Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Assessment of the Disposition of 

SC&A’s Linde Site Profile Review Issues 

in Response to SEC Petitioner Concerns 

Contract No. 200-2009-28555 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

August 2009 

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. 
TABLE OF CONTENTS 

Abbreviations and Acronyms ........................................................................................................iii 

1.0 Introduction......................................................................................................................... 1 

2.0 Issue Resolution Process..................................................................................................... 2 

3.0 Verification of Final Issue Closure..................................................................................... 5 

4.0 References......................................................................................................................... 12 

Linde Assessment of Issues ii SC&A – August 20, 2009 

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. 
ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

BNI Bechtel National, Inc. 

CDC Centers for Disease Control and Prevention 

CFR Code of Federal Regulations 

Ci Curie: unit of activity 

DOE Department of Energy 

DOL Department of Labor 

dpm Disintegrations per Minute 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

GM Geometric Mean 

GSD Geometric Standard Deviation 

HASL Health and Safety Laboratories 

HHS U.S. Department of Health and Human Services 

ICRP International Commission on Radiological Protection 

IMBA Integrated Modules for Bioassay Analysis 

INEL Idaho National Engineering Laboratory 

INL Idaho National Laboratory (formerly, INEL, etc.) 

IREP Interactive RadioEpidemiological Program 

L Liter 

LAPC Linde Air Products Company 

LOD Limit of Detection 

MAC Maximum Allowable Concentration 

MED Manhattan Engineering District 

mg Milligram 

mR milli-Roentgen 

μR micro-Roentgen 

m3

 cubic meters 

Linde Assessment of Issues iii SC&A – August 20, 2009 

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. 
NIOSH National Institute for Occupational Safety and Health 

NYOO (AEC) New York Operations Office 

OGC (CDC) Office of the General Counsel 

OCAS (NIOSH) Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities 

ORAUT Oak Ridge Associated Universities Team

PAS Personal Air Sampling 

pCi pico-curies 

R Roentgen 

rem Roentgen Equivalent Man 

SRS Savannah River Site 

SC&A Sanford Cohen & Associates 

SEC Special Exposure Cohort 

TIB Technical Information Bulletin 

TBD Technical Basis Document 

WG (ABRWH) Work Group

Linde Assessment of Issues iv SC&A – August 20, 2009 

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. 
1.0 INTRODUCTION 

This report is intended to provide information to help inform the deliberations of the Advisory 

Board on Radiation and Worker Health (the Board or ABRWH) Linde Work Group (WG) 

related to (1) the disposition of issues raised by SC&A about NIOSH’s Linde Site Profile, and 

(2) certain concerns expressed by a petitioners’ representative for Special Exposure Cohort 

(SEC) status. NIOSH issued its initial, Rev. 0, Linde Site Profile (NIOSH 2005a) in May 2005, 

and SC&A reviewed it in July 2006 (SC&A 2006a). The SC&A review identified 22 issues 

(some labeled “findings” and some “observations”) that were subsequently discussed and 

addressed in meetings and technical papers until all issues were declared closed by the WG in 

June 2008, nearly 2 years later; but, has NIOSH incorporated all its issue resolution 

commitments into its latest Linde Site Profile (NIOSH 2008a)? 

In the course of this study, SC&A examined the latest Linde Site Profile, Rev. 1 (NIOSH 2008a), 

to see if NIOSH met its issue resolution commitments, but did not perform an in-depth review 

(“audit”) of the document, nor look for any “new” issues beyond those already identified. These 

actions were deemed beyond SC&A’s authorized scope at this time. In addition, while SC&A 

(SC&A 2009a) had looked at aspects of SEC Petition 00107 (SEC-00106/00107 2008) and 

NIOSH’s related Petition Evaluation Report (NIOSH 2008g), SC&A was not authorized to 

examine SEC Petition 00106 (SEC-00106/00107 2008), which, according to its author, was 

prepared based on Rev. 0 of the Site Profile, rather than Rev. 1.1 As mentioned above, NIOSH 

purports to have addressed identified Rev. 0 issues in Rev. 1. 

Linde Assessment of Issues 1 SC&A – August 20, 2009 

 1

 SEC-00106 covers the period from November 1, 1947– December 31, 1953, and SEC-00107 from 

January 1, 1954–July 31, 2006. 

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. 
2.0 ISSUE RESOLUTION PROCESS 

In the time between SC&A’s review of the original (Rev. 0) Linde Site Profile and the resolution 

in concept of all issues,2 NIOSH, SC&A, the Linde WG, and the ABRWH held several meetings 

in person or via teleconference, and generated a number of reports and less formal notes on 

various technical subjects. Furthermore, NIOSH revised the Linde Site Profile twice—Rev. 1, 

NIOSH 2008a, is the current version, and Rev. 0, PC-1 (NIOSH 2006a), an intermediate, 

“minor” revision. In order to help sort out the disposition of the issues and determine whether all 

were finally closed, SC&A felt it would be valuable to document the major events in the issue 

resolution process, and has done so in Table 1, which presents an annotated chronology of 

significant events, starting with the original Site Profile. References are cited for each event; 

these references should be consulted for detailed information. 

SC&A went through all the significant documents to trace the disposition of the 22 identified 

issues from the time they were first raised in SC&A 2006a to the time the last one (the so-called 

“Burlap Bag” issue) was closed in NIOSH 2008f. Table 23

 lists the 22 issues by row and the 

evolution of the resolution process in five columns following the first, ranging from SC&A’s 

initial site profile review (SC&A 2006a) in the second column to closeout of all issues except the 

Burlap Bag issue at the January 2008 Linde WG meeting, shown in the last column. 

Unfortunately, as noted in Table 1, NIOSH 2007b, issued November 29, 2007, after the March 

26, 2007, Linde WG meeting, which responds to all 22 issues in some detail and is a particularly 

important document, cannot be placed neatly in a column in Table 2, since it discusses subjects 

by topic rather than by individual issue. The interested reader must refer to NIOSH 2007b for 

details. 

The Burlap Bag issue, after further discussion and trading of SC&A and NIOSH technical 

reports, was finally declared closed by the WG at a June 2008 Linde WG meeting (NIOSH 

2008f); the relevant events in its closure can be found in Table 1. It will be discussed further in 

Section 3.0. 

It should be noted that the information presented in Tables 1 and 2 is not “new,” but a 

compilation into a compact and useful form of already existing information; it is hoped that the 

tables also capture some of the flavor of the back-and-forth discussions that went on to resolve 

the issues. 

Linde Assessment of Issues 2 SC&A – August 20, 2009 

 2

 “Resolution in concept” – Some issues were effectively put in “abeyance” pending further action by 

NIOSH, such as incorporation into Rev. 1 of the Site Profile. 3

 In recognition of its length and format, Table 2 has been placed for convenience after the body of the 

report. 

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: Linde Issue Resolution Chronology 

Date Documentation Description Comment 

2005

5/31 NIOSH 2005a Linde Exposure Matrix (Site Profile), 

Rev. 0. 

2006

1/18 NIOSH 2006a Linde Exposure Matrix (Site Profile), 

Rev. 0, PC-1. 

7/14 SC&A 2006a SC&A Site Profile Review Report. Review of Rev. 0 Site Profile (NIOSH 

2005a). Identified 22 Issues (aka 

Comments). The issues are listed in 

Table 2 of this report. 

2007

3/22 NIOSH 2007a NIOSH response to SC&A’s Site 

Profile Review (SC&A 2006a). 

SC&A 2006a Issue Resolution Matrix 

(Attachment 4), with an additional 

column showing NIOSH responses to 

each issue. The responses appear in the 

third column of Table 2 of this report. 

3/26 NIOSH 2007c First meeting of the Advisory Board 

Linde Work Group (WG), Cincinnati, 

Ohio 

3/27 SC&A 2007a SC&A’s informal matrix summarizing 

the disposition of issues discussed at 

the 3/26/07 WG meeting. 

SC&A’s summary for each issue appears 

in the fourth column of Table 2 of this 

report. 

4/27 SC&A 2007b SC&A responded to an action item 

from the 3/26/07 WG meeting by 

clarifying its comments on items 13, 

14, and 18. 

OGC reviewed: 5/16/07. 

11/29 NIOSH 2007b NIOSH detailed response to the 22 

issues following discussion at the 

3/26/07 WG meeting. 

Table 1-1 reproduces the summary 

matrix of SC&A 2007a. Discussion is 

by topic, rather than by issue, so the 

issues don’t conveniently map into Table 

2 of this report. 

2008

1/3 SC&A 2008a SC&A assessment of NIOSH’s 

response (NIOSH 2007b) to TBD 

issues. 

Table 1 of SC&A 2008a notes whether 

SC&A considers each issue “closed” or 

“open.” The report then briefly 

discusses the issues. SC&A 2008a 

recommended closing 16 of the 22 

comments. Still open are 2, 7, 8, 13, 17, 

and 22. The discussion for each issue 

appears in the fifth column of Table 2 of 

this report. 

1/8 Roessler 2008 Informal notes of the Linde WG 

meeting in Las Vegas, 1/8/08. 

All open items closed with the exception 

of 17 and 22, which are combined into 

the “Burlap Bag” issue. See last column 

of Table 2 of this report. 

11/4 NIOSH 2008a Linde Exposure Matrix (Site Profile), 

Rev. 1. 

NIOSH claims in the Publication Record 

to have resolved all WG comments. 

Linde Assessment of Issues 3 SC&A – August 20, 2009 

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: Linde Issue Resolution Chronology 

Linde Assessment of Issues 4 SC&A – August 20, 2009 

Date Documentation Description Comment 

2/15 SC&A 2008b SC&A notes from a 2/13/08 technical 

call with NIOSH and the WG on the 

Burlap Bag issue. 

A former Linde employee and an SEC 

petitioner also participated in the 

teleconference. 

2/20 NIOSH 2008b Advisory Board Teleconference 

Meeting. 

The Burlap Bag issue was one of the 

topics of discussion. NIOSH committed 

to produce a white paper on the potential 

exposure from the burlap bags. 

3/18 NIOSH 2008c NIOSH white paper calculating 

potential dose from exposure to 

hypothesized burlap bags. 

6/4 SC&A 2008c SC&A response to NIOSH 2008c on 

burlap bags. SC&A used MCNPx to 

calculate exposures from several 

different scenarios. 

Note: Typo on cover of report has the 

incorrect date of March 29, 2008; the 

correct date of June 4, 2008 appears in 

the footer. 

6/6 NIOSH 2008d Linde WG teleconference. Discussion of Burlap Bag issue focusing 

on NIOSH 2008c and SC&A 2008c. 

6/10 SC&A 2008d Rev. 1 of SC&A 2008c following the 

6/6/08 teleconference. 

6/19 NIOSH 2008e NIOSH informal response to SC&A 

2008d. 

The last bullet states, “Assignment of 

exposures to all Linde employees for 

what seems to be a highly localized and 

limited exposure scenario would seem to 

be inappropriate. If there is indication 

that such an exposure is likely for a 

specific claimant, consideration would 

be made in the dose reconstruction 

report. In all other cases, the current 

exposure matrix...provides an ample 

buffer between the likely exposure 

conditions and those that, albeit possible, 

are highly unlikely. In other words, the 

existing exposure matrix is broad enough 

to cover all likely exposure scenarios, up 

to and including the possibilities outlined 

in the “burlap bag” scenario.” 

6/23 NIOSH 2008f Linde WG meeting, St. Louis, 

Missouri. 

The WG voted to accept NIOSH’s offer 

to add a discussion of the potential 

burlap bag exposure to the next revision 

of the TBD (Rev. 1) and to apply it to a 

dose reconstruction, only if there is some 

evidence of actual exposure to the 

individual. This action then closed (in 

concept) all the site profile issues. 

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. 
3.0 VERIFICATION OF FINAL ISSUE CLOSURE 

Several of the issues raised in SC&A’s Site Profile Review (SC&A 2006a) were “resolved in 

concept” by placing them in “abeyance,” with NIOSH committing to address them in a future 

revision of the site profile; i.e., in Revision 1.4

 In order to completely close the issues, it is 

necessary to verify if NIOSH did indeed address those issues as promised. This also responds to 

one of the concerns expressed by a petitioner’s representative for Special Exposure Cohort 

(SEC) status in the SEC-00106 and SEC-00107 petitions (SEC-00106/00107 2008) and in 

several of the representative’s communications to the ABRWH and SC&A. 

SC&A’s Linde Site Profile Review (SC&A 2006a) examined Rev. 0 of the Site Profile (NIOSH 

2005a). However, NIOSH subsequently issued Rev. 0, PC-1 (NIOSH 2006a) and Rev. 1 

(NIOSH 2008a). The latter states the following in its Publication Record: 

Approved revision to change from a page change revision (Rev 00 PC-2-B) to a 

total rewrite (Rev 01-A) as a result of formal NIOSH review. Revised to 

incorporate: (1) change in facility designation, (2) DOL interpretation of 

applicability of residual period to Ceramics Plant [Linde], (3) and resolution of 

Advisory Board Working Group comments, (4) clarified the implementation 

instructions for SEC00044 for the period October 1, 1942 through October 31, 

1947. Incorporates formal internal and NIOSH review comments. Constitutes a 

total rewrite of the document...

Item number (3) in the above quotation from the Rev. 1 Site Profile Publication Record clearly 

states NIOSH’s claim to have incorporated “resolution of Advisory Board Working Group 

comments.” SC&A will examine 100% of the issues as a check. In a table in Appendix A of a 

previous report, SC&A 2009a, looking at SEC Petition-00107 and the NIOSH Petition 

Evaluation Report, SC&A had presented a detailed comparison of Rev. 1 and Rev. 0 of the Linde 

Site Profiles; that table is reproduced here as Table 3 for convenience to illuminate the changes 

NIOSH made and to help assess whether NIOSH incorporated the material resulting from the 

issues resolution process.5

The first step in ascertaining whether NIOSH met its commitments with respect to issue 

resolution is to identify which issues are affected. This is followed by identifying where in the 

Rev. 1 Linde Site Profile the commitments are addressed and whether SC&A believes that the 

NIOSH response is adequate. Table 2 summarizes the issue resolution process, and Table 4 

summarizes SC&A’s findings with respect to incorporating required changes in the site profile. 

It should be emphasized that all the tables in this report present only summary information, and 

that the interested reader should consult the referenced documents to receive a fuller 

understanding of the issues involved and the issue resolution process. 

Linde Assessment of Issues 5 SC&A – August 20, 2009 

 4

 The terms “resolved in concept” and “in abeyance” were not used at the time of the Linde Site Profile 

review, but came into common usage in the NIOSH project at a later date. 5

 In recognition of its length and format, Table 3 has been placed after the body of this report. 

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. 
A “No” in the second column of Table 4 indicates that, after examining the relevant documents 

of the issue resolution process as summarized in Table 2, SC&A regards a particular issue as 

closed without committing NIOSH to further action, while a “Yes” indicates that SC&A regards 

a particular issue as “resolved in concept,” pending an action by NIOSH. The last column of 

Table 4 lists for each issue the “shorthand” title of the issue, presents a short discussion, then 

closes with SC&A’s assessment of NIOSH’s action or position. 

As can be seen from Table 4, SC&A considered that NIOSH made commitments to “resolve in 

concept” 12 of the 22 issues,6

 which resulted in those issues being categorized as closed in the 

issue resolution process. Of those 12 issues requiring verification, SC&A’s review in this report 

suggests that 11 should be reclassified as “closed” without further qualification, with only Issue 

17 requiring some further discussion and possible NIOSH action. Item 17 is the so-called Burlap 

Bag issue, whose resolution at the June 23, 2008, Linde WG meeting (NIOSH 2008f) required 

that NIOSH make certain modifications in its Rev. 1 Linde Site Profile. As summarized in 

Table 4, NIOSH, in Attachment E, did include a discussion of the Burlap Bag issue and the 

potential exposure consequences from an employee during the post-operations period standing 

near or sitting on a pile of bags during lunch. However, SC&A does not believe that NIOSH’s 

revision with respect to this issue is complete since, as stated in this report’s Table 4: 

1. Neither the body or Attachment E of the Site Profile appear to explicitly state 

that the dose reconstructor should add a dose from post operations burlap 

bag exposure if there is some evidence of such an exposure; this was part of 

NIOSH’s commitment to resolve this issue. 

2. The dose reconstructor is not appropriately directed toward Attachment E in 

the body of the site profile. Section 1.2, Scope, makes the only reference: 

“Attachment E provides an assessment of dose consequences from uranium 

ore bag that were stored on the site during the postoperations period.” 

However, Section 6, which treats exposures during the residual period, does 

not mention Attachment E. 

One further point of SC&A’s review should be noted. Several of the issues, beginning with 

Issue 2, were resolved in concept by NIOSH’s commitment to develop a coworker exposure 

model to be used in the absence of adequate specific applicant data. NIOSH developed such a 

model, which is described in Attachment D of the Rev. 1 Linde Site Profile (NIOSH 2008a). 

SC&A, consequently, reclassified the affected issues as closed in Table 4. SC&A, however, did 

not examine the technical basis of the coworker model for this report; that can be done at a later 

time, if desired by the Board WG. 

Linde Assessment of Issues 6 SC&A – August 20, 2009 

 6

 Issues: 2, 3, 4, 6, 9, 10, 11, 12, 13, 17, 20, and 22. 

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 4: Verification of NIOSH’s Issue Resolution Commitments 

Issue(a)

Verification 

Required? Closeout Discussion 

1 No SC&A 2008a Unsupported Assumptions and Significant Uncertainties in 

Information Used 

SC&A Assessment: Verification not required. 

2 Yes Roessler 2008 Use of Air Concentration Data 

Closure of several identified issues relies on resolution of Issue 2. 

As shown in the last column of Table 2, NIOSH committed to use 

“coworker data and a bounding procedure for estimating internal 

doses for unmonitored workers.” 

Attachment D of NIOSH 2008a (Site Profile, Rev. 1), “Linde 

Uranium Coworker Assessment for November 1947 to January 

1950,” is a standalone report providing guidance to the dose 

reconstructor on how to estimate uranium intakes during the 

specified period. As the attachment states, “Due to the limited 

availability of bioassay data from the Linde site, it was necessary to 

conduct a coworker study of all the bioassay data for use to 

determine intake estimates.” 

Attachment D is referenced in Section 1.2, “Scope;” Section 2.0, 

“Estimation of Internal Exposure, 1947 to July 7, 1954;” and 

Section 3.2.1, “Uranium Urinalysis Data” of NIOSH 2008a. 

Section 3.2.1 states: 

Analysis of Coworker Bioassay Data for Internal Dose 

Assignment (ORAU 2005d) [i.e., ORAUT-OTIB-0019; 

ORAUT 2005b in this report] describes the general 

process used for analyzing bioassay data for assigning 

doses to individuals based on coworker results. Bioassay 

results described above were analyzed in accordance with 

this procedure (Attachment D). The results of this analysis 

are presented in Tables 3-1 and 3-2. Individual uranium 

urinalysis results should be used to determine internal 

exposure to the individual when they are available. Where 

individual results are not available, the coworker data 

included in Attachment D and summarized in Tables 3-1 

and 3-2 are to be used to estimate internal exposures that 

are favorable to claimants. 

SC&A Assessment: NIOSH complied with its issue resolution 

commitment here and for several other issues by virtue of creating a 

coworker model in accordance with ORAUT-OTIB-0019. 

3 Yes SC&A 2008a Urinalysis Data 

NIOSH adopted a coworker model for uranium intakes in 

Attachment D of the Rev. 1 Site Profile (NIOSH 2008a) (see the 

discussion for Issue 2). 

SC&A Assessment: NIOSH complied with its issue resolution 

commitment. 

Linde Assessment of Issues 7 SC&A – August 20, 2009 

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. 
Linde Assessment of Issues 8 SC&A – August 20, 2009 

Table 4: Verification of NIOSH’s Issue Resolution Commitments 

Issue(a)

Verification 

Required? Closeout Discussion 

4 Yes SC&A 2008a Time-weighted Averages

NIOSH adopted a coworker model for uranium intakes in 

Attachment D of the Rev. 1 Site Profile (NIOSH 2008a) (see the 

discussion for Issue 2). 

SC&A Assessment: NIOSH complied with its issue resolution 

commitment. 

5 No SC&A 2007a Breathing Rate 

SC&A Assessment: Verification not required. 

6 Yes SC&A 2008a Ingestion Rate 

NIOSH 2008a treats ingestion in Section 3.7, which states: 

In the case where inhalation intakes are calculated from air 

concentrations, ingestion intakes are also to be considered. 

NIOSH (2004) [NIOSH 2004a in this report] indicates that 

the ingestion rate, in terms of 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... 

This site-wide practice, as adopted in NIOSH 2004a (OCAS-TIB009), bases ingestion rates on air concentrations, not on inhalation 

intakes, as noted in NIOSH 2007a. 

SC&A Assessment: NIOSH has addressed SC&A concerns of 

SC&A 2006a about this observation. 

N.B. NIOSH 2008a, Section 3.7 appears to have a typo; SC&A 

believes the two highlighted values should be the same in the 

following: “...so the uranium ingestion rate based on an air 

concentration of 7 alpha dpm/m3

 would be 0.563 dpm/wd. To 

adjust this to ingestion intake per calendar day, 0.685 dpm/wd was 

multiplied by 250 wd/yr and divided by 365 d/yr, which equals 

0.469 dpm/d.” Note that 0.685 times 250 and divided by 365 does 

equal 0.469 as written. 

7 No Roessler 2008 Radon Exposure and Concentration 

SC&A Assessment: Verification not required. 

8 No Roessler 2008 Raffinate Trace Radionuclides 

SC&A Assessment: Verification not required. 

N.B. Section 3.4 of NIOSH 2008a covers uranium progeny, and 

includes in Table 3-3 the isotopes Th-230, Ra-226, Po-210, Ac-227, 

and Pa-231, which are, typically, found in trace amounts in 

raffinates. 

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. 
Linde Assessment of Issues 9 SC&A – August 20, 2009 

Table 4: Verification of NIOSH’s Issue Resolution Commitments 

Issue(a)

Verification 

Required? Closeout Discussion 

9 Yes SC&A 2008a Assigned Work Hours 

NIOSH’s coworker model in NIOSH 2008a Attachment D (see 

Issue 2) is based on bioassay data, which automatically “integrates” 

dose rates over time to obtain exposures. 

SC&A Assessment: NIOSH has addressed SC&A concerns of 

SC&A 2006a about this observation. 

10 Yes SC&A 2008a Surrogate Air Concentration Data 

NIOSH adopted a coworker model for uranium intakes in 

Attachment D of the Rev. 1 Site Profile (NIOSH 2008a) (see the 

discussion for Issue 2). 

SC&A Assessment: NIOSH has addressed SC&A concerns of 

SC&A 2006a. 

11 Yes SC&A 2008a Use of Geometric Mean Values 

NIOSH agreed (SC&A 2008a) “...that the estimated co-worker 

external doses should be revised based on the guidance of ORAUTOTIB-0020 [ORAUT 2005a in this report] rather than the geometric 

mean of a distribution approach...” 

SC&A Assessment: NIOSH 2008a (Rev. 1 Site Profile) uses a 

coworker model (although the Rev. 1 Site Profile does not appear to 

reference ORAUT-OTIB-0020); NIOSH has addressed SC&A 

concerns of SC&A 2006a. 

12 Yes SC&A 2008a Lack of Comprehensive Uncertainty Analysis 

NIOSH adopted a coworker model for uranium intakes in 

Attachment D of the Rev. 1 Site Profile (NIOSH 2008a) (see the 

discussion for Issue 2). 

SC&A Assessment: NIOSH complied with its issue resolution 

commitment. 

13 Yes Roessler 2008 Complex Missed External Dose Surrogate System 

SC&A had made several comments and “subcomments” through 

several rounds of review; the only one that requires verification that 

NIOSH took an action was Subcomment 5 of Roessler 2008. 

NIOSH committed to making the 14 footnotes of Table 36 of the 

Rev. 0 Site Profile (NIOSH 2005a) clearer in the next revision of 

the site profile. 

SC&A Assessment: Table 36 of NIOSH 2005a became Table 4-24 

of NIOSH 2008a. The 14 footnotes became 18, and provide clearer 

explanations; thus, NIOSH complied with its issue resolution 

commitment. 

14 No SC&A 2008a Film Badge Data

SC&A Assessment: Verification not required.

15 No SC&A 2008a Survey Measurement Data 

SC&A Assessment: Verification not required.

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. 
Linde Assessment of Issues 10 SC&A – August 20, 2009 

Table 4: Verification of NIOSH’s Issue Resolution Commitments 

Issue(a)

Verification 

Required? Closeout Discussion 

16 No SC&A 2008a Time-Weighted Averages 

SC&A Assessment: Verification not required. 

17 Yes NIOSH 2008f Contaminated Burlap Bags 

The Rev. 1 Site Profile report (NIOSH 2008a) includes a new 

section, Attachment E, entitled: “Focused Assessment of Dose 

Consequences from Uranium Ore Bags on the Site During the 

Postoperations Period.” The section recapitulates the issue and its 

development from the original SC&A site profile review 

identification (SC&A 2006a) through subsequent discussions and 

documents. 

Page 4 of Attachment E summarizes NIOSH’s position: 

Based on the weight of the available evidence (tabulated 

below), it is unlikely that two pallets of uranium ore (which 

was last processed at Linde in 1946) would have been in 

Building 30 in 1951 (5 years after the cessation of 

processing of uranium ore). The current external exposure 

model for the period in question incorporates uncertainty 

in the external dose assignment by application of a 

lognormal distribution with a GM of 1.85 and a GSD of 

4.04. This assumed distribution (with a 95th-percentile 

value of 18.5 R/yr) accounts for possible deviation of the 

actual worker exposure of the magnitude that would result 

from the assumption that two pallets of uranium ore were 

in Building 30 in 1951. 

SC&A Assessment: SC&A acknowledges that NIOSH has 

addressed the burlap bag issue (although, perhaps not completely) 

in its Rev. 1 Site Profile. However, while Attachment E treats 

potential burlap bag exposure during the post operations period: 

1. Neither the body nor Attachment E of the Site Profile 

appear to explicitly state that the dose reconstructor should 

add a dose from post-operations burlap bag exposure if there 

is some evidence of such an exposure; this was part of 

NIOSH’s commitment to resolve this issue. 

2. The dose reconstructor is not appropriately directed toward 

Attachment E in the body of the site profile. Section 1.2, 

Scope, makes the only reference: “Attachment E provides 

an assessment of dose consequences from uranium ore bags 

that were stored on the site during the post-operations 

period.” However, Section 6, which treats exposures during 

the residual period, does not mention Attachment E. 

18 No SC&A 2008a Surrogate External Exposure Data 

SC&A Assessment: Verification not required. 

19 No SC&A 2008a Assigned Work Hours 

SC&A Assessment: Verification not required. 

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. 
Linde Assessment of Issues 11 SC&A – August 20, 2009 

Table 4: Verification of NIOSH’s Issue Resolution Commitments 

Issue(a)

Verification 

Required? Closeout Discussion 

20 Yes SC&A 2008a Geometric Values 

NIOSH committed to apply a coworker model; this model appears 

in Attachment D of NIOSH 2008a. 

SC&A Assessment: NIOSH complied with its issue resolution 

commitment. 

21 No SC&A 2008a Lack of Comprehensive Uncertainty Analysis 

SC&A Assessment: Verification not required. 

22 Yes NIOSH 2008f Outdoor Doses/SC&A Assessment 

SC&A Assessment: The review process found that the only 

significant outdoor dose pathway that may have been missed is the 

hypothesized burlap bag exposure in the post-operations period. 

This is covered by Issue 17 and does not have to be tracked here as 

well. 

Notes: 

(a) Refer to Table 2 for a summary of the issues

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. 
4.0 REFERENCES 

42 CFR Part 81, 2002. Title 42, Public Health, Part 81, Guidelines for Determining the 

Probability of Causation Under the Energy Employees Occupational Illness Compensation 

Program Act of 2000; Final Rule, Code of Federal Regulations, May 2, 2002. 

42 CFR Part 82, 2002. Title 42, Public Health, Part 82, Methods for Radiation Dose 

Reconstruction Under the Energy Employees Occupational Illness Compensation Program Act 

of 2000, Code of Federal Regulations, May 2, 2002. 

AEC (Atomic Energy Commission) 1949a. “Health Hazards in NYOO Facilities Producing and 

Processing Uranium: A Status Report- April 1, 1949,” Prepared by the New York Operations 

Office Medical Division, Issued April 18 [Mallinckrodt\08-28-03 – Data Capture\010001510]. 

ACE Buffalo (U.S. Army Corps of Engineers Buffalo District) 2004a. Former Linde Site 

Frequently Asked Questions, Formerly Utilized Sites Remedial Action Program (FUSRAP), 

March. [Linde Air and Ceramics, NY\12-06-04- Data Capture\030001720.pdf]

Davidson, G.R., 2005. An Exposure Matrix for Linde Ceramics Plant (including Tonawanda 

Laboratory), ORAUT-TKBS-0025, Revision 0, Office of Compensation Analysis and Support, 

Cincinnati, Ohio, May 31, 2005. 

Eckerman, K.F., and G.D. Kerr, 1999. Y-12 Uranium Exposure Study, ORNL/TM-1999-114, 

August 5, 1999. 

Eisenbud, M., 1954. Memorandum to Paul B. Pew, Linde Air Products Company, July 12. 

[SRDB 35732, p. 11] 

HHS (Health and Human Services) 2005. Designating a Class of Employees from Linde 

Ceramics Plant, Niagara Falls, NY, December 8. [SRDB Ref ID: 48223]

Harris, W. B., 1954. "Decontamination of Linde Air Products Co., Contract No. AT-(30-1)-

GEN-165,Radiation Survey of April 11-15, 1954," memorandum to R. L. Kirk (Production 

Division),Industrial Hygiene Branch, Health and Safety Laboratories, AEC New York 

Operations Office,April 23 [Linde Air and Ceramics, NY\03-05-04 - Data Capture Air 

Products\260000048 p. 2]. 

Hickey 1993. NUREG-1400, Air Sampling in the Workplace, Final Report, Nuclear Regulatory 

Commission, September 1993. 

Howland, J. W., 1946. "Possible Hazards at Linde Ceramics and Electro-Metallurgical Plants," 

memorandum to the Area Engineer, Madison Square Area, New York, NY, from U.S. Engineer 

Office, Rochester Area, Rochester, NY, November 19 [Linde Air and Ceramics, NY\01-6-04 

Data Capture\240000580]. 

Linde Assessment of Issues 12 SC&A – August 20, 2009 

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. 
ICRP (International Commission on Radiological Protection) 1994. Human Respiratory Tract 

Modelfor Radiological Protection, ICRP Publication 66, Pergamon Press, Oxford, England. 

NIOSH (National Institute for Occupational Safety and Health) 2004a. Estimation of Ingestion 

Intakes, OCAS-TIB-009, Rev. 0, April 13, 2004. 

NIOSH (National Institute for Occupational Safety and Health) 2005a. An Exposure Matrix for 

Linde Ceramics Plant (Including Tonawanda Laboratory), ORAUT-TKBS-0025, Rev. 00. May 

31, 2005. 

NIOSH (National Institute for Occupational Safety and Health) 2006a. An Exposure Matrix for 

Linde Ceramics Plant (Including Tonawanda Laboratory), ORAUT-TKBS-0025, Rev. 00 PC-1; 

January 19, 2006; SRDB Ref ID: 22268. 

NIOSH (National Institute for Occupational Safety and Health) 2007a. Attachment 4: Issue 

Resolution Matrix for Findings and Key Observations. NIOSH markup of Attachment 4 of 

SC&A 2006a, filling in the “NIOSH Response” column. Transmitted via e-mail on March 22, 

2007. 

NIOSH (National Institute for Occupational Safety and Health) 2007b. NIOSH Response: Linde 

TBD Issues, November 29, 2007. 

NIOSH (National Institute for Occupational Safety and Health) 2007c. Transcript of the 

Advisory Board on Radiation and Worker Health Meeting, Cincinnati, Ohio, March 27, 2007. 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/wgtr032607.pdf. 

NIOSH (National Institute for Occupational Safety and Health) 2008a. An Exposure Matrix for 

Linde Ceramics Plant (including Tonawanda Laboratory), ORAUT-TKBS-0025, Rev. 01, 

November 4, 2008. 

NIOSH (National Institute for Occupational Safety and Health) 2008b. Transcript of the 

Advisory Board on Radiation and Worker Health Teleconference, February 20, 2008. 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2008/tr022008.pdf. 

NIOSH (National Institute for Occupational Safety and Health) 2008c. Focused Assessment of 

Dose Consequences from Uranium Ore Bags Onsite During the Post Operations Period, March 

18, 2008. 

NIOSH (National Institute for Occupational Safety and Health) 2008d. Transcript of the 

Advisory Board on Radiation and Worker Health Linde Work Group Teleconference, June 6, 

2008. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2008/wgtr060608.pdf. 

NIOSH (National Institute for Occupational Safety and Health) 2008e. ORAU/OCAS Review of 

Revised SC&A Response to NIOSH Ore Bag Analysis, (Informal note attached to a NIOSH 

e-mail), June 19, 2008. 

Linde Assessment of Issues 13 SC&A – August 20, 2009 

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. 
NIOSH (National Institute for Occupational Safety and Health) 2008f. Transcript of the 

Advisory Board on Radiation and Worker Health Linde Work Group, June 23, 2008. 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2008/wgtr062308lind.pdf. 

NIOSH (National Institute for Occupational Safety and Health) 2008g. SEC Petition Evaluation 

Report, Petition SEC-00107: Linde Ceramics Plant, Submittal Date: November 3, 2008. 

ORAUT (Oak Ridge Associated Universities Team) 2007. Internal Dose Reconstruction, 

ORAUT-OTIB-0060, Rev. 0, February 26, 2007. 

ORAUT 2005a. Use of Coworker Dosimetry Data for External Dose Assessment, ORAUTOTIB-0020, Rev. 1, October 7, 2005. 

ORAUT 2005b. Technical Information Bulletin: Analysis of Coworker Bioassay Data for 

Internal Dose Assignment, ORAUT-OTIB-0019, Rev 1. October 7, 2005. [SRDB Ref ID: 

19438]

ORAUT 2006. Generating Summary Statistics for Coworker Bioassay Data, ORAUT-PROC0095, Rev. 0. June 5, 2006. 

Roessler 2008. Informal notes of the Linde Board Work Group meeting in Las Vegas, Nevada. 

January 8, 2008. 

SC&A 2006a. Review of the NIOSH Site Profile for the Linde Ceramics Plant and Tonawanda 

Laboratory, Tonawanda, New York, Document No. SCA-TR-TASK1-0014, S. Cohen & 

Associates, Vienna, Virginia. July 14, 2006. 

SC&A 2007a. Linde Issue Resolution Matrix Disposition: Advisory Board Committee Meeting, 

March 26, 2007, Cincinnati, Ohio, (Informal matrix of the disposition of issues at the Work 

Group meeting). S. Cohen & Associates, Vienna, Virginia. March 27, 2007. 

SC&A 2007b. Linde Site Profile Review: SC&A Comments on Issue Resolution Matrix Items, 

SC&A Working Group Draft Report (OGC Reviewed May 16, 2007), S. Cohen & Associates, 

Vienna, Virginia. April 27, 2007. 

SC&A 2008a. SC&A Assessment of NIOSH Response: Linde TBD Issues, November 29, 2007, 

Working Draft. S. Cohen & Associates, Vienna, Virginia. January 3, 2008. 

SC&A 2008b. Linde: Burlap Bag Issue Technical Call Notes, February 13, 2008. February 15, 

2008. 

SC&A 2008c. Linde: Radiation Exposure to Ore-Containing Burlap Bags, Working Draft, 

S. Cohen & Associates, Vienna, Virginia. June 4, 2008. (Note: the report’s cover page 

incorrectly shows the date as March 29, 2008). 

Linde Assessment of Issues 14 SC&A – August 20, 2009 

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. 
Linde Assessment of Issues 15 SC&A – August 20, 2009 

 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. 

NOTICE:

SC&A 2008d. Linde: Radiation Exposure to Ore-Containing Burlap Bags – Revision 1, 

Working Draft, S. Cohen & Associates, Vienna, Virginia. June 10, 2008. 

SC&A 2009a. Review of the Linde Ceramics Plant Special Exposure Cohort (SEC) Petition 

00107 and the NIOSH SEC Petition Evaluation Report, SC&A Report SCA-SEC-TASK5-0006, 

Rev. 0, Draft, S. Cohen & Associates, Vienna, Virginia. June 18, 2009. 

SEC-106/107 2008. Linde Ceramics SEC Petitions: SEC00106, November 1, 1947 through 

December 31, 1953; SEC00107, January 1, 1954 through July 31, 2006 – Linde Ceramics 

Facility, Tonawanda, New York. March 19, 2008. 

Snapp, L, M. 2003. Practical Use of Personal Air Sampling (PAS) Data in the Internal 

Dosimetry Program at the Y-12 National Security Complex, RCO-2003-004, Oak Ridge, 

Tennessee. 

Turcic, P. M., 2008. Memorandum to P. R. Worthington, U.S. Department of Labor, 

Washington, D.C., May 21. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

1/1 (Section 5.1.1, p. 38) 

Unsupported Assumptions 

and Significant Uncertainties in Information Used: SC&A has identified numerous assumption or values used in missed dose estimations (both internal and external) in the Linde Site Profile that are not either supported or adequately supported by explanation, available data, technical study, or references. Many of these parametric assumptions are made arbitrarily without adequate technical basis. In some cases, an assumption was made or a value was selected from a range of estimated values in order to bound a dose parameter that is not entirely justified or explained in the document. In other cases, the assumption or value selected is not deemed by SC&A as bounding. This is a serious flaw that significantly affects 

This comment is too general to warrant a specific response, 

except to say that the site profile development process has undergone a number of modifications since dose reconstruction startup, and that what might have been reasonable at the beginning of the project might not be deemed so now. Although the goal is sometimes to bound parameters, parameters can also be defined as distributions. 

None required. Open/Closed: Closed 

Comment: SC&A accepts NIOSH’s

response. 

Linde Assessment of Issues 16 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

the credibility and validity of the assigned missed dose estimates in this Linde Site Profile. 

2/2 (Section 5.1.2.2, p. 42) Use of 

Air Concentration Data: The 

use of airborne uranium dust concentration data (air concentration) as the sole basis for missed occupational internal dose estimation is not defensible or claimant favorable, because there are significant uncertainties regarding using air concentration data to estimate worker inhalation intakes at uranium processing facilities. Several technical studies, including the 2003 Y-12 study, Practical Use of Personal Air Sampling (PAS) Data in the Internal Dosimetry Program at the Y-12 National Security Complex (Snapp 2003), and the Nuclear Regulatory Commission’s NUREG 1400, Air Sampling in the Workplace(Hickey 1993), demonstrate 

1. Air concentration data are 

not used to assign “missed” internal dose, rather they are used to provide reasonable estimates of internal doses received by unmonitored workers. 

2. Air concentration data have 

been used in a number of instances to assign intakes for the purpose of estimating internal dose, and are commonly used in environmental, chemical and nuclear, and emergency response evaluations to estimate exposures. 

3. We agree that measurements 

and models for equating air concentration measurements to intakes have uncertainties, but don’t believe this negates the use of air sample data to estimate intakes. 

NIOSH will develop a new exposure model 

derived from the 700 newly found bioassays; the results of the new model will supersede the use of air concentration data as the basis for occupational internal dose estimation. 

Open/Closed: Open Comment: NIOSH 2007 [NIOSH 2007b in this 

report] notes that NIOSH was mistaken in identifying 700 newly found (as of the March 26, 2007, WG meeting) urinalysis data as belonging to Linde. NIOSH appears to have met SC&A’s objection to using air concentration data to estimate internal doses received by unmonitored workers by conducting a coworker study using the available urine samples, the details of which are provided in Attachment 1 of NIOSH 2007 [NIOSH 2007b in this report]. Data were analyzed according to the 

Linde Assessment of Issues 17 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

that using air concentration data would lead to underestimating the worker intakes and, subsequently, the internal exposures. The Y-12 study shows as high as 10 times difference (underestimation) between intakes derived from bioassay data and intakes derived from air concentration data. 

4. At this time, we were unable 

to locate the Snapp 2003 reference, but note that NUREG 1400 does not indicate that air sampling cannot be used to estimate internal exposures. 

5. Another Y-12 reference 

previously cited by SC&A, Y-12 Uranium Exposure Study (Eckerman and Kerr 1999 [Ref ID 11600]), supports the intake estimation method proposed in the TBD as reasonable; in the Y-12 study, the ratios of air concentration to bioassay-derived intakes range from 0.11 to 1.38, with an average of 0.49 in Table 11 of the Y-12 study, indicating that if bioassay is the gold standard, Y-12 intakes derived from bioassay might be low in some cases by up to a factor of 9. However, the intakes in the Y-12 study were reduced to account for 

methodology of ORAUTPROC-0095, “Generating 

Summary Statistics for Coworker Bioassay Data,” culminating in the Table 2-1 and 2-2 chronic intake rates for Type M and Type S uranium respectively, at the 50% and the 84th percentiles 

(ORAUT 2006). SC&A supports this approach; however, the 

NIOSH response states that “the intakes calculated using coworker data extending through January 1950 (during Step III operations) were extended through the end of the operations period (currently listed as 12-31-53 by DOL) because these intakes are believed to be bounding during the final decontamination phases at the site” (NIOSH 2007, Sect. 2.0) [NIOSH 2007b 

Linde Assessment of Issues 18 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

respiratory protection factors ranging from 1 (no respirator) to 50, but typically in the 25 to 50 range. For Linde, there is no proposal to apply a respiratory protection factor, although some workers did wear respiratory protective devices. 

in this report]. SC&A would like NIOSH to 

explain why it believes these intakes are bounding. 

3/3 (Section 5.1.2.3, p. 45) 

Urinalysis Data: Using air 

concentration data only, but neglecting urinalysis data, to estimate worker inhalation intakes in the Linde Site Profile is not in full compliance with 42 CFR 82 requirements. There are 8 sets of urinalysis data for over 100 uranium workers in the ORAU Database for the period between December 16, 1947, and January 30, 1950. The air concentration data used in the site profile are not complete either, and are deemed inadequate (see Finding 2). However, NIOSH decided to 

Although we agree that air concentration data were used 

to estimate intakes for unmonitored workers, we disagree that uranium urinalysis data were ignored. A set of Linde bioassay data including uranium urinalyses were compiled and the data were reviewed in relation to the air concentration exposure data, as briefly noted in Section 3.8 of the site profile. NIOSH has always advocated using individual monitoring data when adequate and complete, and nothing in the Linde site profile precludes the 

See Comment 2. Consideration of the 700 

bioassays will also resolve Comment 3. 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

response (Comment 2). 

Linde Assessment of Issues 19 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

use these air concentration data only for dose reconstruction. This approach is not in full compliance with the hierarchy approach stipulated in 42 CFR 82. 

use of the individual dosimetry data. 42 CFR 82.10(j) notes, 

“an occupational exposure matrix, using the general hierarchical approach discussed in § 82.2.” 42 CFR 82.2 notes that individual

monitoring, if complete and accurate, is given the highest priority, but in 42 CFR 82(b), preference is not assigned to either coworker or air monitoring data for estimating internal dose for unmonitored individuals, although these methods are given preference over exposures analytically derived from process descriptions. 42 CFR 82.17 also mentions the types of analyses that can be done, but again, preference is not given to estimating internal dose from either coworker or air monitoring data. 

4/4 (Section 5.1.2.2, p. 42) TimeWeighted Averages: Timeweighted averages of internal 

and external exposure values 

Although we agree that air concentration data were used 

to estimate intakes for unmonitored workers, we 

The validation of 33 MAC as the upper-bound 

time-weighted average air concentration or its 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

Linde Assessment of Issues 20 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

contain significant uncertainties and frequently fail to capture dose to workers in areas of high uranium dust concentration. The site profile uses time-weighted calculations to determine average dose values for both internal and external pathways. In the internal dosimetry section, NIOSH determines the time-weighted average air concentration value of 33 MAC by time weighting the air concentration data with average worker exposure times and summing to determine daily time-weighted average air concentrations by job categories. This calculational approach would potentially underestimate the average air concentrations for high-dose or high-risk tasks that a claimant might have participated in at the Linde Site. 

disagree that uranium urinalysis data were ignored. 

A set of Linde bioassay data, including uranium urinalyses, were compiled and the data were reviewed in relation to the air concentration exposure data, as briefly noted in Section 3.8 of the site profile. NIOSH has always advocated using individual monitoring data when adequate and complete, and nothing in the Linde site profile precludes the use of the individual dosimetry data. 42 CFR 82.10(j) notes, “an occupational exposure matrix, using the general hierarchical approach discussed in § 82.2.” 42 CFR 82.2 notes that individual monitoring, if 

complete and accurate, is given the highest priority; but in 42 CFR 82(b), preference is not assigned to either coworker or air monitoring data for estimating internal dose for unmonitored individuals, 

replacement by the new bioassay data 

(Comment 2) would resolve this comment. 

response (Comment 2). 

Linde Assessment of Issues 21 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

although these methods are given preference over exposures analytically derived from process descriptions. 42 CFR 82.17 also mentions the types of analyses that can be done, but again, preference is not given to estimating internal dose from either coworker or air monitoring data. 

5/O (Section 5.1.2.4, p. 45) 

Breathing Rate: The Linde 

Site Profile assumed a breathing rate of 1.2 m3/hour 

for worker intake. This value implies that workers were primarily involved in light exercise during the course of the day. A single value may not be consistent with the working conditions in the facility, especially during the early years of operation, and is inconsistent with other NIOSH site profiles, such as Mallinckrodt, Bethlehem Steel, Y-12, INL, SRS, and Hanford. 

This is not a site-specific issue, and the Linde site profile 

breathing rate assignment is consistent with the Mallinckrodt site profile. (We are not aware of any inconsistencies with breathing rate assumptions in the Y-12, SRS, INEL, and Hanford site profiles either, and are also unaware of changes in breathing rate estimates for different years.) 

None required. Decided that breathing rate isn’t a 

material issue. 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

response. 

6/O (Section 5.1.2.5, p. 45) 

Ingestion Rate: The Linde 

This is a not a site-specific issue. The ingestion intake 

None required. New bioassay data (Comment 

Open/Closed: Closed 

Linde Assessment of Issues 22 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

Site Profile determines the worker ingestion intake by multiplying the inhalation intake by 0.2 (20%). Since the inhalation intake is estimated by using air concentration data, SC&A believes that the NIOSH approach would lead to the underestimation of ingestion intake and eventual missed ingestion doses for Linde workers.

rate is based on OCAS-TIB009, and is based on 

multiplying the air concentration (activity per cubic meter) by 0.2 to estimate daily ingestion activity (the ingestion intake is not calculated directly from the inhalation intake, as stated in the review comment). 

2) supersedes assumption that the ingestion rate is 

20% of the inhalation rate. 

Comment: SC&A accepts NIOSH’s

response. 

7/O (Section 5.1.2.6, p. 46) Radon 

Exposure and Concentration: 

The Site Profile used the “lowest indoor concentrations measured at the Ceramics Plant during African ore processing” as the upper limit to both indoor and outdoor radon concentrations. The assumed indoor radon concentration of 10 pCi/L is based on the lower limit of detection. SC&A believes these assumed radon concentration values based on the GM of measurements are not claimant favorable or representative of the actual 

The site profile developed a stratified approach to assigning 

radon exposures for the entire operational period. In July 1946, work with African ore ceased and a standby period began. Records indicate that processing after this period started with UO2 and the 

uranium ore receipts (the primary source of the radium that produced the radon) had been discontinued. The quote (out of context) applied only to the period prior 

to Ceramics Plant start-up 

NIOSH will look at radon data and treatment more 

closely, including investigating the location, content, and disposition of tailings piles that may have exposed workers to radon. 

Open/Closed: Open Comment: NIOSH refers to its discussion on 

Comment 8 (Section 4.0, Raffinates) [of NIOSH 2007b] to treat this comment, noting that “...raffinates were removed from the Linde site prior to the current non-SEC period (11-01-47).” However, it is not clear that NIOSH fulfilled its commitment to “...look at radon data and treatment more closely 

Linde Assessment of Issues 23 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

exposure conditions that the Linde workers experienced during the period of operation from 1942 to 1954. 

(which is now an SEC period [designated December 2005]), 

and the cited levels were used to estimate possible exposures to Ceramics Plant employees from the radon at the Tonawanda Laboratory, which began research and development operation prior to the initiation of uranium ore processing at the Linde Ceramics Plant. The assumed indoor radon concentration was not based on the detection threshold, which was 1 pCi/L, not 10 pCi/L. In December 2005, an SEC class for Linde Ceramics employees (which we interpret to include Tonawanda Laboratory personnel) was established for October 1, 1942, through October 31, 1947, so radon exposures are not considered for that period. 

including investigating the location, content, and 

disposition of tailings piles that may have exposed workers to radon,” and estimated potential radon exposures (Table 1, Comment 7, Disposition). 

8/5 (Section 5.1.2.7, p. 46) 

Raffinate Trace 

We concur that there might be issues with assigning nonNIOSH agreed in its written response to review Open/Closed: Open 

Linde Assessment of Issues 24 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

Radionuclides: The dose consequences of raffinate trace radionuclides have not been adequately addressed in the Linde Site Profile. Raffinate contains Ac-227 and Pa-231, which are in the U-235 decay chain, as well as Th-230. Possible doses from raffinaterelated exposures have not been evaluated in the site profile. Inhalation of even small quantities of some raffinates, such as filter cake (one of the waste products at Linde Site), could result in significant doses to the workers. The issue of potential airborne contamination of raffinates must be more carefully assessed. 

uranium intakes that have not been adequately addressed. 

This will be reviewed further. 

further its treatment of raffinate trace material. 

Comment: NIOSH performed an extensive 

review of raffinate characterization and disposition to estimate potential airborne exposures. Table 4-2 in NIOSH 2007 [NIOSH 2007b in this report] presents isotopic data for soils and sediments in various site locations, and Table 4-3 presents progeny/U (total) ratios for several isotopes. The Linde Site Profile (NIOSH 2006) [NIOSH 2006a in this report] Table 5 presents uranium intake fractions for several nuclides, determined by assuming secular equilibrium of the uranium progeny. It is not clear to SC&A how Table 4-2 in the NIOSH response (NIOSH 2007) [NIOSH 2007b in this report] relates to Table 5 in the TBD and how the 

Linde Assessment of Issues 25 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

former values are intended for use in dose reconstruction. 

9/6 (Section 5.1.2.8, p. 47) 

Assigned Work Hours: The 

number of work hours used in calculating occupational internal and external doses for workers is inconsistent for different periods of Linde operations and, therefore, not claimant favorable. The site profile represents in Table 4 (Davidson 2005, p. 24), and in many other places, that workers at Linde had longer workweeks than 40 hours per week, and, in some cases, the workweeks were as long as 9 hours per day for 6 days a week and 50 weeks per year. But in most instances, NIOSH uses the standard 40 hours per week assumption for the missed dose estimation. This approach is not only inconsistent, but also not claimant favorable. 

The work periods in Table 4 include lunch periods and 

other non-operational periods during which exposures are likely to be lower. Parameters used in deriving exposure estimates are included in the site profile and can be modified, based on claimspecific details, by dose reconstructors. The assumption that unmonitored workers were exposed to what were judged as favorable estimates of intakes and exposure rates appeared to adequately balance this concern when the site profile was developed, but this issue will be reviewed in conjunction with other items noted in these responses. 

NIOSH’s new exposure model based on the 

bioassay data (Comment 2) will resolve this issue (bioassay data automatically integrates dose over time to obtain exposure). 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

response (Comment 2). 

10/7 (Section 5.1.2.9, p. 47) The intake rate at Linde was See Comment 4. Open/Closed: Closed 

Linde Assessment of Issues 26 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

Surrogate Air Concentration Data: Using the GM of air concentration data of seven AWE facilities in New York from a 1949 AEC/NYOO report (AEC 1949a) as surrogate data to develop Linde site-specific worker inhalation intakes for the entire period of Linde Operation from 1942 to 1954 is over-reaching and may, potentially, underestimate the missed occupational internal dose to workers. This approach is inappropriate, because the surrogate data are very limited and not representative of the actual Linde operation condition because, at Linde, ventilation was poor or non-existent, and adequate radiation protection practices had not yet been developed in the earlier years of operation. 

based on the greatest timeweighted average air 

concentration reported for Linde Ceramics in the AEC/NYOO report for the period 1947 to 1954. This intake was not applied to the period 1942 to 10/31/1947, and was not based on the GM of the seven AWE facilities included in the NYOO report. [It’s not clear why it is thought that data in the NYOO report are very limited for the seven listed facilities, nor why it is thought that ventilation was worse at Linde than at other facilities of the period.] There is much evidence that radiation protection practices were in use and being further developed at Linde Ceramics, and that practices were in place to limit air concentrations and exposures. Note that Linde Ceramics is included in the SEC through October 31, 1947. 

Comment: SC&A accepts NIOSH’s

response (Comment 2). 

Linde Assessment of Issues 27 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

11/11 (Section 5.1.2.10, p. 48) Use 

of Geometric Mean Values:

The statistical analysis approach used in the Linde Site Profile is not bounding and, most importantly, not claimant favorable. In Table 6 of the Occupational Internal Dose Section (Davidson 2005, p. 33), the site profile lists the GM or the GSD values for measured radon concentrations during African ore processing. First, there are no supporting calculations or data to show how these geometrical quantities are calculated. Second, the use of GMs and GSDs of airborne radon concentrations as default values could be considered claimant neutral and not claimant favorable. Unless there is good reason to believe that a given worker was exposed to the full distribution of the measured concentrations and could not have experienced protracted exposures to higher than average radon 

Data and calculations are available and will be provided 

to the reviewer. Whether a parameter is claimant favorable or not is only an issue if that parameter cannot be defined. The use of distributions to define parameters is judged reasonable in general by NIOSH, and the regulations and guidance governing this project refer to the use of distributions. In preparing the site profile, the sentiment was that workers would not likely have been exposed to the higher end of the distributions for the extended periods under consideration, so assigning the whole distribution for exposure periods of 2,040 hours per year was (and is) believed to be claimant favorable for an operation that no longer processed ore. 

NIOSH agreed (Comment 20) that the estimated 

coworker external doses should be revised based on the guidance of ORAUT-OTIB-0020, rather than the geometric mean of a distribution approach, and that estimated internal doses would be considered on a case-by-case basis to determine whether to use GM or 95th percentile 

data. 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

response. As noted in the NIOSH response for this comment in Table 1, “NIOSH agreed...that the estimated co-worker external doses should be revised based on the guidance of ORAUTOTIB-0020 [ORAUT 2005a] rather than the geometric mean of a distribution approach...” 

Linde Assessment of Issues 28 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

concentrations, it may be more appropriate to use the upper 95th percentile as the default 

exposure level. 

We will look again at the available radon data and the 

information used to estimate exposures. We will make the compiled radon data and its subsequent re-analysis available for review. 

12/9 (Section 5.1.2.11, p. 48) Lack 

of Comprehensive 

Uncertainty Analysis: There 

are no uncertainties or potential errors estimated for different assumed parameters and factors used in the estimation of occupational internal dose in the site profile. An assessment of uncertainties, as required by OCAS-IG-001 and OCAS-IG002, has not been adequately developed for air concentration and radon measurement data used in lieu of the absence of adequate bioassay data to assign internal dose. 

We do not believe the information gathered to create 

the site profile is “inaccurate and uncertain,” as stated in the review; however, we do acknowledge that dose reconstructions are based on the ability to define the exposure conditions and apply the appropriate measurement data. We further acknowledge that all measurements have some uncertainty associated with them, but note that this does not invalidate the measurements. Words such as “probably,” “likely,” and “assume” allow the reader to clearly see what was based on an author’s judgment versus what was based on another record, and do not imply that 

See Comment 4. Open/Closed: Closed 

Comment: SC&A accepts NIOSH’s

response (Comment 2). 

Linde Assessment of Issues 29 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

the resulting analysis is thought to be inaccurate and uncertain. University of Rochester and AEC’s Health and Safety Laboratory (HASL) provided (or oversaw) the dosimetry measurements used in the internal dosimetry section of the site profile. OCAS-IG-001 does not generally apply to air concentration and radon measurements. OCAS-IG-002 discusses uncertainty, but states in Section 8.7. “It is important to remember at this point that if the preliminary overestimate or underestimate is conclusive, no uncertainty analysis is required since the estimate is already a bounding case.” The site profile uranium intakes for unmonitored workers represent what we believed to be a bounding case. The uncertainty associated with the 

Linde Assessment of Issues 30 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

radon exposure assignments is encompassed by the defined parameters for the lognormal distribution. Detection thresholds are listed for the uranium urinalyses. Project documentation (OTIB-0060) [ORAUT 2007 in this document] provides generic information regarding assignment of bioassay uncertainties when fitting data with IMBA and when assigning doses in IREP. Further uncertainty analysis discussion is not likely to influence dose estimates. After another careful review of 42 CFR 81, 42 CFR 82, and OCAS-IG-002, we do not see that the assessment of uncertainties, which are encompassed by the distributions (including overestimates) of dose, are inadequately described in the site profile. 

13/8 (Section 5.1.3, p. 49) Complex We agree that the evaluation of SC&A will produce Open/Closed: Open 

Linde Assessment of Issues 31 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

Missed External Dose Surrogate System: The Linde Site Profile uses a very complex scheme to evaluate missed occupational external dose to Linde workers from 1942 to the present time. In this scheme, NIOSH/ORAU used a combination of film badge data, solid sample analysis results, and facility field measurements to estimate missed external doses to workers in different periods of the Linde operations. These data are, however, limited and, most importantly, not facility/building specific. Furthermore, the Linde Site Profile uses different sets of data to estimate worker beta and gamma doses separately. 

unmonitored external dose is complicated, but note this is 

because of the different processes and monitoring data available for different eras of the Linde Ceramics operation. Although there was an early attempt to further complicate the analysis by incorporating building-specific information into the analyses, it was decided that for most unmonitored workers and unmonitored periods, it would not be feasible to associate specific workers for specific periods with specific buildings at a level that is even further refined (and more complicated) than is found in the current site profile. 

specific questions to NIOSH to clarify/explain 

external dose model (as summarized in TBD Table 36). 

Comment: SC&A had raised several questions 

about NIOSH’s external dose model and summarized them in its draft report, SC&A 2007 [SC&A 2007b in this report]. Section 6.0 of the NIOSH response (NIOSH 2007) [NIOSH 2007b in this report] reproduces and responds to the six SC&A comments: Comment 1: NIOSH 

satisfactorily explains how it derived the factor of 3 and elaborates on why it chose that value, rather than a factor of 4. NIOSH notes that “the single value of 3 for both beta and gamma components was selected for simplicity of application. Since the predominant external radiation at Linde was from beta, use of 3 for the 

Linde Assessment of Issues 32 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

gamma component (as opposed to 4.01) is overshadowed by its application for the beta component (as opposed to 1.29)” (NIOSH 2007, Section 6.0) [NIOSH 2007b in this report]. SC&A still believes that, not withstanding some gain in simplicity from choosing a single multiplication factor, it would be more accurate to use separate multiplication factors for the beta and gamma components. Comment 2: SC&A 

accepts NIOSH’s response. Comment 3: SC&A accepts NIOSH’s explanation of why the 1976 survey was used. However, it is still not clear how the TBD (NIOSH 2006) [NIOSH 2006a in this report] 

Linde Assessment of Issues 33 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

Table 13 estimated beta and gamma dose rates referred to in table footnote 

d are derived 

from Table 14 Building 30 radiation survey values. Comment 4: SC&A 

accepts NIOSH’s response. Comment 5: SC&A accepts NIOSH’s response that “unfortunately, the footnotes are not clear enough to allow the reader to easily reproduce the listed values. It is recognized that this table will need to be clarified in any document revision” (NIOSH 2007, Section 6.0, Comment 5) [NIOSH 2007b in this report]. Comment 6: SC&A accepts NIOSH’s response. 

14/8 (Section 5.1.3.4, p. 58) Film To develop external dosimetry See Comment 13. NIOSH Open/Closed: Closed 

Linde Assessment of Issues 34 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

Badge Data: The use of the 1948 weekly film badge data for assigning both beta and gamma doses during the removal of equipment in Building 30 is not appropriate for the entire period from 1949 to 1954. These beta and gamma dose assignments in Table 36 contain median weekly photon doses and weekly median electron doses for use of unmonitored workers from 1942 to 1954. These dose assignments are not likely to capture the full range of external exposures during that time period. Table 36 is hardly representative of various facilities and job functions that defined Linde operations and processes. Another problem in Table 36 is that some of the beta and gamma doses cannot be reproduced or traced back to the original sources. For example, there is no explanation or discussion on how the 1947 and 1949 (beta/gamma/neutron) doses 

models for unmonitored coworkers, the available film 

badge data from 1948–1949 (note there was a standby period from 8/1/46–9/14/47 and production did not start up until 11/1/1947) were initially considered by job category (more than 50 categories for the gamma results and more than 10 categories for beta). Because this scheme was judged to be generally too complicated for application, the work categories were then combined to obtain low, medium, and high groups according to job title. Note that when the work category cannot be determined, the high value would be used. This comment seems to ask for further assumptions (complications) to be considered, and to further break down the data to apply it to yet smaller work groups. Although the fact that this site is included in an SEC through 

will also look at the application of ORAUTOTIB-0020. Comment: SC&A accepts NIOSH’s

response. NIOSH answered SC&A’s comment on the use of film badge data by referring to its response to SC&A’s Comment 13, and by stating in Table 1 that “NIOSH will relook at consistency with ORAUT-OTIB-20,” Use of Coworker Dosimetry Data for External Dose Assignment (ORAUT 2005)[ORAUT 2005a in this report]. NIOSH discusses application of ORAUT-OTIB-0020 in Section 7.0 of its response (NIOSH 2007) [NIOSH 2007b in this report]. SC&A agrees that the OTIB should be applied appropriately to assign beta and gamma external doses where there is a lack of claimant-specific exposure data; any issues 

Linde Assessment of Issues 35 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

were calculated, since they are all based on 1947–1949 weekly film badge data presented in Table 29 and Table 31 of the site profile. 

October 31, 1947, does not imply that our methods to 

assign individual doses from the available data should be less than rigorous, it does color our judgment regarding how much more detail needs to be (and can be supported) in the analyses. In addition, we feel that an unmonitored worker during the 1947–1949 period had a reduced likelihood of exposure from his/her monitored coworker. Table 36 does contain median beta and gamma values, but the instructions prior to the table state these values are to be used with a GSD of 3 (which produce a 95th

percentile dose that is a factor of 6 greater than the median). The neutron doses are assumed to be constant. The derivation of the 1947–1949 beta and gamma doses is 

explained in the text of the sections with Tables 29 and 

that may have arisen from SC&A’s review of the 

OTIB itself are not considered here. 

Linde Assessment of Issues 36 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

31. The neutron doses are separately estimated and defined as upper bounds, and explained in Section 4.3 (although we now note that spontaneous fission was not specifically considered). 

15/8 (Section 5.1.3.5, p. 60) Survey 

Measurement Data: Several 

sets of survey measurement data were used in the Linde Site Profile to calculate the missed beta and gamma doses for workers from 1942 to 1954. These survey measurements do not cover the entire period of Linde operation. SC&A believes that NIOSH should improve the use of these film badge data, because significant gaps exist for time periods when workers were not monitored for external or internal exposure. In addition, NIOSH did not evaluate or attempt to evaluate the adequacy, uncertainty, and accuracy of these data. This 

The Linde Ceramics source term consisted of uranium ore 

and its progeny, which is readily characterized and fairly straightforward to measure. Instrument surveys are almost always biased (unless particular measurement points are defined in advance), due to the fact that surveyors typically attempt to find and report values that represent the greatest exposure rate or contamination level. We believe that the application of a GSD of 3 to estimate unmonitored worker exposures adequately accounts for bias and uncertainty. A rigorous analysis of instrument accuracy, bias, and uncertainty 

NIOSH will relook at consistency with 

ORAUT-OTIB-0020. 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

response to “relook at consistency with ORAUT-OTIB-0020” (Table 1). NIOSH discusses application of ORAUT-OTIB-0020 (ORAUT 2005a in this report) in Section 7.0 of its response (NIOSH 2007) [NIOSH 2007b in this report]. 

Linde Assessment of Issues 37 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

further weakens the assigned missed worker beta and gamma doses for the Linde workers. 

[if such a rigorous study could be done for these instruments 

from the 1940s and 1950s] is unlikely to change compensability outcomes. [The comment in this matrix appears to confuse the subject by mentioning both survey instruments and film badge data, and it is not clear which film badge data are being referenced in the third sentence of this comment.] 

16/4 (Section 5.1.3.6, p. 61) TimeWeighted Averages: Timeweighted averages of external 

exposure values contain significant uncertainties and frequently fail to capture doses to workers in areas of high beta or gamma fields. In the external dosimetry section of the Site Profile, NIOSH determines the time-weighted average beta and gamma radiation dose rates during the standby period from 1946 to 1947 by time-weighting the dose rates with average worker 

At this time, we are not aware of any such high-dose or highrisk tasks performed during the 

standby period. Timeweighting of exposures is common practice and does capture doses to workers in high beta and gamma exposure areas. Dosimetry worn by individuals “automatically” time-weights exposures. OCAS-IG-001 states for unmonitored workers, “At some facilities, radiation surveys were conducted and this data, in conjunction with 

See Comment 4. Also, NIOSH will relook at 

whether there were any “high-risk”/”high-dose” tasks that were not considered. 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

assessment of available records to identify any workers engaged in “high exposure tasks” during the standby period (1946–1947). 

Linde Assessment of Issues 38 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

exposure times and summing to yield annual time-weighted averages by job category (Davidson 2005, p. 41). This approach would certainly underestimate the dose rates for high-dose or high-risk tasks in which a claimant might have participated at the Linde Site. 

frequency of exposure, should be used to estimate the annual 

dose,” which means exposures should be time-weighted. 

17/O (Section 5.1.3.7, p. 61) 

Contaminated Burlap Bags: 

During the interview in Buffalo, Linde site experts and past workers indicated that there were many thousands of used burlap bags stacked up in the open bay area behind Building 30 (see Attachment 3 of this review report). These burlap bags were used for transporting uranium ore to the Linde site for processing. After the end of the operation period, these contaminated burlap bags were stored behind Building 30 awaiting disposal. Many Linde workers, operation staff, and administrative personnel sat on these 

Doses from relatively lightly contaminated burlap bags 

would not compare to the doses derived for the other sources at Linde. Consideration of exposures to the burlap bags was included in the dose calculations during the ore processing period, and the presence of these bags was noted and can be considered in individual dose reconstructions. Note that receipt of ore bags would not have occurred at Linde after July 31, 1946, although it’s possible that the UO2 (lower 

dose rate) would have been received in similar bags. 

• NIOSH to investigate 

details of used burlap bags—which bags (formerly containing African or domestic ore) were stored at which location and during which periods of time. This may affect both internal and external exposures. Even though African ores were processed only during the SEC period (pre10/31/1947), empty bags that had contained African ore may have been around longer (i.e., after 

Open/Closed: Open Comment: Section 5.0 of the NIOSH response discusses the “burlap bag issue.” NIOSH concludes that, “Based on the reviewed historical records, and considering the fact that the period during which the burlap bags were staged and burned is within the current SEC period, a revision to the current dose reconstruction methodology is not warranted” (NIOSH 2007Section 5.0) [NIOSH 2007b in this report]. 

Linde Assessment of Issues 39 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

contaminated bags during breaks and lunch periods over a period of many years. They definitely had been exposed at close distance to beta and gamma radiation sources left over in those uranium contaminated bags. The Linde Site Profile does not estimate the missed beta and gamma doses to workers resulting from sitting or standing next to those contaminated burlap bags. 

1950). 

• NIOSH to determine 

whether there was an on-site incinerator to burn used burlap bags and, if so, the possible effects on internal and external exposures. 

This, however, does not adequately respond to the 

site expert interview assertion that thousands of burlap bags were still stacked behind Building 30 after 1950; as stated in the SC&A site profile review: “During the MED period, they stacked all the contaminated burlap bags in storage area of Building 30. These contaminated burlap bags were kept in there until they were removed to be burned in the incinerator in the late 1950s. Many of the people working in Building 30, including operation personnel, secretaries, and maintenance workers, would sit on those bags resting or eating their lunch. This went on for many years” (SC&A 2006, Attach. 3, p. 112) [SC&A 2006a in this 

Linde Assessment of Issues 40 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

report]. 

18/7 (Section 5.1.3.8, p. 62) 

Surrogate External Exposure 

Data: The lack of complete film badge data for the period from 1942 to 1954 at Linde Site represents a period for which the potential for unaccounted beta and gamma doses is greatest. NIOSH’s use of pre-cleanup survey data for the pre-production period from 1942 to 1943, the use of eight solid ore samples data for the period from 1943 to 1946, the use of a 1-day survey data in six locations in Building 30 for the period from 1946 to 1947, the use of two 1-day precleanup survey data after vacuuming and flushing in Building 30 for 1949, and the use of post-decontamination survey data for 1950 is complex, over-reaching, inadequately supported, and, likely, not claimant favorable. In addition, the use of the 1948 film badge data collected 

We believe this comment does not accurately reflect the basis 

or the considerations that went into developing the exposure estimates for unmonitored workers. Although the assigned doses are, in some cases, based on a single study, it is important to realize that many records were reviewed before these studies were selected to derive unmonitored worker dose estimates. In addition, it should be noted that the estimates of doses are assumed to be central estimates in a lognormal distribution with a GSD of 3. During the period 1942 to May 1943, production had not yet started at the Ceramics Plant, but because there was a possibility of spread of contamination from the Tonawanda Laboratories, estimates of exposure levels from contamination measured 

See Comment 13. Open/Closed: Closed 

Comment: SC&A accepts NIOSH’s

response, covered under Section 6.0, on the external dose model. 

Linde Assessment of Issues 41 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

during the removal of equipment in Building 30 for assigning both beta and gamma doses for the period from 1949 to 1954 is not appropriate, because these data do not account for external exposures to contaminated burlap bags, contaminated soil, and other contaminated sources during the clean-up activities. 

in later years were made. The eight-sample contact measurements used as the 

basis of beta dose estimates are samples of materials generated or used in different parts of the uranium processing and are not all ores. These contact measurements provide actual information regarding potential exposures in different parts of the process. We believe the estimates of doses for unmonitored workers are reasonable and tend to be claimant favorable. 

19/6 (Section 5.1.3.9, p. 62) 

Assigned Work Hours: The 

Linde Site Profile states in Table 4 (Davidson 2005, p. 24) and several other sections that workers had longer workweeks than the standard 40 hours; as high as 9 hours per day, 6 days a week, and 50 weeks per year. However, in calculating external exposure values, 

Because work hours changed over time, and because 

workers did not all work the same number of hours, and because exposure hours are not always the same as work hours, we don’t agree with this comment. As noted in the response to Comment 9, the work periods 

See Comment 9. Open/Closed: Closed 

Comment: SC&A accepts NIOSH’s

response. 

Linde Assessment of Issues 42 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

NIOSH uses different workhour values. SC&A believes that applying these different work-hour values to the missed occupational external dose estimation would underestimate the eventual missed dose or exposure assignments. NIOSH should use a set of consistent and claimant-favorable work hours for use in the dose reconstruction.

in Table 4 include lunch periods and other nonoperational periods during 

which exposures are likely to be lower. Parameters used in deriving exposure estimates are included in the site profile and can be modified based on claim-specific details. The assumption that unmonitored workers were exposed to what were judged as favorable estimates of intakes and exposure rates appeared to adequately balance this concern when the site profile was developed, but this issue will be reviewed in conjunction with other items noted in these responses. 

20/11 (Section 5.1.3.10, p. 63) 

Geometric Values: The 

geometrical approach used in the Linde Site Profile is not bounding and, most importantly, not claimant favorable. In Tables 13, 14, 

1. Although the reviewers 

did not have access to the 

data and calculations to support the resulting quantities, this should not be a basis for inference that such information 

NIOSH will review the GM vs. 95th percentile 

model based on the guidance of ORAUTOTIB-020 (see also Comments 11 and 15). 

Open/Closed: Closed Comment: SC&A accepts NIOSH’s

response to apply the coworker model in ORAUT-OTIB-0020 

Linde Assessment of Issues 43 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

15, 17, 18, 21, 23, 24, 25, 26, 29, 30, 31, 32, and 33, the site profile lists the GM or the GSD values for various assigned default assumptions. First, there are no supporting calculations or data to show how these geometrical quantities are calculated. Second, the geometrical approach does not provide maximized default values to arrive at claimant-favorable worker doses. Third, NIOSH does not provide a comparison of this geometrical approach with NIOSH-prescribed 95th

percentile values. NIOSH should re-evaluate the uncertainties associated with this geometrical approach. 

does not exist. 

2. There is no requirement 

that we can find to 

estimate maximum doses for unmonitored workers. The regulations, guidance, procedures, and the IREP input sheet allow for dose distributions to be assigned. 

3. At the time the Linde 

external exposure coworker model was initially issued (May 2005), ORAUT-OTIB0020 (October 2005) was not issued). After reviewing this reference, we note that for coworker studies there are three categories of exposure to be considered: “the 50th percentile doses are to be applied if the worker was likely exposed intermittently, and the 95th percentile doses are to be applied if the 

(ORAUT 2005). 

Linde Assessment of Issues 44 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

worker was likely exposed routinely. External on-site ambient doses are to be used instead of external coworker doses if the worker was unlikely to have been exposed.” 

We agree, based on this ‘new to the site profile team’ 

information, that the estimated coworker doses in the Linde site profile should be revisited. 

21/9 (Section 5.1.3.11, p. 63) Lack 

of Comprehensive 

Uncertainty Analysis: An 

assessment of uncertainties, as required by OCAS-IG-001 and OCAS-IG-002, has not been adequately developed for air concentration and radon measurement data used in lieu of bioassay data to assign internal dose; and, for external exposure data (including film badge beta and gamma measurements, and survey measurements) used to assign 

We do not believe the information gathered to create 

the site profile is “uncertain” as stated in the review; however, we do acknowledge that dose reconstructions are based on the ability to define the exposure conditions and apply the appropriate measurement data. We further acknowledge that all measurements have some uncertainty associated with them, but note that this does not invalidate the 

See Comment 12. Open/Closed: Closed 

Comment: SC&A accepts NIOSH’s

response. 

Linde Assessment of Issues 45 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

external dose. measurements. Words such as 

“probably,” “likely,” and “assumes” allow the reader to clearly see what was based on an author’s judgment versus what was based on another record, and do not imply that the resulting analysis is thought to be inaccurate and uncertain. 

OCAS-IG-001 does not generally apply to air 

concentration and radon measurements. Further uncertainty analysis/discussion is not likely to influence dose estimates. After another careful review of 42 CFR 81, 42 CFR 82, and OCAS-IG001, we do not see that the assessment of uncertainties, which are encompassed by the lognormal distributions and GSDs of 3 for beta and gamma doses, and in the overestimating nature of the neutron doses, are 

Linde Assessment of Issues 46 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

inadequately assessed for the purpose of compensation determination. 

22/10 (Section 5.1.4.1, p. 64) 

Outdoor Doses: The Linde 

Site Profile does not address missed occupational environmental doses to workers. NIOSH did evaluate several potential outdoor beta and gamma exposures to workers, but, in some cases, NIOSH ignores the outdoor doses (Section 4.1.3.1.2, p. 46; Section 4.1.3.2.2, p. 54) after the doses are calculated. 

Estimates of external exposures that might have 

been received outdoors are included in the Linde Ceramics site profile, and these estimates are specifically added to dose estimates for the exposure periods prior to production in 1943 and after production in 1946. The outdoor exposure estimates for the 1943–1946 period are 0.1 rem/y beta and 0.02 R/y gamma, as compared to the assigned medians of 3 to 74 rem/y beta and 5.35 R/y gamma, which are both assigned a GSD of 3 (which means the 95th percentile is a 

factor of 6 times the median). Further, it is noted that outdoor exposures are not typically included separately in estimated external dose totals in other site profiles, because these are typically either monitored by dosimetry or 

NIOSH will investigate whether it has accounted 

for all outdoor sources (e.g., waste piles, ore piles, incinerators, burlap bags). 

Open/Closed: Open Comment: SC&A asked NIOSH to investigate 

further outdoor (environmental) doses to workers. Section 9.0 notes that “raffinates were moved off site (see Section 4.0)” (NIOSH 2007, Section 9.0) [NIOSH 2007b in this report]. However, SC&A would like further consideration given to the burlap bag issue raised in Comment 17. 

Linde Assessment of Issues 47 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 2: Linde Issue Resolution Tracking Matrix 

Issue/ 

Finding 

(a),(b)

SC&A Site Profile Review(c) 

(SC&A 2006a) 

NIOSH Initial Response 

(NIOSH 2007a) 

SC&A Summary of 

Actions per 3/26/07 

Advisory Board Linde 

WG Meeting 

(SC&A 2007a) 

SC&A Assessment of 

(NIOSH 2007b)(d) 

(SC&A 2008a) 

considered to be within the assigned uncertainty of the dose estimate. 

Notes: 

(a) “Issues” are referred to as “Comments” in some documents. (b) “O” denotes Observation. (c) SC&A 2006a (SC&A’s Site Profile Review) examined NIOSH 2005a (NIOSH’s Rev. 0 Site Profile). 

(d) NIOSH 2007b, which SC&A 2008a responds to, is not included in this table, since NIOSH addresses the issues by topic rather than 

Linde Assessment of Issues 48 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

Publication Record Additional information on 

revisions to Document 01 

Approved revision to chrevision (Rev. 00 PC-2-

A) as a result of formal incorporate (1) change iDOL interpretation of ato Ceramics Plant, (3) rWorking Group commeimplementation instructperiod October 1, 1942 Incorporates formal intecomments. Constitutes 

document. Training reqTask Manager. Initiated 

1.0 Introduction Rev. 01 has additional language 

indicating disclaimers to 

designations of DOE/Atomic Weapons Facilities. 

N/A In this document, the w

general term for an area

buildings that served a sdoes not necessarily conemployer facility” or a [DOE] facility” as definOccupational Illness Co[EEOICPA; 42 U.S.C. § EEOICPA defines a DOstructure, or premise, in

which such building, str... in which operations by, or on behalf of, the (except for buildings, stor operations ... pertainPropulsion Program)” [Accordingly, except for Nuclear Propulsion Profacility that performs or 

Linde Assessment of Issues 49 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

of any nature whatsoeveencompassed by EEOICFor employees of DOE the DOE facility definiteligibility for a dose recprerequisite to a compemembers of the Special compensation decision on a section of the statuPerformance of Duty.” 7384n(b)] says that an ibe determined to have sperformance of duty for compensation program was at least as likely as the facility [where the edetermined in accordanof causation1] guidelinesubsection (c) ...” [42 Uthe statute nor the proba(nor the dose reconstruc82) define “performancemployees with a cover“duty” to nuclear weapoThe statute also includefacility that excludes “bpremises, grounds, or oExecutive Order No. 12(42 U.S.C. 7158 note), pNuclear Propulsion Pro7384l(12)]. While this Nuclear Propulsion Facunder the Act, the sectio

Linde Assessment of Issues 50 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

with the compensation demployees with cancer entitled “Exposure in thdoes not contain such an statute requires NIOSH derived radiation exposdose reconstructions for including radiation expoNuclear Propulsion Proand external occupationconsidered valid for increconstruction. No effoeligibility of any fractiofor inclusion in dose rechowever, does not consto be occupationally der• Background radiation, naturally occurring radostructures • Radiation from x-rays injuries or illnesses or fUnder EEOICPA, emplcategorized as either (1) period (i.e., when the Aproducing material that used in the production oduring the residual contperiods that NIOSH has potential for significant the period in which weaoccurred). For contract occupationally derived covered facilities must b

Linde Assessment of Issues 51 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

reconstructions. This inrelated to the Naval Nucany radiation exposure of commercial radioacticoncurrently manufactuduring the covered periothe following exposures (NIOSH 2007a): • Background radiation, naturally occurring radostructures • Radiation from x-rays injuries or illnesses or fFor employment during period, only the radiatio42 U.S.C. § 7384n(c)(4received from DOE-relain dose reconstructions. are not reconstructed ducontamination period (Nnoted that under subpar7384n(c)(4), radiation aNuclear Propulsion Profrom the employee’s radonly applies to those AWduring the residual contunder subparagraph B oradiation from a source A that is not distinguishdocumentation from radsubparagraph A is consradiation dose. This sitexposures resulting from 

Linde Assessment of Issues 52 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

work. Exposures resulting from if applicable, will be co

1.1 Purpose Added to Rev. 1 

Also disclaimers on infeasibility of dose reconstruction prior to 

1947 

This site profile documematrix for workers at th

Linde Ceramics Plant faProducts Company (LAYork. NIOSH has determinedand Human Services hafeasible to reconstruct i“Atomic weapons emplLinde Ceramics Plant frOctober 31, 1947, and wnumber of work days agdays either solely under combination with work parameters (excluding arequirements) establisheemployees included in tSubsequent correspondethat the Tonawanda Labbuildings on the Linde Sdesignation (cohort). Rexposure (including mebeen determined to be fFor any claim referred temployee, (1) who was period, but because of lthis period, is not a memwho is a member of the not defined as a specifie

Linde Assessment of Issues 53 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

(and so is not eligible foEEOICPA without a dowill continue to attempt reconstruction for the exon external and medical However, because of th2005) that it is infeasiblinternal dose during the through October 31, 194period are considered p

1.2 Scope Added to Rev. 1 This document covers b

information in this site poperational and residuabelow. DOL has determcontamination period fois also applicable to the 2008). Although cleanuPlant continued into Julcovered period for this f1953 exposures are also EEOICPA, but this periexposure period. Becau

potential at the Ceramic1954 (January 1 through the immediately previouinformation on reconstrfrom January 1 through operational period sectiinstructions in this docudose at the Ceramics Pl(as defined by DOL as pertain to exposures sta7, 1954 is used as the de

Linde Assessment of Issues 54 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

decontamination period on the date of the final sis documented in a memYork Operations Office that asserts that the decothe contract were fulfillSection 2.0 describes thhistory. Sections 3.0 aninternal and external ex1954, respectively. Secoccupational medical exinformation on exposurcontamination period afannotations, indicated bto identify the source, juthe associated informati7.0. Attachment A contains analyzing exposures of Attachment B lists codethe LAPC records. Attasources on uranium proAttachment D provides assessment for NovembAttachment E provides consequences from uranon the site during the po

2.6 Additional Narrative on 

Decontamination During 

MED/AEC contract period doesn’t appear in Rev. 1 

This document assumes the end date of the Ceramics Plant cleanup period to be the date of 

turnover of the four Ceramics Plant production buildings to Linde for its use. This date is sometimes stated as 1953 (see, for example, ACE Buffalo 2004a, Response to Question 4). 

Linde Assessment of Issues 55 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

However, Harris (1954) indicates that the decontamination of Building 38 was not complete as of April 1954. For dose reconstruction, it is assumed that turnover did not occur until December 31, 1954. 

This section develops pof doses due to internal 1947, until July 7, 1954NIOSH has concurred, reconstruct internal exp1947 (HHS 2005). 

3.0 Change in estimation of Internal 

exposure to remove dates prior 

to 11-1-1947. Also change in last sentence. 

This section develops parameters for reconstruction of doses due to internal exposures 

from October 1, 1942, the assumed start date of MED work at Linde, until December 31, 1954, the assumed date of initial cleanup completion and building turnover from MED/AEC to Linde. .....Continued lower level exposures to uranium progeny and to radon are assumed, because some radioactive waste was disposed on site and because initial cleanup was not completed until the end of 1954; however, for the Ceramics Plant, the uranium exposures would have dominated during the 1947 to 1954 period. 

...Continued lower-leveprogeny and to radon w

radioactive waste was dbecause initial cleanup end of 1954; however, furanium exposures woupost-1946 period. 

3.1 Detail from Rev. 00 removed 

from Rev. 01, including dose 

reconstruction standards. 

As of this writing, the pre-1947 operational period intakes are reserved. Therefore, the pre-1947 

information is provided only as a description of what the likely upper bound exposures might have been, and is not currently planned for use in Linde dose reconstruction. Document No. ORAUT-TKBS-0025 Revision 00, Effective Date: 05/31/2005 Page 28 of 94 for the pre-1947 period, the MAC would have been assumed to be based on inclusion of uranium’s alpha emitting progeny. Although short-term exposures might have exceeded 300 MAC, it is very unlikely that long-term exposures would have. A review of the predicted urinalyses, kidney 

After the ore processingperiod. It was assumed 

0.1 MAC at the Tonawain 1946 until December of later air concentratioconcentration data from exposures would have bperiods. The standby period at Lto end on September 14Step III process was ass15, 1947, and continue 

Linde Assessment of Issues 56 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

burdens, and lung burdens, indicate that it is highly unlikely that an individual would have sustained exposures like these for any length of time. Evidence of sustained exposure to the more soluble uranium compounds might have shown up in the medical urinalyses, as increases in proteins and glucose in the urine (note that other conditions can also account for these increases). The assumption of air concentrations at 300 MAC seems adequate to provide a quick estimate of exposure, and although the Type F uranium bioassay results are high, they do not seem inconceivable for some workers during this early period. However, it is also likely that Linde workers were exposed to a mixture of uranium absorption types. The analysis of radium exposures in Section 3.8 is partially based on the assumption of alpha activity air concentrations of 300 MAC during Linde’s ore processing period. After the ore processing, Linde began a standby period. It was initially and arbitrarily assumed that exposures decreased to 1 MAC during the standby period at the Ceramics Plant, and that exposures decreased to 0.1 MAC at the Tonawanda Laboratory after cleanup in 1946 until the end of cleanup at the Ceramics Plant in 1954. Based on reviews of later air concentrations at Linde, and reviews of air concentration data from other sites, it is believed that most workers’ exposures would have been much lower during these periods. The standby period at Linde Ceramics was assumed to end on September 14, 1947. Rehabilitation of the Step III process was assumed 

Linde Assessment of Issues 57 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

to begin on September 15, 1947 and continue through October 31, 1947. Intakes from the standby and rehabilitation periods are reserved. Beginning November 1, 1947 at Linde Ceramics, workers were assumed to be exposed to 33 MAC and it was assumed this exposure continued through cleanup in 1954. Uranium progeny are not included in this later period, because only refined uranium was used and because the dose from intakes of contamination left from earlier work would have been insignificant compared to the dose to uranium during operations. To simplify calculations, it assumed that the workweek was 40 hours long during all years, although it is likely that the workweek for many was in excess of 40 hours especially during the earlier years. The assumed air concentrations are sufficiently large to account for any differences in actual hours 

exposed. Dose reconstructions should assume International Commission on Radiological Protection (ICRP) 

Publication 66 default parameters for particle deposition (ICRP 1994). 

3.2.1 Rewording of sentence Note that it is possible that the January 1948 

determination level of 0.1 mg/L is a typographical error, because this is the same as the determination level reported for (nonradioactive) fluoride urinalysis, and because there seems to be no change in the format of the numbers reported. 

The January 1948 deterassumed to be a typogra

the same as the determi(nonradioactive) fluoridthere seems to be no chreported numbers. 

3.2.1 Additional data in Rev. 01 NA Analysis of Coworker B

Dose Assignment (ORA

Linde Assessment of Issues 58 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

general process used foassigning doses to indivresults. Bioassay resultanalyzed in accordance (Attachment D). The represented in Tables 3-1 urinalysis results should internal exposure to the available. Where indivithe coworker data inclusummarized in Tables 3estimate internal exposuclaimants. 

3.3 Disclaimer on Radium in Rev. 

01 

All radium compounds are lung absorption Type M. Radon breath analyses have been used to 

provide information on the amount of radium in the body and are available for some Linde workers. Assignment of radium exposures when radon breath analyses are not available or cannot be interpreted is addressed below in Section 3.4. 

HHS has determined, anit is not feasible to reco

prior to November 1, 19on radon exposure prior provided only as a basis and is not intended to bwhich reconstruction of determined to be infeas

Linde Assessment of Issues 59 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

Ceramics Plant 1943 tTonawanda Laborator

3.4 Data on Uranium Progeny in 

Rev. 00 deleted and replaced by 

disclaimer in Rev. 01. 

In the absence of data on exposures to uranium progeny, their intake rates are determined by 

assuming secular equilibrium. Table 5 lists equilibrium-based ratios for uranium progeny of particular interest in dose reconstruction. Absorption types for their likely chemical forms are also shown. The intake ratios provide reasonably realistic estimates of intakes of progeny due to dust from African ore. The uranium activity fractions overestimate relative intakes of most progeny when the dust is from preprocessed domestic ore. They may underestimate intakes of progeny when the dust is from filter cakes or waste products that contain uranium progeny, but very little uranium. The ratios in Table 5 are for use for the entire 1943–1946 production period for all workers, even though only about 70% of the ore processed was African ore (see Section 2.3.2) and many workers handled only refined uranium materials. This, along with the claimant-favorable assumptions made in the estimation of worker dust exposures, is judged to provide sufficient overestimation to balance any underestimation associated with the handling of waste products. Note that the uranium fractions are applied when the activity of uranium is known. The activity fractions for gross alpha are applied to data measured as alpha activity. 

HHS has determined, anit is not feasible to reco

prior to November 1, 19

Linde Assessment of Issues 60 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

3.4 More detail on production and 

cleanup in Rev. 01 

Ceramics Plant 1947–1949 Step III Production, 

and Subsequent Initial Cleanup

During this period, refined uranium materials were handled. None of the progeny listed in Table 5 

would have been present in significant quantities, compared to the uranium at the Ceramics Plant. 

Ceramics Plant 1947 t

and Subsequent Initia

During this period, refinhandled. None of the ubeen present in significauranium materials but, tprogeny potentially preresuspended during decdecommissioning (D&Dpostoperations period wbounding activity ratios presents bounding indooDocument No. ORAUT01 Effective Date: 11/0use for dose reconstructNovember 1, 1947, throin this table were the hithe indoor and storm se

3.5 Disclaimer on Radon added to 

Rev. 01 

HHS has determined, anit is not feasible to reco

prior to November 1, 19on radon exposure prior provided only as a basis and is not intended to b

Linde Assessment of Issues 61 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

which reconstruction of determined to be infeas

3.5.1 Detail on analysis methodology 

not carried through to Rev. 01 

To simplify, this analysis assumes that workers, who were likely to spend the majority of their time 

in process areas, or in boxcars (where some of the highest radon levels were measured, about 200 times tolerance), or whose jobs were unknown, were exposed to 99.3 pCi/L of radon for 2,040 hours (12 work-months) per year prior to standby. Workers who did not work or have their offices in the process buildings are assumed to have been exposed to 22.4 pCi/L of radon prior to standby. Because a job in current times might not be in or near a process area, does not mean the same held true 60 years ago. Nurses, some stenographers, launderers and seamstresses, and some clerical workers had jobs or locations that put them in contact with the uranium and progeny (Homes 1944b). The initial period of African ore processing was followed by a second period of domestic ore processing. Thirteen measurements of radon concentration during the domestic ore processing were available. The GM of the measurements, assuming the <LOD values were equal to the LOD, was 9.1 pCi/L. To estimate exposure during this domestic ore processing period, both indoor and outdoor radon concentrations were assumed to be 10 pCi/L. 

N/A 

Linde Assessment of Issues 62 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

3.5.1 Pre-1947 Radon rates deleted 

from table in Rev. 01 

3.6 Pre-1947 Inhalation Intake 

Estimates of Particulates 

Removed from Rev. 01 

3.6 Different constants in alpha 

fraction of uranium resulting in difference in annual inhalation intake calculations 

For example, the annual uranium inhalation intake due to chronic exposure at 0.1 MAC is estimated 

by multiplying the air concentration of 7 dpm/m3

by the alpha fraction of uranium, 0.402; the ICRP 66 (ICRP 1994) recommended breathing rate of 1.2 m3/h; and the assumed 2000 work-hours per calendar year. This results in an annual chronic inhalation intake of 6.75E+03 dpm, which is equal to a daily intake rate of 18.5 dpm/day. For the assumed exposure at 33 MAC, no alpha activity is apportioned to progeny, so the daily uranium intake would be 1.52E+04 dpm/day. 

For example, the annuadue to chronic exposure 

by multiplying the air c

the alpha fraction of uraPublication 66 (ICRP 1rate of 1.2 m3/hr, and th

per calendar year. This inhalation intake of 8..2

to a daily intake rate of 

3.7 Ingestion Intake Estimates at 

Tonawanada Laboratories have 

different computation. 

In the case where inhalation intakes are calculated from air concentrations, ingestion intakes are also 

to be considered. NIOSH (2004) indicates that the ingestion rate, in terms of dpm for an 8-hour 

In the case where inhalafrom air concentrations

be considered. NIOSH ingestion rate, in terms 

Linde Assessment of Issues 63 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

workday, can be estimated by multiplying the air concentration in dpm per cubic meter by a factor of 0.2, so the uranium ingestion rate based on an air concentration of 7 alpha dpm/m3 would be 

0.563 dpm/workday. To adjust this to ingestion intake per calendar day, 0.563 dpm/workday is 

multiplied by 250 workdays per year and divided by 365 days per year, which equals 0.385 dpm/day. For the assumed exposure at 33 MAC, no alpha activity is apportioned to progeny, so the daily uranium intake would be 316 dpm/day. In accordance with NIOSH 2004, the f1-value used for inhalation dose calculations is to be used for ingestion dose calculations. 

workday, can be estimaconcentration in dpm pe

0.2, so the uranium ingeconcentration of 7 alpha 

0.563 dpm/wd. To adjucalendar day, 0.685 dpm250 wd/yr and divided b0.469 dpm/d. In accordf1-value used for inhalaused for ingestion dose 

3.8 Consideration of Bioassay Data 

removed from Rev. 01. 

Predicted uranium urinalysis results, provided in Table 10, were calculated for the last day of 

assumed chronic intake periods of 30 and 60 days, 0.5 years, 1 year and extended annually thereafter through the end of operations, assuming the estimated inhalation and ingestion intakes of natural uranium were based on a uranium air concentration of 33 MAC. A cursory review of the highest uranium urinalysis data from facilities that handled uranium in large quantities (Mallinckrodt, Harshaw, Hanford, ORNL, K-25, Paducah, and Portsmouth) indicates that results exceeding 10 mg/L are rare and that most results are less than 1 mg/L. At the Ceramics Plant, where the first Linde uranium bioassays were 

performed after standby, [Redact] of the available urinalysis results exceeded 1 mg/L. Subsequent results from these individuals were much lower. From November 1947 through January 1950, most 

N/A 

Linde Assessment of Issues 64 

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

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

Linde uranium urinalyses (about 95%) were less than 0.1 mg/L, but it is notable that exposures would likely have been lower during this period than in the earlier days of operations. The predicted results in Table 10 do not seem inconsistent with the limited Linde urinalyses. 

Table 10. Predicted uranium urinalyses from Ceramics Plant assumed inhalation and ingestion chronic uranium intake from November 1, 1947 to December 31, 1954 based on 33 MAC in air.

Bioassay Type M Type S 

date dpm/d mg/L dpm/d mg/L 

12/--/1948 566 0.3 18 0.01 12/--/1948 661 0.3 20 0.01 5/--/1949 853 0.4 28 0.01 11/--/1948 961 0.5 36 0.02 11/--/1949 1,013 0.5 48 0.02 11/--/1950 1,022 0.5 57 0.03 11/--/1951 1,026 0.5 64 0.03 11/--/1952 1,028 0.5 70 0.03 11/--/1953 1,031 0.5 74 0.03 11/--/1954 1,033 0.5 77 0.04 12/--/1954 1,033 0.5 78 0.04 *Mass results assume natural uranium exposure 

Given a chronic exposure to uranium and its alpha emitting progeny at 300 MAC, the activity fraction of Ra-226 would be 0.196, which means that the chronic inhalation rate would be 2.7E+04 dpm/d. This gives a whole-body activity of 2.6E+05 dpm at one year, and about 4.0E+05 dpm at 4 years (calculated using IMBA Expert (OCAS), Version 3.2.20). The Ra-226 body activity was estimated using the largest breath radon result found for Linde, 2.2 pCi/L, by multiplying the radon result by a conversion factor of 2.52E+05 pCi/(pCi/L) (ORAUT 2005) [ORAUT 2005a in this report]. 

Linde Assessment of Issues 65 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

This gives a body activity of 5.5 E+05 pCi, which is equal to 1.2 E+06 dpm, and is within a factor of 3 of the estimated intake from a 4-year chronic exposure to 300 MAC. Because other Linde radon breath analyses are lower, and because a chronic exposure scenario may not best represent a worker’s exposure pattern, the assumption of 300 MAC chronic exposure was believed to be adequate for reconstructing doses in the pre-1947 research and production period, but at this time this period is reserved. 

3.8 Occupational Internal Dose 

Reconstruction Assumptions and Summary Disclaimer 

added in Rev. 01. 

HHS has determined, anit is not feasible to reco

prior to November 1, 19

3.8 Summary table for 00 starts at 

1942, Rev. 01 starts at 1947. 

4.0 ESTIMATION OF EXTERNAL 

EXPOSURE, 1942–1954 

Dislaimer for pre-1947 data in Rev. 01 

Because of the SEC det

it is infeasible to adequaduring the period Octob31, 1947, dose estimateconsidered partial dose 

4.0 Additional statement on 

measurement assumptions for 

Beta Radiation in Rev. 01 

For the purpose of calcuexposure geometries are 

anteriorposterior (AP). 

4.1.1 Differing titles, subparagraph 

(typo?) 

4.1.1 Post-production Radiation in Building 30

Little information was available on radiation levels in Ceramics Plant buildings during periods of 

nonproduction. Estimates for these periods were based on measurements made after the end of production in Building 30, the main processing 

4.1.1 Preproduction, 1

Linde Assessment of Issues 66 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

building. 

4.1.2.3 Cleanup section placed at end of 

section in Rev. 01 

4.1.2.2 New information in Rev. 01 for 

“Gamma” 

Film badges were proviof the MED (presumabl

Rochester). 

4.1.3 Standby Section only in Rev. 01 4.1.3 Standby, 1946 to 

Little information is avaactivities during the stan

the onsite staff consisteof management and janwhom worked primarily and guards. For dose reduring standby was clasgeneral worker, and wohave been spent in an obuildings, and outdoorsstandby period, each woassumed to have been afactors in Table 4-13. 

Measurements were mainterest. The results wefour of the locations and for the other two locatiodumping grill) (Howlandumping grill was one ospots in the plant, the ex

Linde Assessment of Issues 67 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

considered typical of thbeen encountered upon standby. Instead, the infor a production buildinTable 4-1 before vacuum Outdoor gamma and beto the indoor rates based in the discussion of the gamma and beta radiatiwere assumed to be zerTable 4-13 summarizes radiation rates based on Because there would hahandling of radioactive workers in this period, band forearms was taken to the remainder of the 

4.4 External Dose Reconstruction 

Summary, October 1, 1942, to July 7, 1954, disclaimer in Rev. 

01 about dosages prior to Oct. 31, 1947 

Because of the SEC det

it is infeasible to adequaduring the period Octob31, 1947, dose estimateconsidered partial dose 

5.0 Occupational Medical 

Exposure disclaimer on dose 

estimates prior to Oct. 31, 1947 

Because of the SEC det

it is infeasible to adequaduring the period Octob31, 1947, dose estimateconsidered partial dose 

5.1.1 Bases of Assumptions. Slightly 

different wording on one sentence under “Applicability” 

Therefore, the general assumption for dose reconstruction is that all employees were subject to 

the same chest x-ray imaging requirements. 

Therefore, the general areconstruction is that al

the same chest x-ray req

Linde Assessment of Issues 68 

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Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

5.1.1 Bases of Assumptions “Period.” 

Different dates between Rev. 00 and Rev. 01 

Production work at the Ceramics Plant is assumed to have ended on June 30, 1949; cleanup work is 

assumed to have ended on December 31, 1954. 

Production work at the 

have ended on June 30, assumed to have ended 

5.1.3 X-ray Dose Reconstruction 

Guidelines. Markedly different 

wording in introductory paragraphs

Dose reconstruction should be based on information specific the subject to the extent that it 

is available and adequate. The guidelines in this section are for use when the records for an individual worker are not available or are incomplete. The guidelines are for use only to the extent that they are not inconsistent with the worker's records. For example, if the medical records are complete and indicate a lower or higher examination frequency than stated in the assumptions provided above, the data in the medical records should be used. X-ray doses shall be determined in accordance with the latest revision of the project technical information bulletin, Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedures (current version is ORAU Team 2003) [ORAUT 2005a in this report] when applicable. 

Dose reconstruction shospecific to the subject to 

available, adequate, and screening examinations (i.e., dose from x-ray exresult of occupational inin dose reconstructions)section are for use when worker are not available guidelines are for use onnot inconsistent with thexample, if the medical indicate a lower or highthan stated in the assumdata in the medical recodoses shall be determinlatest revision of the probulletin, Dose ReconstrRelated Diagnostic X-Rversion is ORAUT 2005report] when applicable

6.0 Estimation of Exposures from 

Residual Contamination after 1954 (1953 in Rev. 01) 

Different dates. 

This section develops parameters for reconstruction of doses due to internal and external 

exposures of Ceramics Plant and Tonawanda Laboratory workers after December 31, 1954, the assumed completion date of cleanup at the Ceramics Plant. Both facilities were on Linde’s Tonawanda, New York, site. Initial cleanup of the Tonawanda Laboratory is assumed to have been 

This section develops pof doses due to internal 

Ceramics Plant starting Laboratory starting Januof the Tonawanda Labocomplete on December Tonawanda Laboratory from January 1, 1947, t

Linde Assessment of Issues 69 

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Table 3: Comparison of an Exposure Matrix for Linde Ceramics Plant (Including Tonawa

ORAUT-TKBS-0025, Rev. 1 (NIOSH 2008a) to Rev. 0 (NIOSH 2005a) (reproduced from 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

completed on December 31, 1946. Tonawanda Laboratory workers’ radiation exposures from January 1, 1947 to December 31, 1954 are discussed in Sections 3.0 and 4.0. The assumed Ceramics Plant initial cleanup date is December 31, 1954. Beginning on January 1, 1955, It is assumed that Linde employees could have been exposed to residual contamination for 2000 hours per year. 

discussed in Sections 3.It was assumed that beg

Tonawanda Laboratory exposed to residual con

6.1.2 External Beta and Gamma 

Exposure different dates 

The total number of readings ≥25 μR/h reported by 

BNI was 16. The net readings (after subtraction of 8 μR/h to correct for background) had a GM of 

94.0 μR/h and a GSD of 3.95. This was taken as an estimate of worker exposure rate when outdoors. This estimate was assumed to apply from January 1, 1955 to the present (2005). 

The total number of rep

16. The net readings (acorrect for background) GSD of 3.95. This was worker exposure rate wwas assumed to apply sTonawanda Laboratory Ceramics Plant. 

Attachment C Not in Rev. 0 Attachment C 

Data Sources on UranConcentrations in Lin

Attachment D Not in Rev. 0 Attachment D 

Linde Uranium CowoNovember 1947 to Jan

Attachment E Not in Rev. 0 Attachment E 

Focused Assessment oUranium Ore Bags on 

Operations Period 

Linde Assessment of Issues 70 

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