Page 1 of 4 

This working document was 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.

NIOSH Response to Sanford Cohen & 

Associates Review of Battelle -TBD-6000 

Appendix BB

(General Steel Industries, Rev. 2)

Response Paper 

National Institute for Occupational Safety and Health

Division of Compensation Analysis and Support 

November 4, 2016 

By David Allen

Reviewed by James W. Neton, Ph.D., CHP 
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 2) 

Page 2 of 4 

This working document was 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.

Background 

The Advisory Board’s work group on TBD-6000 held numerous meetings to discuss issues 

identified in Sanford and Cohen’s review of Appendix BB to TBD-6000, the site profile for 

General Steel Industries (GSI). During these discussions, most issues associated with estimating 

doses at GSI were resolved. On June 6, 2014, NIOSH issued revision 1 of Appendix BB. 

SC&A reviewed this document and issued a memo on December 10, 2014, that contained 9 

findings. On January 8, 2015, NIOSH issued two white papers providing responses to the 9 

findings. On January 26, 2015, SC&A issued a new memo responding to the NIOSH white 

paper. This new memo added one additional finding. 

The work group held additional meetings on February 5, 2015, and November 3, 2015, resulting 

in a resolution to each finding. As a result, revision 2 of Appendix BB was issued on May 26, 

2016. On September 6, 2016, SC&A issued a memo discussing their review of revision 2 which 

concurred that all findings had been resolved with the exception of findings 1 and10. This paper 

provides the NIOSH response to these two findings. 

Finding 1 – Neutron Dose Rates

Appendix BB specifies that neutron doses are assumed to be from exposure in the 0.1-2 MeV 

energy interval. Based on the distribution of neutron energies in the modeled exposure 

scenarios, SC&A pointed out that this assumption underestimates the dose. While using the 0.1-

2 MeV neutron energy range is a favorable approximation when the dose comes from film 

badges calculated using a quality factor of 10, NIOSH agrees it is not necessarily a favorable 

assumption when doses are modeled. 

Because the doses are small, we do not believe it is necessary to assign a dose for each of the 

four neutron energy intervals proposed by SC&A. DCAS will still assign all the neutron dose to 

one energy range, but the 2 to 20 MeV range will be used to provide a claimant favorable 

simplification. That requires the revision to one sentence in the paragraph that follows table 9 in 

Appendix BB. A revised version of Table 1 from SC&A’s review is provided below which

shows that the use of a default 2 to 20 MeV energy range is a claimant favorable simplification.
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 2) 

Page 3 of 4 

This working document was 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.

Energy

range

Lung

DCF

Betatron Operator Layout man

Uranium 

radiography

Uranium 

handling

Uranium total Steel radiography Steel radiography

H*(10) H*(10) H*(10) Lung H*(10) Lung H*(10) Lung

0-10 keV 1.523 0.574 0.003 0.577 0.879 0.160 0.244 0.106 0.162

10–100 keV 0.751 0.100 0.047 0.147 0.111 0.058 0.044 0.084 0.063

0.1–2 MeV 0.579 0.731 0.795 1.526 0.884 0.588 0.340 1.413 0.818

2-20 MeV 1.004 0.063 0.006 0.069 0.069 0.051 0.051 0.234 0.235

Total 1.469 0.851 2.319 1.942 0.857 0.679 1.837 1.278

NIOSHa 1.004 1.469 0.851 2.319 2.328 0.857 0.860 1.837 1.844

Δb -17% -21% -31% a

 Lung dose calculated using lung DCF for 2 – 20 MeV neutrons 

b Δ = Total ÷ NIOSH - 1 

Finding 10 – External Exposure of Betatron Operator 

In its review, SC&A indicated the site profile should specify that the maximum dose conversion 

factor (DCF) from the <30 keV photon range should be used to calculate the betatron operator 

photon dose. 

Use of the maximum DCF as recommended by SC&A did not appear to have any basis at first. 

After careful review, however, it was realized that the appropriate DCF would be that of a 30 

keV mono-energetic photon rather than from the zero to 30 keV range. This is because the 

mono-energetic DCF for breast was used to derive the 204.5 mrem/week dose rate. The 30 keV 

mono-energetic photon DCF corresponds with the maximum DCF of the zero to 30 keV range. 

Since the PA geometry DCF was used in the derivation, the PA geometry, air kerma, 30 kev 

photon DCFs will be specified in a revision to the appendix. 

Using the 30 kev DCF then changes the limiting exposure scenario for the skin of the hands and 

forearms. Table 9 values for 1964 through 1966 will change to the Betatron Operator values 

instead of the layout man values. 

Changes to be made to Appendix BB

The discussion of the photon DCF mentioned in finding 10 and the neutron DCF mentioned in 

finding 1 are both contained in the same paragraph following Table 9 of Appendix BB revision 

2. The photon DCF is also mentioned on page 15 and in footnotes to Tables 8 and 9 of the

Appendix. Therefore, the list of recommended changes to Appendix BB would be: 
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 2) 

Page 4 of 4 

This working document was 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.

1. Change the footnote of Table 8 and the text on page 15 from <30 keV to 30 keV.

2. Change the values for the last three years of Table 9, as well as the footnote. Table 9 now

reads as follows:

Table 9 – Operator Dose Estimate for the Skin of the Hands and Forearms (H&F) 

Year Gamma Dose 

(rad/yr) (a)

Neutron Dose 

(mrem/yr)

Beta Dose 

(mrad/yr)

Source of Estimate

1952 10.225 108 7312 Betatron Operator

1953 10.225 432 29249 Betatron Operator

1954 10.225 432 29249 Betatron Operator

1955 10.225 432 29249 Betatron Operator

1956 10.225 432 29249 Betatron Operator

1957 10.225 432 29249 Betatron Operator

1958 10.225 419 24810 Betatron Operator

1959 10.225 413 22982 Betatron Operator

1960 10.225 413 22982 Betatron Operator

1961 10.225 423 26115 Betatron Operator

1962 10.225 403 19456 Betatron Operator

1963 10.225 365 6627 Betatron Operator

1964 10.225 356 3591 Betatron Operator

1965 10.225 354 3113 Betatron Operator

1966 5.112 176 1317 Betatron Operator

(a) Gamma doses represent a constant distribution, PA geometry, air kerma, 30 kev photons 

3. Change the paragraph following Table 9 to read as follows:

“Except for the triangular distributions described in Table 8, all doses should be assigned as a 

constant distribution. Gamma doses should be assigned as 30 to 250 keV photons except for the 

10.225 and 5.112 rad/yr doses from betatron operations. Those should be used with the 30 keV 

DCF for air kerma in the PA geometry. The 30 keV DCF is the maximum of the <30 keV range 

DCFs. Neutron doses should be assigned as 2 to 20 MeV neutrons and beta doses should be 

assigned as >15 keV electrons.”