Draft

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

SC&A’s Review of the NIOSH Document Issued July 29, 2015, 

Titled, NIOSH Response to SC&A Review of the Ames Site Profile 

Document Regarding Uranium Internal Exposure

Contract No. 211-2014-58081 

Revision 0 

Prepared by 

U. Hans Behling, PhD, MPH 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

September 8, 2015 

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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S. COHEN & ASSOCIATES: Technical Support for the Advisory Board on Radiation & 

Worker Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

SC&A’s Review of the NIOSH Document Issued July 29, 2015,

Titled, NIOSH Response to SC&A Review of the Ames Site Profile 

Document Regarding Uranium Internal Exposure

DOCUMENT NUMBER/

DESCRIPTION: Review of NIOSH Response to SC&A Ames Site Profile Review

REVISION NO.: Rev. 0

SUPERSEDES: N/A

EFFECTIVE DATE: September 8, 2015

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

PROJECT MANAGER: John Stiver [signature on file]

DOCUMENT 

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

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 09/08/2015 Initial issue
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TABLE OF CONTENTS

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

1.0 Chronology and Summary of Relevant Background Information Pertaining to the 

Ames Site Profile, ORAUT-TKBS-0055, Rev. 03 ............................................................. 5

2.0 SC&A’s Review of ORAUT-TKBS-0055, Rev. 03 ........................................................... 6

2.1 Occupational Environmental Dose ......................................................................... 6

2.2 Occupational Internal Dose..................................................................................... 7

2.3 Occupational External Dose ................................................................................... 8

3.0 NIOSH’s Response to the SC&A Review of the Ames Site Profile .................................. 9

3.1 NIOSH’s Proposed Revisions for Uranium Intakes ............................................. 10

4.0 Discussion of and Response to Revised Uranium Intakes for Ames Laboratory 

Proposed by NIOSH ......................................................................................................... 11

5.0 References ......................................................................................................................... 13
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ABBREVIATIONS AND ACRONYMS

Advisory Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission

ALRR Ames Laboratory Research Reactor

ERDA Energy Research and Development Administration 

FMPC Feed Materials Production Center

GSD geometric standard deviation

m meter

m3

/d cubic meter per day

NIOSH National Institute for Occupational Safety and Health

ORAUT Oak Ridge Associated Universities Team

pCi/d picocuries per day

R&D Research and Development

Th thorium 

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

SEC Special Exposure Cohort 

SRDB site research database

TBD Technical Basis Document

U uranium 
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1.0 CHRONOLOGY AND SUMMARY OF RELEVANT BACKGROUND 

INFORMATION PERTAINING TO THE AMES SITE PROFILE, 

ORAUT-TKBS-0055, REV. 03

Revisions to the Ames Site Profile. The first Site Profile for Ames Laboratory, ORAUT-TKBS0055, Rev. 00 (ORAUT 2007) was issued on June 22, 2007. Since then, the Ames Site Profile 

has been revised four times: Rev. 00 PC-1 on August 20, 2008 (ORAUT 2008); Rev. 01 on 

December 18, 2009 (ORAUT 2009); Rev. 02 on January 14, 2011 (ORAUT 2011); and Rev. 03 

on January 3, 2012 (ORAUT 2012a).

While some of the aforementioned revisions resulted in an increase in assigned dose, others 

decreased the dose, and still others decreased in an earlier revision and increased in a subsequent 

revision, as summarized below:

Special Exposure Cohort (SEC) Classes Added. During this time period, NIOSH added classes 

to SEC-00038 in 2006 (NIOSH 2006), SEC-00075 in 2007 (NIOSH 2007), and SEC-00166 in 

2010 (NIOSH 2010) to cover three separate groups of employees based on work location and job 

description. While the classes added in 2006 and 2007 included specific workers performing 

specific tasks in designated buildings, the 2010 class determined that the information available 

about worker job description, work location, or movement about the site was insufficient to 

determine if an employee worked in the affected area(s).

In 2011, NIOSH designated a fourth class [SEC-00185 (NIOSH 2011)] that encompasses all 

previous Ames SEC periods from August 13, 1942, to December 31, 1970, and designates all 

Ames employees (including predecessor agencies, contractors, and subcontractors) who were 

employed for a number of workdays aggregating at least 250 workdays.

In behalf of these four SEC classes, NIOSH in Rev. 03 of ORAUT-TKBS-0055 (ORAUT 2012a) 

provided the following statements and guidance for the dose reconstruction of Ames workers 

who were employed after December 31, 1970, as well as for workers who were employed prior 

to 1970, but who are not eligible for inclusion in SEC-00185: 

Although NIOSH cannot bound doses for certain areas and periods as described 

in the SECs, internal and external data that become available for an individual 

claim (and that can be interpreted using existing NIOSH dose reconstruction 

processes or procedures) and applicable dose reconstruction methods that are 

defined in Sections 4, 5, and 6 of this site profile, will be used to complete partial 

dose reconstructions for workers who worked during the SEC periods but are 

not eligible for the SEC. [Emphasis added.] 
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2.0 SC&A’S REVIEW OF ORAUT-TKBS-0055, REV. 03 

In a teleconference held by the Advisory Board on February 7, 2013, SC&A was tasked to 

review/evaluate the Site Profile for Ames Laboratory, ORAUT-TKBS-0055, Rev. 03 (ORAUT 

2012a), which was issued on January 3, 2012. On August 14, 2013, SC&A submitted to the 

Advisory Board the draft document, Review of the NIOSH Site Profile for the Ames Laboratory, 

SCA-TR-SP2013-0044, Rev. 0 (SC&A 2013). 

The purpose of this review was to provide NIOSH and the Advisory Board with an independent 

assessment of issues that surround the Ames Site Profile in behalf of energy employees with 

non-presumptive cancers and/or fewer than 250 workdays. Findings identified in SC&A’s

review provided NIOSH and the Advisory Board with a preliminary overview of potential 

issues that may impact the feasibility of dose assessment.

SC&A’s review of ORAUT-TKBS-0055, Rev. 03 (ORAUT 2012a) principally focused on the 

following three sections of the Ames Laboratory Site Profile:

• Section 4.0 – Occupational Environmental Dose 

• Section 5.0 – Occupational Internal Dose

• Section 6.0 – Occupational External Dose

Of the 22 preliminary findings identified by SC&A, 9 findings pertained to Occupational 

Environmental Dose, 11 to Occupational Internal Dose, and 2 to Occupational External Dose. 

These findings are briefly summarized in Sections 2.1, 2.2, and 2.3 below. 

2.1 OCCUPATIONAL ENVIRONMENTAL DOSE

Finding #1: Derived environmental intakes of U and Th, as given in Table 4-7 of the Technical 

Basis Document (TBD), are improperly referenced and appear without technical basis. 

Finding #2: NIOSH provides no basis for the “assumed” losses of 0.1% of U and Th to the 

environment and fails to identify a value for resuspension. 

Finding #3: NIOSH’s selection of personnel at the Ames Laboratory Research Reactor (ALRR) 

Facility as the target population is inappropriate and results in dose estimates that are not 

claimant favorable. 

Finding #4: NIOSH’s selection of data from the 1961 survey conducted at the Synchrotron 

Facility defines fenceline dose rates that are 1 to 2 orders of magnitude lower than other 

measurements reported in the survey when beam direction was shifted from a westerly to 

easterly direction. 

Finding #5: SC&A concludes that the 1961 survey measurements, which were limited to 

gamma dose rates, were incomplete and may have substantially underestimated total exposure by 

excluding the contribution of particulate radiation.
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Finding #6: Statements in Section 4.3 of the Ames Site Profile are factually incorrect. For all 

years for which Voss reported environmental sampling data (1974, 1975, 1976), there were two 

sampling sites (not one, as stated by NIOSH) that provided data in behalf of air concentrations 

and corresponding dose estimates.

Finding #7: The nearly “instantaneous” 100-fold reduction of U and Th environmental intakes 

that represent the transition of the uranium and thorium metal production facilities at the end of 

1953 to research and development (R&D) facilities in 1954 are improperly modeled. Also not 

included in the model are the contribution of blowouts to environmental contamination and the 

persistence of these radionuclides in the environment post-1953. 

Finding #8: Environmental intakes cited in Table 4-7 of the Ames TBD are based on 

unsupported assumptions and model parameters, which moreover are inconsistent with 

parameter values used to model worker intakes inside the hot laboratory described in Section 5.0 

of the TBD.

Finding #9: Uranium and Th blowouts represent significant environmental events that should 

be included in Section 4.5 of the Ames TBD for the assessment of environmental exposures.

2.2 OCCUPATIONAL INTERNAL DOSE

Finding #10: Available empirical bioassay and air-sampling data for Annex 1 workers are 

substantially higher than modeled/surrogate data assigned by NIOSH. 

Finding #11: NIOSH further minimized the intake value of 853 pCi/d for Annex 1 production 

workers by assigning the “distribution” as a constant.

Finding #12: Default intake rates defined in Table 5-8 of the Ames TBD are improper for 

absorption Types F or S. 

Finding #13: The scaling of uranium intake values based on (1) facility and (2) job function is 

without technical support and conflicts with statements given in the Ames Site Profile. 

Finding #14: Although NIOSH briefly acknowledged the occurrence of “frequent fires and 

explosions” associated with the production of uranium metal, no attempt was made to assess 

potential intakes of these episodic events.

Finding #15: Technical Basis for Estimating the Maximum Plausible Dose to Workers at 

Atomic Weapons Employer Facilities, ORAUT-OTIB-0004, Rev. 03 (ORAUT 2006) is 

referenced for estimating non-operational intakes. OTIB-0004 was canceled before Rev. 03 of 

the Ames Site Profile (ORAUT 2012a) was issued. Moreover, the much higher intake values for 

inhalation and ingestion during non-operating years (i.e., 1954–1976) are inconsistent with 

intake values for operating years (1942–1953) as given in Table 5-8 of the Ames TBD.
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Finding #16: NIOSH’s approach for deriving estimates of thorium intakes from residual 

contamination post-1954 does not make the best use of survey data reported by Klevin (1952) 

and use of ORAUT-OTIB-0070, Rev. 01 (ORAUT 2012b). 

Finding #17: Given the availability of credible data, NIOSH’s exclusion of thorium exposure in 

dose reconstruction is not justified.

Finding #18: Due to the fact that very little is known about the design features and technical 

specifications of the Hot Lab and the absence of worker monitoring/facility survey data, the 

applicability of NUREG-1400 (Hickey et al. 1993), Section 1.2, for use in dose reconstruction 

lacks technical merit and credibility for a facility that operated between 1943 and 1951. 

Finding #19: Although Section 5.4.2 of the Ames TBD is titled, “Fission Product Intakes from 

Research Reactor Operations and Decontamination and Decommissioning,” NIOSH restricted 

intakes to two activation products that are arbitrarily based on a 1977 Energy Research and 

Development Administration (ERDA) gross beta air concentration limit.

2.3 OCCUPATIONAL EXTERNAL DOSE

Finding #20: By means of documented anecdotes/testimonials regarding potential frequencies 

of blowouts, technical data for a specific blowout documented at Feed Materials Production 

Center (FMPC), and reasonable assumptions, SC&A derived significant U and Th intakes and 

associated organ doses that are applicable to workers at the Ames Laboratory, but were not 

considered/included in ORAUT-TKBS-0055, Rev. 03 (ORAUT 2012a).

Finding #21: SC&A’s concerns about the use of the same surrogate data sources and 

questionable assumptions for deriving external dose for Ames’ workers exposed to uranium 

closely parallel those related to uranium intakes as cited in Findings #10 and #13. 

Findings #22: Given the availability of highly credible and site-specific data for deriving 

external doses from thorium exposure, NIOSH’s decision to exclude said exposures/doses is not 

justified.
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3.0 NIOSH’S RESPONSE TO THE SC&A REVIEW OF THE AMES 

SITE PROFILE

In response to SC&A’s review of ORAUT-TKBS-0055, Rev. 03 (ORAUT 2012a), NIOSH 

issued a report titled NIOSH Response to SC&A Review of the Ames Site Profile Document 

Regarding Uranium Internal Exposures, Rev. 0, dated July 29, 2015 (NIOSH 2015). This report 

addressed 11 of the 22 findings cited above (i.e., Findings #1, #2, #7, #9, #10, #11, #12, #13, 

#14, #15, and #20). A shared feature of these findings is that they pertain either exclusively or in 

part to uranium intakes. In Section 2.0 of the response, NIOSH provided the following 

summary statements and conclusions: 

The current Site Profile for Ames Laboratory (ORAUT 2012a), or Technical 

Basis Document (TBD), provides intake rates of uranium for different job 

categories from the three buildings previously used to process uranium. The TBD 

also provides environmental uranium intakes. The various uranium intakes in the 

TBD are based on surrogate air sampling data from other facilities and 

exposure models. [Emphasis added.]

. . . NIOSH has reviewed [SC&A’s] comments, the TBD methods, and available 

references and agrees that the uranium intakes in the TBD need to be 

re[-]evaluated. 

In this paper, NIOSH proposes to replace the uranium intakes in the TBD with 

intakes derived from bioassay data from 1944 and 1945 of workers engaged in 

uranium production, which includes some of the peak uranium production months 

at Ames during World War II. This is the bioassay data discussed in the SC&A 

report. Intakes in subsequent years are then derived from the production era 

intake rates. None of the current methods used to model intakes in the TBD, and 

to which SC&A had comments, are being retained in the proposed changes. 

Thus, this paper does not attempt to respond to each technical issue identified by 

SC&A, although Section 3.2 identifies the method being proposed to resolve 

each finding. [Emphasis added.] 

In brief, Section 3.2 of the NIOSH Report (NIOSH 2015) identifies each of SC&A’s 11 findings 

listed above (i.e., Findings #1, #2, #7, #9, #10, #11, #12, #13, #14, #15, and #20) and categorizes 

them based on commonalities that permit their collective resolution. For example, SC&A’s 

Findings #1, #2, #7, and #9 pertain to current dose models used to derive uranium intakes from 

environmental sources. To resolve these findings, NIOSH proposes the following: 

. . . This paper addresses those comments by proposing a new method to calculate 

intakes. The uranium intakes presented herein include a “Low” exposure 

category based on bioassay data from workers who were incidentally exposed to 

uranium during the production years, as discussed below. This method should 

account for environmental intakes from all sources, including blowouts. 

Additionally, methods are presented to estimate intakes from a gradually depleted 

source term after the end of uranium production. [Emphasis added.] 
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3.1 NIOSH’S PROPOSED REVISIONS FOR URANIUM INTAKES

Production Years/Demolition. In Section 5.0 of the report, NIOSH evaluated 67 uranium 

urinalysis samples representing 48 workers who were ranked by their supervisors into 4 exposure 

categories. NIOSH re-evaluated these data and derived uranium intake estimates during 

production years for High, Medium, and Low exposure categories of workers, as given in 

Tables 2, 3, and 4 of Section 5.4. 

Residual Contamination. After 1953, Section 5.5 of the NIOSH Report modeled internal 

exposure potential to uranium by deriving the air concentration level that represented the 50th

percentile inhalation intake rate during the operational period. By assigning a 30-day period of 

settling, a starting surface contamination was defined, which by means of a resuspension factor 

of 1 × 10-5/m and a breathing rate of 9.6 m3/d was used to define the daily inhalation rate for 

1953. For subsequent years, a depletion rate of 0.00067 per day was applied, as given in 

Table 5. 

Table 6 identifies daily intakes by ingestion by year, which are based on guidance cited in 

OCAS-TIB-009 (OCAS 2004), the derived starting surface contamination in 1953, and the 

previously identified deletion rate of 0.00067 per day. 
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4.0 DISCUSSION OF AND RESPONSE TO REVISED URANIUM 

INTAKES FOR AMES LABORATORY PROPOSED BY NIOSH

SC&A’s assessment of proposed revisions reflects a multi-step process. At the core of revisions 

proposed by NIOSH was the use of empirical, site-specific urinalysis data reported by Ferretti, 

et al. 1951, which was a principal SC&A recommendation, as summarized in Section 2.1 above 

in Finding #10. 

From this data set, NIOSH derived intake estimates (1) for operational/material processing years 

and (2) from exposures due to residual contamination for the years post-1953. 

For operational years, NIOSH derived intakes for the following worker categories:

• High (95th percentile intakes): for individuals who operated process equipment and 

maintenance/laboratory/health physics workers

• Medium (50th percentile intakes with GSD of 3): for supervisory staff, engineers, and 

others who were routinely in production areas and may have episodically been in the 

vicinity of processing areas.

• Low: for individuals that include office workers or non-uranium workers whose 

exposure may have been highly restricted and/or limited to onsite ambient/ 

environmental levels.

For subsequent years, inhalation and ingestion intakes from residual contamination were based 

on the air concentration (corresponding to the 50th percentile intake value during the period of 

uranium processing) and subsequently modeled by means of assumed parameter values of 

particle deposition, resuspension, and inhalation rates as previously described. 

Included in our evaluation of NIOSH’s revised approach for deriving uranium intakes, SC&A 

assessed the following elements:

• NIOSH’s interpretation of the uranium urinalysis data used for deriving intake/inhalation 

values in terms of their technical merit and claimant favorability

• Use of established/approved guidance documents and protocols for the revised estimates 

of uranium intakes 

• Assumptions and parameter values used for modeling exposures to residual 

contamination 

• Verification of revised intake values cited in Tables 2, 3, 4, 5, and 6 of the NIOSH report 

(NIOSH 2015). 

Based on our review of the proposed revisions to uranium intakes for the Ames Site Profile, 

SC&A agrees with the revised methodology used by NIOSH. SC&A further concludes that the 

revised estimates of uranium intakes are technically defensible, claimant favorable, and 
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adequately address SC&A’s concerns cited in Findings #1, #2, #7, #9, #10, #11, #12, #13, #14, 

#15, and #20. 

Correspondingly, it is SC&A’s recommendation to the Board that said findings be closed. 
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5.0 REFERENCES

Ferretti, R.J., G.R. Price, and S. Schwartz, 1951. Uranium Excretion Studies, In Industrial 

Medicine on the Plutonium Project, Survey and Collected Papers, Edited by Robert S. Stone, 

M.D., McGraw-Hill Book Co. [SRDB Ref ID: 739]

Hickey, E.E., G.A. Stoetzel, D.J. Strom, G.R. Cicotte, C.M. Wiblin, and S.A. McGuire, 1993. 

Air Sampling in the Workplace, NUREG-1400, U.S. Nuclear Regulatory Commission, Office of 

Nuclear Regulatory Research, Washington, DC. September. [SRDB Ref ID: 20129] 

Klevin, P.B., 1952. Ames Research Laboratory Occupational Exposures to Thorium and 

Beryllium, U.S. Atomic Energy Commission (AEC), New York Operations Office, Health and 

Safety Division, New York, New York. [SRDB Ref ID: 18942] 

NIOSH (National Institute for Occupational Safety and Health) 2006. SEC Petition Evaluation 

Report, Petition SEC-00038, Rev. 0, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. April. 

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

Report, Petition SEC-00075, Rev. 0, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. May. 

NIOSH (National Institute for Occupational Safety and Health) 2010. SEC Petition Evaluation 

Report, Petition SEC-00166, Rev. 0, Division of Compensation Analysis and Support, 

Cincinnati, Ohio. July. 

NIOSH (National Institute for Occupational Safety and Health) 2011. SEC Petition Evaluation 

Report, Petition SEC-00185, Rev. 0, Division of Compensation Analysis and Support, 

Cincinnati, Ohio. June. 

NIOSH (National Institute for Occupational Safety and Health) 2015. NIOSH Response to 

SC&A Review of the Ames Site Profile Document Regarding Uranium Internal Exposures,

Rev. 0, Division of Compensation Analysis and Support, Cincinnati, Ohio. July 29, 2015. 

OCAS 2004. Estimation of Ingestion Intakes, OCAS-TIB-009, Rev. 00. Office of 

Compensation and Analysis Support, NIOSH, Cincinnati, Ohio. April 13, 2004. 

ORAUT (Oak Ridge Associated Universities Team) 2006. Technical Information Bulletin: 

Technical Basis for Estimating the Maximum Plausible Dose to Workers at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0004, Rev. 03 PC-2, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. December 6, 2006. 

ORAUT (Oak Ridge Associated Universities Team) 2007. Site Profile for Ames Laboratory, 

ORAUT-TKBS-0055, Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

June 22, 2007. 
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ORAUT (Oak Ridge Associated Universities Team) 2008. Site Profile for Ames Laboratory, 

ORAUT-TKBS-0055, Rev. 00 PC-1, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. August 20, 2008.

ORAUT (Oak Ridge Associated Universities Team) 2009. Site Profile for Ames Laboratory, 

ORAUT-TKBS-0055, Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

January 18, 2009.

ORAUT (Oak Ridge Associated Universities Team) 2011. Site Profile for Ames Laboratory, 

ORAUT-TKBS-0055, Rev. 02, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

January 14, 2011.

ORAUT (Oak Ridge Associated Universities Team) 2012a. Site Profile for Ames Laboratory, 

ORAUT-TKBS-0055, Rev. 03, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

January 3, 2012.

ORAUT (Oak Ridge Associated Universities Team) 2012b. Dose Reconstruction During 

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

Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 5, 2012.

SC&A, Inc. 2013. Review of the NIOSH Site Profile for the Ames Laboratory, SCA-TRSP2013-0044, Rev. 0, Vienna, Virginia. August 14, 2013.

Voss, M.D., 1975. Environmental Monitoring at Ames Laboratory Calendar Year 1974, IS3613, Iowa State University, Ames Laboratory, Ames, Iowa, May. [SRDB Ref ID: 25446]

Voss, M.D., 1976. Environmental Monitoring at Ames Laboratory Calendar Year 1975, IS3856, Iowa State University, Ames Laboratory, Ames, Iowa, May. [SRDB Ref ID: 25445]

Voss, M.D., 1977. Environmental Monitoring at Ames Laboratory Calendar Year 1976, IS4139, Iowa State University, Ames Laboratory, Ames, Iowa, May. [SRDB Ref ID: 25444]