alpha intake 

rates in the uranium laboratory are higher than the alpha intake rates in the plutonium area.

The uranium laboratory air concentrations are interpreted as 100% uranium alphas because no 

other alpha emitting radionuclides have been identified in those areas, although intakes of other 

radionuclides that may have been present in recycled uranium are applied as a function of the 

uranium intakes. 

The plutonium laboratory used both uranium and plutonium in the fabrication of fuel pellets. The 

intakes are based on alpha air concentration estimates. Since workers could have been exposed to 

either uranium or plutonium, or a mixture, NIOSH intends to assign intakes from whichever 

element provides the higher internal dose for the claimant. 

For the situation of alpha intakes in the plutonium laboratory, NIOSH performed scoping 

calculations for dose to the various organs per unit intake of Pu-239 and U-234; those scoping 

calculations indicated plutonium usually, but not always, provided the higher organ dose per unit 

intake. Since the alpha air concentrations in the plutonium cell could have been uranium, 

plutonium, or a mixture, dose reconstructions should interpret alpha intakes for exposure in the 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

plutonium cell as either plutonium or uranium, whichever results in the higher dose. However, if 

an assumption of uranium is made, the uranium laboratory always provides the highest dose 

because the intakes are higher. Thus, the highest internal dose can be determined by a choice 

between 100% plutonium alphas for the plutonium laboratory or 100% uranium alphas in the 

uranium laboratory. 

SC&A also mentioned that it was not logical to assume external exposure to plutonium fuel 

pellets in the plutonium laboratory while assuming internal exposure to uranium in the uranium 

laboratory. NIOSH agrees in principle; however, NIOSH assumes that a worker could have been 

exposed in both laboratories for portions of their work. NIOSH intends to apply the more 

favorable internal and external doses separately to ensure total doses are not underestimated. 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

Page 8 of 11

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

REFERENCES

ABRWH (Advisory Board on Radiation and Worker Health), 2017, ABRWH discussion on 

Carborundum Company SEC Petition 00225, transcripts of the 116th meeting of the Advisory 

Board on Radiation and Worker Health, pp. 47-79, March 22, 2017. [SRDB Ref ID: 172563]. 

Anigstein, R., 2016, SC&A, Inc., “Review of the Carborundum Special Exposure Cohort (SEC) 

Petition-00223 and the NIOSH SEC Petition Evaluation Report,” SC&A-TR-SEC-2016-0001, 

Revision 1, January 27, 2016. [SRDB Ref ID: 169330].

Anigstein, R. and Mauro, J, 2016, SC&A, Inc., “Review of NIOSH Use of Surrogate Data in the 

SEC Evaluation Report for Carborundum,” memorandum to Advisory Board on Radiation and 

Worker Health, Work Group on Carborundum Company, November 10, 2016. [SRDB Ref ID: 

169331]. 

Anigstein, R. and Mauro, J, 2017a, “Updated Status Report on SC&A Review of NIOSH 

Response Paper,” memorandum to Advisory Board on Radiation and Worker Health, Work 

Group on Carborundum Company, March 12, 2017. [SRDB Ref ID: 172562]. 

Anigstein, R. and Mauro, J, 2017b, “Final Audit of NIOSH Response Paper and Example DRs,”

memorandum to Advisory Board on Radiation and Worker Health, Work Group on 

Carborundum Company, June 30, 2017. [SRDB Ref ID: 172561]. 

ICRP (International Commission on Radiological Protection), 1996, “Conversion Coefficients 

for use in Radiological Protection Against External Radiation, ICRP Publication 74,” Annals of 

the ICRP, volume 26, number 3-4. [SRDB Ref ID: 7979].

NIOSH (National Institute for Occupational Safety and Health), 2016, “Use of Surrogate Data at 

the Carborundum Company,” Division of Compensation Analysis and Support, Cincinnati, Ohio, 

October 27, 2016. [SRDB Ref ID: 169329].

NIOSH, 2017, “NIOSH Evaluation of Carborundum Company, Response to Site Profile Issues 

and Comments,” Division of Compensation Analysis and Support, Cincinnati, Ohio, February 

22, 2017. [SRDB Ref ID: 166028].

NIOSH, 2018, “Estimates of Dose Rates from the Plutonium-bearing Fuel Pellets Fabricated at 

Carborundum,” Division of Compensation Analysis and Support, Cincinnati, Ohio, August 3, 

2018. [SRDB Ref ID: 172595]. 

Work Group (Advisory Board on Radiation and Worker Health, Carborundum Work Group), 

2016a, transcripts of the Carborundum Work Group, August 18, 2016. [SRDB Ref ID: 172565]. 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

Page 9 of 11

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Work Group, 2016b, transcripts of the Carborundum Work Group, November 17, 2016. [SRDB 

Ref ID: 172566]. 

Work Group, 2017, transcripts of the Carborundum Work Group, March 13, 2017. [SRDB Ref 

ID: 172564]. 
White Paper Resolution of Site Profile Issues for the Carborundum 

Company, Niagara Falls, New York

August 16, 2018

Page 10 of 11

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ATTACHMENT A

Table A-1: List of Issues Identified by SC&A Review

Issue Reference Status

Dose from X ray Diffraction

(SEC Issue 1)

SC&A January 27, 2016

 March 12, 2017 

 June 30, 2017 

Closed as SEC Issue by Work 

Group on 8/18/2016 and 

3/13/2017. 

Open site profile Issue-see 

Table 1.

Possible exposure from 

thorium contamination 

(SEC Issue 2)

SC&A January 27, 2016 Closed as SEC Issue by Work 

Group on 8/18/2016. 

Closed as site profile Issue by 

Work Group on 3/13/2017.

Possible exposure from Sr-90 

source (SEC Issue 3)

SC&A January 27, 2016 Closed by Work Group on 

8/18/2016.

Medical x-ray dose during 1st

Operational Period

(SEC Issue 4)

SC&A January 27, 2016 Closed by Work Group on 

8/18/2016. 

Update site profile.

Medical x-ray dose during 2nd

Operational Period

(SEC Issue 5)

SC&A January 27, 2016 Closed by Work Group on 

8/18/2016. 

Use of Federal Guidance 

Report 12 factors 

(SEC Issue 6)

SC&A January 27, 2016 Closed by Work Group on 

8/18/2016. 

Update site profile.

Doses in Example DR not 

reproducible (SEC Issue 7)

SC&A January 27, 2016 Closed by Work Group on 

3/13/2017.

Use of surrogate external 

dose data in 1st Operation 

Period

SC&A November 10, 2016

 March 12, 2017 

NIOSH October 27, 2016

Closed by Work Group on 

3/13/2017. 

Update site profile.

Use of surrogate external 

dose data in 2nd Operation 

Period

SC&A November 10, 2016

 March 12, 2017 

NIOSH October 27, 2016

Closed as SEC Issue by Work 

Group on 3/13/2017. 

Open site profile Issue-see 

Table 1.

Finding 4.1.1

Inconsistent work-hours used 

in residual dose calculations

SC&A June 30, 2017 Open site profile Issue-see 

Table 1.
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Company, Niagara Falls, New York

August 16, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Issue Reference Status

Finding 4.1.2

Incorrect distribution type 

used for external doses in 

example DR for 1959 and 

1960.

SC&A June 30, 2017 Open site profile Issue-see 

Table 1.

Finding 4.1.3

Incorrect source term and 

glovebox model used to 

model dose from plutonium 

SC&A June 30, 2017

January 27, 2016

Open site profile Issue-see 

Table 1.

Finding 4.1.4

Incorrect surrogate organ 

used for medical x-ray dose 

to kidney in Example DR; 

incorrect standard deviation 

used for medical x-ray to lung 

in Example DR

SC&A March 13, 2017

 June 30, 2017 

That was an error in draft 

example DR, as discussed in 

Work Group meeting on 

3/13/2017. 

No action needed by NIOSH. 

Finding 4.1.5

Workers exposed to glovebox 

operations should be assigned 

intakes of both uranium and 

plutonium

SC&A June 30, 2017 Open site profile Issue-see 

Table 1.

Finding 4.1.6

Incorrect intake category used 

in one of the Example DRs. 

SC&A June 30, 2017 Open site profile Issue-see 

Table 1.

Observation 4.2.1

SC&A commented that the 

methods to assign residual 

external dose using only the 

30-250 keV energy band in 

the Example DR resulted in a 

small overestimate of dose

SC&A June 30, 2017 Open site profile 

Observation-see Table 1.

Observation 4.2.2

SC&A commented that the 

method NIOSH used to 

calculate ingestion intakes in 

the 2nd Operational Period 

resulted in a slightly lower 

dose as opposed to the 

methods described in OCASTIB-009 

SC&A June 30, 2017 Open site profile 

Observation-see Table 1.