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. 

MEMO 

To: TBD-6000 Work Group 

From: Bob Barton, SC&A 

Date: June 3, 2014 

Re: SC&A Position on Findings 6 and 7 of the Simonds Saw and Steel TBD Review 

Background: 

On June 13, 2012, SC&A transmitted its review of the Simonds Saw and Steel site profile 

(SC&A 2012), which consisted of seven main findings. Findings 1–5 pertained to external and 

internal dose assignments during the operational period at Simonds (1/1/1948–12/31/1957); a 

summary of these findings and their current status can be found in Attachment 2. Findings 6 and 

7 related to the external and internal dose assignment during the residual period and are the 

subject of this memo. These two findings are summarized below: 

 Finding 6 – More Quantitative and Substantive Discussion of Available External 

Monitoring during Residual Period: The TBD was deemed deficient in its description 

and analysis of available residual survey data as well as its justification for the 

penetrating and non-penetrating dose assignments made. Additionally, SC&A 

recommended expanding the assumed annual employment from 2,000 hours to 

2,500 hours to be consistent with the assumed employment duration during the 

operational period. 

 Finding 7 – Appropriateness of Chosen Internal Methodology during Residual Period 

and Consistency with OTIB-0070 (ORAUT 20121): The Site Profile’s use of the 

average general air samples collected from 1949–1953 is inappropriate for 

characterizing conditions at the end of operations. Additionally, no depletion factor was 

assumed for the period from 1982 to 2007 as prescribed by the methodology of OTIB0070.

This memo discusses the status of these two findings including: discussions to date, NIOSH 

white paper responses, and SC&A’s current position and recommendations to the Work Group.

Discussions to Date: 

Subsequent to the transmittal of SC&A’s site profile review, NIOSH provided responses to the 

seven review findings on February 1, 2013, in the form of an updated review matrix (NIOSH 

2013a). The original findings and NIOSH’s responses were first substantively discussed at the 

TBD-6000 Work Group meeting on April 26, 2013 (ABRWH 2013a). During the course of 

 

1

 ORAUT 2008 was cited in the original TBD review; however, the revised methodology present in ORAUT-OTIB0070 Rev. 1 does not change SC&A’s original findings related to internal dose assignment during the residual 

period. 
Memo to the TBD-6000 Work Group 2 SC&A – June 3, 2014

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.

discussions at this meeting, NIOSH acknowledged that they needed to revisit the proposed 

methodology for reconstructing internal and external doses during the residual period. 

With respect to Finding 6 (reconstruction of external doses during the residual period), NIOSH 

agreed to investigate whether it was justifiable to shorten the assumed work day from 10 hours to 

8 hours, as well as provide a more complete characterization of available survey data during the 

residual period (ABRWH 2013a, pp. 147–148). This would help justify the proposed dose 

assignments presented in the Technical Basis Document (TBD). With respect to Finding 7, 

NIOSH agreed that the current method of assigning internal dose during the residual period does 

not comport with ORAUT-OTIB-0070. NIOSH’s action item following this meeting was to 

revise this portion of the TBD to reflect more contemporary approaches to dose reconstruction 

(ABRWH 2013a, pp. 251, 255–256). 

Simonds Saw and Steel was again discussed at the June 20, 2013, Work Group meeting. During 

those discussions, NIOSH and SC&A agreed that the presumed annual work duration should be 

expanded from 2,000 to 2,500 hours per year for consistency between the operational and 

residual periods (ABRWH 2013b, pg. 195). The remaining portions of Finding 6 

(characterization of residual surveys, justification of the choice of TBD assigned values) as well 

as Finding 7 remained under evaluation by NIOSH (ABRWH 2013b, pg. 196–198). 

On September 30, 2013, NIOSH provided a white paper describing their new approach to 

reconstructing external doses during the residual period (NIOSH 2013b). The TBD-6000 Work 

Group met again on October 11, 2013; December 19, 2013; January 16, 2014; and April 23, 

2014; however, Simonds Saw and Steel was not discussed. On February 4, 2014, NIOSH 

transmitted a second white paper describing the new approach to reconstructing internal doses 

during the residual period (NIOSH 2013c). These two white papers are the subject of this memo 

and are summarized in the following section, and include SC&A’s comments and observations. 

Summary of NIOSH Responses and SC&A Observations/Recommendations: 

This section provides a summary of NIOSH’s proposed approach to reconstructing external and 

internal doses during the residual period, as well as comments and observations made by SC&A 

during the review of this approach. SC&A’s final recommendations to the Work Group based on 

this review are found in the next section. 

External Dose during Residual Period: 

NIOSH 2013b provides a brief history of the Simonds Saw and Steel site during the residual 

period. This includes how different areas of the site were parsed during the 1980s when portions 

of the site were purchased by the Allegheny Ludlum Corporation. The white paper also contains 

descriptions of the various radiological surveys performed at Simonds Saw and Steel during the 

residual period, including surveys performed in 1957, 1976, 1980, 1984, 1999, and 2007. A 

brief overview of the results of these surveys is provided in Table 1: 
Memo to the TBD-6000 Work Group 3 SC&A – June 3, 2014

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.

Table 1. Characterization of Survey Measurements Presented in NIOSH 2013b and 

Associated Survey Reports

Survey

Year

Range of 

Gamma 

Values (μr/hr 

@ 3 ft)

Range of 

Beta Values

(mrep/hr 

@ 3 ft)

Additional Comments

1957 ND2–80 0.05–1.7

Only five numerical values are listed for each external dosimetry 

category (gamma @ 3 feet and beta @ 3 feet) for this survey.

High beta value of 1.7 mrep/hr was taken in approximately a 75 ft2area 

near the 10” bar mill (measurements in this area ranged from 1.3–1.7 

mrep/hr).

Trip Report states: “The areas which were monitored included the 

Forge Area, the 16” Bar Mill Area, the 10” Strip Metal Area, and the 

shipping and receiving areas... With the exception of two small areas, 

the radiation readings at 3 feet above the floor never exceeded 0.2 

mreps/hr combined beta and gamma radiation.” (Heatherton 1957)

1976 5–48 None Taken

Maximum observed gamma measurement (48 μR/hr) was in an area of 

the floor south of the 16” mill, east of the 10” mill and west of the 16” 

furnace area. The floor is bare (no floor plates) and was used for storing 

mill rollers.

Gamma measurements near the 10” bar mill and 10” cooling bed ranged 

from 5–10 μR/hr.

Survey report notes that 12 μR/hr (maximum measurement outside the 

main plant area) is within the range of background measurements in the 

Lockport, New York, area.

See Attachment 1 for the contamination map of the plant area taken 

during this survey, as well as the 1980 ORNL survey.

1980 ND–300 None Taken

Survey report describes maximum gamma reading with the following: 

“One spot under a step to the raised cinder bed area was found to read 

300 μR/hr. It was determined that cooling water during the uranium 

milling operations ran in this direction. Apparently metallic uranium 

shavings were washed into this area and dropped out in a localized 

spot, as measurements directly south of this spot, where the water 

continued to flow, were reduced to 48 μR/hr about 10 ft (3m) away, and 

dropped to background thereafter.” (FDBU 1981)

Another location about 10 feet to the west of the 300 μR/hr 

measurement read 100 μR/hr. Another area on the east side of the 16” 

rolling mill read 60 μR/hr.

This report contained survey data not considered by NIOSH in 

developing its penetrating dose distribution (see SC&A Observation 1).

See Attachment 1 for the contamination map of the plant area taken 

during this survey, as well as the 1976 ORNL survey.

 

2

 ND = Not Detected 
Memo to the TBD-6000 Work Group 4 SC&A – June 3, 2014

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.

Table 1. Characterization of Survey Measurements Presented in NIOSH 2013b and 

Associated Survey Reports

Survey

Year

Range of 

Gamma 

Values (μr/hr 

@ 3 ft)

Range of 

Beta Values

(mrep/hr 

@ 3 ft)

Additional Comments

1984 30–120 None Taken

From the survey report, pg. 6: “Based on information provided by [the 

site escort] and on the physical appearance of the plant, there have not 

been any significant changes in the physical layout of the rolling mill 

area during its operation (i.e., there has been no apparent grading, 

scraping, or filling done). The material beneath the cast iron plates 

seems to contain most of the contamination. Specifically, a layer of 

yellowish material lying two to three inches below the iron plates 

appears to be the source of the elevated radiation levels. A sample of 

this material was collected as well as a sample of black dirt above this 

layer. Below is a vertical cross-section of the raised area” (DOE 

1984). The “vertical cross-section” mentioned is shown in Figure 1 

below.

1999 5–50 None Taken

Highest observed measurement (50 μR/hr) was in Building 8, which is 

connected to Building 6; these two areas are considered “the main 

rolling area.”

As was noted in NIOSH 2013b, the survey in 1999 only presented a 

range of gamma exposures at 1 meter. In its data analysis, NIOSH did 

not consider the maximum values from selected areas which were not 

explicitly used during Atomic Energy Commission (AEC) operations. 

Additionally, NIOSH did not consider the lower end values of the 

ranges presented for any area. See SC&A Observation 2. 

2007 2–63 None Taken

NIOSH does not utilize the gamma survey data presented in 2007 in 

developing their penetrating dose distribution (NIOSH 2013b). See 

SC&A Observation 3.

It can be seen in Table 1 that measurements of the beta dose component at a distance of 3 feet 

exist only in the earliest survey of the site post-operations (the 1957 survey). The actual beta 

measurements from that survey were contained in Table I of Heatherton 1957 and are recreated 

below in Table 2. As shown in that table, three beta dose rate measurements are provided for the 

following locations: front of shear, between mill floor plates, and the forge area. These dose 

rates ranged from 0.05–0.4 mreps/hr. The highest observed beta dose rates were in the 10” bar 

mill bed area. While it is unknown how many measurements were made in this area, the beta 

dose rate ranged from 1–1.7 mreps/hr. NIOSH has chosen to take the midpoint of this range 

(1.35 mreps/hr) and apply that dose rate as a constant throughout the entire residual period (see 

SC&A Observation 4). Heatherton 1957 noted that aside from “two small areas,” the betagamma dose rate never exceeded 0.2 mreps/hr. 

NIOSH has chosen the highest observed gamma dose rate from the 1957 survey (0.08 mR/hr or 

80 μR/hr) to use as a constant value throughout the residual period. While some later surveys 

showed higher dose rates in localized hot spots, 80 μR/hr exceeds the 95th percentile of all 

available gamma measurements (see SC&A Observations 1–3). Of the 79 total gamma 

measurements available from 1958–2000, only 4 measurements exceeded the proposed value of 

80 μR/hr. None of the 2007 measurements (nearly 2,100 in total) exceeded 80 μR/hr. 
Memo to the TBD-6000 Work Group 5 SC&A – June 3, 2014

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.

Table 2. Survey Results from Heatherton 1957 (Recreation of Table I) 

Location 

(Approximate Volume of 

Contamination)

Contact β, γ – mreps/hr 3 Feet β – mreps/hr 3 Feet γ – mR/hr

10” Bar Mill Bed 

(75 ft2–1/2 in. thick) 10–20 1.0–1.7 0.04, 0.05

Front of Shear 

(10 ft2–1 in. thick) 1–2 0.4 0.08

Between Plates on Mill 

Floor

(not given)

0.15 0.05 None Detected

Forge Area

(not given) 0.7–1.2 0.2 0.02

Top of Furnace

(150 ft2–2 in. thick) 1.0 No Reading Taken No Reading Taken

Figure 1. Cross Section of Raised Milling Area at Simonds as Characterized by the 

Department of Energy 1984 Residual Survey 

SC&A Observation 1: NIOSH did not consider the additional gamma survey data contained in 

the 1980 residual survey performed by Ford, Bacon, and Davis Utah Inc. (FBDU 1981). This 

survey indicated measured contamination in the vicinity of the 16” bar mill as high as 300 μR/hr 

and another nearby area measuring 100 μR/hr. SC&A added the data from FBDU 1981 to the 

NIOSH compilation of survey data described in NIOSH 2013b. The resulting distribution 

increased the 95th percentile slightly (75 μR/hr increased to 77.6 μR/hr). Therefore, the effect of 

this additional data was negligible and the 95th percentile is still bounded by the proposed dose 

rate of 80 μR/hr. 
Memo to the TBD-6000 Work Group 6 SC&A – June 3, 2014

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.

SC&A Observation 2: In developing the distribution of gamma exposure values, NIOSH only 

considered the maximum values from Buildings 3, 6, and 8 from the 1999 residual survey 

(Vitkus 1999). Maximum values from other survey areas, as well as the minimum observed 

values from the 1999 survey, were not used. SC&A added these missing values to the 

distribution of gamma measurements and the resulting 95th percentile dropped from 75 μR/hr 

(NIOSH 2013b) to 66.5 μR/hr. If only the upper end of the range for each building was used, the 

95th percentile still decreased from 75 to 72.1 μR/hr. Therefore, NIOSH’s selection of 80 μR/hr 

bounds the 95th percentile of the combined dataset. 

SC&A Observation 3: NIOSH elected not to include the 2007 gamma survey data (Earthtech 

2010) in the distribution of penetrating dose rates, but did characterize the maximum 

measurements observed (NIOSH 2013b). SC&A examined the 2007 gamma survey data for 

relevance to the reconstruction of external doses (specifically penetrating doses) in the residual 

period. As noted in NIOSH 2013b, the highest observed gamma dose rate was 63 μR/hr in 

Building 2. The next highest measurements were taken in Buildings 6/8 at 45 and 30 μR/hr. 

Over 2,000 distinct measurements were taken at Simonds in 2007. When these measurements 

were fit to a lognormal distribution, the 95th percentile was only 9.72 μR/hr. If only Buildings 3, 

6, and 8 are considered (where the AEC work was performed), the 95th percentile dose rate rises 

slightly to 11.34 μR/hr (nearly 1/8 the value proposed for residual dose assignment). Building 

24’s maximum value did not exceed 12 μR/hr. In essence, the 2007 survey data display the 

bounding nature of the proposed penetrating dose assignment of 80 μR/hr as presented in 

NIOSH 2013b. 

SC&A Observation 4: Table 3.10 of Battelle 2011 provides factors for converting uranium 

surface contamination to external dose. The table displays conversion factors for both beta dose 

(non-penetrating) and photon dose (penetrating). The ratio of the dose conversion factors is 

approximately 100; in other words, one could expect the beta dose component from deposited 

natural uranium to be 100 times higher than the photon dose component. SC&A 2013 performed 

calculations using MCNP (Monte Carlo N-Particle Transport Code) that calculated a 

beta/gamma dose ratio closer to 45. However, in both cases (Battelle 2011 and SC&A 2013), it 

was assumed that the contamination was an infinitely thin slab of uranium with no self shielding 

taken into account. In reality, the beta component of natural uranium can only travel through a 

fraction of a millimeter of uranium metal, so the actual beta-to-gamma dose ratio will be much 

lower than either estimate. 

NIOSH has chosen a beta dose value of 1.35 mrep/hr and a gamma value of 0.08 mR/hr (a ratio 

of approximately 17). Inspection of Table 2 shows that actual measured beta/gamma dose ratios 

ranged from 5–34. Given that the actual beta dose would have been partially shielded by the 

thickness of the contamination, as well as the fact that a significant portion of the contamination 

is contained under steel floor plates, SC&A believes that the chosen beta dose component is 

reasonable and claimant favorable. Additionally, the 1984 survey (DOE 1984) noted that the 

majority of the contamination was in the form of a “yellow material,” which was located under 

both the steel plates and a 2–3” layer of black dirt and scale (see Figure 1 and the 1984 Survey 

entry in Table 1, above). This would further lower the actual beta dose rate. 
Memo to the TBD-6000 Work Group 7 SC&A – June 3, 2014

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.

Internal Dose during Residual Period: 

NIOSH 2013c describes the proposed methodology for reconstructing internal doses during the 

residual period. No air sampling exists in the final 3 years of operation at Simonds Saw and 

Steel (1955–1957). Therefore, NIOSH utilized general air sampling data from 1954 uranium 

operations to establish a dust loading at the start of the residual period. There are 21 samples 

explicitly labelled “GA” or general air taken on 2 separate rolling days in 1954. When samples 

taken in the same area are averaged, the total number of values drops to 16. This total matches 

the number of general air samples SC&A identified in its original TBD review (SC&A 2012). 

Given that these general air samples reflect airborne contamination while the plant was in 

operation and handling uranium, they logically represent an overestimate of the actual airborne 

contamination that could have been resuspended during the residual period. 

To estimate the potential dust loading at the end of the residual period, NIOSH utilized the 2007 

Earthtech survey of the site (Earthtech 2010). Appendix B of NIOSH 2013c provides the 

analysis and rationale for the data used in the analysis. The analysis specifically looked at the 

buildings where AEC work took place and did not utilize survey data from buildings that were 

not involved in uranium milling. Additionally, only samples from the southern portion of 

Building 24 were included, because the northern portion of the building was not present during 

the operational period at Simonds. SC&A reviewed the original Earthtech survey reports and the 

underlying data provided by USACE and concurs with NIOSH’s assessment of the survey data. 

Based on the analysis of three specific buildings (3, 8, and 24-South), NIOSH determined that 

the 95th percentile area contamination value was highest in Building 24 (67,000 dpm/100 cm2

). 

This value is a factor of approximately 1.2 higher than the 95th percentile contamination value 

measured in Building 24 during the 1999 survey (Vitkus 1999). This contamination value is 

utilized along with a resuspension factor of 10-6 m

-1, a breathing rate of 1.2 m3

/hr and a 

2,500-hour work year. This results in an annual intake of 20,100 dpm or 24.6 pCi/d (see SC&A 

Observation 5). This daily intake rate is approximately a factor of 4.5 higher than the original 

TBD intake rate at the end of the residual period (5.4 pCi/d). 

NIOSH 2013c also noted that the dust loading calculated based on area contamination is about 

an order of magnitude higher than the maximum measured air concentration that was observed 

during the 2007 residual survey. The air concentrations in 2007 were measured using breathing 

zone samplers during activities deemed likely to create resuspended contamination. These 

activities included: 

 Brush clearing activities using the hydro-axe 

 Boring activities in Buildings 6 and 8 

 Radiological survey work conducted on the roof trusses of Building 24 

Earthtech concludes the following: “Breathing zone sample results demonstrated that airborne 

contamination during site activities was minimal. The maximum value for the breathing zone 

samples equated to 0.2 DAC-hrs, with the majority below detection limits.”
Memo to the TBD-6000 Work Group 8 SC&A – June 3, 2014

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.

SC&A Observation 5: In the absence of data to establish airborne radioactivity levels during 

the residual period, ORAUT 2012 recommends using operational source term data with a 

depletion factor of 0.00067 d-1 to account for the removal of the contamination over time. In this 

case, there are obviously monitoring data during the residual period that can be used to 

reconstruct the airborne radioactivity from resuspended contamination. NIOSH proposes to use 

operational data to establish the starting source term and area contamination measurements taken 

at the end of the residual period. This method results in a depletion factor of 0.00016 d-1, which 

is roughly 25% of the recommended depletion rate in OTIB-0070. Therefore, the proposed 

method for Simonds Saw and Steel represents a more conservative (claimant-favorable) 

approach than what is recommended in ORAUT 2012. 

SC&A Recommendation: 

Based on the above discussion, SC&A believes that NIOSH has satisfactorily addressed the 

original concerns with reconstruction of both internal and external doses during the residual 

period. SC&A’s position is that the currently proposed methods represent a scientifically 

defensible, sufficiently accurate and claimant-favorable approach. Therefore, SC&A 

recommends that the Work Group accept the proposed approaches outlined in NIOSH 2013b and 

NIOSH 2013c and place Findings 6 and 7 “in abeyance” until the TBD is revised to reflect the 

new methodology.
Memo to the TBD-6000 Work Group 9 SC&A – June 3, 2014

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.

References: 

ABRWH 2013a. Transcript of the Teleconference Meeting of the Work Group on TBD-6000. 

Advisory Board on Radiation Worker Health. April 26, 2013. 

ABRWH 2013b. Transcript of the Teleconference Meeting of the Work Group on TBD-6000. 

Advisory Board on Radiation Worker Health. June 20, 2013. 

Battelle 2011. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals. 

Battelle-TBD-6000, Rev. 1. Division of Compensation Analysis and Support. June 17, 2011. 

DOE 1984. DOE Completion Report – Residual Survey of Guterl Steel Corporation, Lockport, 

New York. Department of Energy. December 1984. 

Earthtech 2010. Remedial Investigation Report Former Guterl Specialty Steel Corporation 

FUSRAP Site Lockport, New York. Prepared for the U.S. Army Corps of Engineers (USACE) 

July 26, 2010. 

FBDU 1981. Preliminary Engineering and Environmental Evaluation of the Remedial Action 

Alternatives for the Former Simonds Saw and Steel Company Site, Lockport, New York. 

Prepared for Bechtel National, Inc. by Ford Bacon and Davis Utah Inc. Salt Lake City, Utah. 

November 1981. 

Heatherton 1957. Trip Report to Simonds Saw and Steel Company, Lockport, New York. 

National Lead Company. July 12, 1957. 

NIOSH 2013a. Simonds Saw and Steel Site Profile Review Issues Matrix. National Institute for 

Occupational Safety and Health – Division of Compensation Analysis and Support. February 1, 

2013.

NIOSH 2013b. Review of Simonds Saw and Steel Plant Residual External Dose. National 

Institute for Occupational Safety and Health – Division of Compensation Analysis and Support. 

September 30, 2013. 

NIOSH 2013c. Review of Simonds Saw and Steel Plant Residual Internal Dose. National 

Institute for Occupational Safety and Health – Division of Compensation Analysis and Support. 

February 4, 2014. 

ORAUT 2008. Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities, ORAUT-OTIB-0070, Rev. 0. Oak Ridge Associated Universities Team. 

March 10, 2008. 

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

Employer Facilities, ORAUT-OTIB-0070, Rev. 1. Oak Ridge Associated Universities Team. 

March 5, 2012. 
Memo to the TBD-6000 Work Group 10 SC&A – June 3, 2014

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.

SC&A 2012. Review of the Site Profile for the Simonds Saw and Steel Plant. SC&A, Inc., 

Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. June 13, 2012. 

SC&A 2013. Analysis of Table 3.10, NIOSH TBD-6000: “Dose conversion factors from natural 

uranium surface contamination. SC&A, Inc., Vienna, Virginia. April 27, 2013. 

Vitkus 1999. Radiological Survey of the Guterl Specialty Steel Corporation, Lockport, New 

York. Oak Ridge Institute for Science and Education – Environmental Survey and Site 

Assessment Program, Oak Ridge, Tennessee. December 1999.
Memo to the TBD-6000 Work Group 11 SC&A – June 3, 2014 

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.

Attachment 1: Survey Map from 1980 Residual Survey in Comparison to 1976 Survey Results 

Source: FBDU 1981, Figure 4-3
Memo to the TBD-6000 Work Group 12 SC&A – June 3, 2014 

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.

Attachment 2: Status of Additional Findings (1-5) for the Simonds Saw and Steel Site Profile Review 

This attachment provides a condensed version of the Simonds Saw and Steel Site Profile Issue Matrix as transmitted to the Work 

Group on May 2, 2013. This material is provided for reference only and attempted to incorporate comments received by 

NIOSH/DCAS on that document subsequent to the original transmission. 

Table A-1: Summary of Status for Findings 1-5 for Reference

Summary of Original Finding Path Forward

Official 

Matrix 

Status

Finding 1: Operational External Doses

TBD external dose assignment in operational period utilizes a 

combination of MCNP modeling, surrogate data from Aliquipa 

Forge, and a single general area measurement taken by the AEC. 

The TBD should discuss the limited available film badge at 

Simonds in the context of the claimant favorability of the approach 

taken in the TBD. 

NIOSH provided their official position in an email to the TBD-6000 

Work Group on 6/12/2013 which reflected the path forward agreed upon 

during the 4/26/2013 Work Group meeting. 

NIOSH to add/clarify discussion of film badges in the next TBD revision 

to justify the use and claimant favorability of the modeled external doses 

as discussed.

In Abeyance

Finding 2: Temporal Variations in Industrial Controls and Thus 

Exposure Potential for Simonds Saw and Steel Workers

Simonds Saw and Steel had well documented changes in industrial 

hygiene practices as early visits from the AEC noted unacceptable 

worker exposure conditions. Subsequent changes improved 

working conditions markedly. However, these industrial controls 

were later removed or rendered ineffective in the latter years of 

operation.

The TBD should discuss this variation in exposure potential in the 

context of the claimant favorability of the proposed internal model.

NIOSH plans to revise the TBD with an entirely new internal coworker 

model during the operational period to better comport with more recent 

methods utilized at other sites. One facet of the new internal coworker 

model will be to apply the 95th percentile of observed intake values for 

all plant workers to account for the variation in exposure potential. 

Alternately, the median value will be applied as a constant to office and 

administrative type workers.

As part of the revision, NIOSH will add explanatory text how the new 

internal coworker model accounts for these variations in exposure 

potential. 

In Abeyance
Memo to the TBD-6000 Work Group 13 SC&A – June 3, 2014 

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.

Table A-1: Summary of Status for Findings 1-5 for Reference

Summary of Original Finding Path Forward

Official 

Matrix 

Status

Finding 3: Available Urinalysis Samples Showed Significant 

Variation Among Different Job Types and Among Different Shifts 

(Day versus Night).

Urinalysis sampling generally occurred just prior and just after a 

rolling period. It may be beneficial to analyze the data for 

individual workers and individual job types to gain insight to 

varying exposure potential among workers. Additionally, 

documentation notes that there may have been a higher exposure 

potential to 2nd shift workers than to the 1st. 

NIOSH examined the data for trends among different job types and 

among different shifts. The results of this investigation were 

inconclusive and did not indicate a reasonable basis for stratification of 

the coworker model. Due to significant, but not predictable, variations in 

urinalysis values among different job types and shifts, NIOSH is revising 

their coworker approach to apply the 95th percentile to mill workers and 

the 50th percentile to office/administrative workers. 

In revising the TBD, NIOSH will include the justification of the new 

coworker model as described herein. No further analysis of the 

urinalysis data is required.

In Abeyance

Finding 4: Large Variation in Exposure Potential Based on Daily 

Weighted Exposure Studies

Similar to observed urinalysis values (Finding 3), daily weighted 

exposure studies at Simonds Saw and Steel showed significant 

variation in exposure potential even among the same job title. 

NIOSH should demonstrate that the proposed intakes are bounding 

for all types of workers and all types of exposure potential.

NIOSH acknowledges that there was significant variation in exposure 

potential to mill workers at the Simonds Saw and Steel facility. NIOSH 

is revising the internal coworker model in the TBD to reflect this 

variation by assigning the 95th percentile to mill workers and the 50th

percentile to office/administrative workers.

In revising the TBD, NIOSH will include the justification of the new 

coworker model as described herein. No further analysis of DWE/air 

sampling data is needed or warranted, although a short explanation of the 

significance of the air sampling data in the context of the internal dose 

model will be considered by NIOSH.

In Abeyance

Finding 5: Choice of Internal Coworker Model using Urinalysis 

Values instead of Daily Weight Exposure Data

The TBD selects coworker intakes based on the urinalysis data 

although intakes derived from the DWE data are higher for certain 

periods and uranium solubility types. The TBD would benefit from 

a substantive discussion of the choice of urinalysis over DWE 

values to assure assigned intakes are bounding. 

NIOSH and SC&A agree that urinalysis sampling is preferable in 

characterizing worker exposures to air sampling data. NIOSH is revising 

the internal coworker model in the TBD to reflect this variation by 

assigning the 95th percentile to mill workers and the 50th percentile to 

office/administrative workers.

In revising the TBD, NIOSH will include the justification of the new 

coworker model as described herein. No further analysis of DWE/air 

sampling data is needed or warranted, although a short explanation of the 

significance of the air sampling data in the context of the internal dose 

model will be considered by NIOSH.

In Abeyance