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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 1

(pp. 24–26)

The TBD would benefit from a more 

substantive discussion and justification of 

its proposed external dose model in light of 

the limited film badge data available. If 

the film badge data are extrapolated to a 

full year of uranium rolling, then the 

proposed external model would 

underestimate doses for 6 of the 20 badged 

workers.

The current external dose model utilizes a 

combination of MCNP modeling, surrogate 

data from Aliquipa Forge, and a single 

general area measurement taken by the 

AEC.

SC&A compared total dose—beta plus gamma—of 

extrapolated film badge results with the total dose 

recommended in the TBD, which would be applicable for 

dose to the skin. NIOSH has done additional evaluation

according to radiation type.

With the exception of a beta dose outlier, the extrapolated 

film badge data is in general agreement with the TBD, 

given the applied uncertainties. NIOSH believes the values 

in the TBD are the preferred method over the limited film 

badges that are available.

SC&A Preliminary Response (2/13/13): It is SC&A’s 

position that consideration should be given towards 

increasing the assigned external doses to assure the 

bounding nature of the model unless there is evidence to 

suggest the limited film badge data available are not 

representative of the exposure potential to workers at 

Simonds.
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 2

(pp. 27–37)

Simonds Saw and Steel had well

documented changes in industrial hygiene 

controls during its operational controls. 

Various dust control measures were 

steadily implemented during the early 

years of operation which markedly reduced 

worker exposures as evidenced by the 

changing Daily Weighted Exposure 

studies. These industrial controls were 

later removed or rendered ineffective in the 

later years of operation.

The TBD would benefit from a more 

substantive and analytical discussion to 

demonstrate that the proposed intakes 

accurately reflect and bound the varying 

exposure potential at Simonds.

The TBD has summary discussions on operations and

practices, and an extensive evaluation of daily weighted 

exposure studies for[m] air sampling. More has been 

provided in the SEC Evaluation Report and in the SC&A 

review. For the next TBD revision, NIOSH will consider 

an additional paragraph(s) to better explain the significance 

of the air sampling results and why urine data was used to 

assess intakes. However, additional evaluation of the air 

sampling data is not necessary for the TBD, given the urine 

measurements are the preferred data source for assessing 

intakes.

SC&A Preliminary Response (2/13/13): SC&A agrees 

that urinalysis measurements are the preferred method 

for evaluating internal exposures. However, SC&A 

feels that the application of urinalysis data in a “one size 

fits all” model should be analytically discussed in the 

context of the significantly different exposure potential 

among different job types (as evidenced by the DWE 

data) to assure that assigned intakes are bounding to 

ALL worker types at Simonds.
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 3

(pp. 37–39)

Urinalysis sampling at Simonds was 

generally conducted just before and right 

after a rolling operation (usually two 

weeks in duration). It is not clear how 

these different types of samples were 

interpreted when developing the proposed 

intakes. It may be beneficial to analyze 

these samples to individual workers and 

compare the proposed intakes to actual 

changes in urine concentrations before and 

after a rolling period.

Furthermore, it was mentioned in the TBD 

and site documentation that the second 

shift may have had higher exposure 

potential due to less supervision during this 

shift. This issue should be more explicitly 

discussed and analyzed to assure that the 

proposed intakes are bounding to all 

workers at Simonds Saw and Steel.

To determine intakes, the daily geometric mean bioassay 

sample results from Table 5 of the TBD were weighted 

equally in IMBA and fit to a continuous curve over the 

specified periods of time that included both uranium rolling 

days and non-rolling days. It is believed that this method 

provides the most accurate means to assess intake.

The AEC reports on the pre- and post-bioassay data 

indicate the overall post-roll bioassay results were higher 

than the pre-roll results (as would be expected); however, 

that is not the case in all instances, nor for all workers. 

Urinalysis data indicate[s] there were exposures from work 

in contaminated areas between uranium rollings that would 

impact “pre-roll” sample results. It is likely that significant 

loose uranium contamination remained and was disturbed

during non-uranium rollings and maintenance activities. 

Housekeeping practices were not consistently applied and it 

is apparent there were some internal exposures between 

rollings. These factors support the inclusion of all sample 

results in the analysis.

The reference to the 2nd shift is from Ref ID 4609, pg. 224. 

The 2nd shift statement was included in a speculative list by 

HASL of possible explanations for pre-roll samples being

higher than the post-roll samples in August 1950. It was 

not a conclusion by HASL. NIOSH is continuing to 

evaluate records of workers on day and night shift to 

determine if there is a statistical difference between 

bioassay data for first and second shift workers.

SC&A Preliminary Response (2/13/13): SC&A agrees 

with NIOSH’s plan to further evaluate the bioassay data 

used to develop intakes to assure that all assigned 

internal exposures are bounding for all workers at 

Simonds (see NIOSH Response to this Finding and 

Finding 4, as well as SC&A’s Preliminary Response in 

Finding 2).

NIOSH Additional Response (4/23/13): NIOSH has done 

additional review of the bioassay data, including the records 
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

of job titles and shifts worked. Some trends are suggested 

by the records and also noted in air sampling studies; 

however, perceived trends do not hold true for all bioassay 

sampling dates. In addition, some of the higher results are 

for workers for which work descriptions and shifts are 

unknown. The available shift information suggests that the 

first shift accounted for more of the higher bioassay result 

on a particular bioassay date, althoughsome of the highest 

results were from second shift worker or from a worker 

whose shift is unknown. NIOSH concludes that there is 

insufficient information to stratify intakes for the rolling

mill workers. However, NIOSH proposes to revise the 

TBD to change the intake rates. The TBD currently applies 

a bias factor of two to the derived intake rates for 

coworkers, which is not consistent with current practice. It 

is proposed that the bias factor be removed and the uppper 

95th percentile intake rate be applied as a constant to all mill 

workers. For office workers, the median intake rate will be 

applied as a constant; this category is intended to provide a 

bounding intake rate for workers that could have

occasionally been in the general area of the rolling mill.
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 4

(pp. 39–41)

Daily weighted exposure studies conducted 

at Simonds Saw and Steel show a large 

variation in exposure potential based on 

the individual job types and in some cases 

the position of the worker (e.g., east side 

roller versus west side roller). Given these 

large changes in exposure potential, 

NIOSH should demonstrate that the 

proposed intakes are bounding for all types 

of workers and associated exposure 

potential.

Workers who were routinely exposed to the highest levels 

of airborne uranium should have at least some bioassay 

results that can be used to provide worker-specific 

evaluations for claims. It is presumed that the distribution 

of worker intakes provides a claimant-favorable means to 

assess intakes for those with insufficient or no bioassay 

results.

NIOSH is continuing to review bioassay and exposure 

records to assess the coworker data in the TBD (see 

response to Finding #3).

SC&A Preliminary Response (2/13/13): SC&A agrees 

with NIOSH’s plan to further evaluate the bioassay data 

used to develop intakes to assure that all assigned 

internal exposures are bounding for all workers at 

Simonds. This may include analysis of job titles with 

regard to bioassay records and/or the evaluation of the 

availability of specific worker bioassay records for the 

highest exposed job titles that would preclude them 

from being assigned the proposed TBD intakes.

NIOSH Additional Response (4/23/13): NIOSH has done 

additional review. Please see the NIOSH Additional 

Response to Finding 3 (4/23/13).
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 5

(pp. 41–43)

The TBD describes two methods for 

deriving intakes for Simonds which utilize 

the urinalysis samples and daily weighted 

exposures. Ultimately the TBD uses the 

urinalysis derived intakes which are often 

preferable from a data hierarchy 

standpoint. However, intakes derived 

using DWE data are higher than urinalysis 

intakes for certain time periods when 

soluble forms (Type M) of uranium are 

considered.

The TBD would benefit from a more 

substantive justification for selecting the 

proposed intake values over the DWE 

derived values to assure that assigned 

doses are bounding to all workers.

The intakes provided in the TBD for Type S are somewhat 

higher than the intakes indicated by the DWE data (the 

TBD intakes based on bioassay data were multiplied by 2 to 

allow for bias). Type M intakes based on bioassay data are 

lower than the DWE intake data. The oxidized uranium 

metal at Simonds would be expected to resemble Type S 

more than Type M, although Type M intakes are provided 

in case they provide a more favorable dose. A check of 

doses indicates that in nearly all situations the Type S 

intakes in the TBD result in higher doses than the Type M 

intakes (for certain periods and short exposures and 

latencies, the Type M intakes may provide a marginally 

higher dose).

As SC&A acknowledges, the use of bioassay data to 

estimate intakes is considered more accurate than the use of 

air sample data. It would be inconsistent to “cherry pick” 

one method over the other just because it could result in 

higher doses for some limited exposure scenarios.

Regarding more TBD discussion of DWE data, see 

response to Finding #2.

SC&A Preliminary Response (2/13/13): SC&A 

acknowledges that the material at Simonds was most 

likely Type S and that this solubility type will be applied 

in most applications. SC&A also agrees that “cherry 

picking” a method of intake such as DWE versus 

bioassay on a case-by-case basis would be inconsistent 

and inappropriate. SC&A believes that further 

discussion on the appropriateness and bounding nature 

of the bioassay versus DWE would help buttress the 

claimant favorability of the proposed approach.

SC&A further agrees and acknowledges that additional 

numerical analysis of the DWE data may not be 

warranted (as noted in NIOSH Response to Finding #2) 

so long as the bounding and claimant favorability of the 

bioassay-based intakes have been established.
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 6

(pp. 44–45)

The TBD would benefit from a more 

substantive discussion of its selected 

external dose assignments during the 

residual period. This should include a 

more detailed description of available 

survey data during the 1970s and 1980s to 

assure claimant favorability. Also, 

justification should be provided as to why 

the work day was decreased from 10 hours 

(assumed during the operational period) to 

8 hours (assumed during the residual 

period).

Additionally, NIOSH should consider the 

methods outlined in Strom 2007 which 

recommend the use of a GSD of 5 when 

sufficient information characterizing the 

distribution is not available.

The GSD for residual external doses used in the TBD is

based on two measured dose rates, one assumed to be the 

median dose rate and a bounding rate assumed for the 95th

percentile rate. Although the median dose rate based on a 

2,000 hour [sic] does not directly allow for overtime work, 

the favorable method used to determine the GSD effectively 

allows for higher exposures. It is believed that 2,000 hours

of exposure at the median dose rate likely bounds external 

exposures; dose from time spent in other, lower dose rate 

areas are insignificant in comparison; the GSD allows for 

the uncertainty.

However, the residual period dose rates used in the TBD 

are currently being reviewed by NIOSH to better address 

SC&A’s comments concerning a more thorough discussion 

and to determine if any changes are needed.

SC&A Preliminary Response (2/13/13): SC&A agrees 

with NIOSH’s plan to further research/analyze/discuss 

the available external dose measurements in the residual 

period to assure that assigned external doses are 

bounding to all workers at Simonds.

NIOSH Additional Response (4/23/13): Please see the 

NIOSH Additional Response to Finding 7 (4/23/13)..
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

Finding 7

(pp. 45–49)

The proposed internal coworker model for 

the residual period appears to differ from 

the methodology described in ORAUTOTIB-0070. Intake rates at the beginning 

of the residual period are based on the 

average of general air samples taken from 

1948–1953 (general air samples taken in 

1954 were not included). The majority of 

these samples were collected while the 

major dust control measures were in place 

and functioning; this would not be 

reflective of conditions at the end of the 

operational period when many of these 

measures had been removed or were not 

functioning properly.

Additionally, a 2007 survey was used to 

develop intakes at the end of the period;

however, the conditions observed in 2007 

were assumed to be identical to those 

experienced 24 years earlier. NIOSH 

should consider a correction factor to 

account for source term degradation 

between 1983 and 2007.

The method used in the TBD for deriving intakes during the

residual period follow[s] the method prescribed in ORAUTTKBS-0070 Section 4.1.4, which specifies that the air 

concentration during the operational period and the air 

concentration during the residual period can be used to 

determine an exponential depletion rate, with the two 

measurements and the elapsed time between those 

measurements used to determine the rate.

ORAUT-TKBS-0070 does not specify the method to 

estimate the air concentration during the operational period, 

and the method can vary depending on the type of data that 

is available. The TBD used results from 1949–1953. Air 

concentrations in 1948 were noticeably higher (prior to 

controls) and not representative of air in any of the later 

years. Although 1954 data was not used in the estimate, the 

1954 average result is in the range of values for 1949–1953, 

although there are only limited 1954 data available, 

presumably because of infrequent uranium rolling in the 

later years. NIOSH believes the values in the TBD bound 

the air concentrations at the end of the operational period.

NIOSH continues to evaluate the following issues identified

by SC&A:

It is not clear why the average air concentration values in 

the TBD differ from those estimated by SC&A.

SC&A’s suggestion that an additional factor be applied 

for depletion 1983–2007.

SC&A Preliminary Response (2/13/13): While TKBS0070 is not specifically prescriptive on how to derive the 

starting and ending values used to define the residual 

period, the values selected for the beginning of the 

residual period should be representative of the 

conditions at the end of operations.

SC&A agrees that air concentrations in 1948 were 
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

higher than in the 1949–1953 period; however, it should 

be noted that in estimating internal exposures during 

the operational period, the TBD assumes that internal 

exposure potential was the same in 1948 as it was in 

1953–1957, due to the absence of engineering controls 

(TBD Table 17). However, the TBD indicates that 1948 

data were in fact used, as it cites AEC 1948c,d (visits to 

Simonds in October and December of 1948, 

respectively) in association with the residual 

contamination estimate. Note: General and Editorial 

Issue #11 below.

SC&A also disagrees that the 1954 air sample data, 

which would more closely resemble conditions at the 

end of the operational period, are sufficiently in the 

range of the 1949–1953 general air sample data. 

SC&A’s compilation shows that the average for 1949–

1953 is a factor of 1.6 lower than the average value for 

1954. Additionally, the geometric mean value from 

1949–1953 is a factor of 2.5 lower than the geometric 

mean value from 1954.

SC&A agrees with NIOSH’s plan to look into an 

additional depletion factor for the 1983–2007 timeframe 

and investigate potential discrepancies between the two 

separate general air data compilations.

NIOSH Additional Response (4/23/13): NIOSH’s 

previous response above indicated additional review was 

being done on estimates of general area concentrations 

based on SC&A comments and that a review was being 

done on SC&A’s comment concerning the residual period 

depletion factor. Response to those two issues are provided 

below.

The 94 ug/m3 air concentration used in the TBD as the air 

concentration at the start of the residual contamination

period is based on an average of 50 General Area (GA) 

results of 4 specific areas at the site. The values used were 

taken from worker exposure studies from 1949 through 
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SC&A Finding #

(reference pages 

in TBD review)

Summary of SC&A Finding

(6/13/2012) Draft NIOSH Response (2/1/2013) Actions to be Taken

1953; many of these daily average values were also 

averages of multiple samples. Although the TBD discussion 

includes 1948 references for the GA air samples, the 1948 

results were compiled and included in a spreadsheet, but

were not used in the estimates because they were noticeably 

higher and not representative of GA air at the end of the 

operational period, as the data indicates. With the 

exception of one noticeably higher result in 1949, the GA 

results for 1949 through 1953 are similar. However, 

NIOSH agrees with SC&A that the 1954 data should be 

considered in the TBD. NIOSH will analyze the general 

area air sampling data to determine the appropriate value to 

use for the start of the residual peirod. The value selected 

should be representative of general area air concentrations 

at the end of the AWE operational period.

SC&A commented that NIOSH should consider a 

correction factor to allow for depletion from 1982 to 2007. 

The depletion factor will be reviewed as part of the review 

of the air concentration at the beginning of the residual 

period. NIOSH will also perform additional review of the 

data to address the basis of the depletion period in the TBD. 
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Other General Issues and Editorial Comments

1.) Pg. 10: SC&A could not verify the start date based on the reference provided (AEC 

1948a).

2.) Pg. 11: “The process generated a considerable amount of waste, as evidenced from a 

1952 Tonawanda Progress Report (AEC 1952): ‘Approximately fifty drums of [uranium 

contaminated] scrap and oxide were received from Simonds at the completion of the 

January rolling.’” SC&A could not find the provided reference based on the SRDB REF 

ID. SC&A found an equivalent document as REF ID 75071, but could not find mention 

of the ‘fifty drums’ therein.

3.) Pg. 11: "Information on material processing was compiled from all available Simondsrelated documents and places the total quantities of uranium and thorium processed at 

11,500 tons and 114,000 pounds respectively (NIOSH 2010b). These values exceed the 

amounts stated in various documented historical narratives by about a factor of three." 

It appears the factor of 3 only applies to the amount of thorium processed.

4.) Pg. 17: Paragraphs one and three are essentially identical.

5.) Pg. 20: “It was assumed that operations in 1953 continued at the same level as those in 

1952, although the available records indicate significant curtailment at the end of 1953.” 

Table 3 shows the number of rolling days in 1953 as 20% of the load in 1952—this 

assumption (per the text) should not be applied until January 1, 1954. The title for 

Table 3 should be clarified to number of uranium rolling days per year.

6.) Pg. 20: Table 4 only extends to January 1, 1957, and should be December 31, 1957.

7.) Pg. 22: “In addition, some postrolling samples might have been collected at the rolling 

day’s end (i.e., at the very end of rolling, not after rolling.” It is unclear what this 

sentence is meant to convey and should be clarified.

8.) Pg. 27: “Several assumptions included in the dose reconstruction are likely to be 

overestimating assumptions, which increase the estimate of the median intakes from air 

concentrations.” These assumptions should be described and some idea of the 

quantitative effect on the dose reconstruction discussed.

9.) Pg. 32: Table 16 displays assumed contaminant ratios for Np, Pu, and Tc; however, the 

intakes displayed in Table 17 only show intake rates for Np and Pu.

10.) Pg. 33: Row for Np-237 instructs to use absorption Type M “if U is S.” This is likely a 

typo and should be Type S “if U is S.”

11.) Pg. 39: “The average of general area air sample results reported during air monitoring 

studies conducted between 1949 and 1953 was used as an estimate of the air 

concentration at the start of the residual period (AEC 1948 c,d, 1949d,e,h, 1950; 
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Heatherton 1950 a,b, 1951b, 1953b; Klevin 1951; Klevin and Weinstein 1953 a,b).” 

Sentence should likely say it used the average of general area air samples reported form 

1948–1953.

12.) Pg. 39: The text shows the intake rate starting in 1982 as 5.5 pCi/d; however, Table 23

on the following page lists it as 5.4 pCi/d. It is not clear whether the 5.5 pCi/d is meant 

to include both the inhalation and ingestion rates or is a typo.

13.) Pg. 41: Column 3 of Table 24 appears to have the wrong footnote.