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				Bethlehem Steel						Print
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			Special Exposure CohortWorker Outreach ActivitiesAdvisory Board Work GroupTechnical DocumentsAdvisory Board and NIOSH DiscussionsProgram Evaluation Plans and Reports (PEPs and PERs)Public CommentsDocument Archive
		
(Site Profile/Docket Number 011)
Location: Lackawanna, New York
Special Exposure Cohort Petition Information
The Special Exposure Cohort (SEC) is a unique category of employees established by the Act (42 CFR Part 83). Claims compensated under the SEC do not have to go through the dose reconstruction process. To qualify for compensation under the SEC, a covered employee must meet specific requirements (e.g., must have at least one of 22 “specified cancers,” and have worked for a specified time period at one of the SEC sites). Classes of employees and work sites can be considered for addition to the SEC through a NIOSH petition process. More information about the Special Exposure Cohort can be found on our Frequently Asked Questions page.
Open/Active SEC Petitions
To date, there are no open/active SEC petitions from Bethlehem Steel.
Classes Added to the SEC
All Atomic Weapons Employer employees who worked at the Bethlehem Steel Corporation facility in Lackawanna, New York from January 1, 1949 to December 31, 1952, for a number of work days aggregating at least 250 work days, occurring either solely under this employment or in combination with work days within the parameters established for one or more other classes of employees in the Special Exposure Cohort.
**Note:** This class was established from Petition 56
Petitions Qualified for Evaluation
Below is a list of the petitions that qualified for evaluation. Select a petition on the list to view the table for that particular petition.
Petition 56 (Jan 1, 1949 to Dec 31, 1952)
	Petition 56
Steps in Petition Process:
Petition Details:Date Received
March 13, 2006Date Qualified for Evaluation
August 29, 2006Summary of Information in Petition
**Location:** 10 inch Bar Mill and Blooming Mill
**Job Titles and/or Job Duties:** Millwrights, welders, electricians, bricklayers, carpenters, all maintenance, testers, rollers, supervisors, crane operators, hookers, clean-up crews, grinders
**Period of Employment:** 1949 through 1952
**Note:** The information above is what qualified for evaluation. During our evaluation of whether dose reconstructions can adequately be completed for the above job titles and period of employment, information may cause NIOSH to change some the dates or job titles/duties. Therefore, as this petition proceeds through the SEC petition process and if an SEC class is proposed, the proposed class may not exactly match the above information.Copy of the Petition Received
March 13, 2006 [4.1 MB (10 pages)] (January 1, 1949 to December 31, 1952)
Petition Attachments:
13′′ Bar Mill: Lackawanna Plant (brochure) [2.1 MB (5 pages)]
Photo of cooling bed [493 KB (1 page)]
Sketch of cooling tables [717 KB (1 page)]Federal Register Notice Announcing that the Bethlehem Steel Corporation SEC Petition has met the Minimum Qualifications for Review and Evaluation
September 7, 2006 [79 KB (1 page)](January 1, 1949 to December 31, 1952)SEC Petition Evaluation Report
February 21, 2007 [202 KB (53 pages)](January 1, 1949 to December 31, 1952)Evaluation Report Sent to the Advisory Board
February 22, 2007(January 1, 1949 to December 31, 1952)Petition Discussed by the Advisory Board
The petition was discussed by the Advisory Board on May 20, 2010; May 3, 2007; July 18, 2007; January 9, 2008; and April 9, 2008, during its regular meetings.
**Note:** Agendas and transcripts for Board meetings will be posted on the Advisory Board and Public Meetings page as soon as they become available.Advisory Board Recommendation on SEC Petition
June 11, 2010 [34 KB (2 pages)](January 1, 1949 to December 31, 1952)HHS Letters to Congress Regarding the SEC Petition
June 14, 2010 [108 KB (11 pages)](January 1, 1949 to December 31, 1952)HHS Designation/Determination of Additional Members to the SEC
**Designation:**
July 14, 2010 [48 KB (6 pages)](January 1, 1949 to December 31, 1952)
**Note:** A “designation” means that HHS is recommending a class be added to the SEC. A “determination” means that HHS is recommending a class **not** be added to the SEC.Federal Register Notice: Designation/Determination of a Class of Employees for Addition to the Special Exposure Cohort
**Designation:**
July 30, 2010 [69 KB (1 page)](January 1, 1949 to December 31, 1952)
**Note:** A “designation” will be published if there is a recommendation to add a class to the SEC. A “determination” will be published if there is a recommendation **not** to add a class to the SEC.Effective Date for the SEC Class
August 13, 2010(January 1, 1949 to December 31, 1952)
**Note:** This only applies if the class is added to the SEC.Federal Register Notice: Final Effect of Designation of a Class of Employees for Addition to the Special Exposure Cohort
August 23, 2010 [67 KB (1 page)](January 1, 1949 to December 31, 1952)
**Note:** This only applies if the class is added to the SEC.Letter to DOL Regarding the Addition of a New Class of Employees to the SEC
August 24, 2010 [29 KB (1 page)](January 1, 1949 to December 31, 1952)
**Note:** This only applies if the class is added to the SEC.
SEC Petitions Not Qualifying for Evaluation
Two separate petitions were received but did not qualify for evaluation because one petition did not meet the minimum petition requirements and the other petition was withdrawn by the applicant.Worker Outreach Activities
Based on a recommendation from the Advisory Board to provide workers and site experts with opportunities to participate in developing the technical documents used in dose reconstruction, NIOSH established a Worker Outreach Program.
At Worker Outreach Meetings, current and former DOE and AWE employees have opportunities to obtain information about Site Profiles, Technical Basis Documents, and Technical Information Bulletins, and to provide information for consideration and possible use in dose reconstruction. This process is valuable to ensure that the technical documents used in dose reconstruction contain correct and useful information.
Worker Outreach Activities for the Bethlehem Steel:
**August 13, 2012** Town Hall Meeting
In response to a Congressional inquiry concerning the possibility of residual radioactive contamination at the Bethlehem Steel site, NIOSH conducted a reanalysis of its original determination. This reanalysis included a review of the comments received from participants at a town hall meeting in Hamburg, NY. The report of NIOSH’s reanalysis was included in a response to the Congressional Representative’s office.
NIOSH/DCAS: Review of the Potential for Residual Contamination at Bethlehem Steel Corporation [385 KB (18 pages)]
**June 21, 2006** Meeting with Bethlehem Steel Claimants Action Group–Discussion of Various IssuesFinal Minutes [24 KB (6 pages)]
**July 1, 2004** Meeting with Bethlehem Steel Claimants Action Group–Retired Plan Workers Advocacy GroupFinal Minutes [81 KB (17 pages)]
**May 4, 2004** Public meeting Presentation: Reconstruction of Doses at the Bethlehem Steel [186 KB (16 pages)]Advisory Board Work Group on Bethlehem Steel
This Work Group is responsible for a review of the Bethlehem Steel Site Profile and a review of the Site Profile by the Board’s contractor (SC&A). The Work Group shall consider issues identified by SC&A concerning the Site Profile and shall assist NIOSH and SC&A in the resolution of such issues. The Work Group may recommend to the Board changes in the Site Profile as appropriate.
Work Group Members:
James Malcolm Melius, M.D., Dr. P.H. (Chair)
Josie Beach
James E. Lockey, M.D., M.S.
Wanda I. MunnMeeting Information
**May 13, 2010** Teleconference Meeting of the Advisory Board’s Work Group on the Use of Surrogate Data
Time/Location:
1:00 p.m. Eastern Standard Time (EST) Meeting Type: Teleconference; Public, No Comment Period
Teleconference: 
                    +1-866-659-0537
                    Participant Code: 9933701
Pre-Decisional Document Policy
Available Meeting Items:
Agenda [45 KB (1 page)]
Transcript [126 KB (69 pages)]
**November 16, 2007** Teleconference Meeting of the Advisory Board’s Work Group on the Use of Surrogate Data
Time/Location:
2:00 p.m. Eastern Standard Time (EST) Meeting Type: Teleconference; Public, No Comment Period
Teleconference:
                    +1-866-659-0537
                    Participant Code: 9933701
Pre-Decisional Document Policy
Available Meeting Items:
An agenda will be provided at a later date.
Transcript [253 KB (69 pages)]Pre-Decisional Document Policy
Please note that as part of the procedures and processes of the Advisory Board’s Work Groups, several kinds of pre-decisional documents may be developed. These pre-decisional documents, such as white papers, matrices, working drafts, etc., are distributed among Work Group members as research and background tools to facilitate discussion and deliberation. Although discussion during a public meeting may cover pre-decisional documents, these documents often are not further revised or finalized, and thus do not reflect the final determination or evaluation of the Advisory Board and its Work Groups. Additionally, some pre-decisional documents not otherwise posted on the website may contain sensitive information, which would require an interested party to obtain such documents by filing a Freedom of Information Act (FOIA) request with the CDC/ATSDR FOIA office at foiarequests@cdc.gov.
Technical Documents
If the energy employee’s personal radiation information is incomplete, NIOSH will use other sources to estimate the radiation dose. This may involve using technical documents called Site Profiles, Technical Basis Documents, and Technical Information Bulletins.
Technical Basis Documents
Basis for Development of an Exposure Matrix for Bethlehem Steel [364 KB (34 pages)] Revised November 30, 2010
**Revision Includes:** Incorporates SEC designation information; additional changes include deletion of unnecessary information throughout document affected by SEC; added information regarding recycled uranium at BSC and additional rolling data to Table 1; corrected minor typographical errors; included NIOSH internal comments.Advisory Board and NIOSH Discussions on Bethlehem Steel
The Bethlehem Steel Corporation discussion papers listed below are working documents prepared by NIOSH or its contractor for use in discussions with the Advisory Board on Radiation and Worker Health or its Working Groups or Subcommittees. Draft, preliminary, interim, and white paper documents are not final NIOSH or Advisory Board (or their technical support and review contractors) positions unless specifically marked as such. These documents represent preliminary positions taken on technical issues prepared by NIOSH or its contractor.
The discussion papers have been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and have been cleared for distribution.
NIOSH/DCAS: Comments on the SC&A Review of the Bethlehem Steel Site Profile – Specific Responses to Findings, Observations, and Procedural Non-conformances [65 KB (14 pages)] January 25, 2005
SC&A: Review of NIOSH Site Profile for Bethlehem Steel Plant, Lackawanna, NY [512 KB (87 pages)] Contract No. 200-2004-03805 Task Order No. 1 SCA-TR-TASK1-0001 October 2004
NIOSH/DCAS: NIOSH Worker Outreach Meeting with Bethlehem Steel Claimants Action Group–Retired Plan Workers Advocacy Group [81 KB (17 pages)] July 1, 2004Program Evaluation Reports (PERs) and Program Evaluation Plans (PEPs)
NIOSH is committed to applying the best available science in dose reconstructions. In keeping with this commitment, completed cases with probabilities of causation less than 50% are reviewed as relevant new information becomes available. The results of these reviews are described in a Program Evaluation Report (PER). The PER details the effect, if any, of the new information on the completed dose reconstruction. If it appears that the new information may result in an increase in dose for a completed dose reconstruction with a probability of causation of less than 50%, NIOSH is committed to working with the Department of Labor to reopen and rework the dose reconstruction, as appropriate. A Program Evaluation Plan (PEP) describes plans for evaluating specific program details or issues.
OCAS-PER-0003 Rev-00: Evaluation of the Effect of Adding Ingestion Intakes to Bethlehem Steel Cases [31 KB (3 pages)] January 28, 2005
**About this Document:** Describes the evaluation of the programmatic effect of the effect of adding ingestion intakes to Bethlehem Steel cases.
**Summary:** As a result of adding ingestion intakes, the probability of causation of none of the previously completed Bethlehem Steel claims would increase to greater than 50%.
OCAS-PER-0007 Rev-00: Evaluation of the Effect of Revision 2 of the Site Profile on Previously Completed Bethlehem Steel Cases [42 KB (7 pages)] November 9, 2006
**About this Document:** New document to evaluate the effect of revision 2 of the Site Profile on previously completed dose reconstructions from Bethlehem Steel.
**Summary:** The Bethlehem Steel Technical Basis Document was revised on July 27, 2006. The revision changed the estimated quantity of uranium inhaled and ingested as well as external dose to the skin. As a result of revisions to the Bethlehem Steel Technical Basis Document, three claims that were previously determined to have a PC of less than 50% will now have a PC greater than 50%. Eight cases that previously had a PC greater than 50% now have a PC less than 50%. This report, along with detailed information on the specific cases and calculations, has been provided to DOL for determination of further action.Public Comments on Bethlehem Steel Documents
How to Submit Comments
Comments on Bethlehem Steel Documents can be submitted to the NIOSH Docket Officer electronically by email at nioshdocket@cdc.gov or printed comments can be mailed to:
NIOSH Docket Office Robert A. Taft Laboratories, MS-C34 1090 Tusculum Avenue Cincinnati, OH 45226 Please include the Site Profile/Docket Number (011) on all comments.
Comments Received:
Letter to the Advisory Board from Congressman Brian Higgins on behalf of Bethlehem Steel workers [80 KB (1 page)] May 19, 2010
Advisory Board response to May 19, 2010, letter from Congressman Brian Higgins [27 KB (1 page)] June 2, 2010
Comments from DOL regarding the Bethlehem Steel SEC Petition Evaluation Report [105 KB (1 page)] February 21, 2007
Letter to Ed Walker [32 KB (2 pages)] September 11, 2006
Note: The enclosures to the letter are available upon request.
Letter from Ed Walker [67 KB (8 pages)] June 2006
NIOSH response to Ed Walker’s June 2006 letter [1.3 MB (17 pages)] August 22, 2006
Letter from Ed Walker [142 KB (5 pages)] January 10, 2006
NIOSH response to Mr. Ed Walker’s letter [149 KB (4 pages)] February 3, 2006
Comments from Ed Walker: New Acquired Information Pertaining to the Bethlehem Steel Site Profile [948 KB (13 pages)] June 25, 2005
NIOSH response to Ed Walker’s comments [252 KB (3 pages)] August 16, 2005
Comments from M. Resnikoff on behalf of Radioactive Waste Management Associates: NIOSH Dose Reconstruction — Manhattan Project. [65 KB (1 page)]Document Archive for Bethlehem Steel
Basis for Development of an Exposure Matrix for Bethlehem Steel Corporation
Site Profile for the Bethlehem Steel [618 KB (41 pages)]
**Revision Includes:** Approved issue of Revision 0 of OCAS-TKBS-003. This supersedes rev. 1 of the previous ORAUT-TBKS-0001.
An Exposure Matrix indicates the type and quantity of radiation exposure to individuals for a specific location and specific time. Locations can be as broad as an entire facility or as narrow as a single small room. Time can be years, months, or even a single event. When personnel monitoring data are incomplete or do not exist, an exposure matrix is developed to estimate the dose. The matrix is typically developed using a combination of personnel monitoring data in conjunction with area monitoring data. Once the exposure is estimated, data about how long the worker was exposed (time) is used to estimate their total exposure.
There was no identified documentation that contained personal monitoring data for employees of the Bethlehem Steel site. Therefore, an exposure matrix that relied on air sampling data was developed to estimate radiation dose to many individuals. The matrix that was developed can be used to estimate the dose for a large number of the employees at the Bethlehem Steel site.
In many cases, the development of a facility specific matrix is more difficult but due to the limited operations that took place in this AWE, this matrix was able to be developed more quickly. The following documented facts were used in the development of this matrix:
Uranium processing occurred on one rolling mill.
The amount of time involving work with uranium was no more than 500 hours total over a four year period.Because of these two facts, the workplace exposure conditions could be estimated from the available data. Once the workplace exposures were estimated, Bethlehem Steel employees are then assumed to be exposed to these “worst-case scenario” conditions as a claimant favorable approach.
Revised June 29, 2004 [150 KB (13 pages)]
**Revision Includes:** Revision to incorporate occupational X-ray doses from the OTIB-0006, estimates of ingestion intakes, and additional OCAS comments.
Approved March 31, 2003 [149 KB (14 pages)]
							
					
							Last Reviewed:  June 30, 2022						Source: 	National Institute for Occupational Safety and Health
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