Page 1 of 3 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Fernald Recycled 

Uranium Constituents

Discussion Paper

 

National Institute for Occupational 

Safety and Health

July 31, 2018

Mutty M. Sharfi 

Oak Ridge Associated Universities Team

Stuart L. Hinnefeld, Director 

Division of Compensation Analysis and Support 
Discussion Paper Fernald Recycled Uranium Constituents July 31, 2018

Page 2 of 3 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ORAUT RESPONSE TO FERNALD RECYCLED URANIUM CONSTITUENTS, 

SC&A CLARIFYING QUESTION 3

This document supersedes NIOSH’s (National Institute for Occupational Safety and Health) 

response to Clarifying Question 3 in the Response Paper, ORAUT Responses to Fernald SC&A 

Clarifying Questions (ORAUT 2018).

SC&A CLARIFYING QUESTION 3

NIOSH (2011) indicates that for the period prior to 1973, Subgroup 6A (UO3 from Hanford) was 

utilized in arriving at 10 ppb Pu, though it is not clear if this assumption is still being utilized. It 

is also not clear if the Subgroup 6A data was extrapolated backwards from post-1973 to the 

earlier period. If data is being back extrapolated, further discussion of the use of this later data as 

a substitute may be warranted. 

NIOSH RESPONSE TO CLARIFYING QUESTION 3

NIOSH recently concluded that the lot code sequence number is not a reliable indicator of the 

date that materials were generated. There were several different techniques that Fernald used to 

assign lot code sequence numbers as found in the DOE (U.S. Department of Energy) Ohio Field 

Office Report (DOE 2000, p. A-6). 

To verify this, NIOSH sorted the data in the “Fernald Recycled Uranium raw data – validated” 

spreadsheet (NIOSH 2011) by sequence number and eliminated any line with a sequence code 

greater than 132. Based on guidance in DOE (2000), sequence 132 should correspond to 

December 1972. 

NIOSH then eliminated the rows that had an alphabetical source code because a 3-letter source 

code is generally associated with material that was generated offsite. For those materials, the lot 

sequence is not necessarily tied to a date of generation (DOE 2000, p. A-6, 3rd paragraph under 

“LOT-MARKING AND COLOR-CODING SYSTEM”), rather it is more often associated with 

the DOE Form 741 number. NIOSH validated this by reviewing shipping documents and 

comparing the dates on DOE Form 741 to the dates associated with the lot code sequence 

numbers. NIOSH did not find any evidence that these lot code sequence numbers represented 

generation dates.

Almost all of the remaining rows referred to UO3 and carried the notation “UO3 from Tower 

Ash” in the “SORT_CLASS” field. Some of these Tower Ash lots contain the lot code sequence 

number of “001”. This lot code sequence number should represent a generation date of January 

1961. However, based on information in DOE (2000), the tower ash had not been sent to 

Fernald that early in time. This confirms NIOSH’s belief that the lot code sequence number is 

not a reliable indicator of the date that materials were generated. 

As early as 1976, it is indicated that Fernald personnel recognized the impact of receiving highcontaminant recycled uranium from other sites. This is illustrated in the 1977 report, Refinery 
Discussion Paper Fernald Recycled Uranium Constituents July 31, 2018

Page 3 of 3 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Processing of Paducah Scrap Materials, that describes how a group of those materials was

handled (Cavendish 1977). It appears that “tower ash” and “feed plant ash” were the material 

types most likely to contain high concentrations of plutonium, neptunium, and technetium

contaminants. DOE (2000) also discusses tower ash and feed plant ash received from the Oak 

Ridge and Portsmouth gaseous diffusion plants (GDP). NIOSH has not been able to identify any 

documentation on how those materials were handled. However, the Ohio Field Office Report 

contains the dates on which they arrived. According to Table E.2-4 (DOE 2000, p. E.2-8), the 

earliest arrivals of “feed plant ash,” or “tower ash” from the three GDPs were 1973 for Oak 

Ridge, 1976 for Paducah, and 1985 for Portsmouth. Cavendish (1977) also indicates that there 

was an established permissible limit of 1,500 dpm/g U for transuranics in uranium products to be 

shipped. A concentration of 10 ppb Pu would result in an activity of 1,350 dpm/g U. 

In addition, in 1985, Fernald issued a letter to DOE entitled, Joint Task Force on Recycled 

Material Processing, (Spenceley 1985, PDF p. 15), which supports the conclusion that the 

average plutonium contaminant level did not exceed 10 ppb. In this letter, Fernald provides a 

summary of recycled feeds by year. According to the plutonium content provided to DOE, the 

average plutonium contaminant level did not exceed 10 ppb Pu in total or by material source 

prior to receipt of ash in 1980. 

Based on the absence of feed plant ash and tower ash prior to 1973, NIOSH believes the 

assumption of 10 ppb Pu is an appropriate and claimant favorable assumption for use in dose 

reconstruction during the 1961-1972 period at Fernald. 

REFERENCES

Cavendish, J. H., 1977, Completion Report, PTA-302; Refinery Processing of Paducah Scrap 

Materials, National Lead Company of Ohio, Cincinnati, Ohio, January 26. [SRDB Ref ID: 

93161] 

DOE (U.S. Department of Energy), 2000, Ohio Field Office Recycled Uranium Project Report, 

Fernald, Ohio Field Office, Springdale, Ohio, May 15. [SRDB Ref ID: 3644] 

NIOSH (National Institute for Occupational Safety and Health), 2011, “Fernald Recycled 

Uranium raw data – validated.xlsx,” spreadsheet, T. Clark, Cincinnati, Ohio, June 17. 

[SRDB Ref ID: 172545] 

ORAUT (Oak Ridge Associated Universities Team), 2018, ORAUT Responses to Fernald SC&A 

Clarifying Questions, Oak Ridge, Tennessee, March 14. [SRDB Ref ID: 170033] 

Spenceley, R. M., 1985, “Joint Task Force on Recycle Material Processing,” letter to J. A. 

Reafsnyder (U. S. Department of Energy), National Lead Company of Ohio, Cincinnati, 

Ohio, January 26. [SRDB Ref ID: 4301]