Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

SC&A REVIEW OF DCAS-TKBS-0009, REVISION 03, FOR 

HOOKER ELECTROCHEMICAL COMPANY

Contract No. 211-2014-58081 

SCA-TR2016-SP008, Revision 0 

Prepared by

William Thurber, MS

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

November 2016 

DISCLAIMER

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

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

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

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

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

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

issues.

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

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

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

SC&A Review of DCAS-TKBS-0009, Revision 03, for Hooker 

Electrochemical Company

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SP008 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: November 21, 2016

TASK MANAGER: William Thurber, MS [signature on file]

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

DOCUMENT 

REVIEWER(S): John Mauro, PhD, CHP [signature on file] 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 11/21/2016 Initial issue
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TABLE OF CONTENTS

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

1.0 Introduction .......................................................................................................................... 5

2.0 Background .......................................................................................................................... 5

3.0 Review of SC&A Findings .................................................................................................. 7

3.1 Finding 4 .......................................................................................................................... 7

3.2 Finding 5 .......................................................................................................................... 9

3.3 Finding 6 ........................................................................................................................ 10

4.0 References .......................................................................................................................... 11
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

DCAS Division of Compensation Analysis and Support 

ER evaluation report 

dpm disintegrations per minute

dpm/hr disintegrations per minute per hour 

dpm/m2 disintegrations per minute per square meter 

dpm/m3 disintegrations per minute per cubic meter 

Electromet Electro Metallurgical Company

HCl hydrochloric acid

Hooker Hooker Electrochemical Company

MCNP Monte Carlo N-Particle

MgF2 magnesium fluoride

mr/hr milliroentgen per hour 

mrad/hr millirad per hour 

mrem/hr millirem per hour

NIOSH National Institute for Occupational Safety and Health

OCAS Office of Compensation Analysis and Support 

SEC Special Exposure Cohort 

SRDB Site Research Database

TBD technical basis document

U uranium 

UF4 uranium tetraflouride

URAWE Uranium Refining Atomic Weapons Employers 
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1.0 INTRODUCTION

On April 14, 2016, SC&A was tasked (Katz 2016) to review Revision 02 to DCAS-TKBS-0009, 

Technical Basis Document for the Hooker Electrochemical Company (NIOSH 2015b; all 

revisions of this document hereafter referred to as “TKBS-0009”) and determine whether it 

addressed SC&A’s six findings made during its 2013 review of Revision 01 to this technical 

basis document (TBD) (SC&A 2013). SC&A documented the status of six findings in its 

June 2016 review of TKBS-0009, Revision 02 (SC&A 2016). These findings were discussed at 

the Uranium Refining Atomic Weapons Employers (URAWE) Work Group Meeting on July 19, 

2016, which concluded that three of the findings had been resolved and three remained open. On 

September 13, 2016, the National Institute for Occupational Safety and Health (NIOSH) issued 

Revision 03 to TKBS-0009 (NIOSH 2016b), and the Work Group tasked SC&A to review 

Revision 03 with a view of determining whether the remaining three findings had been 

addressed. As discussed here, SC&A recommends that Findings 5 and 6 be closed. With regard 

to Finding 4, NIOSH has added an approach to addressing ingestion exposures during the 

residual period that had not been previously included. However, SC&A requests further 

clarification of the specific approach taken to develop the ingestion exposures, because there was 

apparent agreement, based on prior discussions with NIOSH, that the approach presented in 

OCAS-TIB-009, Estimation of Ingestion Intakes, Revision 00 (OCAS 2004; hereafter 

“TIB-009”) was not appropriate. 

2.0 BACKGROUND

The Hooker Electrochemical Company (Hooker) in Niagara Falls, New York, processed 

so-called “C-2 slag” from July 11, 1944, through January 15, 1946 (NIOSH 2011b). The 

operations at Hooker involved the treatment of C-2 slag from the nearby Electro Metallurgical 

Company (Electromet) with hydrochloric acid (HCl) to increase the slag’s uranium content. The 

C-2 slag from Electromet was a byproduct of the bomb reduction process in which uranium 

tetrafluoride (UF4) was exothermically reacted with magnesium metal to produce uranium metal. 

Dolomite was used as the refractory liner in the steel bomb at that point in time (NIOSH 2011b). 

After 1948, recycled magnesium fluoride (MgF2) was used as the liner. The dolomite was highfired or fused, resulting in a product with the approximate formula CaO∙MgO. The HCl was 

excess acid produced at Hooker under an Atomic Energy Commission contract as a byproduct 

from the non-radioactive P-45 process.

In 2007, NIOSH issued the original site profile for Hooker, Site Profiles for Atomic Weapons 

Employers that Refine Uranium and Thorium – Appendix AA, Revision 00 (NIOSH 2007), as 

Appendix AA to Battelle-TBD-6001, Site Profiles for Atomic Weapons Employers that Refine 

Uranium and Thorium, Revision F0 (NIOSH 2006; hereafter “TBD-6001”). As an appendix to 

TBD-6001, the Hooker site profile relied heavily on the parent document for dose reconstruction 

guidance. Based on a May 2010 request by the Advisory Board on Radiation and Worker Health 

(ABRWH), SC&A reviewed Appendix AA and reported 10 findings (SC&A 2010). Several of 

the findings related to TBD-6001, upon which much of Appendix AA was based. TBD-6001 was 

subsequently cancelled by NIOSH, and alternate modeling approaches were used in revising the 

Hooker site profile.
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Subsequently, at the TBD-6001 Work Group Meeting held in Cincinnati, Ohio, on November 4, 

2010, the Work Group asked SC&A to prepare a focused review of the Hooker petition 

evaluation report (ER) on Petition SEC-00141, prepared by NIOSH (2010). Because the ER 

contained new information developed since Appendix AA was issued in 2007 (NIOSH 2007), 

the Work Group felt that a focused review of the new information was needed. In response to 

this tasking, SC&A provided SCA-SEC-2011-0018, A Focused Review of the Hooker 

Electrochemical Company Petition Evaluation Report for SEC-00141, Revision 0, in 

January 2011 (SC&A 2011), in which SC&A made nine findings.

After the 2010 SC&A review of Appendix AA, NIOSH converted Appendix AA to a stand-alone 

site profile, DCAS-TKBS-0009, Technical Basis Document for the Hooker Electrochemical 

Company, Revision 00, published on April 4, 2011 (NIOSH 2011a), and issued Revision 01 to 

that document on June 17, 2011 (NIOSH 2011b).

According to NIOSH, the following changes were made in TKBS-0009, Revision 00 (NIOSH

2011a):

Changes Battelle-TBD-6001 Appendix to a stand- alone document. Revises dose 

models to eliminate dependence on Battelle-TBD-6001. Provides more detailed 

description of dose models. Incorporate review comments.

In Revision 01 to TKBS-0009, NIOSH described the changes as follows (NIOSH 2011b):

Revision initiated to correct errors in Tables 2, 3, and 6 [of NIOSH 2011a]. 

Renumber Tables after Table 4. Added language on page 10 to indicate 95th 

percentile of the airborne values was used. Corrected typographical error on 

pages 7 and 14.

At the January 2013 meeting of the Procedures Work Group, SC&A was authorized to conduct a 

critical review of Revision 01 to TKBS-0009 (NIOSH 2011b). During that review, SC&A 

uncovered some information that had not been utilized in prior reviews of Hooker. This new 

information dealt with quantities and uranium content of the C-2 slag. The critical review 

resulted in six findings, which are documented in SCA-TR-SP2013-0034, Review of NIOSH 

Technical Basis Document for the Hooker Electrochemical Company, DCAS-TKBS-0009

(SC&A 2013).

NIOSH issued Revision 02 to TKBS-0009 in December 2015 (NIOSH 2015b) with the 

following stated purpose:

Revision initiated to include information about a Special Exposure Cohort 

designation for Hooker. Revision also incorporates changes due to new 

information describing the operations at Hooker.
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As noted above, NIOSH issued Revision 03 to TKBS-0009 (NIOSH 2016b) on September 13, 

2016, with the following stated purpose: 

Revision initiated to include discussion about ingestion intakes. Also revised 

Table 4 to correct units. Revised Table 5 to correct values in the third column. 

Corrected photon exposures in Table 7. Various editorial changes to text. 

This report presents SC&A’s review of TKBS-0009, Revision 03, and determines whether the 

three remaining findings from SC&A 2013 have been satisfactorily addressed.

3.0 REVIEW OF SC&A FINDINGS

3.1 FINDING 4

Finding 4: NIOSH should review the ingestion intake to ensure that it is 

calculated in a manner consistent with calculation of inhalation intake.

SC&A recognizes that workers at Hooker have been added to the Special Exposure Cohort 

(SEC) for the operational period (November 1, 1945, through October 11, 1976) based on lack of 

air concentration data at the site for all of the operational period. However, inhalation and 

ingestion intakes are needed to assess operational exposures resulting in cancers not specified 

under the Energy Employees Occupational Illness Compensation Program Act of 2000

regulations and to calculate inhalation and ingestion exposures during the residual period. 

NIOSH did not address ingestion exposures in Revision 02 to TKBS-0009 but did address this 

omission in Revision 03. NIOSH stated in Revision 02 that inhalation intakes during the residual 

period are 3.2 disintegrations per minute (dpm) per calendar-day, presumably based on 

resuspended surface contamination of 0.404 dpm/cubic meter (m3), a breathing rate of 1.2 m3/hr, 

an 8-hour work day, and 300 work days per 365 calendar days (NIOSH 2015b, Table 7). 

However, NIOSH did not address ingestion exposures during the residual period. Ingestion 

during the residual period has been the subject of recent deliberations by the URAWE Work 

Group (NIOSH 2015c), and it determined that the procedures for the operational period, as 

described in TIB-009, were not appropriate for the residual period. Ingestion exposures are 

apparently higher than inhalation exposures during the residual period because of an increase in

hand-to-mouth transfer relative to inhalation in low-dust environments. For example, NIOSH has 

shown, for the DuPont Deepwater site, that ingestion during the residual period was 100 times 

the inhalation intake (NIOSH 2015a, Section 6.0).

NIOSH stated in Section 4.1 of TKBS-0009, Revision 02, that the operational airborne 

concentration was used in the residual contamination section to calculate the surface 

contamination and the resulting internal and external doses. Applying this statement, the surface 

concentration based on 30 days of continuous deposition is:

208 dpm/m3 (avg. air conc.) × 0.00075 m/s × 3,600 sec/hr × 24 hr/day × 30 days = 

404,352 dpm/m2
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This is a very conservative approach, because it assumes 24-hour-per-day deposition and no 

degradation of surface contamination during the 30-day deposition period. As noted above, using 

this limiting surface concentration, the inhalation intake is 3.2 dpm per calendar day. Using the 

approach from DCAS-TKBS-0006, Technical Basis Document for DuPont Deepwater Works, 

Deepwater New Jersey, Revision 02 (NIOSH 2015a), and the hand-to-mouth transfer factor from 

NUREG/CR-5512, Residual Radioactive Contamination from Decommissioning (NRC 1992), to 

calculate the ingestion intake results in the following: 

1.1E-04 m2

/hr × 404,352 dpm/m2 = 44.5 dpm/hr

44.5 dpm/hr × 9.6 hr/work day × 250 work-days/365 calendar-days = 293 dpm/calendar-day 

However, in Revision 03 to TKBS-0009, NIOSH assumes that the average airborne 

concentration during the operating period (not the resuspended concentration from surface 

deposition) is bounding for the residual period and calculates that ingestion during the residual 

period is as follows, based on the procedures in TIB-009 (OCAS 2004):

208 dpm/m3 × 0.2 (m3/day) × 9.6 hr/day/8 hr/day × 250 work-days/yr ÷ 365 calendar-days/yr

= 34.2 dpm/calendar-day.

Thus, the approach used in Revision 03 to TKBS-0009 produces a result that is a factor of 8.5 

lower than that obtained by applying the DuPont Deepwater Site approach to Hooker 

(NIOSH 2015a).

More important than the magnitude of the difference between the two approaches is a clear 

explanation of why the approach used in TKBS-0009, Revision 03, is more appropriate than the 

approach used in DCAS-TKBS-0006 (NIOSH 2015a). NIOSH needs to clarify why it chose to 

use TIB-009 procedures that are based on the fallout of airborne particulates from operations,

rather than the approach used in DCAS-TKBS-0006, which is based on a hand-to-mouth transfer 

factor. This issue was extensively discussed at the URAWE Work Group Meeting on January 22, 

2015 (NIOSH 2015c, pp. 59–61). The following exchange between Messrs. Allen (NIOSH), 

Mauro (SC&A), and Thurber (SC&A) from the January 22 transcript highlights the discussion:

MR. ALLEN: So the way to look at it is that the ingestion is truly related to the 

surface contamination. In TIB-9, we related that to the airborne which caused 

that surface contamination. 

DR. MAURO: Yeah.

MR. ALLEN: That airborne is gone in the residual period. 

MR. THURBER: Wouldn’t you then think that the residual period number would 

be lower? And it’s much, much higher. 

MR. ALLEN: No, actually you would think — the common sense would be that, if 

the ingestion is caused by contamination, the day you stop operations, the 

contamination doesn’t change unless, of course, there’s a cleanup of some kind. 
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DR. MAURO: Yeah, but the air goes away. Yeah, I think I’ve got it. 

MR. ALLEN: The air goes away, but the ingestion rate should —

DR. MAURO: So the 0.2 can’t work because the air just went away. 

MR. ALLEN: Right.

Similarly, at the July 16 meeting of the URAWE Work Group (NIOSH 2016a, p. 11), NIOSH 

(J. Neton) stated:

So, we’re still debating on how we’re going to do that. In principle, though, we 

totally agree with SC&A’s comments. And I think we are going to have to put 

together a little more formal response to how we’re going to deal with that issue, 

whether it’s 1.1 times 10 to the minus 4 independently or whether we add back in 

this contaminated coffee cup, because they were derived from somewhat different 

principles and I think we’re kind of mixing modalities a little bit.

Given the cited discussions, there appears to be general agreement that the TIB-009 approach 

was not acceptable during the residual period. In spite of this discussion and general agreement, 

NIOSH chose in Revision 03 to TKBS-0009 to use an estimation approach based on TIB-009. 

NIOSH needs to clarify why it did not use the same procedure, as was done at DuPont 

Deepwater, based on an established hand-to-mouth transfer factor.

During the course of this review of Hooker TKBS-0009, Revision 03, SC&A revisited the 

methodology for estimating ingestion dose during operations as described in TIB-009. Two 

ingestion mechanisms are considered in TIB-009. In Mode 2, airborne contamination generated 

from operations is assumed to fall on the surface of a cup of coffee. In Mode 3, airborne 

contamination is assumed to fall on a work surface and is subsequently ingested by hand-tomouth transfer from the work surface. According to TIB-009, in Mode 3, “the only removal 

mechanism is the transfer of material from the surface to an individual’s hands. An equilibrium 

contamination level can then be calculated in which the deposition of contamination (from the 

settling of airborne contamination) is equal to the removal rate (from transfer to hands).” 

TIB-009 states, “Also note that the time interval is 24 hours. That accounts for the possibility of 

24 hour per day operations.” It is not clear why, for a particular operator, the time interval should 

be 24 hours per day rather than for a single shift. NIOSH needs to explain why 24 hours rather 

than about 8 hours should be used in the Mode 3 calculation.

3.2 FINDING 5

Finding 5: NIOSH should confirm that the correct units of measure are cited in 

Tables 2 and 3. [Tables 3 and 4 in NIOSH 2015b]

In its prior review of TKBS-0009, Revision 01, SC&A noted that the photon exposure was 

expressed differently in Tables 2 and 3 (SC&A 2013). The titles of both tables include the phrase 

“External Dose Rate,” but the units of measure in Table 2 (now Table 3) are milliroentgen per 

hour (mr/hr), while the units in Table 3 (now Table 4) are millirem per hour (mrem/hr). Based on 

the information in the text of Revisions 01 (NIOSH 2011b) and 02 (NIOSH 2015b) to
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TKBS-0009, SC&A concluded that the units of measure in Table 2 should be mrem/hr and noted 

that the distinction was important because it can have a significant impact when selecting organ 

dose conversion factors from OCAS-IG-001, External Dose Reconstruction Implementation 

Guidelines, Revision 03 (OCAS 2007). 

In its 2013 review, SC&A also noted that, in Table 2, the beta dose is expressed in units of 

millirad per hour (mrad/hr), while in Table 3 the units are in mrem/hr. SC&A recognizes that, for 

beta dose, the units are equivalent but, in the interests of clarity, consistent units should be used.

In its 2013 review, SC&A also uncovered some concerns about Table 5 in Revision 02 to

TKBS-0009. The dose rates in the third column of that table are not correct. The correct value of 

the exposure (not dose) rate should be 2.74E-04 mr/hr (6.79E-10 mr/hr per dpm/m2 × 404,314 

dpm/m2). Based on a 9.6-hr work day, 50 weeks per year, the photon exposure rate would be 

0.659 mr/yr, which agrees with the value in Table 6. So, the error in Table 5 was not propagated. 

Similarly, the beta dose rate in Table 5 should be 2.44E-02 mrem/hr (58.6 mrem/yr), not 

1.669 E-02 mrem/yr. Again, the error in the Table 5 beta dose rate was not propagated into 

Table 6.

Revision 03 to TKBS-0009 makes all of the needed corrections discussed above for Tables 3, 4,

and 5. Table titles were also revised to indicate that the information presented was for exposure 

rates, not dose rates.

SC&A notes that the Monte Carlo N-Particle (MCNP) surface contamination conversion factors 

in Table 5 of TKBS-0009, Revision 02, were based on the dose rate (or exposure rate) at 1 foot 

from the contaminated surface. This is in contrast to the methodology in Revision 01 to BattelleTBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium Metal (NIOSH 

2011c; hereafter “TBD-6000”), where the dose rate was determined at 1 meter from the 

contaminated surface. While the calculational approach for Hooker is more claimant favorable, it 

is not apparent why the already vetted values from TBD-6000 were not used.

SC&A’s 2013 review also noted an error in Table 7 of TKBS-0009, Revision 02. The photon 

doses for the residual period were incorrect. The stated photon doses were actually beta doses to 

the skin. This error has also been corrected in TKBS-0009, Revision 03. Therefore, SC&A 

recommends that Finding 5 be closed.

3.3 FINDING 6

Finding 6: NIOSH should review the units of measure for the photon dose 

conversion factors in Table 4 [now Table 5] and determine if they are correct. If 

they are correct, the companion text needs to be revised to discuss exposure rates 

rather than dose rates.

Table 4 of TKBS-0009 listed the photon conversion factor as 6.79E-10 mr/hr per dpm 

alpha/square meter (m2) and the dose rate as 1.90E-04 mr/hr. If the units are correctly stated, then 

the table and the text need to refer to the photon parameters as exposure rates. 

This was corrected in Revision 03 to TKBS-0009. Therefore, SC&A recommends that Finding 6 

be closed.
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4.0 REFERENCES

Katz 2016. E-mail from Ted Katz (CDC/NIOSH/OD) dated April 14, 2016, Subject: URAWE 

WG Items. 

NIOSH 2006. Site Profiles for Atomic Weapons Employers that Refine Uranium and Thorium. 

Battelle-TBD-6001, Revision F0, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. December 13, 2006.

NIOSH 2007. Site Profiles for Atomic Weapons Employers that Refine Uranium and Thorium –

Appendix AA, Hooker Electrochemical Company, Battelle-TBD-6001, Appendix AA, 

Revision 00, National Institute for Occupational Safety and Health, Cincinnati, Ohio. June 15, 

2007.

NIOSH 2010. SEC Petition Evaluation Report, Petition SEC-00141: Hooker Electrochemical,

National Institute for Occupational Safety and Health, Cincinnati, Ohio. May 3, 2010.

NIOSH 2011a. Technical Basis Document for the Hooker Electrochemical Company, DCASTKBS-0009, Revision 00, Division of Compensation Analysis and Support, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. April 4, 2011.

NIOSH 2011b. Technical Basis Document for the Hooker Electrochemical Company, DCASTKBS-0009, Revision 01, Division of Compensation Analysis and Support, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. June 17, 2011.

NIOSH 2011c. Site Profiles for Atomic Weapons Employers that Worked Uranium Metal,

Battelle-TBD-6000, Revision 01, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. June 17, 2011.

NIOSH 2015a. Technical Basis Document for DuPont Deepwater Works, Deepwater New 

Jersey, DCAS-TKBS-0006, Revision 02, Division of Compensation Analysis and Support, 

National Institute for Occupational Safety and Health, Cincinnati, Ohio. March 20, 2015.

NIOSH 2015b. Technical Basis Document for the Hooker Electrochemical Company, DCASTKBS-0009, Revision 02, Division of Compensation Analysis and Support, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. December 8, 2015.

NIOSH 2015c. Transcript of the Uranium Refining Atomic Weapons Employers Work Group, 

National Institute for Occupational Safety and Health, Cincinnati, Ohio. January 22, 2015.

NIOSH 2016a. Transcript of the Uranium Refining Atomic Weapons Employers Work Group, 

National Institute for Occupational Safety and Health, Cincinnati, Ohio. July 19, 2016.

NIOSH 2016b. Technical Basis Document for the Hooker Electrochemical Company, DCASTKBS-0009, Revision 03, Division of Compensation Analysis and Support, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. September 13, 2016.
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NRC 1992. Residual Radioactive Contamination from Decommissioning, NUREG/CR-5512, 

Volume 1, U.S. Nuclear Regulatory Commission, Washington, DC. October 1992. [SRDB 

Ref. ID 23558]

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

Compensation Analysis and Support, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. April 13, 2004.

OCAS 2007. External Dose Reconstruction Implementation Guidelines, OCAS-IG-001, 

Revision 03, Office of Compensation Analysis and Support, National Institute for Occupational 

Safety and Health, Cincinnati, Ohio. April 13, 2007.

SC&A 2010. Review of NIOSH Site Profile for Hooker Electrochemical Company, BattelleTBD-6001, Appendix AA, SCA-TR-SP2010-0034, SC&A, Inc., Vienna, Virginia. September 9,

2010.

SC&A 2011. A Focused Review of the Hooker Electrochemical Company Petition Evaluation 

Report for SEC-00141, SCA-SEC-2011-0018, Revision 0, SC&A, Inc., Vienna, Virginia, and 

Saliant, Inc., Jefferson, Maryland. January 19, 2011.

SC&A 2013. Review of NIOSH Technical Basis Document for the Hooker Electrochemical 

Company, DCAS-TKBS-0009, SCA-TR-SP2013-0034, Revision 0, SC&A, Inc., Vienna, 

Virginia. March 28, 2013.

SC&A 2016. Review of NIOSH Technical Basis Document for the Hooker Electrochemical 

Company, DCAS-TKBS-0009, Revision 02, SCA-TR2016-SP006, Revision 0, SC&A, Inc., 

Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. June 28, 2016.