Draft

RESOLUTION OF SC&A FINDINGS DEVELOPED DURING 

REVIEW OF DCAS-TKBS-0006, REVISION 00 

Contract No. 211-2014-58081

Revision 0 

Prepared by 

William C. Thurber 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

November 2014 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
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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 

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S. Cohen & Associates:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No.: 

Resolution of Findings – Review of 

DCAS-TKBS-0006

Effective Date: 

Draft – November 21, 2014

Revision No.:

0 (Draft)

RESOLUTION OF SC&A FINDINGS

DEVELOPED DURING REVIEW OF DCAS-TKBS0006, REVISION 00

Page 2 of 10

Task Manager:

_____________________________ Date: ___________

John Mauro, PhD, CHP

Supersedes:

N/A

Project Manager:

_____________________________ Date: ___________

John Stiver, MS, CHP

Reviewers:

 

 John Mauro

 John Stiver

 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 11/21/2014 Initial issue
Effective Date:

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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TABLE OF CONTENTS 

Chronology ..................................................................................................................................... 5

Background..................................................................................................................................... 5

Resolution of Open Findings.......................................................................................................... 6

Summary......................................................................................................................................... 9

References..................................................................................................................................... 10
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

AWE Atomic Weapons Employer

CEDE Committed Effective Dose Equivalent

cm centimeter

cm

2

square centimeter

DCAS Division of Compensation Analysis and Support

dpm/m3disintegrations per minute per cubic meter

GM geometric mean

GSD geometric standard deviation

hr/yr hours per year

m

2

/hr square meter per hour

m

3

/hr cubic meter per hour

mg/day milligrams per day

mR/hr milliroentgen per hour

mR/yr milliroentgen per year

mrad millirad

mrem/hr millirem per hour

mrem/yr millirem per year

NIOSH National Institute for Occupational Safety and Health

NRC (U.S.) Nuclear Regulatory Commission

NUREG U.S. Nuclear Regulatory Commission Regulation

OCAS Office of Compensation Analysis and Support

ORAUT Oak Ridge Associated Universities Team

rad a unit of absorbed dose of ionizing radiation

rem Roentgen equivalent man

SC&A S. Cohen and Associates

SRDB Site Research Database

TBD Technical Basis Document

U uranium

UF4 uranium tetrafluoride
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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. 

This draft white paper presents the status of findings made by SC&A (SC&A 2011) during its 

review of Rev. 00 of DCAS-TKBS-0006, Technical Basis Document for the DuPont Deepwater 

Works Deepwater, New Jersey (DCAS 2011), against a new baseline established by Rev. 01 

(DCAS 2013) of that document. 

 

CHRONOLOGY 

 2/14/2011 – NIOSH issues DCAS-TKBS-0006, Technical Basis Document for the 

DuPont Deepwater Works Deepwater, New Jersey (DCAS 2011). This TBD was 

intended to eliminate reliance on TBD-6001 (Battelle 2006), which had been withdrawn.

 8/12/2011 – SC&A delivers site profile review of DCAS-TKBS-0006 (SC&A 2011). 

 9/7/2012 – NIOSH is requested by AWE Work Group to provide response to SC&A’s

site profile review. 

 3/18/2013 – NIOSH provides response to site profile review (Neton 2013). 

 6/6/2013 – SC&A provides critique of March 2013 NIOSH response (SC&A 2013).

 10/16/2013 – Anderson provides status report to ABRWH on DuPont Deepwater 

(Anderson 2013). 

 12/12/2013 – NIOSH issues Rev. 01 to DCAS-TKBS-0006 (DCAS 2013).

BACKGROUND 

In its August 2011 review of DCAS-TKBS-0006 (DCAS 2011), SC&A made the following 

seven findings: 

Finding SC&A Review

Finding 1 The site profile should discuss the degree to which the air sampling data, which was collected in 1944 and 1945, 

can be used to reasonably bound doses in the earlier years of operation (e.g., 1942–1943).

Finding 2 We would request that the site profile discuss the levels of surface contamination at the facility and explain that, 

at these levels, the default ingestion rate of 0.5 mg/day, which is inherent to OCAS-TIB-009 [OCAS 2004], 

applies to this facility. NIOSH should also describe how the ingestion intake in Table 1 was calculated.

Finding 3 It appears that uranium metal was produced at the site using the UF4 to U magnesium bomb reduction process, 

which, because of the Putzier effect, could have produced uranium ingots that were associated with external beta 

radiation fields that were 10 to 20 times greater than those adopted in the site profile.

Finding 4 There seems to be a substantial disparity between the explanation of how the annual photon doses to operators 

were derived and the actual values employed in the site profile.

Finding 5 There seems to be a substantial disparity between the explanation of how the annual contact doses to operators 

were derived and the actual values employed in the site profile. In addition, justification should be provided as to 

why TBD-6000 default values should not be used at DuPont since no site data are available for external exposure 

during the operating period.

Finding 6 Assuming 50% of the beta/gamma dose rate measured at 3 ft from a surface is 50% from gamma and 50% from 

beta does not appear to be appropriate. In addition, beta dose cannot contribute significantly to whole-body dose.

Finding 7 The development of the photon dose is convoluted and not scientifically sound. A simpler approach would be to 

assume the deep dose rate was 0.05 mrad/hr, based on measurements at 3 ft from contaminated surfaces, and prorate this dose rate between beta and gamma based on Table 3.10 of TBD-6000.

Source: SC&A 2011 

Based on the NIOSH responses (Neton 2013) and AWE Work Group discussions, Findings 1 

and 3 were closed. Based on Work Group discussions, there was general agreement on how to 
Effective Date:

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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. 

resolve the other five findings, but final resolution could not be achieved until a revised TBD 

was issued by NIOSH. Accordingly, Rev. 01 to DCAS-TKBS-0006 (DCAS 2013) was 

published by NIOSH on December 13, 2013. The present white paper addresses the question of 

whether Rev. 01 of TKBS-0006 provides a satisfactory resolution to the open findings. 

RESOLUTION OF OPEN FINDINGS 

Finding 2. As described in DCAS-TKBS-0006, Rev. 1: 

A total of 252 air samples were collected. These air samples were analyzed by 

assuming they fit a lognormal distribution. The geometric mean of that distribution 

was 181 dpm/m3 with a geometric standard deviation of 5.73. 

The ingestion dose for the operating period was assumed to be constant at the 95th percentile. From 

these data, one can calculate that the 95th percentile airborne concentration is 3,198 dpm/m3. NIOSH 

used the procedure presented in OCAS-TIB-009 (OCAS 2004) to estimate the ingestion dose from 

the airborne concentration, namely, “The amount of activity ingested on a daily basis can be 

approximated by assuming it to be 0.2 times the activity per cubic meter of air.” Using this 

methodology, the ingestion dose would be 640 dpm/day (3,198 × 0.2), which needs to be 

adjusted from work days to calendar days (640 × 300/365 = 526 dpm/calendar day. This value is 

20% higher than the value of 438 dpm/day1

reported in Table 1 of DCAS-TKBS-0006. As a 

check on how the adjustment from work days to calendar days was made, Table 1 cites a daily 

inhalation intake of 25,245 dpm/day for an operator (3,198 dpm/m3× 1.2 m3/hr × 8 hr/work-day 

× 300 work-days/365 calendar-days). The check calculation suggests that two different methods 

were used to convert work days to calendar days. SC&A is satisfied that the correct basic 

methodology is used to calculate operator ingestion doses (i.e., it is the same as TIB-009), but 

questions whether the ingestion exposures have been properly adjusted to a calendar-day basis. 

This issue had been raised previously, but not resolved. While the difference between ingestion 

exposures of 438 dpm/day and 526 dpm/day for the operational period is not significant from a 

health effects standpoint, the issue should be resolved consistent with established procedures. 

NIOSH pointed out previously (Neton 2013) that the methodology of OCAS-TIB-009 (OCAS 

2004) had been approved by the Procedures Review Subcommittee and SC&A concurred with 

that decision. NIOSH also pointed out that the methodology for calculating ingestion doses 

during the residual period based on TIB-009 was incorrect and would be revised when DCASTKBS-0006 was revised. This was done with ingestion doses during the residual period being 

increased from 0.00685 dpm/day (in Rev. 00) to 30.1 dpm/day (in Rev. 01). For the residual 

period, NIOSH used an approach documented in NUREG/CR-5512 (NRC 1992), where the 

annual ingestion dose is calculated as follows: 

CEDE for Ingestion = Exposure Duration for Occupancy × Effective Transfer Rate for 

Ingestion × Ingestion Dose Factor × Average Surface Activity per Unit Area 

 

1

 A value of 438 dpm/day is obtained by assuming 250 work days per year, which is not the correct 

assumption for the early days of the Manhattan Engineer District. 
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As stated in DCAS-TKBD-0006, Rev. 01:

As with the airborne estimate, the fixed contamination will be assumed to be 

transferable to the point of causing inadvertent ingestion intakes. Again, the 

500 dpm/100cm2value will be used and combined with a value of 1.1E-4 m2/hr (NRC 

1992) to estimate an ingestion rate. This results in an estimated ingestion rate of 

30.1 dpm/day.

For an exposure duration of 8 hours per work-day, a surface concentration of 500 dpm/100 cm2, 

and 250 work-days/365 calendar-days, the calculated exposure is 30.1 dpm/calendar-day in 

agreement with the value quoted by NIOSH for ingestion in Table 10 of DCAS-TKBS-0006, 

Rev. 01.

ORAUT-OTIB-0070 (ORAUT 2012) provides an alternative approach to estimating ingestion 

during the residual period. The geometric mean (GM) air concentration during operations was 

181 dpm/m3. Per OTIB-0070, this can be assumed to decrease exponentially during the residual 

period based on a rate constant of 0.00067/day. As stated in Section 3.6 of OTIB-0070:

If inhalation intakes are calculated from air concentrations, ingestion intakes are 

to be considered. The ingestion rate, in terms of disintegrations per minute (dpm) 

for an 8-hour workday, can be estimated by multiplying the air concentration in 

dpm per cubic meter by a factor of 0.2 (NIOSH 2004) [OCAS 2004]. To adjust 

this to ingestion intake per calendar day, the calculated ingestion rate is 

multiplied by 250 workdays per year and divided by 365 d/yr.

The following table uses this methodology and the factors taken from Table 4-2 of OTIB-0070 

(ORAUT 2012) for an alternative calculation of ingestion during the residual period.

Year Factor Air conc. 

(dpm/m3)

Ingestion

(dpm/workday)

Ingestion

(dpm/calendar-day)

1 1.00E+00 181 36.2 24.8

2 7.83E-01 1.42E+02 28.3 19.4

3 6.13E-01 1.11E+02 22.2 15.2

4 4.80E-01 8.69E+01 17.3 11.9

5 3.76E-01 6.81E+01 13.6 9.3

6 2.94E-01 5.32E+01 10.6 7.3

7 2.31E-01 4.18E+01 8.3 5.7

8 1.81E-01 3.28E+01 6.5 4.5

9 1.41E-01 2.55E+01 5.1 3.5

10 1.11E-01 2.01E+01 4.0 2.8

11 8.67E-02 1.57E+01 3.1 2.1

12 6.79E-02 1.23E+01 2.4 1.7

13 5.32E-02 9.63E+00 1.9 1.3

14 4.16E-02 7.53E+00 1.5 1.0

15 3.26E-02 5.90E+00 1.2 0.8

16 2.55E-02 4.62E+00 0.9 0.6

17 2.00E-02 3.62E+00 0.7 0.5

18 1.56E-02 2.82E+00 0.5 0.4

19 1.23E-02 2.23E+00 0.4 0.3

20 9.60E-03 1.74E+00 0.3 0.2

21 7.51E-03 1.36E+00 0.3 0.2
Effective Date:

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Revision No.

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Resolution of Findings – Review of DCAS-TKBS-0006

Page No.

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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Year Factor Air conc. 

(dpm/m3)

Ingestion

(dpm/workday)

Ingestion

(dpm/calendar-day)

22 5.88E-03 1.06E+00 0.1 0.1

23 4.61E-03 8.34E-01 0.1 0.1

24 3.61E-03 6.53E-01 0.1 0.1

25 2.83E-03 5.12E-01 0.1 0.1

26 2.21E-03 4.00E-01 0.1 0.1

27 1.73E-03 3.13E-01 0.0 0.0

28 1.36E-03 2.46E-01 0.0 0.0

29 1.06E-03 1.92E-01 0.0 0.0

30 on 8.32E-04 1.51E-01 0.0 0.0

For Year 1, the ingestion exposure is similar to that calculated based on the NUREG transfer 

rate, but after that, due to the assumed exponential decay, the ingestion exposure drops off 

rapidly.

With consistent adjustment of the ingestion dose during the operational period for calendar-days, 

SC&A considers this finding closed.

Finding 4. In Rev. 01 to the TKBS-0006, NIOSH changed the methodology for calculating 

photon exposure to operators. In Table 6, NIOSH calculated the photon exposure rate to 

operators as a function of distance from drums of various sizes containing uranium compounds. 

The exposure rate, including Bremsstrahlung at 1 meter from a 55-gallon drum, was calculated to 

be 0.28 mR/hr (DCAS 2013, Table 6). This value was assumed to be the median of a lognormal 

distribution with a geometric standard deviation (GSD) of 5 to account for uncertainty in the 

source-to-object distance. Based on a 2,400-hour work-year, the GM operator photon exposure 

rate was 672 mR/yr. This value is reported in Table 7 of TKBS-0006, Rev. 01. However, it 

should be noted that value of 672 mR/yr is based on work-days, not calendar-days. Adjusting to 

a calendar-day basis would reduce the GM exposure rate to 552 mR/yr (i.e., 672 × 300/365).

SC&A finds that this approach is consistent with prior discussions and agreements and is 

appropriate for dose reconstruction. The assumptions regarding photon doses in Rev. 01 are 

more claimant-favorable that those in Rev. 00 (GM of 672 mR/yr versus 519 mR/yr)

Fiinding 5. NIOSH presented data in Figure 1 of DCAS-TKBS-0006, Rev. 01 showing the 

measured decay of beta dose as a function of distance from a yellowcake source. The 

yellowcake measurements were made 100 days after processing the yellowcake from uranium 

ore to insure build-up of Th-234 and Pa-234m to peak levels (NRC 2002). NIOSH then 

determined that the beta dose from Figure 1 could be approximated by a lognormal distribution 

with a GSD of 5 and a median value of 1 mrem/hr at 100 cm from the source as shown in 

Figure 2 of TKBS-0006, Rev. 01. It was assumed that the operator spends a portion of his time 

at a distance of 100 cm from the source and the balance at 1 foot from the source. For the period 

of time at 1 foot from the source, it was further assumed that for half of that time, the operator 

had his hands in contact with the source. Based on the photon exposure rate spatial distribution 

and the lognormal behavior, it can be calculated that 17% of the time, the operator would be at 1 

foot (30 cm) from the source and 8.5% of the time, his hands would be in contact with the 

source. The contact beta dose rate per Table 5 of TKBS-0006, Rev. 01, is 233 mrem/hr. Thus,

the beta dose would be:
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Contact: 2,400 hr/yr × 0.085 × 233 mrem/hr = 47,500 mrem/yr 

At 1 foot: 2,400 hr/yr × 0.085 × ca. 2 mrem/hr = 408 mrem/yr

At 100 cm: 2,400 hr/yr × 0.83 × 1 mrem/hr = 1990 mrem/yr

Total beta dose: 50,000 mrem/yr

Beta dose to skin other than hands and arms: 2,400 mrem/yr (408 mrem/yr + 1990 mrem/yr)

These doses are the same as reported by NIOSH in Table 7 of TKBS-0006, Rev. 01. The dose to 

the hands and arms is characterized as a bounding dose, rather a dose with an assigned 

distribution.

SC&A was able to verify most of the modeling assumptions used by NIOSH. However, we 

could not easily duplicate the assumed lognormal function that NIOSH presented in Figure 2. 

More details should be provided as how that curve was developed. In addition, as noted in the

findings table above, SC&A questioned why the approach to calculating external dose used in 

TBD-6000 (Battelle 2011) was not used for DuPont. DCAS-TKBS-0006, Rev. 01, does address 

this issue. We note in TBD-6000 that an operator is assumed to spend 50% of the time with his 

hands in contact with a uranium source, as compared to the assumption at DuPont Deepwater 

that the operator spends only 8.5% of his time with his hands in contact with a uranium source. 

Thus, the annual contact dose for an operator at DuPont is 47,500 mrem compared to 276,000 

mrad in TBD-6000. Similarly, the annual other skin dose is 2.4 rem at DuPont as compared to 

25 rad in TBD-6000. Discussion should be provided by NIOSH to reconcile these significant 

differences.

Finding 6. As discussed in Finding 5, the photon exposure in Rev. 01 is based on the calculated 

exposure at 100 cm from a 55-gallon drum of uranium (0.28 mR/hr), and is assumed to be the 

median exposure for a lognormal distribution with a GSD of 5. The beta exposure is based on 

taking measured values at various distances from a yellowcake source and approximating this 

measured distribution by a lognormal distribution with a GM of 1 mrem/hr (at 100 cm) and 

assuming a GSD of 5. The revised approach in Rev. 01 addresses prior concerns and is 

acceptable.

Finding 7. As discussed under Findings 4 and 6, the photon exposure rate was based on 

MicroShield calculations (adjusted to include Bremsstrahlung), assuming that the operator was at 

various distances from a 55-gallon drum of uranium during the work day. The GM distance 

from the source was 100 cm. The approach used to develop the photon exposure is a significant 

improvement over that in Rev. 00 and is scientifically sound.

SUMMARY

 NIOSH should ensure that all dose reconstruction parameters are clearly identified as to 

whether they are on a work-day or calendar-day basis. In addition, NIOSH should ensure 

that inhalation and ingestion exposure parameters are presented on the same basis.

 To provide transparency in DCAS-TKBS-0006, Rev. 01, NIOSH should describe how 

the lognormal curve in Figure 2 was developed.

 NIOSH should provide a rationale as to why the beta doses to the hands and arms are 

substantially higher in TBD-6000 than in DCAS-TKBS-0006, Rev. 01.
Effective Date:

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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

REFERENCES

Anderson 2013. DuPont Deepwater Works, Deepwater, New Jersey Status of Site Profile Issues 

Resolution, Presentation to the Advisory Board on Radiation and Worker Health prepared by 

Henry Anderson, MD, Chair of the AWE Work Group. October 16, 2013.

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

Battelle-TBD-6001, Rev. F0; Battelle Team Dose Reconstruction Project for NIOSH. December 

13, 2006; SRDB Ref ID: 30673.

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

Battelle-TBD-6000. Rev. 01. National Institute for Occupational Safety and Health (NIOSH); 

Cincinnati, Ohio; Division of Compensation Analysis and Support (DCAS); effective June 17, 2011; 

SRDB Ref ID: 101251.

DCAS 2011. Technical Basis Document for the DuPont Deepwater Works Deepwater, New 

Jersey, DCAS-TKBS-0006, Rev. 00. National Institute for Occupational Health and Safety 

(NIOSH), Division of Compensation Analysis and Support (DCAS), Cincinnati, Ohio. February 

14, 2011.

DCAS 2013. Technical Basis Document for the DuPont Deepwater Works Deepwater, New 

Jersey, DCAS-TKBS-0006, Rev. 01. National Institute for Occupational Health and Safety 

(NIOSH), Division of Compensation Analysis and Support (DCAS), Cincinnati, Ohio. 

December 12, 2013.

Neton, James W., 2013. DuPont Deepwater Works – NIOSH’s Response to Findings in SC&A’s 

Review, Dated August 12, 2011. March 18, 2013.

NRC 1992. NUREG/CR 5512 Vol. 1, Residual Radioactive Contamination From 

Decommissioning, U.S. Nuclear Regulatory Commission. October 1992.

NRC 2002. Regulatory Guide 8.30, Health Physics Surveys in Uranium Recovery Facilities, 

Rev. 1. U.S. Nuclear Regulatory Commission. May 2002.

OCAS 2004. Estimation of Ingestion Intakes. OCAS-TIB-009, Rev. 0. National Institute for 

Occupational Health and Safety (NIOSH), Office of Compensation Analysis and Support 

(OCAS), Cincinnati, Ohio. April 13, 2004.

ORAUT 2012. Technical Information Bulletin: 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 2011. Review of the NIOSH Site Profile for DuPont Chambers Works, Deepwater, NJ, 

SCA-TR-SP2011-0035, Rev. 0. SC&A, Inc., Vienna, Virginia. August 12, 2011.

SC&A 2013. SC&A Response to NIOSH’s Commentary on Findings Regarding the Site Profile 

for Dupont Deepwater Works, SC&A, Inc., Vienna, Virginia. June 6, 2013.