Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF NIOSH PETITION EVALUATION REPORT FOR 

PETITION SEC-00136 DATED JULY 21, 2009, 

ELECTRO-METALLURGICAL CORPORATION 

Contract No. 200-2009-28555 

SCA-TR-SEC2010-0010, Revision 1

Prepared by 

William C. Thurber 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

May 2011 

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 pre-decisional 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.
Effective Date: 

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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 

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Document No. 

SCA-TR-SEC2010-0010 

Effective Date: 

Draft – May 11, 2010 

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

1 – Draft 

Review of NIOSH Petition Evaluation Report for 

Petition SEC-00136 Dated July 21, 2009, ElectroMetallurgical Corporation 

Page 2 of 67 

Task Manager: 

________________________ Date: ___________ 

William C. Thurber 

Supersedes: 

Rev. 0 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 

Reviewers: 

 Arjun Makhijani 

 John Mauro 

Record of Revisions 

Revision No. Effective Date Description of Revision 

0 04/12/2010 Initial Draft 

1 05/19/2011 Replace original Appendix E (review of a single interview) 

with a new Appendix E (summary of interviews with 

numerous individuals). Minor edits to the text regarding the 

content of Appendix E. 
Effective Date: 

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TABLE OF CONTENTS 

List of Acronyms .............................................................................................................................5 

Executive Summary.........................................................................................................................6 

1.0 Introduction..........................................................................................................................9 

2.0 Review of Petition SEC-00136..........................................................................................10 

3.0 Review of NIOSH Petition Evaluation Report for SEC-00136.........................................12 

3.1 Description of Electro-Met Activities Related to Atomic Weapons 

Production..............................................................................................................12 

3.2 Electro-Metallurgical Plant and Process Descriptions (5.1)..................................17 

3.3 Internal Radiological Exposure Sources from Electro-Met Operations 

(5.2.1).....................................................................................................................17 

3.4 Available Electro-Metallurgical Internal Monitoring Data (6.1)...........................17 

3.5 Urinalysis Data (7.1.1.1)........................................................................................27 

3.6 Methods for Bounding Operational Internal Dose at Electro-Metallurgical 

(7.2.3).....................................................................................................................30 

3.7 Methods for Bounding Operational Period External Dose (7.3.4.1) .....................31 

3.7.1 Photon Dose...............................................................................................31 

3.7.2 Medical X-rays...........................................................................................32 

3.7.3 Beta Dose...................................................................................................33 

3.7.4 Doses from High Surface Concentrations of U-238 Progeny....................34 

3.8 A Critical Question ................................................................................................35 

4.0 References..........................................................................................................................40 

Appendix A: Example Daily Weighted Average Concentrations of Uranium in Air 

Samples..............................................................................................................................44 

Appendix B: Comments of Data Reduction in TBD-6001...........................................................46 

Appendix C: Area Plant Plot Plan ................................................................................................49 

Appendix D: Air Sampling Results..............................................................................................50 

Appendix E: Master Interview Summary .....................................................................................52 
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NOTICE:

LIST OF TABLES 

Table 1. Availability of Monitoring Data at Electro-Met.........................................................16 

Table 2. Summary of Air Sampling Results at Electro-Met.....................................................18 

Table 3. Comparison of Number of Available Air Samples.....................................................19 

Table 4. Daily Weighted Average Air Samples (Alpha) Based on 

Breathing Zone Samples and General Air Samples in Areas 

Frequented by Workers in Each Job Description .......................................................20 

a

Table 5. Summary of Air Concentration Measurements from August 1949 Survey at 

Electro-Met (Dust Samples 1949) ..............................................................................21 

Table 6. Three Methods for Estimating Lognormal Distribution Parameters..........................24 

Table 7. Comparison of Numerical Results for Operators Using 

Three Methods of Estimation (N=13).........................................................................24 

Table 8. Inhalation Exposures for Job Descriptions in Table 8.29 of TBD-6001 that are 

Comparable to Operator Jobs at Electro-Met .............................................................25 

Table 9. Post-Decontamination Air Sampling Measurements Made on August 14, 1953, 

at Area Plant ...............................................................................................................26 

Table 10. Comparison of Lognormal Distributions for 1944 and 1949 .....................................28 

Table 11. Comparison of Measured and Calculated Uranium Excretion Rates 

from Urinalysis...........................................................................................................30 

Table 12. Comparison of Annual Photon Exposures..................................................................31 

Table 13. Comparison of Annual Beta Exposures......................................................................33 

Table 14. Comparison of Lognormal Parameters for Air Samples Taken Before and After 

Use of Portable Vacuum Cleaner ...............................................................................36 

LIST OF FIGURES 

Figure 1. Normal Score Plot of Operator Data ..........................................................................24 

Figure 2. Normal Score Plots for 1944 and 1949 with Regression Lines..................................28 

Figure 3. Best Estimate and Approximate 95% Confidence Region for the Intercept (μ) 

and Slope (σ) of the Regression Lines for 1944 and 1949 .........................................29 

Figure 4. Examples of the Elliptical Shape of Confidence Intervals for the Intercept and 

Slope of Regression Lines..........................................................................................29 

Figure 5. Comparison of 95% Confidence Regions for General Air Sample 

taken on April 5, 1944, and July 26, 1944..................................................................37 
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LIST OF ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

dpm disintegrations per minute 

DOE U.S. Department of Energy 

DWA daily weighted average 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

GA general air 

GM geometric mean 

GSD geometric standard deviation 

IMBA Integrated Modules for Bioassay Analysis 

MAC maximum air concentration 

MED Manhattan Engineer District 

Mg magnesium 

MLE maximum likelihood estimate 

mr milli-roentgen 

mrad millirad 

NIOSH National Institute for Occupational Health and Safety 

NYOO New York Operations Office 

OCAS NIOSH Office of Compensation and Support 

ORAUT Oak Ridge Associated Universities Team 

pCi picocurie 

pdf portable document format 

PFG photofluorography 

R&D Research and Development 

SC&A S. Cohen and Associates (SC&A, Inc.) 

SEC Special Exposure Cohort 

SRDB Site Research Database 

TBD technical basis document 
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EXECUTIVE SUMMARY 

The Advisory Board on Radiation and Worker Health (ABRWH) requested that SC&A review 

the Special Exposure Cohort (SEC) Petition Evaluation Report, Petition SEC-00136, for the 

Electro-Metallurgical Corporation (Electro-Met) prepared by the National Institute for 

Occupational Safety and Health (NIOSH) (NIOSH 2009). This report presents SC&A’s review 

of the SEC-00136 Petition Evaluation Report and related documents. Beginning in 1943, the 

Electro-Met received uranium tetrafluoride (UF4), or green salt, from the Linde Division of 

Union Carbide in Tonawanda, New York, and processed this salt into uranium metal. The 

uranium metal was recast into ingots suitable for fabrication and shipped to a variety of locations 

for further processing. 

A petition was filed on behalf of a former employee at Electro-Met requesting that Electro-Met 

employees who worked on atomic weapons during the period from April 1943 through June 

1953 be added to the SEC. NIOSH reviewed the petition and concluded that it had sufficient 

information to estimate bounding radiation doses, or to estimate doses more precisely than the 

maximum dose, and therefore the Electro-Met employees should not be added to the SEC. 

To some extent, the current review is also a review of certain aspects of Battelle-TBD-6001 and 

its Appendix C, since these documents provide the basis for NIOSH’s assumed ability to 

calculate bounding doses. In the course of its review, SC&A made a number of findings that are 

summarized below. 

Finding 1: NIOSH should discuss the issue of access controls explicitly in the Evaluation Report 

to justify the basis for including all workers at Electro-Met, rather than just those who worked in 

the Area Plant. 

Finding 2: Research and Development (R&D) work with uranium ores was not mentioned in 

NIOSH 2009. While the information reviewed here does not indicate that significant quantities 

of uranium-bearing materials other than green salt were used by Electro-Met, NIOSH should 

address the scope of work that might actually have been done at Electro-Met (and in which 

facilities). 

Finding 3: NIOSH should review the start and end dates for the operational period to insure 

that all relevant documentation has been evaluated. 

Finding 4: The NIOSH assumption that the uranium metal reduction process and associated 

industrial production and industrial hygiene conditions were unchanged from 1943 to 1949 may 

not be correct. The changes that appear to have been made in 1947 would need to be 

investigated before this assumption can be used to implicitly back-extrapolate post-October 1947 

data to the 1943–1946 period. (See also Finding 17.) 

Finding 5: NIOSH should clarify the text to remove what appears to be an inconsistency 

regarding the availability of internal exposure data during standby periods. 
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Finding 6: NIOSH should take into account the difference between fixed head samplers, process 

samplers, and general area samplers and actual intake, and the uncertainties this creates for 

estimating bounding intakes. 

Finding 7: NIOSH needs to establish that job titles corresponded to the jobs actually done for 

the period of employment. NIOSH’s job title consolidation scheme would not produce bounding 

estimates for all workers in the proposed class in the absence of such an analysis. 

Finding 8: We note that the graphical method used by NIOSH in Appendix C of TBD-6001 

(Battelle 2007) to calculate the inhalation intakes for operators results in the lowest estimate of 

the 95th percentile among possible alternative calculational approaches. Arguably, in this case, 

the graphical method is not claimant favorable. 

Finding 9: The site-specific values for inhalation intakes for Electro-Met from Appendix C are 

significantly more claimant favorable than the generic intakes proposed in Table 8.29 of TBD6001 (Battelle 2006), which raises questions as to whether TBD-6001 is appropriately 

conservative for its intended purpose. This is noted for the record, but it is not an Electro-Met 

finding. 

Finding 10: Given the high frequency of blowouts at other facilities using the same equipment, 

NIOSH should re-examine the possibility that blowouts occurred at Electro-Met. 

Finding 11: NIOSH should address residual exposures in the SEC-00136 Petition Evaluation 

Report. 

Finding 12: NIOSH should provide more detailed information to support their position stated in 

Section 7.2.3 of NIOSH 2009 that, “Considering the intake scenarios established in BattelleTBD-6001 Appendix C, the calculated urinary excretion of uranium from these intakes was 

compared to actual data and was found to be bounding in each case.” Independent calculations 

by SC&A do not support this conclusion as to the bounding nature of the intakes in Appendix C, 

Table C.2. 

Finding 13: The approach taken to bound external photon exposure values in Table C.4 of TBD6001, Appendix C, appears to be reasonable for the operating period beginning June 1948. 

However, NIOSH must demonstrate that this approach is bounding for the earlier operating 

period, when essentially no film badge data are available. In addition, NIOSH should explicitly 

define in Appendix C how to proceed with dose reconstruction when the job description is 

uncertain or unknown. 

Finding 14: NIOSH should state in the Petition Evaluation Report for SEC-00136 and in 

Appendix C of TBD-6001, that estimates of occupational medical exposure should be based on 

photofluorography, unless there is evidence that this technique was not used at AWE sites and 

only at DOE sites. 

Finding 15: SC&A independently developed a database for annual beta and found that the 95th

percentile value was in excellent agreement with that developed by NIOSH for Table C.5. 
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NOTICE:

However, 50th and 5th percentiles were somewhat higher, based on the SC&A analysis. 

Consequently, it is possible that the dose to Supervisor/Laborers could be understated by about 

40% and the dose to Others by about 80%. 

Finding 16: Use of 95th percentile exposures, as proposed in Tables C.4 and C.5 of TBD-6001, 

Appendix C, adequately accounts for enhanced exposures from high surface concentrations of 

Th-234 and Pa-234m produced during melting and casting of uranium ingots, except for 

exposures to the hands and arms. Table C.5 is specific to “Other Skin.” Guidance should be 

added to Appendix C to specifically address exposure to the hands and arms. 

Finding 17: NIOSH needs to provide convincing arguments that 95th percentile values based on 

1948/1949 data are bounding for the period prior to December 1947. 

Revision 0 of this report (April 12, 2010) included one worker interview in Appendix E. Since 

Revision 0 was issued, we have conducted additional interviews and have, accordingly, revised 

Appendix E to summarize all of the worker interviews. 
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1.0 INTRODUCTION 

At the October 20–22, 2009, meeting of the Advisory Board on Radiation and Worker Health 

(ABRWH) in Port Jefferson, New York, the ABRWH requested that SC&A review the SEC 

Petition Evaluation Report, Petition SEC-00136, Electro-Metallurgical Corporation,1 prepared 

by the National Institute for Occupational Safety and Health (NIOSH) (NIOSH 2009). This 

report presents SC&A’s review of the SEC-00136 Petition Evaluation Report and related 

documents. 

At various times during the period from April 1, 1943, through June 30, 1953, the ElectroMetallurgical Corporation (Electro-Met) received uranium tetrafluoride (UF4), or green salt, 

from the Linde Division of Union Carbide in Tonawanda, New York, and processed this salt into 

uranium metal. The uranium metal was recast into ingots suitable for fabrication and shipped to 

a variety of locations for further processing. A petition was filed in December 2008 by the 

survivor of one of the employees at Electro-Met requesting that a group of Electro-Met 

employees be added to the Special Exposure Cohort (SEC). NIOSH reviewed the petition and 

determined that (NIOSH 2009, p. 3): 

Per Energy Employees Occupational Illness Compensation Act of 2000 

(EEOICPA) and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has 

access to sufficient information to (1) estimate the maximum radiation dose, for 

every type of cancer for which radiation doses are reconstructed, that could have 

been incurred in plausible circumstances by any member of the class; or 

(2) estimate radiation doses of members of the class more precisely than an 

estimate of maximum dose. Information available from the site profile and 

additional resources is sufficient to document or estimate the maximum internal 

and external potential exposure to members of the evaluated class under plausible 

circumstances during the specified period. 

In the particular case of Electro-Met, NIOSH has chosen the approach of estimating the 

maximum, or bounding, dose. 

In the following sections, SC&A presents its independent review of the SEC petition, the NIOSH 

Petition Evaluation Report, and related dose reconstructions.

1

 At the beginning of the Manhattan Engineer District work in 1943, the Electro-Metallurgical Company, 

the National Carbon Company, and the Linde Air Products Company were all units of Union Carbide and Chemical 

Corporation. Successor organizations included the Metals Division, the Carbon Products Division, and the Linde 

Division of Union Carbide Corporation. 
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2.0 REVIEW OF PETITION SEC-00136 

A petition to add “All workers who worked in any area at the Electro-Metallurgical Corporation 

facility, for the period from August 13, 1942 through December 31, 1953” was received by 

NIOSH on December 2, 2008, and qualified on March 12, 2009. The basis for the petition, as 

stated on Form B, Section F.1, of the SEC Petition was that only limited data on the range of air 

concentrations were available for dose reconstruction. Because uranium processing did not 

begin until April 1943 and the contract with the AEC ended in June 1953, NIOSH modified the 

proposed class definition to include “All workers who worked in any area at the ElectroMetallurgical Corporation for the period from April 1, 1943 through June 30, 1953.” 

A second petition (SEC-00132) was received on November 14, 2008. This petition was merged 

with SEC-00136. According to Form B, Section E, the proposed class definition in Petition 

SEC-00132 was all workers who worked in the entire building (50 × 217) from September 29, 

1952, through August 31, 1959. The petitioner indicated in a letter dated January 7, 2009 (CCR 

2009), that it was acceptable to change the covered period to 1942–1953 and reaffirmed that the 

petition was “on behalf of all employees who worked in the Electro-Metallurgical facility (one 

50 × 219 building).” This is significantly different from the NIOSH proposed class of “all 

workers who worked in any area at the Electro-Metallurgical Corporation.” One definition 

includes the entire industrial plant whose main function was to produce commercial 

metallurgical products for steel-making and other heavy industries, while the other definition 

includes only the facility specifically constructed for Manhattan Engineer District (MED)/ 

Atomic Energy Commission (AEC) work. Given the differences in the size of one building 

versus the entire plant, the ambiguity in the area covered by the petitions needs to be clarified, 

perhaps through additional interviews and data capture efforts. 

The SEC-00132 petition includes a February 27, 2008, letter from Union Carbide discussing the 

energy employee’s employment history with that company. It is stated in the letter that, “It 

appears that he spent his entire career with the Carbon Products division.” The Carbon Products 

Division of Union Carbide (see footnote 1) operated several plants at Niagara Falls. Thus, it is 

possible that the presumed energy employee worked for Carbon Products, rather than ElectroMet. Again, whether the Atomic Weapons Employer (AWE) operations of concern to this 

petition include a limited number of buildings or the entire Electro-Met plant is critical, not only 

to the definition of the class, but also to the reconstruction of doses to AWE workers. 

We note in Section 5.1 of the Petition Evaluation Report (NIOSH 2009) that MED and the 

successor AEC contracted with Electro-Met to build a special facility for the weapons work—the 

Area Plant. The Area Plant was fenced in and housed all the operations required under the 

government contract. The plot plan in Appendix C provides the reader with some idea as to the 

physical separation of the Area Plant from other facilities on the Electro-Met site. However, an 

interviewee (see Appendix E) states that initial work was performed at the Research Building, 

which apparently is separate from the Area Plant. More than one building in the plot plan 

(Appendix C) has the term “Research” in it. It is not clear to SC&A whether the work was in 

one of these two buildings, or whether another building was meant by the interviewee. Some 

discussion of this area is needed in order to ensure a full understanding of the AWE activities 
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NOTICE:

that took place at Electro-Met. SC&A is doing some follow-up in this regard, and will provide 

any new information in a supplemental report. 

The Petition Evaluation Report does not establish whether workers may have been assigned to 

both the Area Plant and the other Electro-Met facilities at different time periods. However, 

information in Blatz 1949 (pdf p. 32) indicates that about 30 workers provided intermittent 

services to the Area Plant. Intermittent services ranged from electricians, who worked about 

2 days per month, to pipe fitters, who worked 2 or 3 days per year. The Area Plant Plot Plan 

(Appendix D) indicates that the uranium facility was gated; [redacted] guards were part of the 

Area Plant work force. In response to written questions, one former worker indicated that there 

was a chain link fence around the Area Plant with a guarded gate. Workers were required to 

show a badge to obtain entry. Details are provided in Appendix E. In addition, TBD 6001 

Appendix C states that, “[a]vailable information indicates that all uranium operations (including 

the business office lunchroom and shipping areas) were conducted within a single building” 

(Battelle 2007, Appendix C, p. 1). 

The issue of access control to the Area Building and the scope of employees covered should be 

further explored through additional employee interviews with those who were actually involved 

with MED/AEC work. If there were other buildings, such as the Research Building, where 

substantial AWE activities were carried out during one or more periods, access control 

evaluations would also be relevant for these buildings. An exploration of the issue, which is not 

discussed in the Evaluation Report, is warranted, since NIOSH has included all workers at the 

entire Electro-Met in the facility, even though it appears that only a small fraction of the total 

workforce did AEC-related work. Most of the AEC work was done in the Area Plant, where 

there is evidence of access controls.

Finding 1: NIOSH should discuss the issue of access controls explicitly in the Evaluation Report 

to justify the basis for including all workers at Electro-Met, rather than just those who worked in 

the Area Plant. 
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3.0 REVIEW OF NIOSH PETITION EVALUATION REPORT 

FOR SEC-00136 

3.1 DESCRIPTION OF ELECTRO-MET ACTIVITIES RELATED TO ATOMIC 

WEAPONS PRODUCTION 

All uranium production operations were carried out in the Area Plant, which was specifically 

built by Electro-Met for the required work under Contract W-7405-Eng-14. The Area Plant was 

situated in a fenced-in area on land owned by Electro-Met (ElectroMet 1946a, pdf p. 5). The 

location of the Area Plant in relation to other nearby Electro-Met facilities is shown in 

Appendix C. 

Operations at the Area Plant involved the reduction of UF4 (green salt) to uranium metal, and 

recasting the metal into ingots suitable for further fabrication by rolling or extrusion. Green salt 

was shipped to Electro-Met from Linde. The green salt mixed with magnesium was packed into 

a metal bomb lined with a refractory material (e.g., dolomite). The bomb was placed in a 

furnace and heated to a temperature sufficient to initiate an exothermic reduction reaction. When 

the reaction was complete, the bomb was opened and the uranium metal was separated from the 

MgF2 slag. The resultant uranium biscuits weighed between 110 and 135 kg. The biscuits were 

cleaned by chipping away any adhering slag, and then remelted and recast in a vacuum induction 

furnace. The recast ingots were shipped offsite for further fabrication. Electro-Met also received 

uranium scrap from other contractors and remelted this scrap into ingots. Electro-Met shipped 

process residues, including dolomite slag, crucible dross, and uranium chips, offsite for storage, 

disposal, or uranium recovery (DOE 1986). 

The design capacity of the plant was 50 tons of uranium metal per month as billets;2

 actual 

production was lower, averaging 44 tons/month from April 1943 through August 1946, when the 

plant was placed on standby. The plant began restart operations during the last week of 

November 1947 (AEC 1947, pdf p. 30). Table 5-1 of NIOSH 2009 indicates that restart 

occurred in October 1947, and production for Fiscal Year (FY) 1948 was about 26 tons/month. 

The average production rate in FY 1949 was about 35 tons/month (NYOO 1951, pdf p. 38). 

According to the New York Operations Office of the AEC (NYOO 1951), the plant was shut 

down in October 1949, and the report makes no mention of further activities prior to issuance of 

the NYOO report on May 22, 1951. The plant was given a “thorough vacuum cleaning and 

washing of the entire area” after shutdown (NYOO 1951, pdf p. 52). The staff included 70 

employees (NYOO 1951, pdf p. 52). 

The MED contract also provided for research and development (R&D) work. Apparently, some 

work was done under this contract provision from April through October 1945. “The exact 

nature of the work is not known, but it may have involved low- or high-grade uranium ores” 

(DOE Undated). A March 17, 1945, letter from the War Department to Electro-Met discusses 

R&D work specifically on uranium extraction from low-grade ores (Kelley 1945). Another 

indication of R&D activities is a letter from the War Department (Corps of Engineers) to 

2

 According to SRDB 59225, the capacity was 30 tons/month, and according to SRDB 9036, the production 

rate was 45 tons/month. 
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Electro-Met, dated October 7, 1943 (War Department 1943), describing problems with reactivity 

of Product 65 (UO2) supplied by the Laboratories to Harshaw Chemical Company compared to 

Product 65 from other suppliers. The letter requested that the Laboratory prepare a 6,000-lb 

sample of Product TC (UO3) and send half to Mallinckrodt for reduction to Product 65. The 

other half was to be reduced at the Laboratories. The basic processes at Harshaw involved the 

conversion of UO2 to UF4 (Product O-71) and conversion of UF4 to UF6 by reaction with F2. 

According to AEC 1949, Mallinckrodt supplied Harshaw with its UO2 feedstock. Thus, it is not 

known to what extent the Electro-Met laboratories supplied UO2 to Harshaw. It is possible that 

only experimental quantities were involved. A search for information related to Harshaw on the 

NIOSH secure web site did not reveal any use of feedstocks from Electro-Met. It should also be 

noted that the Corps of Engineers request was directed to the Electro-Met laboratories on Royal 

Avenue. As shown on the site plan in Appendix C, the Area Plant was a separate facility from 

the research laboratories building. 

We have uncovered no evidence that the Area Plant contained the requisite equipment to convert 

ore into UO2; the Area Plant received green salt from Linde and processed it into uranium 

billets. Processing of ore to UO2 requires digester tanks, filter presses, driers, precipitation 

tanks, and hydrogen reduction furnaces. The absence of ore processing equipment is supported 

by the equipment list in the Completion Report for the Construction of Electro Metallurgical 

Company Area Plant (Electro-Met 1946a), which includes vacuum induction furnaces and bomb 

heating furnaces, but none of the items needed for ore processing. 

Indication of other R&D activities is a letter from the Corps of Engineers to the Linde Air 

Products Company, dated February 17, 1944, advising Linde to ship 25 lbs of high-grade ore to 

Electro-Met for experimental work (War Department 1944). In addition, according to War 

Department 1945 (pdf p. 6), 2 lbs of uranium tetrachloride, 3 lbs of uranium tetrafluoride, and 

1 lb of UO2F2 were shipped to Electro-Met in the second quarter of 1945 for experimental use. 

It was noted in a progress report on R&D projects, dated March 15, 1945 (Unknown 1945, 

pdf p. 14), that Electro-Met had started small-scale casting of rods in graphite. This work was 

done in anticipation of a possible process change from casting billets to casting rods. 

The processing of ores, and notably of high grade ores, would have introduced radionuclides 

other than uranium-234, -235, and -238, and the short-lived decay products of uranium-238 (Th234 and Pa-234m). Specifically, the ores would contain thorium-230 and radium-226, with the 

latter causing radon emissions. Furthermore, raffinate streams would have concentrated 

thorium-230 and radium-226, for which uranium urinalysis would not provide a satisfactory 

basis for dose reconstruction. The presence of these radionuclides would make the use of TBD6001 Appendix C inappropriate, since this document does not cover radionuclides other than 

uranium. Given that the dose conversion factors for thorium-230 are more than 2 orders of 

magnitude larger than those for U-234 (the reference uranium radionuclides used in dose 

reconstruction) for the bone surface and the red bone marrow, and more than an order of 

magnitude larger for several other organs and the whole body, it is important to identify the 

specific activities that were carried out, and explore the relevance of the available data to be used 

to put a scientifically plausible upper bound on doses. 
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Finding 2: Research and Development (R&D) work with uranium ores was not mentioned in 

NIOSH 2009. While the information reviewed here does not indicate that significant quantities 

of uranium-bearing materials other than green salt were used by Electro-Met, NIOSH should 

address the scope of work that might actually have been done at Electro-Met (and in which 

facilities). 

 

Uranium processing began in April 1943 and continued until September 1949, except for the 

period from September 1, 1946, through September 30, 1947. The start date is attributed by 

NIOSH (2009, p. 14) to NYOO (1951, p. 31). However, the weekly report to the District 

Engineer for the period December 26, 1942, through January 1, 1943, states that Electro-Met 

experimentally cast 175 pounds of uranium during the week. This material was referred to as 

“crude metal,” which required recasting elsewhere (Crenshaw 1943). Uranium processing 

ceased in September 1949, when the Area Plant was again placed in standby. From April until 

September 1950, the plant was reactivated to cast zirconium sponge, and then again returned to 

the standby mode. From January through June 1951, the Area Plant was used for an R&D 

contract with the AEC to study metal forming techniques that would reduce finishing operations 

and reduce waste. Although the contract was not specific, DOE presumed that the contract 

involved uranium metal (DOE 1986). But, as noted above, NYOO makes no mention of 

additional production activities after shutdown in October 1949 (NYOO 1951). It is stated in 

DOE 1986 that, “AEC involvement at the site ended when Contract W-7405-Eng-14 expired on 

June 30, 1953.” However, DOE (1986, pdf p. 4) is ambiguous about the end of AEC 

involvement.3

 In the sentence prior to that quoted above, DOE states that, “Later, just prior to 

demolition, the building was also apparently used for titanium processing (contract number 

unknown).” This is important, because it creates an opportunity for exposure to residual 

radioactivity between June 30, 1953, and the time of building demolition. 

Finding 3: NIOSH should review the start and end dates for the operational period to insure 

that all relevant documentation has been evaluated. 

After the contract expired, the Area Plant was purchased by Electro-Met. Electro-Met 

decontaminated the plant and equipment using washing, vacuuming, and, in some locations, 

removing concrete floors and wooden platforms (DOE 1986). The plant was then surveyed by 

the Health and Safety Division of the AEC in August 1953. Alpha counting of smear samples is 

reported in Smear Results 1952–1953. The maximum alpha count observed on 28 samples was 

711 dpm/sample (arithmetic mean - 158 dpm/sample). This maximum was higher than for a 

December 1952 pre-decontamination survey involving 164 samples, where the maximum was 

300 dpm/sample (Smear Results 1952–1953). Based on the August 1953 survey, the AEC 

recommended in September 1953 that the facility be released to the purchaser (DOE 1986). 

The Area Plant was demolished in 1957 (DOE 1986). Debris and uranium processing wastes 

were transferred to another AEC location (the Lake Ontario Ordnance Works). NIOSH reported 

that Electro-Met subsequently processed uranium and thorium ores for commercial purposes 

under radioactive materials license 950-0139 issued by the State of New York (NIOSH 2009, 

 3

 According to information included in SRDB 9036 (pdf p.166), Contract W-7405-Eng14 was closed out 

with Amendment 28 on November 27, 1953. 
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NOTICE:

p. 16). From August 1965 through April 1972, 505 tons of slag containing 9,212 pounds of 

ThO2 and 1,293 pounds of uranium oxide was generated (DOE undated). 

To assist in dose reconstruction, film badge data, air sampling data, surface smear samples, direct 

radiation measurements on surfaces and equipment, and bioassay samples are available for 

various time periods, as summarized in Table 1. 

Certain broad features of the available data in relation to the periods and types of production 

discussed above are noted here: 

(1) There are no internal or external dosimetry data for the late-1942–early-1943 period of 

experimental uranium production. We note that in Petition SEC-00136, the petitionerrequested start date was August 13, 1942, but that NIOSH changed the start date to 

April 1, 1943. NIOSH stated in their Petition Evaluation Report that a contract for the 

construction of the Area Plant was issued in November 1942, but that uranium processing 

did not begin until April 1943 (NYOO 1951). However, the discussion related to 

Finding 3 above indicates that experimental uranium production was being done in late 

1942. 

 

(2) There are no internal or external data for 1945, when experimental ore processing might 

have occurred and when radium-226 and thorium-230 may have been introduced into the 

site as part of ore processing. 

(3) There are almost no external dose (film badge) data for 1944 ([redacted] badge results in 

all) when radium-226 may have been introduced into the site. 

 

(4) Extensive air sampling and film badge data are available during the 1948–1949 operating 

period 

In the ensuing paragraphs, the headings are generally the same as those in the Petition Evaluation 

Report (NIOSH 2009); the NIOSH 2009 paragraph numbers are indicated in parentheses. Since 

the Petition Evaluation Report relies heavily on information in Battelle-TBD-6001 (referred to 

subsequently as TBD-6001), and more specifically Appendix C of that report, this review is also 

a limited critique of those NIOSH documents to some extent. 
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Table 1. Availability of Monitoring Data at Electro-Met 

Operational 

Status Air Samples Film Badges Bioassays Smear Sampl

(alpha) 

Period 

April 1, 1943–December 31, 1943 

Operating 4 (ElectroMet 1943) 0 0 0 

January 1, 1944–December 31, 1944 

Operating 15 (Dust Samples June 

1944, Dust Samples July 1944, Dosimetry Results 1944) 

[redacted] (Dosimetry Results 1944) 

67 (Dosimetry Results 1944) 

0 

January 1, 1945–December 31, 1945 

Operating 0 0 0 0 

January 1, 1946–August 31, 1946 

Operating 0 0 0 0 

Standby 0 0 0 0 

September 1, 1946–December 31, 1946 

January 1, 1947–September 30, 1947 

Standby 0 0 0 0 

October 1, 1947–December 31, 1947 

Operating >10 (Dust Sample Results 

1947–1948) 

0 0 0 

January 1, 1948–December 31, 1948 

Operating 164 (Dust Sample Results 

1947–1948, Dust Sample Results 1948–1949, Urinalysis Results 1949) 

1156 (Dosimetry Results 1948–1949) 

0 0 

January 1, 1949–September 30, 1949 

Operating 215 (Dust Samples 1948–

1949, Dust Samples 1949, Urinalysis Results 1949) 

884 (Dosimetry Results 1948–1949, Dosimetry Results 1949) 

0 0 

October 1, 1949–December 31, 1949 

Standby 0 0 43 (Urinalysis 

Results 1949) 

0 

January 1, 1950–December 21, 1950 

Standby 0 0 0 0 

January 1, 1951–June 30, 1951 

Operating 0 0 0 0 

July 1, 1951–June 30, 1953 

Standby 0 0 0 164 (Smear Res

1952–1953)a

July 1, 1953–?? 1957 

Shutdown 11 (Dust Samples 1953) 0 0 28 (Smear Resu

1952–1953) 

a – This December 10–12, 1948, survey also included contract radiation measurements for α, β, and γ for the many of the same items o

were taken (Blatz 1949). 

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3.2 ELECTRO-METALLURGICAL PLANT AND PROCESS DESCRIPTIONS (5.1) 

The authors of NIOSH 2009 state the following in Section 5.1: 

NIOSH did not locate any documentation indicating that the uranium reduction 

process initiated in April 1943 was modified or altered during the course of 

operations (i.e., the same process steps were employed during uranium handling 

operations over the entire history of AEC involvement at the site). 

While the process steps may have remained unchanged over the course of the operations, we 

believe that it is inappropriate to equate this statement with the corollary that radiation exposures 

remained unchanged over time without further documentation. This statement is particularly 

important to the NIOSH approach to dose reconstruction, since the vast majority of the data are 

from 1948 and 1949. Effectively, any validation of the dose values in TBD-6001 using these 

data involves an implicit back-extrapolation that air concentrations were generally the same in 

the 1943–1946 operating period. However, there is some doubt as to whether the NIOSH 

assumption of unchanged process is correct. Specifically, in its semi-annual report to Congress, 

dated December 1, 1947, the Uranium-Thorium Branch of the AEC noted that, “A thorough 

health survey was made before operations were [re]started and many changes were made as 

recommended by the Medical Division” (Harris 1953, pdf p. 75). Due to the date of the report, 

we presume that this AEC report to Congress refers to the restart on October 1, 1947 (see 

Table 1). This issue will be discussed further in Section 3.7. 

Finding 4: The NIOSH assumption that the uranium metal reduction process and associated 

industrial production and industrial hygiene conditions were unchanged from 1943 to 1949 may 

not be correct. The changes that appear to have been made in 1947 would need to be 

investigated before this assumption can be used to implicitly back-extrapolate post-October 1947 

data to the 1943–1946 period. 

3.3 INTERNAL RADIOLOGICAL EXPOSURE SOURCES FROM ELECTRO-MET 

OPERATIONS (5.2.1) 

NIOSH notes in this section that, “NIOSH found no information pertaining to exposure conditions 

during the standby periods shown in Table 5-1.” However, NIOSH notes in Section 6.1 that, “With 

the exception of the 11 results from 1953 (during the last standby period), 135 air samples were 

collected during Electro-Met operational periods.” Hence, there appear to be 11 results during the 

standby period. 

Finding 5: NIOSH should clarify the text to remove this apparent inconsistency regarding the 

availability of internal exposure data during standby periods. 

 

3.4 AVAILABLE ELECTRO-METALLURGICAL INTERNAL MONITORING 

DATA (6.1) 

In Section 6.1, the NIOSH list of available dust sampling references is incomplete. Additional 

references are included in the reference list in Section 10.0, but are missing from this section of 

the report. In addition, NIOSH did not note that there are a large number of dust samples 
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tabulated in Urinalysis Results 1949 (pdf pp. 64–77). The cover letter transmitting the sample 

data to the Kettering Laboratory, dated December 30, 1959, states that the dates covered range 

from November 1948 through August 1949. However, examination of the individual sample 

records suggests that the period may have been from August 18, 1948, through February 22, 

1949. Data are provided on 78 general air (GA) and operator samples, plus 16 process samples 

from various exhaust stacks. 

A summary of air sampling results is provided in Table 2. The number of available air samples 

listed in Table 2 is significantly more than those listed in Table 6-1 of the NIOSH Petition 

Evaluation Report (see Table 3 below). Particularly noteworthy are four air samples taken from 

May/June 1943, since these measurements were made soon after start-up (Electro-Met 1943). 

The maximum observed air activity was about 48,300 dpm/m3 for an “Operator” filling a bomb 

with green salt and Mg. This operation typically produced the highest exposures. Based on the 

descriptions of the sampling locations on the data sheets, we believe that the sampling was at 

fixed head stations near a worker, rather than lapel sampling. This can make a major difference 

in the intake. Furthermore, while sampling times are given (10 minutes), the task times are not 

provided. The sample results are summarized in Appendix D, Table D-1. Table D-1 provides 

information on sampling locations that were taken near various operations, with the sampling 

head located 4.5 ft off the ground. It is not possible to tell whether these should be construed to 

be process samples, breathing zone analogs, or GA samples. 

Table 2. Summary of Air Sampling Results at Electro-Met 

SRDB 

Reference Sampling Date Number of Samples (excluding controls) 

Alpha Concentration 

Range (dpm/m3

) Comments 

5809 May/June 1943 4 188 (GA), 642 to 

43,800b 

(Operator) 

GA and operator samples 

8887 April 5, 1944 6 273 to 4,094b GA samples 

7726 May 16, 1944 4 317 to 664b GA samples 

7727 July 26, 1944 5 98.6 to 379b GA samples 

8917 December 24, 1947 Unknown, only 

averages provided, 

but more than 10 

samples were taken. 

106 to 6,145a Measurements converted 

to daily weighted 

averages. See Table 4 

below. 

8917 March 30, 1948 8 77.6 to 9,840 Mixed GA and operator? 

8912 April 5, 1948 10 8 to 180 (GA), 32,700 

to 97,000 (Operator) 

8917 May 14, 1948 18 38.8 to 57,300 Mixed GA and operator? 

35738 August 18, 1948 8 0 to 810 (GA), 240 to 

3,250 (Operator) 

8912 November 3–4, 1948 120 12 to 2,490 (GA), 0 to 

480,000 (Operator) 

Measurements converted 

to daily weighted 

averages. See Table 4 

below. 

8912 January 12, 1949 13 8 (GA), 0 to 72,000 

(Operator) 

35738 January 26, 1949 13 16 to 3,500 (GA), 4,400 

to 140,000 (Operator) 

35738 February 2, 1949 14 141 to 680 (GA), 250 to 

3,040 (Operator) 
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Sampling Date Number of Samples 

(excluding controls) 

Alpha Concentration 

Range (dpm/m3

) Comments 

Table 2. Summary of Air Sampling Results at Electro-Met 

SRDB 

Reference 

35738 February 7, 1949 16 63 to 520 (GA), 

60 to 4,400 (Operator) 

35738 February 16, 1949 11 130 to 1,100 (GA), 

500 to 128,500 

(Operator) 

35738 February 22, 1949 16 0 to 3,000 (GA), 

2,700 to 60,600 

(Operator) 

8930 August 17–19, 1949 132 Individual sample data 

illegible. Average of 

[redacted] samples for 

green salt loaders was 

92,700 dpm/m3 

Prior to standby on 

September 30, 1949. 

Measurements converted 

to daily weighted 

averages. See Table 4 

below. 

8889 August 14, 1953 11 1.2 to 24.7 After shutdown and 

decon 

a – range of averaged values 

b – converted to dpm/m3

 based on specific activity of natural U of 6.84E+02 pCi/mg 

Table 3. Comparison of Number of Available Air Samples 

Year NIOSH 2009, Table 6-1 This Review 

1943 0 4 

1944 5 15 

1945 0 0 

1946 0 0 

1947 7 >10 

1948 29 164 

1949 82 215 

1950 0 0 

1951 0 0 

1952 0 0 

1953 11 11 

During air sampling campaigns in 1947, 1948, and 1949, daily weighted average (DWA) 

exposures associated with various job descriptions were determined. Results of these DWA 

exposures are presented in Table 4. 

 
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Table 4. Daily Weighted Averagea Air Samples (Alpha) Based on 

Breathing Zone Samples and General Air Samples in Areas 

Frequented by Workers in Each Job Description 

Job Description December [redacted], 

1947 (dpm/m3

) 

November [redacted], 

1948 Samples (dpm/m3

) 

August [redacted], 1949 

Samples (dpm/m3

) 

Green Salt Loader 1,136.6 40,400c 15,300c

Repairman – Furnace Parts 2,240 1,310 

Head Electric Furnace Remelt 

Operator and Assistant 

263.2 882 440 

Back Saw Operator 151.5 284 368 

Topper 355 308 

Jolter Operator 1,759.9 N/A 229 

Plant Guard 200b 218 

Utility Man/Laborers 1,185 142 

Laboratory Handyman 1,793 138 

Reaction Furnace Operator 194.5 384 133 

Shift Foremen/Foreman 243* 93 

Technician 71.5 101 

Repair Man and Handyman 178* 72 

Janitor 189 30.4 

General Foreman 218 26.5 

Storekeeper and Attendant 53* 30 

Guards 180 30 

Chemists 53 18 

Office Personnel 30 16 

a – Based on 515 minutes per day, including 20 minutes in lunch room and 15 minutes in locker room, except for 

“guards” who worked 495 minutes with no lunch break, “chemists” who worked 500 minutes with no locker 

room time, and “office personnel” who worked 480 minutes with no lunch or locker room time 

b – Estimated from Figure 1 in Dust Samples 1949 

c – See Appendix A for details 

* – Weighted average of two job categories

The DWA results were based on analyses performed by the AEC Health and Safety Division. 

Additional insight into the number of samples used to calculate the DWAs for the August 1949 

sampling period (Table 4, Column 4) is provided in Table 5. The table indicates the number of 

workers involved with each job description, the number of time-weighted operations included in 

the DWA, and the total number of air samples averaged for all of the sampled operations. 

Details of the DWA calculations for the green room operator for the surveys of November 

[redacted], 1948, and August [redacted], 1949, are included in Appendix A. 
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Table 5. Summary of Air Concentration Measurements from August 1949 Survey at 

Electro-Met (Dust Samples 1949) 

Job Description No. of 

Workers 

Operations 

Sampled1

Total Air 

Samples for 

All Tasks 

Daily Weighted Air 

Concentration 

(dpm/m3

 - alpha) 

Green salt loader [redacted] 6 19 15,300a

Repair man – furnace parts [redacted] 6 21 1,310 

Head electric re-melt furnace 

operator and assistant [redacted] 7 23 440 

Hack saw operator [redacted] 4 15 368 

Topper [redacted] 6 28 308 

Jolter operator [redacted] 6 26 229 

Plant guard [redacted] 3 22 218 

Utility men and laborers [redacted] 10 59 142 

Laboratory handyman [redacted] 5 12 138 

Reaction furnace operator [redacted] 4 16 133 

Shift foreman [redacted] 5 50 93 

Technician [redacted] 5 50 101 

Repair man and handyman [redacted] 4 48 72 

Janitor [redacted] 4 8 30.4 

General foreman [redacted] 5 N/A 26.5 

Storekeeper and attendant [redacted] 5 11 30 

Guards [redacted] 3 46 30 

Chemists [redacted] 2 4 18 

Office personnel 10 2 2 16 

1 – Includes 15 minutes in locker room, 20 minutes in lunch room, and 480 minutes at other tasks for each job 

category except the guards, for whom no lunch room time was assigned, and chemists/office personnel, for 

whom no locker room time was assigned. 

a – See Appendix A for details. 

One cannot add the samples in Column 4 of Table 5 for each job category to obtain the total 

number of air samples taken during the August 1949 survey, because in several cases, the same 

average for a task was assigned to several operators working in the same area. The total number 

of air concentration measurements quoted in Dust Samples 1949 is about 132. (The detailed air 

sampling sheets in Appendix C of Dust Samples 1949 are somewhat illegible, but a count of the 

number of samples is possible.) 

 

The approach used to calculate internal exposure presented in Appendix C of TBD-6001 is based 

on taking the data from the surveys of November 1948 and August 1949 summarized in Table 4 

above, and dividing the job descriptions into three groups: 

 Operators – workers who routinely handled uranium or operated uranium processing 

equipment 

 Supervisors/Laborers – foremen, guards, maintenance personnel, chemists, janitors, lab 

technicians, etc. 

 Other – office personnel, storekeepers, storeroom attendants, etc. 

Using the daily weighted averages for the job descriptions in each group, the 95th percentile of an 

assumed lognormal distribution for each group was then calculated. This metric was 
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recommended to calculate the inhalation intake for each group during the various operating 

periods. During standby periods, it was recommended that inhalation intakes for the “Other” 

group be used (TBD-6001, Appendix C, Section C.5). 

We divided our comments on the use of air sampling data into five parts: 

(1) The type of air sampling data 

(2) Consolidation of many worker categories into just three types with very different 

assigned intakes 

(3) The statistical analysis that NIOSH has performed on the data 

(4) Accidents, specifically blowouts 

(5) Residual contamination 

(1) Type of air sampling data 

The sample sheets from 1943 indicate that the sampling may not have been using lapel samplers, 

but rather fixed head samplers close to the worker concerned. There can be a considerable 

difference between a worker’s actual intake and that indicated by a fixed head sampler. See 

above discussion regarding Table D-1. 

Finding 6: NIOSH should take into account the difference between fixed head samplers, process 

samplers, and general area samplers and actual intake, and the uncertainties this creates for 

estimating bounding intakes. 

(2) Job categories 

NIOSH has not discussed the mobility of workers in practice between job types. Was the Area 

Plant a union shop with strict work rules, or was mobility between jobs permitted? It is not clear, 

for instance, whether laborers may also have done jobs that had exposures closer to those of 

operators. The constancy of jobs as done in practice needs to be established before the job 

consolidation scheme that NIOSH proposes can be used in the context of estimating bounding 

dose in an SEC context. 

Finding 7: NIOSH needs to establish that job titles corresponded to the jobs actually done for 

the period of employment. NIOSH’s job title consolidation scheme would not produce bounding 

estimates for all workers in the proposed class in the absence of such an analysis. 

(3) NIOSH approach to estimating intakes from air sampling data 

NIOSH did not use the limited daily weighted average data from December 1947 (Table 4, 

Column 2) for this analysis. With the exception of the bomb room activities, which we assume 

here were comparable to the job description for the jolter operator, the December 1947 data were 

lower than the data used by NIOSH in calculating bounding values. Inclusion of these data 

would have reduced the proposed bounding values, so the approach taken by NIOSH is claimant 

favorable. Inspection of the other air sampling data in Table 2 not used in the bounding 
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calculation, because they were not reduced to DWAs, suggests that these values are generally 

encompassed by the range of values used to calculate the DWAs. Some exceptions to this 

generalization will be discussed elsewhere. 

NIOSH did not provide sufficient documentation to permit an audit of 95th percentile 

calculations by job description described in Section C.5, Appendix C, of TBD-6001. They also 

did not provide any reference to the data underlying the statement, “Air samples were collected 

in various areas of the plant in 1948 and 1949.” However, to assist in the current review, NIOSH 

provided a spreadsheet and list of supporting documentation to SC&A (Allen 2009). 

NIOSH used a graphical method for estimating the parameters of lognormal distributions needed 

for estimations of inhalation intakes. This method is particularly useful when the data include 

non-detect values (missing values that are below the minimum detectable level). However, the 

graphical method is not the method that generally would be used to estimate parameters of a 

lognormal distribution if there were no missing values. The most commonly recommended 

approach is to use the maximum likelihood estimate (MLE) method. The MLE method is 

applied by taking logarithms of the data, then calculating the parameter estimates using the 

standard formulas for the normal distribution. 

The parameter mu is estimated using the average of the logarithms. The MLE is also an 

unbiased estimate of mu. The parameter sigma is estimated using the MLE for the standard 

deviation of the logarithms. The MLE for sigma is obtained by dividing the sum of squared 

deviations for mu by the factor N. Another common approach is to use an unbiased estimate for 

sigma. This estimate is obtained by dividing the sum of squared deviations by the factor N-1. 

The three methods for estimating lognormal parameters are shown in Table 6. 

The three methods often yield very similar results when the sample size is over 30. For small 

samples, the three methods may yield different results. In the case of operator exposures, the 

sample size is N=13, a relatively small sample. The results of applying the three methods in this 

case are shown in Table 7. The three methods yield substantially different results for the 95th

percentile, ranging from 60,661 dpm/calendar day for the NIOSH graphical method shown in 

Figure 1 up to 83,721 dpm/calendar day for the unbiased method. The MLE method yields a 

value in between, at 75,203 dpm/calendar day. The differences between the three methods are 

due to the different weight assigned to the two highest values. The unbiased estimate yields the 

highest estimate for sigma, because of the large magnitude of the squared deviations for these 

two extreme values. For the supervisors/laborers and other workers categories, agreement 

among the three approaches is much better, since the results are not significantly affected by 

extreme high-end values. The MLE method is generally preferred by statisticians over other 

methods if there are no missing values. 
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Table 6. Three Methods for Estimating Lognormal Distribution Parameters 

Method of Estimation 

Parameter NIOSH SC&A 

Mu Graphical Method Maximum Likelihood Maximum Likelihood 

Sigma Graphical Method Maximum Likelihood Unbiased 

S2/N S2/(N-1) 

Table 7. Comparison of Numerical Results for Operators Using 

Three Methods of Estimation (N=13) 

Numerical Results by Method of Estimation 

Parameter/ NIOSH SC&A 

Statistic Graphical Method Maximum Likelihood Unbiased Units 

Mu 8.615 8.600 8.600 

Sigma 1.458 1.597 1.663 

Geometric Mean 5,516 5,433 5,433 dpm/calendar day 

Geometric Standard Deviation 4.3 4.9 5.3 

95th Percentile 60,661 75,203 83,721 dpm/calendar day 

Operators Data

y = 1.458x + 8.615

R2

 = 0.767

4

5

6

7

8

9

10

11

12

13

-2 -1 0 1 2

z-score

ln(x)

Figure 1. Normal Score Plot of Operator Data 
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Finding 8: We note that the graphical method used by NIOSH in Appendix C of TBD-6001 to 

calculate the inhalation intakes for operators results in the lowest estimate of the 95th percentile 

among possible alternative calculational approaches. Arguably, in this case, the graphical 

method is not claimant favorable. 

It is instructive to compare the generic inhalation intakes for some of the operations listed in 

Table 8.29 of TBD-6001 with those specific to Electro-Met in Table C.2, Appendix C of TBD6001. Tasks listed in Table 8.29 that are comparable to the operator tasks in Table 4 are 

summarized in Table 8. The reader is referred to Appendix B for a discussion of the data sources 

and problems with interpretation of some of the data in Table 8.29. 

The 95th percentile of the values in Table 8 is 4,986 dpm/calendar-day, demonstrating that the 

site-specific approach in Appendix C (Table C.2) of TBD-6001 is clearly more claimant 

favorable than the generic approach embodied in Table 8.29 of TBD-6001 (i.e., 60,661 dpm/ 

calendar-day versus 4,986 dpm/calendar-day). This raises concerns as to the whether the generic 

approach in TBD-6001 is claimant favorable. While a detailed review of this issue probably lies 

within the scope of the TBD-6001 Work Group, we note the issue here for the record. 

Table 8. Inhalation Exposures for Job Descriptions in Table 8.29 

of TBD-6001 that are Comparable to Operator Jobs at Electro-Met 

Operator Job Description Inhalation Exposurea

(pCi/calendar-day) 

Bomb preparation (prior to 1952) 711 

Reduction (prior to 1952) 243 

Bomb breakout (prior to 1952) 693 

Recasting – crucible loading (prior to 1951) 130 

Recasting – recasting (prior to 1951) 1,990 

Recasting – crucible burnout (prior to 1951) 41.5 

Recasting – billet cleaning (prior to 1951) 97.8 

Recasting – crucible assembly (prior to 1951) 678 

a – Assumed geometric mean (GM) for lognormal distribution with a gerometric 

standard deviation (GSD) of 5, based on 40-hr workweek. 

Finding 9: The site-specific values for inhalation intakes for Electro-Met from Appendix C are 

significantly more claimant favorable than the generic intakes proposed in Table 8.29 of TBD6001, which raises questions as to whether TBD-6001 is appropriately conservative for its 

intended purpose. This is noted for the record, but it is not an Electro-Met finding. 

(4) Blowouts 

The petitioner has stated that the process used at Electro-Met typically resulted in blowouts. 

NIOSH’s response in its Evaluation Report is that there is no specific Electro-Met evidence 

indicating blowouts at the plant. NIOSH noted on page 19 of NIOSH 2009 that, “Electro-Met 

documentation recognized that an uncontrolled reaction could result in an explosion of the bomb 

(ElectroMet 1946a, p. 6).” In its Petition Evaluation Report, NIOSH stated that neither of the two 

persons interviewed had any knowledge that such events occurred. As described in Appendix E, 

SC&A also interviewed a former Area Plant worker employed in the 1940s, who stated that he 
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and his coworkers were never involved in an accident, contamination spill, fires, or other 

incidents, and that he was unaware that any blowouts or bomb explosions had occurred. SC&A 

reviewed all the documentation available on the O-drive and other materials, and could find no 

evidence of blowouts. However, as summarized below, the occurrence of blowouts from the 

same process at other sites is well documented. 

Workers at Ames Laboratory, where the UF4 reduction process was invented, were acutely 

aware of the possibility of blowouts; indeed, they occurred frequently. Only some are 

documented, but there is an instance of at least six on a single day (Payne 1992, p. 133). As 

another example, the Fernald plant, which was built as a more modern facility in the early 1950s, 

continued to have blowouts for many years after the start of operations. For instance, one 

document shows that dozens of blowouts occurred in a single 10-day period (there were several 

reduction furnaces at Fernald). 

 

Clearly, the AEC was very concerned about the consequences of blowouts. It is therefore 

surprising that, if blowouts had occurred at Electro-Met, there would be no documentation of that 

fact, especially since their occurrence was well-documented at other facilities. It would also be 

surprising if there were no blowouts at Electro-Met, given the frequency of blowouts in the same 

period and in the same type of equipment at Ames, and given that later facilities also had 

blowouts for long periods after Electro-Met ceased producing uranium metal. If Electro-Met 

knew how to prevent blowouts, it is puzzling that the lessons were not applied elsewhere then or 

later. This is an issue that also needs further investigation. 

Finding 10: Given the high frequency of blowouts at other facilities using the same equipment, 

NIOSH should re-examine the possibility that blowouts occurred at Electro-Met. 

(5) Residual contamination 

Results of final air sampling data taken in August 1953 after the Area Plant had been shut down 

and decontaminated are shown in Table 9. 

Table 9. Post-Decontamination Air Sampling Measurements Made on 

August 14, 1953, at Area Plant 

Sample Number Alpha Concentration (dpm/m3) 

N400 24.7 

N401 13.7 

N402 1.2 

N403 15.5 

N404 1.5 

N405 117 

N405 2.7 

N407 9.8 

N408 2.4 

N409 3.9 

N410 8.6 

Source: AEC 1953 (pdf p. 2) 
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The geometric mean (GM) and geometric standard deviation (GSD) of the data in Table 9 are 

7.1 dpm/m3 (about 0.1 MAC) and 3.9, respectively. We note that NISOH does not consider any 

residual contamination period in the SEC-00136 Petition Evaluation Report; rather, they assume 

that there was no exposure after the AEC contract expired on June 30, 1953. It is possible that 

workers were exposed to residual contamination from July 1, 1953, until 1957, when the Area 

Plant was demolished. Based on the post-decontamination air sampling results in Table 9 and 

the limited time period between plant shutdown and demolition, we expect that exposures would 

be low, but, for completeness, they should be documented. 

Finding 11: NIOSH should address residual exposures in the SEC-00136 Petition Evaluation 

Report. 

3.5 URINALYSIS DATA (7.1.1.1) 

NIOSH states that a total of 111 urinalysis samples were taken in 2 years—1944 and 1949—

from 48 employees, and that about half of the results were 0. We note that the 1949 sampling 

was done in October through December 1949, which was after the Area Plant was placed on 

standby on September 30, 1949. The 1949 samples were collected from 11 to 63 days after 

shutdown. Some decline in the quantity of uranium in urine would occur during the shutdown 

period, so the use of measurements made in the fourth quarter of 1949 would be understated, as 

compared to those for the period prior to shutdown. The fall-off is significantly greater for 

Type M as compared to Type S absorption. 

Since NIOSH assumes in the SEC-00136 Petition Evaluation Report that operations did not 

change substantively over time prior to the institution of extensive monitoring programs in 1948 

(see Section 3.2 above), SC&A examined the two sets of urinalysis data to determine if the 

results were statistically similar for 1944 and 1949. 

The normal score plots and regression lines in Figure 2 look similar for the 1944 and 1949 

datasets. The regression coefficients provide estimates of the lognormal parameters mu (μ) and 

sigma (σ) for each year. The estimated lognormal distributions have similar means and 95th

percentiles, as shown in Table 10. The other lognormal parameters show larger differences. The 

largest differences for GM and GSD have opposite signs, indicating that these are offsetting 

differences. The differences between the two distributions are large enough to require further 

investigation, as described below. 

The approximate 95% confidence intervals for the regression coefficients are shown in Figure 3. 

The smaller size of confidence region in 1949 is due to the larger number of samples over the 

limit of detection. The actual confidence intervals for the regression coefficients have an 

elliptical shape, similar to the examples shown in Figure 4, stretching from the upper left corner 

to lower right corner of the rectangular regions shown in Figure 2. The negative slope of the 

major axis of the ellipses in Figure 3 indicates that there is a negative correlation between 

estimates of the slope and intercept of a regression line. This negative correlation accounts for 

the opposite signs of the differences between 1944 and 1949 for the GM and GSD noted in 

Table 10. 
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The slight overlap of the approximate 95% confidence intervals for the 2 years in Figure 3 

provides statistical evidence that the regression lines for 1944 and 1949 are not significantly 

different. 

 

Table 10. Comparison of Lognormal Distributions for 1944 and 1949 

Lognormal Urinalysis Results Urinalysis Results Percent change 

Parameter 1944 1949 Units 1944 to 1949 

GM 0.018 0.010 mg/L -46% 

GSD 4.14 5.72 38% 

Mean 0.050 0.045 mg/L -10% 

85th 0.080 0.061 mg/L -24% 

95th 0.190 0.175 mg/L -8% 

99th 0.499 0.574 mg/L 15% 

y = 1.4204x - 3.9994

R2

 = 0.7414

y = 1.7434x - 4.6114

R2

 = 0.9522

-10

-8

-6

-4

-2

0

-3 -2 -1 0 1 2 3

SRDB-8887 SRDB-35738

Regression (1944) Regression (1949)

Figure 2. Normal Score Plots for 1944 and 1949 with Regression Lines 
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Best Estimate and Approximate Boundary of 95% 

Confidence Region for Regression Coefficients 

μ and σ in 1944 and 1949

0

1

2

3

-6 -5 -4 -3 -2

μ = Intercept

σ = Slope

SRDB-8887 (1944) SRDB-35738 (1949)

Figure 3. Best Estimate and Approximate 95% Confidence Region for the Intercept 

(μ) and Slope (σ) of the Regression Lines for 1944 and 1949 

Figure 4. Examples of the Elliptical Shape of Confidence Intervals for the Intercept 

and Slope of Regression Lines 

(Source: Box and Tiao 1973) 
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3.6 METHODS FOR BOUNDING OPERATIONAL INTERNAL DOSE AT 

ELECTRO-METALLURGICAL (7.2.3) 

NIOSH reports that they used the uranium inhalation intake data from Appendix C of TBD-6001 

and calculated the uranium urinary excretion. The calculated excretion was compared to the 

actual urinalysis measurements. NIOSH observed that calculated excretion exceeded the actual 

measurements in every case, substantiating that the intakes in Appendix C were bounding. 

However, NIOSH provides no documentation to support this position. 

SC&A used the inhalation intake limits proposed in Table C.2 of Appendix C of TBD-6001 and 

calculated the excretion rates using IMBA. These excretion rates were then compared to 

measured rates from Urinalysis Results 1949 (pp. 82–83). Only a portion of the 1949 urinalysis 

measurements were identified by job description and none of the 1944 measurements. However, 

the maximum observed value from all sampling was for an “Operator” (0.510 mg/L). The 

maximum reported value for the Supervisors/Labors category was a [redacted] (0.487 mg/L), 

while the maximum for the “Other” category was an [redacted], with an exposure of 0.033 

mg/L. Results of the comparison between measured and calculated excretion rates are 

summarized in Table 11. 

Table 11. Comparison of Measured and Calculated Uranium Excretion Rates 

from Urinalysis 

Job Description Intakea

(dpm/day) 

Intake 

(pCi/day) 

Excretion – 

Type Mc

(pCi/day) 

Excretion – 

Type Sc

(pCi/day) 

Max. 

Measured 

Excretion 

(mg/L) 

Max. 

Measured 

Excretion 

(pCi /day)b

Operators 60,661 27,325 1.844E+03 1.347E+02 0.510 4.82E+02 

Supervisors/Laborers 8,159 3,675 2.478E+02 1.812E+01 0.487 4.66E+02 

Other 473 213 1.437E+01 1.050E+00 0.033 3.16E+01 

a – Bounding values from Table C.2, Appendix C, TBD-6001 

b – mg/L converted to pCi/day as follows: mg/L × 1.4L/day × 6.83E+02 pCi/mg per ORAUT-TKBS-0025 

(ORAUT 2006) 

c – IMBA input assumptions: collection period – 1 day; sampling date – 10/11/1949; chronic exposure to natural U 

from 4/1/1943 to 6/30/1953 

It can be seen from Table 11 that intake assumptions for Supervisors/Laborers and Other job 

descriptions in Appendix C.2 do not appear to be bounding, when compared to maximum 

measured urine excretions reported in Urinalysis Results 1949. For the Supervisors/Laborers, 

the maximum measured excretion rate of 466 pCi/day exceeded the calculated excretion rate of 

248 pCi/day for Type M absorption and 18.1 pCi/day for Type S. For the “Other” job 

description, the maximum measured excretion rate of 31.6 pCi/day exceeded the calculated 

values of 14.4 and 2.05 for Type M and Type S absorption, respectively For the Operators, the 

calculated excretion is bounding for Type M, but not for Type S, absorption. However, it should 

be pointed out that the particular worker sampled was an “Operator,” whose exposure was more 

likely to have been Type S (UO2/U3O8), rather than Type M (UF4). 

Finding 12: NIOSH should provide more detailed information to support their position stated in 

Section 7.2.3 of NIOSH 2009 that, “Considering the intake scenarios established in Battelle-TBD6001 Appendix C, the calculated urinary excretion of uranium from these intakes was compared to 
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actual data and was found to be bounding in each case.” Independent calculations by SC&A do not 

support this conclusion as to the bounding nature of the intakes in Appendix C, Table C.2. 

3.7 METHODS FOR BOUNDING OPERATIONAL PERIOD EXTERNAL DOSE 

(7.3.4.1) 

3.7.1 Photon Dose 

NIOSH states that the photon dose can be bounded using guidance provided in Appendix C of 

TBD-6001 (NIOSH 2009, p. 28). The guidance in Section C.4 of Appendix C is based on film

badge data over a 16-month period, from June 1948 through September 1949, which include 

both beta and gamma measurements. The population of badged workers included operators, 

foremen, janitors, laborers, storeroom attendants, etc. It did not include chemists, guards, and 

office personnel. The entire population of film badge measurements was assigned a lognormal 

distribution. The calculated GM and GSD for the population were calculated to be 

20.06 mr/week and 2.30, respectively. NIOSH assumed that operators were exposed to an 

annual dose based on the 95th percentile (3,934 mr/yr), supervisors/laborers at the 50th percentile 

(1,003 mr/yr), and other workers at the 5th percentile (256 mr/yr). These job categories are the 

same as those described in Section 3.3 above. NISOH did not provide a specific reference to the 

film badge data in Appendix C, but we presume, based on references in the NIOSH 2009, that 

the film badge data were extracted from Dosimetry Results 1948–1949 (SRDB 11547) and 

Dosimetry Results 1949 (SRDB 11548). 

SC&A independently developed a spreadsheet, based on the data in Dosimetry Results 1948–

1949 and Dosimetry Results 1949, and calculated lognormal statistics using the graphical 

method (see Table 6 above). We believe that NIOSH generally uses the graphical method, as 

well. This method is better adapted to datasets where there are a large number of measurements 

below the limit of detection, as is the case here. Using the graphical method, SC&A calculated 

that the GM and GSD were 23.76 mr/wk and 2.21, respectively. A comparison of the annualized 

exposures from the two calculations is presented in Table 12. 

Table 12. Comparison of Annual Photon Exposures 

Job Description Percentile NIOSH Appendix C 

(Table C.4) (mr) 

SC&A Graphical Analysis of 

SRDB 11547 and 11548 (mr) 

Operator 95th 3,934 4,375 

Supervisor/Laborer 50th 1,003 1,188 

Other 5th 256 325 

The graphical method as implemented by both NIOSH and SC&A yielded comparable results. 

As a check on the bounding annual operator exposure (i.e., the 95th percentile exposure) of 

3,934 mr proposed by NIOSH, SC&A calculated the annual exposure for the particular worker 

[Supervisor/Laborer] with the highest annual exposure amongst all the badged population. 

Based on 45 weekly measurements above the assumed limit of detection of 50 mr/wk, the 

[Supervisor/Laborer] was exposed to 3,294 mr of gamma radiation during a 50-workweek year. 

This [Supervisor/Laborer] also received the highest single weekly exposure (690 mr), which 

contributed 21% of his annual exposure. A [Operator] with no significant outlier in his exposure 
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pattern received a similar annual exposure of 2,881 mr, based on 59 weekly measurements above 

the limit of detection. These measurements support the NIOSH position that the 95th percentile 

in Appendix C, Table C.4, of 3,934 mr/yr is bounding for gamma exposure. However, Appendix 

C is silent as to how workers with unknown job descriptions should be evaluated. We believe 

that Appendix C should specifically state that, when the job description is uncertain or unknown, 

the worker should be considered to be an operator. Otherwise, NIOSH cannot say that the results 

are bounding. 

It should also be emphasized, as shown in Table 1, that there are virtually no film badge data 

prior to June 1948. Thus, NIOSH needs to clearly demonstrate that the results are bounding for 

earlier years during the operational period. 

 

Finding 13: The approach taken to bound external photon exposure values in Table C.4 of TBD6001, Appendix C, appears to be reasonable for the operating period beginning June 1948. 

However, NIOSH must demonstrate that this approach is bounding for the earlier operating 

period when essentially no film badge data are available. In addition, NIOSH should explicitly 

define in Appendix C how to proceed with dose reconstruction when the job description is 

uncertain or unknown. 

3.7.2 Medical X-rays 

This section of the Petition Evaluation Report indicates that x-ray doses can be bounded by 

assuming that the energy employee receives a pre-employment x-ray, an annual x-ray during 

employment, and a post-employment x-ray, and refers the reader to ORAUT-OTIB-0006 

(ORAUT 2005) for details. TBD-6001, Appendix C, provides the same guidance in Section C.3. 

In principle, this approach should be bounding. However, we note an apparent ambiguity in 

OTIB-0006 with regard to the use of exposures from photofluorography. For the pre-1970 

period, three default exposures are listed in Table 3-4 of that report; PA chest, lateral chest, and 

photofluorographic chest. The report goes on to state the following (ORAUT 2005, p. 21): 

It is reasonable to presume that at least some of the occupational medical 

diagnostic chest x-rays with the DOE and its predecessor organizations were 

accomplished by PFG and in the absence of data to the contrary, the use of PFG 

should be assumed to ensure claimant favorable dose reconstructions. 

The report is silent on whether this presumption is limited only to DOE organizations, or 

includes AWE organizations as well. In order to insure that a bounding calculation is made in 

dose reconstruction, NIOSH should explicitly state that photofluorography should be assumed 

for dose reconstruction at Electro-Met, or clarify ORAUT-OTIB-0006 to state that it does not 

apply to AWE sites. 

We note in SRDB 8897 (Wolf 1949, pdf p. 33) that the Medical Director referred to x-ray 

examinations and x-ray equipment. It is not possible to deduce from the correspondence whether 

x-ray equipment was a generic term embracing photofluorography or not. 
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Finding 14: NIOSH should state in the Petition Evaluation Report for SEC-00136 and in 

Appendix C of TBD-6001 that estimates of occupational medical exposure should be based on 

photofluorography, unless there is evidence that this technique was not used at AWE sites and 

only at DOE sites. 

3.7.3 Beta Dose 

NIOSH states that, similar to the photon dose, the beta dose can be bounded using guidance 

provided in Appendix C of TBD-6001 (NIOSH 2009, p. 28). The guidance in Section C.4 of 

Appendix C is based on film badge data over the 16-month period from June 1948 through 

September 1949, which included both beta and gamma measurements. The entire population of 

film badge measurements was assigned a lognormal distribution. The calculated GM and GSD 

for the population were calculated to be 64.43 mr/week and 3.13, respectively. NIOSH assumed 

that operators were exposed to an annual dose based on the 95th percentile (21,030 mr/yr), 

supervisors/laborers at the 50th percentile (3,221 mr/yr), and other workers at the 5th percentile 

(493 mr/yr) (Battelle 2007, Table C.5). These exposures are to the skin other than the hands and 

arms. 

SC&A analyzed beta exposures using the same graphical method discussed above for photon 

exposures and determined that the GM was 88.69 mr/wk, with a GSD of 2.64. Percentiles from 

this distribution are compared with those from Table C.5 of TBD-6001 in Table 13. 

 

Table 13. Comparison of Annual Beta Exposures 

Job Description Percentile NIOSH Appendix C 

(Table C.5) (mr) 

SC&A Graphical Analysis of 

SRDB 11547 and 11548 (mr) 

Operator 95th 21,030 21,845 

Supervisor/Laborer 50th 3,221 4,434 

Other 5th 493 900 

Values at the 95th percentile for the two sets of calculations are in excellent agreement. Values 

for the 5th and 50th percentiles are lower in Table C.5 than those calculated by SC&A. 

As a check on the bounding annual operator exposure (i.e., the 95th percentile exposure) of 

21,030 mr proposed by NIOSH, SC&A calculated the annual exposure for the particular worker 

[redacted] with the highest annual exposure amongst all the operators. Based on 57 weekly 

measurements above the assumed limit of detection of 50 mr/wk, the [redacted] was exposed to 

17,053 mr of beta radiation during a 50-workweek year. This result supports the NIOSH 

position that the 95th percentile in Appendix C, Table C.5, is bounding for beta exposure. (This 

estimate is conservative, since it assumes a weekly exposure rate of 50 mr for those weeks where 

the reported results are less than the lower limit of detection.) 

 

Finding 15: SC&A independently developed a database for annual beta and found that the 95th

percentile value was in excellent agreement with that developed by NIOSH for Table C.5. 

However, 50th and 5th percentiles were somewhat higher, based on the SC&A analysis. 

Consequently, it is possible that the dose to Supervisor/Laborers could be understated by about 

40%, and the dose to Others by about 80%. 
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3.7.4 Doses from High Surface Concentrations of U-238 Progeny4

High beta radiation levels have been observed at sites where melting and casting of uranium was 

done. The phenomenon was described in a document authored by Edward Putzier (1982), 

formerly Health Sciences Manager at the Rocky Flats Plant, who observed that the surface beta 

dose from as-cast uranium ingots was about an order of magnitude greater than from a clean 

uranium surface in equilibrium with Th-234 and Pa-234m daughters of U-238. For convenience, 

this phenomenon will be referred to here as the Putzier effect. As quoted by Putzier (1982): 

In the earlier years in handling large quantities of depleted uranium, and to some 

extent this is true in more recent years, we did have a significant beta radiation 

control problem in Building 444. This was not experienced so much in the 

machining areas but in the part of the foundry operations we called burnout and 

breakout. Castings were removed by breaking them out of the molds. This 

operation and the recovery of the material from the casting and handling the 

molds themselves resulted in very high beta radiation levels. There was an 

extremely high level of beta radiation associated with this because the first two 

daughters of 238U are beta emitters and during the molten state of the uranium 

there is a tendency for these two daughters to flow to the top and also to show up 

at the interface of the uranium and the mold itself thereby enhancing the amount 

of beta radiation coming off from the chunk of the material. We used to use as a 

rule of thumb that clean uranium metal in equilibrium with at least its first two 

daughters would give off on the order of 200 mrad per hour beta radiation at the 

surface of a piece of the metal. This went up by at least an order of magnitude 

and probably more than that. We can say that we saw readings as high as 2000 

to 3000 mrad/hr on castings of depleted uranium that were in the foundry area. 

Then, too, the dusts which were generated in the burnout and breakout process 

settled on various pieces of equipment and from that there were additional beta 

radiation fields generated. 

Evidence of high surface concentrations of beta emitters has been observed on equipment used in 

uranium casting operations at Electro-Met (AEC 1949). The authors of AEC 1949 state the 

following: 

A similar separation occurs in the processes at Mallinckrodt Chemical Works 

Plant 4 and Electro Metallurgical Company. In these plants, uranium metal, with 

UX1-UX2 in approximate equilibrium, is purified by vacuum recasting at a 

temperature which volatilizes various impurities in the metal, including the UX1-

UX2. These impurities condense on the cooler surfaces of the furnace interior 

and this deposit is the source of intense beta exposure during charging, 

discharging, cleaning and repair of the furnaces. 

It is clear that operators at Electro-Met involved in the melting and casting of uranium ingots 

would have experienced high doses caused by the Putzier effect. As described above, beta and 

gamma exposures defined in Tables C.4 and C.5 of TBD-6001, Appendix C, were based on 

4

 This subject was not included in the SEC-00136 Petition Evaluation Report (NIOSH 2009). 
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about 2,000 film badge measurements made at Electro-Met in 1948 and 1949. The monitored 

population involved those workers with the highest exposure potential, including furnace 

operators. Thus, the film badges would have captured any abnormal exposures from high 

surface concentrations of Th-234 and Pa-234m. Use of the 95th percentiles of the film badge 

measurements for operator exposures per Tables C.4 and C.5 of Appendix C should provide 

reasonable assurance that high exposures resulting from the Putzier effect would be accounted 

for in dose reconstruction. 

However, there is one caveat that must be considered in using the values in Table C.5 of 

Appendix C for dose reconstruction; these exposure values are specific to the skin other than the 

hands and arms. Exposure to the hands and arms would be higher, since film badges are worn at 

a considerable distance from these extremities. One possible approach to addressing exposures 

to the hands and arms is to use a factor developed by NIOSH in OCAS-TIB-0013 (OCAS 2005). 

That document describes a modeling approach to estimate correlations between film badge 

exposures and exposures to other body parts. They determined that the hands-to-badge ratio was 

to 3.65. 

Finding 16: Use of 95th percentile exposures as proposed in Tables C.4 and C.5 of TBD-6001, 

Appendix C, adequately accounts for enhanced exposures from high surface concentrations of 

Th-234 and Pa-234m produced during melting and casting of uranium ingots, except for 

exposures to the hands and arms. Table C.5 is specific to “Other Skin.” Guidance should be 

added to Appendix C to specifically address exposure to the hands and arms. 

3.8 A CRITICAL QUESTION 

A critical question regarding the SEC-00136 Petition Evaluation report is this: 

 Was the process sufficiently constant from 1943 (when very little monitoring data are 

available) to 1948/1949 (when extensive monitoring data are available) that the 95th

percentile exposures based on 1948/1949 monitoring would adequately represent the 

earlier times? 

The information in Section 3.2 above is repeated here to consolidate all of the information 

relevant to this question in one place. 

The authors of NIOSH 2009 state in Section 5.1 that: 

NIOSH did not locate any documentation indicating that the uranium reduction 

process initiated in April 1943 was modified or altered during the course of 

operations (i.e., the same process steps were employed during uranium handling 

operations over the entire history of AEC involvement at the site). 

The items below address the available information. 
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Item 1 

While the process steps may have remained unchanged over the course of the operations, it 

would be inappropriate to equate this statement with the possible corollary that radiation 

exposures remained unchanged over time. In its semi-annual report to Congress, dated 

December 1, 1947, the Uranium-Thorium Branch of the AEC noted that, “A thorough health 

survey was made before operations were [re]started and many changes were made as 

recommended by the Medical Division” (Harris 1953, pdf p. 75). We presume that the AEC 

report refers to the start-up on October 1, 1947 (see Table 1). 

Item 2 

An MED cover letter for July 26, 1944, air sampling (Dust Sample Results 1944) states: 

These samples indicate that the use of the portable vacuum cleaner has reduced 

radioactive dust concentrations in the general plant atmosphere as compared to 

what it was in the report from this office to the Tonawanda Area Engineer, ????5

-

34 dated 7 June 1944 ... 

Additional information on the efficacy of the vacuum cleaner is provided in MED 1944 

(pdf p. 8). 

While June 7, 1944, sampling results have not been retrieved, results from prior sampling in 

April 1944 are available in Dosimetry Results 1944 (see Table 2). The GM and GSD for the 

April 1944 GA samples were 892 dpm/m3 and 2.86, respectively. By comparison, the GM and 

GSD for the July 1944 GA samples were 253 dpm/m3 and 1.72, respectively. 

An analysis similar to that described Section 3.4 for the urinalysis data was conducted to 

determine if the July 26, 1944, GA samples were statistically lower than the April 5, 1944, air 

samples. The lognormal parameters for the two datasets are compared in Table 14, which clearly 

indicates the magnitude of the changes that occurred between April and July of 1944. 

Table 14. Comparison of Lognormal Parameters for Air Samples Taken Before and 

After Use of Portable Vacuum Cleaner 

Lognormal SRDB-8887a SRDB-8887 a Percent Change 

Parameter 4/5/1944 7/26/1944 Units 4/5 to 7/26/44 

GM 891.964 252.749 dpm/m3 -72% 

GSD 2.74 1.61 -41% 

Mean 1482.252 283.287 dpm/m3 -81% 

85th 2535.146 414.646 dpm/m3 -84% 

95th 4680.729 554.476 dpm/m3 -88% 

99th 9302.703 767.796 dpm/m3 -92% 

a – Dosimetry Results, Aug. 1944 

 5

 ???? – text illegible. 
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To further demonstrate that the two datasets are statistically different, the 95% confidence 

regions are compared in Figure 5. The large separation of the two confidence regions provides 

additional evidence that the two datasets are statistically different. This evidence does not 

support the NIOSH hypothesis that the process did not change over time prior to 1948. We 

recognize that this conclusion is based on small samples, but they represent all of the available 

information. 

Best Estimate and Approximate Boundary of 95% 

Confidence Region for Regression Coefficients 

μ and σ (4/5/1944 and 7/26/1944)

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

4567

μ = Intercept

σ = Slope

8

SRDB-8887 (4/5/1944) SRDB-8887 (7/26/1944)

Figure 5. Comparison of 95% Confidence Regions for General Air Sample 

taken on April 5, 1944, and July 26, 1944 

Item 3 

In Section 3.4 above, SC&A compared the results of uranium concentrations in urine samples 

taken in 1944 and 1949. Based on the statistical comparison, one cannot say that the two 

datasets are different. 

Item 4 

 

Three beta exposure measurements were made on August 28–29, 1944 (Dosimetry Results 

1944), with results ranging from 125 to 180 mrem per 8-hour day. Converted to a weekly basis, 

the range would be 626 to 900 mr/wk. This range may be compared to the lognormal statistics 

for a much larger population of measurements made in 1948 and 1949, as discussed under “Beta 

Doses” in Section 3.7. For the 1948/1949 measurements, the median and 95th percentile values 

based on NIOSH calculations were 64.4 and 421 mr/wk, respectively. Based on the limited 
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sample from 1944, use of the 95th percentile value from film badge measurements made in 

1948/1949 is not bounding for beta exposures in the earlier years. 

In some instances, workers wore leather gloves to reduce exposure to the hands. Five 

measurements taken on April 5, 1944, from the inside lining of gloves worn by a [redacted] 

operator ranged from 150 to 200 mrem per 8-hr day. These results are similar to the film badge 

measurements of August 28–29, 1944. 

Item 5 

Seven beta measurements were made on October 22, 1946, when the Area Plant was in a standby 

mode (Electro-Met 1946b). There were three non-zero measurements ranging from 24 to 220 mr 

per 8-hr day. These data are not particularly useful in answering the over-arching question. 

Item 6 

The daily weighted average air samples for operators taken on December [redacted], 1947, are 

lower than the comparable DWAs for operators taken on November [redacted], 1948, and 

August [redacted], 1949 (see Table 4). This comparison indicates that use of the 95th percentile 

from the November 1948 and August 1949 air samples, as proposed in Table C.2 of Appendix C, 

TBD-6001, would be a prudent estimate, at least forward in time from December [redacted], 

1947.

Item 7 

The approach used by NIOSH to develop generic guidance in TBD-6001 differs from the 

specific guidance for Electro-Met provided in Appendix C of that report. As described above, in 

Appendix C, NIOSH used DWA data for operators, based on air sampling campaigns of 

November 1948 and August 1949 (see Table 4), and selected the 95th percentile from the 

combined results as the bounding metric. This upper 95th percentile was assumed to apply to all 

operating periods between 1943 and 1953. On the other hand, in TBD-6001, NIOSH proposed 

that the process-specific data (e.g., metal reduction and recasting) from Christofano and Harris 

1960 be adjusted by a year-specific factor. Year-specific factors are listed below (Battelle 2006, 

Table 8.28): 

 1948 and before – 6.89 

 1949 – 0.897 

 1950 – 0.325 

 1951 – 0.485 

 1952 – 0.116 

 1953 – 0.0656 

Since Christofano and Harris reported no measurements prior to 1948, NIOSH proposed 

assuming that the factor for 1948 be extended to earlier years. However, use of the year-specific 

factors does not work for much of the data in TBD-6001, because for many of the operations in 
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NOTICE:

Section 8, there are two sets of process data for different times, and it is not possible to determine 

which of the process-specific dust levels against which to apply the year-specific factors. 

Item 8 

As noted in Section 3.3, an air sample near an “Operator” loading a bomb with green salt in 

May/June 1943 measured 69,100 dpm/m3. The average of four air samples near an “Operator” 

performing a similar operation in November 1948 was 264,250 dpm/m3 (see Appendix A). 

Obviously, these data should not be construed as saying that environmental conditions 

deteriorated with time, but they do suggest that the situation in the earlier years was captured by 

the 95th percentile exposures in later years. 

Summary of Evidence Related to the Over-Arching Question 

There is conflicting evidence as to whether the process at Electro-Met remained essentially 

unchanged from start-up on April 1, 1943, until June 1948, when significant and regular 

monitoring was undertaken. The following bullets summarize the items discussed above: 

 AEC correspondence indicates that process changes were made prior to restart of 

operations on October 1, 1947 

 Comparison of general air sampling results made in April and July 1944 show 

significant improvements in July, presumably associated with use of a portable vacuum 

cleaner 

 It is not possible to show that results of urinalysis sampling in 1944 and 1949 are 

statistically different 

 Daily weighted air sample for process operators measured in December 1947 are lower 

than for comparable jobs in November 1948 and August 1949 

 A limited number of beta samples (3) taken in 1944 are higher than the upper 95th

percentile of a large population of film badge measurements made in 1948/1949 

 It is not obvious how to apply the generic inhalation approach proposed in TBD-6001 to 

the years prior to 1948 at Electro-Met 

 Air samples taken near a green room operator loading a reduction bomb were no worse in 

1943 than in 1948 

Finding 17: NIOSH needs to provide convincing arguments that 95th percentile values based on 

1948/1949 data are bounding for the period prior to December 1947. 
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4.0 REFERENCES 

AEC (Atomic Energy Commission) 1947. Monthly Status and Progess Report. November 

1947. SRDB 6292 (pdf p. 30) 

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

Processing Uranium. Report by the New York Operations Office Medical Division. April 18, 

1949.

AEC (Atomic Energy Commission) 1953. Electromet Air Dust Alpha Counts, Sample Register 

A4052. August 20, 1953. SRDB Ref ID: 8897 (pdf, p. 2) 

Allen, D. 2009. RE: Appendix C, TBD-6001. E-mail from David Allen, CDC/NIOSH/OD, to 

W.C. Thurber, SC&A, Inc., dated December 9, 2009. 

Battelle 2006. Site Profiles for Atomic Weapons Employers that Refined Uranium and Thorium, 

Battelle-TBD-6001, Rev. F0; Battelle; December 13, 2006; SRDB Ref ID: 30673. 

 

Battelle 2007. Site Profiles for Atomic Weapons Employers that Refined Uranium and 

Thorium—Appendix C, Electro Metallurgical Company, Battelle-TBD-6001, Rev. 0; Battelle; 

December 21, 2007; SRDB Ref ID: 41362. 

Blatz 1949. Proper Film Badge Placement, correspondence to Mr. Winterhaler [Electro-Met]; 

Hanson Blatz [Chief, Radiation Section]; June 20, 1949; SRDB Ref ID: 8897, p. 28. 

Box, G.E.P. and Tiao, G.C. 1973. Bayesian Inference in Statistical Analysis, Addison-Wesley 

Publishing Co., 1973, p.47. 

Christofano E. and W.B. Harris 1960. The Industrial Hygiene of Uranium Refining. Env Health 

1(5):74-96. 

CCR 2009. SEC-00132 Consult Call Response; January 7, 2009; OSA Ref ID: 107789, pp. 1–4. 

Crenshaw, T.T. 1943. [Internal] Weekly Report (December 26, 1942–January 1, 1943) to 

District Engineer. Corps of Engineers. Ref ID: 30778. 

DOE (U.S. Department of Energy) Undated. Elimination Report for the Former Electro 

Metallurgical Company, Niagara Falls, NY. Formerly Utilized Site Remedial Action Program. 

U.S. Department of Energy, Division of Facility and Site Decommissioning Projects. 

www.lm.doe.gov/Considered_Sites/E/Electromet...NY.../NY_04-3.pdf

DOE (U.S. Department of Energy) 1986. History of UMETCO Minerals Company-Formerly 

Electro-Metallurgical Company; Department of Energy (DOE); April 9, 1986; SRDB Ref ID: 

16282. 
Effective Date: 

May 19, 2010 

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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. 

Dosimetry Results, Aug. 1944, Dosimetry Results for Electro-Metallurgical Employees from 

August 26, 1944 through August 29, 1944; SRDB Ref ID: 8887, pp. 9–10. 

Dosimetry Results, March 1948–Jan. 1949, Dosimetry Results for Electro-Metallurgical 

Employees from March 15, 1948 through January 24, 1949; SRDB Ref ID: 11547. 

Dosimetry Results, Jan.–Sep. 1949, Dosimetry Results for Electro-Metallurgical Employees from 

January 3, 1949 through September 26, 1949; SRDB Ref ID: 11548. 

Dust Sample Results, April 1944. Medical Hazards at the Electro-Metallurgical Co: Dust 

Samples Collected April 5, 1944. SRDB Ref ID: 16247 (pdf. p. 6). 

Dust Sample Results, June 1944. Medical Hazards at the Electro-Metallurgical Co: Dust 

Samples Collected May 16, 1944. SRDB Ref ID: 7726. 

Dust Sample Results, July 1944. Electro-Met Dust Sample Results for July 26, 1944; SRDB Ref 

ID: 7727.

Dust Sample Results, Dec. 1947–May 1948. Dust Hazard Reports with Dust Sample Results for 

December 24, 1947, March 30, 1948, and May 14, 1948; SRDB Ref ID: 8917. 

Dust Sample Results, Nov. 1948–Jan. 1949. Dust Sample Results from November 3, 1948 

through January 12, 1949, includes Job Analysis Sheets; SRDB Ref ID: 8912. 

Dust Sample Results, Aug. 1949. Electro-Met Dust Sample Report and Results for August 17–

19, 1949; SRDB Ref ID: 8930. 

Dust Sample Results, Aug. 1953. Electro-Met Dust Sample Results Collected on August 14, 

1953; SRDB Ref ID: 8889. 

Electro-Met 1943. Letter to Major H.L. Friedell, War Department from N.H. Kirkorian, Electro 

Metallurgical Company dated May 28, 1943. SRDB Ref ID: 5809. 

Electro-Met 1946a. Completion Report—Construction of Electro Metallurgical Company Area 

Plant, Contract No. W-7405 Eng-14, Tonawanda Area; Electro-Metallurgical Corporation 

(ElectroMet); February 15, 1946; SRDB Ref ID: 59225 

Electro-Met 1946b. Results of Radiation Measurements Made at the Electro-Metallurgical Plant 

on October 22, 1946; Electro-Metallurgical Corporation (Electro-Met); October 22, 1946; SRDB 

Ref ID: 8940. 

Harris 1953. Dismantlement of Electro-Metallurgical Corporation, Decontamination Survey of 

August 11 and 14, 1953, correspondence with survey results; W.B. Harris [Industrial Hygiene 

Branch, Health and Safety Division, U.S. Govt.]; September 28, 1953; SRDB Ref ID: 9036. 
Effective Date: 

May 19, 2010 

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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. 

Hayden 1947. Survey of Tonawanda Area (September 2–5, 1947). [Internal] Memorandum 

from R.E. Hayden [Health Physicist] to Dr. B.S. Wolf [Medical Director, U.S. Govt.] dated 

November 3, 1947. SRDB Ref ID: 35762. 

Kelley, W.E. 1945. Letter from Major W.E. Kelley, Corps of Engineers, to J.A. Holladay, 

Electro-Metallurgical Company, dated March 17, 1945, SRDB Ref ID 59224. 

MED 1944. Work Report for July 1944. U.S. Engineer Office, Manhattan District. August 2, 

1944. SRDB Ref ID: 17273. 

NIOSH 2009. SEC Petition Evaluation Report, Petition SEC-00136 – Electro Metallurgical 

Corporation. July 21, 2009. 

NYOO 1951. Production of Uranium Feed Materials; Manager of New York Operations Office 

(NYOO) and Director of Production; May 22, 1951; SRDB Ref ID: 4125. 

OCAS (NIOSH Office of Compensation and Support) 2005. Special External Dose 

Reconstruction Considerations for Mallinckrodt Workers, OCAS-TIB-0013, Rev. 0. National 

Institute for Occupational Safety and Health. Effective Date: November 26, 2005. 

ORAUT (Oak Ridge Associated Universities Team) 2005. Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures, ORAUT-OTIB-0006, Rev. 03 PC-1. 

Cincinnati, Ohio. December 21, 2005; SRDB Ref ID: 20220. 

ORAUT (Oak Ridge Associated Universities Team) 2006. An Exposure Matrix for Linde 

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

Cincinnati, Ohio. 

Payne 1992. The Ames Project: Administering Classified Research as a Part of the 

Manhattan Project at Iowa State College, 1942-45, PhD Dissertation of Carolyn Stilts Payne, 

Iowa State University, Ames, Iowa (SRDB Ref ID: 18851). 

Personal Communication 2009. Personal Communication with a Former Production Area 

Worker at Electro-Metallurgical Corporation; Telephone Interview by ORAU Team; May 29, 

2009; SRDB Ref ID: 69863. 

Putzier, E.A., 1982. The Past Thirty Years at Rocky Flats Plant, Rocky Flats Plant, Golden, 

Colorado. November 1982. 

Smear Results, Dec. 1952–Aug. 1953. Electro-Met Smear Results from December 11, 1952 and 

August 14, 1953; SRDB Ref ID: 8892. 

Unknown 1945. Progress Report on Research and Development Projects. Memorandum to 

Files. March 15, 1945. SRDB Ref ID: 30857. 

Urinalysis Results, July 1944–Sept. 1944. Urinalysis Results for Electro-Metallurgical 

Employees from July 10, 1944 through September 8, 1944; SRDB Ref ID: 8887, pp. 3–7. 
Effective Date: 

May 19, 2010 

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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:

Urinalysis Results, Oct. 1949–Dec. 1949. Urinalysis Results for Electro-Metallurgical 

Employees from October 11, 1949 through December 2, 1949; SRDB Ref ID: 35738, pp. 78–83. 

War Department 1943. Letter to J.A. Holladay, Union Carbide and Electro Metallurgical 

Research Laboratories, Inc. from Major C. Hadlock, Corps of Engineers dated October 7, 1943. 

SRBD Ref ID: 45927. 

War Department 1944. Letter to the Linde Air Products Company (Attention A.R. Holmes) from 

Walter Thomas, Tonawanda Area Office, United States Engineer Office. February 17, 1944. 

SRDB Ref ID: 45925. 

 

War Department 1945. Special Shipments of X-Containing Materials. Memorandum from 

Major W.E. Kelley to Colonel K.D. Nichols dated July 2, 1945. SRDB Ref ID: 30742. 

Wolf, B.D. 1949. Letter from B.S. Wolf (NYOO) to J. Winterhaler (Electro-Met) regarding 

x-ray examinations and x-ray equipment. April 27, 1949. SRDB Ref ID: 8897, pdf p. 33.
Effective Date: 

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APPENDIX A: EXAMPLE DAILY WEIGHTED AVERAGE 

CONCENTRATIONS OF URANIUM IN AIR SAMPLES 

Green Room Operator 

1 man per shift – 3 shifts per day – total, 3 men 

Measurement Date – November [redacted], 1948 

No. of 

Minutes 

No. of Times 

per Shift 

Total Time 

(Minutes) 

Alpha Concentration 

if d/m/m3

Alpha 

Concentration 

Times Total Time 

Operation 

Charging bomb and 

cleaning out mixer. 

3.4 12 41 264,250 

(Average of 4 samples) 

(High – 319,000 

 Low – 212,000) 

10,800,000 

Dumps UF4 and 

magnesium into mixer 

1.5 12 18 290,800 

(Average of 4 samples) 

(High – 480,000 

 Low – 91,000) 

5,220,000 

Removing funnel from 

bomb. Works UF4-

magnesium mixture 

down with tapered rod. 

Smooths and packs with 

tamp and mallet. 

4.8 12 58 66,950 

(Average of 4 samples) 

(High – 111,500 

 Low – 44,100) 

3,880,000 

General air magnesium 

room. Sampling and 

riffling magnesium. 

– – 60 106 

(Average of 3 samples) 

(High – 180 

 Low – 80) 

6,300 

General area. – – 294 250 

(Average of 6 samples) 

(High – 360 

 Low – 189) 

75,250 

Sweeping up UF4 from 

the floor. 

– – 6 97,000 582,000 

Removing and cleaning 

3 trays from mixer and 

replacing. 

– – 3 32,700 96,100 

Lunch room – – 20 109 

(Average of 3 samples) 

(High – 203 

 Low – 52) 

2,180 

Locker room – – 15 122 

(Average of 5 samples) 

(High – 289 

 Low – 52) 

1,830 

515 20,663,660 

Average alpha concentration = 

515

660,663,20 = 40,400 d/m/m3

. 

Assuming 10 cubic meters of air per day 

Daily concentration = 40,400 × 10 = 404,000 d/m/day. 

Note: Operators wear masks while working in green salt room. 

Source: SRDB 8912 
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Green Salt Loader 

1 man per shift – 3 shifts per day – total, 3 men 

Measurement Date – August [redacted], 1949 

Time 

(Min.) 

No. of Times 

per Shift 

Total Time 

(Min.) 

Alpha Concentration 

in Alpha dpm/m3

Concentration 

Times Time Operation 

Wheels bomb into 

enclosure, stops mixer, 

loads mix into bomb, 

reloads mixer.* 

6 14 84 92,700 

Average of 4 samples 

7,800,000 

Fills containers with 

weighed amount of 

magnesium. 

60 1 60 1,050 

1 sample 

63,000 

Cleans up green salt 

loading area. 

18 1 18 640 

1 sample 

11,500 

General air, green salt 

area. 

318 72 

Average of 9 samples 

22,900 

Lunch room. 20 97 

Average of 2 samples 

1,940 

Locker room. 15 21 

Average of 2 samples 

315 

515 7,899,655 

Average weighted exposures = 

NOTICE:

515

655,899,7 = 15,300 alpha dpm/m3

. 

Multiple of preferred level = 70

300,15 = 219. 

* Operator wears dust mask. 

Source: Dust Samples 1949 (SRDB 8930) 
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APPENDIX B: COMMENTS OF DATA REDUCTION IN TBD-6001 

In Table 8 of this report, we extracted inhalation limits from Table 8.29 of TBD-6001 and used 

that data as a basis of comparison with the Electro-Met-specific inhalation limits included in 

Appendix C (Table C.2) of TBD-6001. The relevant data in Table 8.29 for metal reduction and 

casting are, in turn, traceable to Tables 8.16 (Lognormal Distributions of Parameters for Metal 

Reduction) and Table 8.19 (Lognormal Distributions of Parameters for Metal Recasting). The 

input data to calculate the lognormal parameters were originally reported in Christofano and 

Harris (1960). Christofano and Harris provided the minimum, maximum, and average values of 

the “weighted average” concentrations for each job category, based on air samples taken from 

1948 through 1958 at seven uranium refining plants. The relevant data used to calculate the 

lognormal parameters are summarized in Tables 8.15 and 8.18 in TBD-6001. 

NIOSH presumably used guidance in Battelle-TIB-5000 (Strom 2006) to calculate the lognormal 

parameters. Specific guidance provided in Section 2.1.2.4 of that document states: 

The average value is generally a more robust statistic than minimum or maximum 

values, which can be outliers. The preferred default assumption is to ignore the 

minimum and maximum values, use the average (arithmetic mean) value, and 

assume a lognormal distribution with 

• A GSD of 5 for data describing a single process (e.g., a series of air 

samples), or 

• A GSD of 10 for data describing an entire site, plant, or factory. 

The basis for assuming these GSDs derives from analyzing data from many 

facilities. The median (GM) x50 is computed from the average (arithmetic mean) 

× using 

 x50 = x exp(-σ

2

/2) 13 

where σ = ln(GSD). 

NIOSH used this approach (i,e., equation 13 from Strom 2006) and an assumed GSD of 5 to 

calculate some of the medians in Tables 8.16 and 8.19. In other cases, NIOSH calculated the 

median using the following equation (Equation 8 from Strom 2006): 

 x50 = √xminxmax 

This equation assumes that xmin and xmax are symmetrical about the median. Table B-1 

compares the calculated medians. Highlighted values in Columns 2 and 3 indicate the values 

selected for inclusion in TBD-6001. For all but two operations, the median was based on the 

square root of the product of xmin and xmax. 
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Table B-1. Calculated Median Values for Operations in Tables 8.16 and 8.19 

of TBD-6001(Units – dpm/m3

) 

Operation 

Median Weighted 

Average from 

Equation 13 

Median Weighted 

Average from 

Equation 8 

Median Weighted 

Average Reported in 

Tables 8.16 or 8.19 

Bomb preparation 831 240 240 

Reduction operations 355 82 82 

Bomb breakout* 234 139 234 

Crucible loading 14 44 44 

Recasting 301 672 672 

Crucible burnout 14 50 14 

Billet cleaning 13 33 33 

Crucible assembly 99 232 232 

 *- Based on general area sample 

Observation: NIOSH does not provide a rationale in TBD-6001 for the approach taken to 

calculate the GM from the Christofano and Harris (1960) data. In most cases, they did not use 

the more robust method described in Section 2.1.2.4 of TIB-5000. NIOSH should document the 

basis for their decision-making. 

SC&A also examined the basis for the GSD calculations in the same sets of tables. Although not 

specifically mentioned in TBD-6001, we assume that σ [i.e., ln(GSD)] was calculated using 

Equation 9 (the companion equation to Equation 8) from Strom 2006: 

 σ

2

 = 2ln x-ln xmin – ln xmax (9)

The values of σ were calculated using Equation 9, converted to GSDs, and compared to the 

values listed in Tables 8.16 and 8.19 of TBD-6001. The comparison is presented in Table B-2. 

Table B-2. Comparison of Calculated Geometric Standard Deviations for Selected 

Operations with Values Reported in Tables 8.16 and 8.19 of TBD-6001 

Operation GSD Calculated 

Using Equation 9 

GSD Reported in 

Tables 8.16 or 8.19 

Bomb preparation 1.381 5 

Reduction operations Sigma is negative 

number 5 

Bomb breakout* 3.596 5.145 

Crucible loading 1.731 1.351 

Recasting 2.700 2.683 

Crucible burnout 1 5 

Billet cleaning 2.280 1.972 

Crucible assembly 2.549 2.4 

 *- Based on general area sample 

It is not always apparent why NIOSH chose the default GSD value of 5 in some cases and not in 

others. It is also not clear why the GSD values calculated using Equation 9 from TIB-5000 do 

not closely agree with the values reported in Tables 8.16 and 8.19 of TBD-6001. 
Effective Date: 

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NOTICE:

Finding: NIOSH should document in TBD-6001 the basis for selecting when the default GSD 

was used, and how the GSD was calculated when the default value was not used. 

References 

Strom D.J. 2006. Default Assumptions and Methods for Atomic Weapons Employer Dose 

Reconstruction. Battelle TIB-5000 Rev. 00-A.14, Battelle, Richland, Washington. 
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APPENDIX C: AREA PLANT PLOT PLAN 

 Source: ElectroMet 1946a (SRDB 59225)
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APPENDIX D: AIR SAMPLING RESULTS 

Table D-1. Air Sampling Results from May/June 1943 

Sample Operation Sampling 

Location 

Total Dust 

(mg/m3

) 

Uranium Dusta 

(μg/m3) 

Alpha Activityb

(dpm/m3

) 

601 Filling bomb with green salt and Mg

4.5 ft from floor, 

1 ft from bomb 

loading, 3 ft from 

mixer 

51.7 31,800 48,300 

602 Emptying bombs with sledge 

hammer 

4.5 ft from floor, 

5 ft from bomb 9.4 2,350 3,570 

603 Lining bomb with dolomite 

4.5 ft from floor, 

1.5 ft from 

2 bombs 

4.7 423 642 

604 General test – above shipping 

platform 

4.5 ft above 

shipping 

platform, 1.5 ft 

from steps 

1.17 188 285 

a – X material 

b – Based on specific activity of natural uranium of 684 pCi/mg and 2.22 dpm/pCi 

Source: ElectroMet 1943 [SRDB 5809] 

Table D-2. Air Sampling Results from April 5, 1944 

Sample Operation Total Dust 

(mg/m3

) 

Uranium Dusta 

(μg/m3) 

Alpha Activityb

(dpm/m3

) 

5 8 ft from packing of dolomite 2.47 400±10% 607 

6 5 ft in front of burners whole metal is being 

burned out of crucibles 6.47 380±10% 577 

7 5 ft from chipping operation 4.23 1,700±10% 2,850 

8 Center of the floor to test general conditions 2.82 330±10% 501 

9 2 ft from where charge is dumped into bomb 4.7 180±10% 273 

10 4 ft from green salt mixing 

(not mixing all the time) 8.81 2,700±10% 4,100 

a – X material 

b – Based on specific activity of natural uranium of 684 pCi/mg and 2.22 dpm/pCi

Source: Dust Sample Results, April 1944 [SRDB 16247, pdf p. 6] 

Table D-3. Air Sampling Results from May 16, 1944 

Sample Operation Total Dust 

(mg/m3

) 

Uranium Dusta 

(μg/m3) 

Alpha Activityb

(dpm/m3

) 

11 4 inches in front of crucible 2.47 437 664 

12 8 feet from chipping bench 0.47 209 317 

13 Center of room in front of remelt 

furnace 2.23 437 664 

14 5 feet from operator of crushing 

machine 16.6 361 548 

a – X material 

b – Based on specific activity of natural uranium of 684 pCi/mg and 2.22 dpm/pCi 

Source: Dust Sample Results, June 1944 [SRDB 7726] 
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The authors of Dust Sample, June 1944 (SRDB 7726), observed that “dust concentrations in the 

chipping room had been cut down to a safe value...” However, because the other dust samples 

were well above the tolerance level of 150 μg/m3

, “it is recommended that steps be taken to keep 

the dust contamination down.” 
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APPENDIX E: MASTER INTERVIEW SUMMARY 

INTRODUCTION 

As a technical support contractor to the Advisory Board on Radiation and Worker Health 

(Advisory Board), SC&A has been tasked with reviewing NIOSH’s SEC Petition Evaluation 

Report for the Electro-Metallurgical Corporation facility (Electro-Met). One component of 

SC&A’s review is a series of interviews with site experts, including former site workers, a 

petitioner, and a petitioner’s representative. The purpose of these interviews was to obtain 

information on past radiological control and personnel monitoring practices, and to better 

understand how operations and safety programs were implemented at the site over time. 

Interviewees were identified through petitioners and other interviewees. This report summarizes 

the results of those interviews. 

SC&A interviewers Kathryn Robertson-DeMers and Lynn Ayers conducted telephone interviews 

or communicated in written form with the interviewees between February 22 and August 16, 

2010. Former workers, one petitioner, and one petitioner representative participated in these 

interviews. All of the former workers were employed at the site during the contract period 

(1942–1953), with one continuing employment at Electro-Met beyond that time. The workers 

represent laboratory and maintenance personnel. The petitioner and petitioner representative 

speak for deceased energy employees who worked at Electro-Met during the atomic weapons 

contract. 

SC&A explained that the interviews were being conducted on behalf of the Advisory Board as 

part of their review of the National Institute for Occupational Safety and Health’s (NIOSH’s) 

Special Exposure Cohort (SEC) petition evaluation report. Participants were told that the 

interviews were unclassified, and that they should not disclose any classified information. 

Summaries from each interview were prepared and provided to the interviewees for review. All 

of the interviewees provided responses to SC&A, have reviewed and approved their written 

summaries, and their responses are represented in this master summary. 

This summary report is not a verbatim presentation of the material contained in the interview 

notes, nor is it a statement of SC&A’s findings or opinions. It is a consolidated summary of 

statements, opinions, observations, and comments that the interviewees communicated to SC&A. 

The sole intent of this summary document is to communicate to the Advisory Board and other 

interested parties the information that the interviewees communicated to SC&A. Where 

conflicting observations and statements have been received, both perspectives have been retained 

in this summary report. Any comments inserted by SC&A for the purpose of clarification are 

designated by brackets. 

Information provided by site experts is invaluable in helping SC&A to better understand the 

operations at Electro-Met. Information provided by the interviewees was based entirely on their 

personal experience with Electro-Met. It is recognized that the site experts’ recollections and 

statements may need to be further substantiated; however, they stand as critical operational 

feedback and reality reference checks. The interview summaries are provided in that context. 
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With the preceding qualifications in mind, this summary has contributed to SC&A’s 

understanding of issues raised in the Electro-Metallurgical Corporation SEC petition. 

PRODUCTION AND ANALYTICAL OPERATIONS 

[The interviewees, collectively, provided their characterization of radiation-related facilities and 

work, as follows.] 

Facilities 

The plant was located at 47th and Royal in Niagara Falls, New York. It was known as ElectroMet and Union Carbide (now Dow Chemical). 

There was one building that supported work for the Manhattan Project; it was knocked down in 

about 1957. The “Area” Plant, Building 166, was a cinder block, single-story building about the 

size of two garages. It was a substantive building for that time. According to the petitioner, [the 

Area Plant] was a small building, only 50 feet by 217 feet, but it housed the lunch room, offices, 

shipping and receiving, the furnace area, etc. With so much going on in such a small building, it 

doesn’t seem possible that any worker who was in there could have avoided contamination and 

exposure. The analytical laboratory was on one end, and the production area and furnaces were 

on the other end. They had one or two furnaces in that building for the uranium project. There 

were fans and hoods in the lab area. The production area had its own ventilation. The furnace 

room was dusty and very hot. 

There were also other furnaces in two or three other buildings where a variety of other metal 

products were made. They had a total of 13 furnaces at Electro-Met. Electro-Met made stainless 

steel—that was a main product. They also made welding rods for an electric welding process, 

including rods for underwater welding. Electro-Met developed this technology. The Navy used 

welding rods like the ones they made at Electro-Met to repair buckling metal while the ship was 

at sea. 

The uranium building was behind the Union Carbide Research Building. Workers were 

interviewed, hired, and had training at the Research Building. There was quite a bit of space 

between the buildings, but workers could go between the buildings easily. Interviewees’ 

estimates of the distance to neighboring buildings ranged from 50–100 feet to at least 100 yards. 

They did not have a lunch room in the uranium facility, so they ate outside or went off-site for 

lunch. 

Some radiological work was done in the Research Building off Royal Avenue before the new lab 

in the Area Plant was operational. When the plant was first starting up in late 1942, there was an 

area in the Research Building where they did analysis on uranium metal to help the workers get 

acquainted with the procedures. Sometime in 1943, the analytical laboratory was moved to the 

new uranium facility [Building 166]. 
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Interviewees were not aware of radiological work being done in any other buildings on site. 

When asked if there were radioactive materials outside of Building 166 [e.g., in the yard], they 

did not know. 

Work Force 

The uranium work was sponsored by the Manhattan Engineering District (MED); it was before 

the Atomic Energy Commission (AEC). The uranium project workers and the research lab 

workers technically worked for Union Carbide Research Lab at the time. 

There was no shift work in the lab. There may have been shift work in the production area. 

People worked very hard at the time; they didn’t watch the clock in those days. 

Interviewees estimated that about 50–75 people worked in the uranium facility at a time. There 

were 8–10 individuals in the laboratory. There were at least 5 or 6 people on the engineering 

side of the house. There were about 15–20 people working in the production area of the uranium 

shop on each shift. 

The entire Electro-Met facility had about 2,000–3,000 people. There was an entire building with 

administrative office workers. New construction was hired from the local union halls. 

It was important to keep the process going. On one occasion, there was so much snow on the 

ground, they weren’t sure if people could get to the plant through the snow. A [redact] got to 

work and turned out to be the senior professional on site for the day. He was worried that if the 

workers were sent home and couldn’t get back to the plant, there wouldn’t be enough individuals 

to run the process. Since this was the case, he had to keep the people at the plant who were 

already there for overtime (24–48 hours). They were treated well, and the professional in charge 

made sure they got fed at the cafeteria during this time. 

Production Operations 

The plant mission was to take uranium tetrafluoride [UF4] and convert it to uranium metal. The 

uranium metal was forwarded to other areas in the Manhattan Project. 

They handled natural uranium in the form of uranium tetrafluoride, and also dolomite, high-fired 

dolomite, and high-purity magnesium. The uranium material came in as green salt (UF4). They 

used only natural uranium, not enriched uranium, at Electro-Met. They only reduced the 

uranium to metal—other facilities did shaping/fabrication of the fuel. There were no other 

[radioactive] projects at Electro-Met. 

The process [used at Electro-Met] was developed at Iowa University at Ames, Iowa. It was 

similar to the Mallinckrodt Chemical Works (MCW) process, but Electro-Met refined it a little 

bit. Electro-Met had a bit of an advantage over MCW, which started the process. By the time 

Electro-Met started the project, they knew what would work, so they were able to make 

improvements. 
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The reaction chambers [used in production] were metal containers (steel, lined with dolomite). 

The material was prepared with care and thoroughness—using dolomite, magnesium, and UF4. 

They used a furnace to initiate the reaction. It operated at high temperature—the reaction is 

exothermic. After cooling, they would disassemble the chamber to get the metal plugs or buttons 

out of the reaction container. 

After the reduction reaction, the uranium metal button was like a large doughnut sitting at the 

bottom of the chamber. They had to clean the product before working on it further; they wanted 

the billets to be pure. [The metal plugs or buttons] were gathered, melted, and cast into 

cylindrical forms as billets. Casting was done in graphite—under vacuum—by radio frequency 

induction heating. After casting, the graphite was broken away and the metal was cleaned. 

Billet samples were taken for laboratory analysis. 

To the best of the interviewee’s knowledge, they did not handle thorium at the Electro-Met 

Building. An interviewee is not aware of Electro-Met receiving any scrap uranium metal from 

outside. The metal that came in was magnesium. 

Packaging and Shipping 

Incoming material was packaged in drums, bags, and barrels. Material was unloaded by towmotors and brought into the facility; the same process was used for outgoing material. Workers 

and furnace operators handled the material. An individual who worked in the furnace area was 

also involved in shipping and metals; he would package the metals that were produced and ship 

them to the companies that ordered the material. 

Uranium was packaged and shipped in a different building than where the material was 

processed. The product didn’t hang around for long. The billets were shipped out by train in 

boxcars; a track went right by the plant. They were put in wooden boxes of the correct 

dimension; each billet was handled separately. The boxes were nailed shut and moved onto the 

trains that came to pick them up. They would go into the boxcars. There was some element of 

reasoning for placement—they designated how to arrange them in the car—the worker didn’t 

know why at the time. 

One interviewee said the incoming and outgoing trains were guarded. Another worker said there 

was no security escort. 

Analytical Operations 

In the Chemistry Laboratory, workers determined the purity and density of the uranium metal 

that was processed in the plant. The material was handled manually. A chemist would take a 

piece of the metal for analysis. The metal was dissolved and analyzed for specific impurities. 

The analysis involved wet chemistry, use of spectroscopic methods, and use of colorimetric 

methods. They observed the valence change and oxidation state in solution during the 

dissolution process. 
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Analytical samples were prepared from samples taken from uranium billets. Laboratory workers 

were responsible for collecting the billet samples [from the production area] and analyzing the 

metal. A worker who collected samples would go in and out of the production area; he visited 

often. The sample taken from the billet was approximately 3 inches in diameter and 

approximately 1⁄4-inch thick. Laboratory workers used a hacksaw to cut the samples. An 

interviewee said pieces were broken off to perform chemical analyses. Some workers recalled 

that they used a vise and a rasp file to remove black residue from the outer surface. Another 

laboratory worker does not remember cleaning magnesium metal off the uranium metal; the 

uranium metal was cleaned by people in the production area before they arrived in the 

laboratory. 

Density of uranium analysis was performed on each billet sample. The sample was sawed in 

half. One half was filed smooth to remove black residue on the outside. The half-moon sample 

was hung by platinum wire on an analytical balance and weighed. It was weighed again while 

immersed in a glass beaker containing distilled water. The difference in the two weights was 

recorded to determine the density of the metal sample. 

Uranium samples were heated in furnaces to determine how much carbon and hydrogen and total 

solids were contained in the uranium. Uranium was dissolved in acid and heated to perform 

analyses for iron, nitrogen, and boron content. 

Analysis of uranium for carbon and hydrogen was done by combustion. The exit of the 

combustion tube was packed with asbestos that had been soaked in a solution of silver nitrate and 

dried. Ascarite [a product used to absorb carbon dioxide] was also used. The sample burned at 

high temperature. The silica combustion tube would not melt at this temperature, but it often 

cracked from the heat. This was time-consuming, because the worker had to start over with a 

new tube and a new sample. A laboratory worker said one reason he left Electro-Met was that he 

was tired of dealing with cracked tubes. 

Laboratory personnel filled out forms for each billet that they analyzed (nickel, boron, cadmium 

elements). They had to report the analysis for each billet; that was standard. 

MAINTENANCE AND CRAFTS 

[The interviewees with maintenance and crafts experience, collectively, provided their 

characterization of their radiation-related work in various onsite facilities, as follows.] 

A dust collector was a big metal or wooden framework that held a screen and a bag. One end of 

the frame was open, and one end had a screen. It was as big as a room. They took a lot of metal 

dust out of the air. Normally, they changed out the bags in the dust collectors about every 

3 months, but sometimes they got busy and went a little longer between changes. Maintenance 

also replaced dust bags when they broke open or got plugged up. As soon as the dust collectors 

started getting plugged, they would send a maintenance group in to change/replace them. If you 

didn’t keep the dust collector working right, the furnace could overheat. 
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To change the dust bag, maintenance would pull out the old bags or filters. Sometimes a 

maintenance worker had to climb into the unit to put the filters and bags back in place. 

Sometimes going into the dust collector was like going into a fog—you couldn’t see or breathe. 

It looked like pictures of old steelwork areas. 

Maintenance workers had to repair furnaces as necessary when they blew out. They would shut 

off the furnace, cut damaged sections out, fabricate replacement pieces, repair the crack or hole, 

and get it back up and running. This required them to go inside the furnace when it was cooled 

down. 

There was a sheet metal shop at the plant. The Area Plant had a repair shop for fixing things that 

broke down, in addition to the uranium processing area. 

Janitors assigned to the Uranium Plant were assigned only to the Uranium Plant. They were 

responsible for keeping things clean. They were definitely in the laboratory and possibly in the 

production area. 

SECURITY 

[The interviewees, collectively, provided their characterization of security practices, as follows.] 

There was a fence around the entire Electro-Met plant, with a guard at the gate. There were two 

entrances to the plant; (1) off Pine Avenue, and (2) at Royal and 47th Street. Family members 

who drove workers to the site would let the workers off before the gate to the plant. The workers 

would pass through the gate; the family members who were not Electro-Met employees were not 

allowed to go beyond the gate. 

An interviewee does not remember [an additional] fence or guard at the Research Building when 

radiological work was done there. All he had to do was to walk into the building. 

[There are some discrepancies in former workers’ recollections of access controls specific to the 

Area Plant.] 

 Laboratory workers recalled that uranium operations areas were restricted to workers 

who were directly involved in these operations. 

o An interviewee does not remember the details of security, but the uranium 

building was not open to everybody. It was a wartime thing, and it was important. 

The worker never discussed anything with anyone outside the building. It was 

kept very hush-hush. 

o Some workers recalled that there was a second enclosure fence around the 

uranium facility [Building 166]. The gate was guarded, and workers had to show 

a badge to the guard to gain entry. 
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o Another worker did not recall any additional barrier separating the Uranium Shop 

from the rest of the Electro-Met facility, but he thinks they had special 

identification to enter the Area Plant and that guards would prevent people from 

coming in without proper identification. 

 A maintenance worker does not remember an additional fence or security checkpoint at 

the uranium area. They had Security at the main gate. Once you got inside the plant, you 

could go into any building. All the plant was pretty wide open to the workers. Nothing 

prevented workers who were not assigned to the uranium program from gaining access to 

the uranium work areas. Anyone could go from building to building. 

The chemists had access to the operations area, but they did not go there every day. Laboratory 

workers didn’t participate in the production activities directly, because it was pretty restricted. 

Workers never mentioned their work on the Manhattan Project [to their family]. Individuals 

were sworn to secrecy. A worker described a situation that illustrates the level of secrecy about 

the project at the time. When a doctor evaluating an unusual health problem asked if he worked 

with a heavy metal, the worker said, “I can’t answer that question.” They were working in a 

wartime situation—the doctor knew enough to ask, and the worker knew enough to say, “I can’t 

answer.” 

RADIOLOGICAL CONTROLS 

[The interviewees, collectively, provided their characterization of radiological control activities 

at the Electro-Met facility, as follows.] 

A laboratory worker did not think the work he did at Electro-Met was particularly hazardous. 

Uranium emits an alpha, which can be stopped by a sheet of paper. There was nothing 

particularly deleterious about the work they did with uranium; it was a lot like working with 

lead, another heavy metal. It wasn’t considered a serious hazard, at least not for the time. 

People have gotten a lot more concerned about hazards over time. For example, a chemist using 

a Bunsen burner often used a screen that contained asbestos; that was just what you did. Now, 

everyone avoids asbestos. 

A worker does not recall a formal Radiation Safety Program. 

When asked about interactions with the New York Operations Office (NYOO), an interviewee 

said they may have been involved with the higher ups. Laboratory workers knew when the big 

shots were coming in, but didn’t interact with them. It was their job to keep the laboratory clean. 

Surveillances 

They took precautions, even in those days. The detection limits have improved over time. 

Methods of detection of radiation have improved to the point where things can be detected at 

very low limits. The detection levels just weren’t there at the time. They did the best they could 

at the time. 
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Workers were not required to survey their clothing, hands, or feet with radiation detection 

instruments for radioactive dust when they left production areas to go to non-radiological areas 

of the building (office, break room, etc.). They were not required to survey when they left the 

buildings where uranium work was conducted. One individual said they may have changed 

shoes, but he was not certain. 

A worker was assigned by management to collect air samples to check for uranium dust in the 

air. The air samples were taken in the general area of the room or at the hood. This was being 

done with some routine frequency—not sporadically—for some time before the summer of 1946. 

They pulled air through a filter and sent the filter out for analysis. The interviewee doesn’t 

remember the details, where they sent it, or who he gave the samples to. Samples were probably 

collected from both the production area and the analytical lab. Management encouraged 

professionals to take the credit and the responsibility for the work they performed. The lab 

worker took it to the supervisor, and he said “You did the work, you sign it.” 

Contamination Control 

The analytical work was done in hoods. They had the usual hoods at Electro-Met that were used 

in an analytical lab. Gloveboxes were not available and were not used for this time period; they 

emerged slowly over time. There were separate hoods and design systems for the lab. Consult 

the engineering drawings for the remainder of the plant. 

They tried to keep the production area clean. It was a metallurgical process area—what does 

clean really mean? They were meeting the standards of the time as they knew them. This was 

an embryonic thing; they didn’t know a lot about things at this time. 

Interviewees did not know if uranium could have been tracked from the uranium shop to other 

areas of the Electro-Met facility; they did not recall any specific issues with uranium tracking. 

Material might have gotten out by mistake, maybe on someone’s clothing. It could be tracked to 

other areas on shoes. There was no difference going from building to building. There were no 

special practices unique to the uranium building. 

Showers were available; the interviewee is not sure how often people showered. A laboratory 

worker did not have to shower after going into the production area; he does not know if the 

production workers were required to shower. A maintenance worker was not required to shower 

after working in the uranium shop. He did shower and change clothes at the end of the workday. 

He took a shower on his own time after work. 

A worker said eating, drinking, and smoking were permitted in “safe areas” (e.g., offices). One 

worker said they were allowed to eat and drink in the chemistry laboratory, and another lab 

worker said they were not. Laboratory workers did some mouth pipetting; this was a routine 

practice at the time. They did not have vacuum suction devices to use in pipetting. 

An interviewee doesn’t know how effective the controls were or how well the material was 

contained. If you did get it on your clothes and walk around with it, you didn’t know. The lack 

of controls would never be acceptable today in the U.S. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Personal Protective Equipment (PPE) 

Maintenance wore regular work clothes they bought at the store, no matter where they were 

working. The company did not provide work clothing and did not have a laundry facility. The 

worker had two or three sets of work clothes. Some personnel left their work clothes at the shop 

unless they were dirty; they brought them home to get washed once or twice a week. Workers in 

the chemistry lab could wear white coats. 

Workers wore hard hats most of the time out in the plant areas. They used safety glasses, 

goggles, gloves (including asbestos gloves for furnace work). Maintenance had no special PPE 

for changing bags in the dust collector; although, they may have chosen to wear a respirator as 

needed for low oxygen, due to the heavy dust levels. In general, dust masks and respirators were 

worn in the furnace room or wherever the dust was bad. The boss was not around telling you to 

wear particular safety gear; a worker used their own judgment and wore what was appropriate 

for the job conditions. Not everyone wore a respirator. 

The respirator was a mask that covered the face; there was a regulator on the back of the neck. 

There was a multiple-use policy; the respirator would be left in the area for the next guy to use. 

All PPE—hard hats, gloves, glasses, respirators, etc.—was made available in an area and was 

worn by multiple users. The equipment was not issued or assigned to a particular worker. 

When laboratory workers cut and filed uranium billet samples, the filings fell on the floor or on 

the vise used to hold the sample. Workers wore eye protection, but no gloves or respirators 

during this process. On occasion, workers saw sparks when they swept up filings. A worker 

held his breath to avoid inhaling the fumes (smoke from the sparking uranium). One interviewee 

wore a face mask when handling and preparing uranium samples; he does not recall where they 

were stored when not in use. 

Environmental Monitoring 

An interviewee does not remember them conducting any analysis of the ground around ElectroMet while he was there. Uranium is found in soil. Rare earths are also prevalent in the soil 

naturally. 

EXTERNAL MONITORING 

[The interviewees, collectively, provided their characterization of how external monitoring was 

performed historically at the Electro-Met facility, as follows.] 

[Recollections about external monitoring were variable.] Of the workers interviewed, some did 

not recall whether or not they wore badges or dosimeters at Electro-Met. One interviewee “did 

not have the pleasure” [of wearing a monitoring device], and one interviewee stated that film 

badges were used at Electro-Met. 
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INTERNAL MONITORING 

[The interviewees, collectively, provided their characterization of how internal monitoring was 

performed historically at the Electro-Met facility, as follows.] 

[Submittal of bioassay reported varied by interviewee.] One interviewee recalls submitting urine 

for bioassay. Other interviewees did not recall submitting urine bioassay. Another recalls that 

Electro-Met First Aid nurses collected a blood sample once a month. Urine samples were given 

during yearly or semi-annual physicals. 

INCIDENTS 

[The interviewees, collectively, provided their recollection and understanding of what incidents 

occurred at the facility and how they were handled, as follows.] 

[Different recollections were presented in regard to “blow-outs” or “bomb explosions.”] 

 There were no high energy explosions at Electro-Met. Sometimes—not frequently—

there might be a leak if the seal didn’t get sealed all the way. 

 You could get blow-outs in the cradle [the bomb or reaction vessel]. These blow-outs 

would include anything from cracks to holes in the cradle. 

An interviewee is not aware of any official documents for documenting blow-outs or other 

incidents. Your boss would tell you to fix the problem. 

Small chemical explosions sometimes happened in the laboratory hoods as a result of a 

perchloric dehydration process. Dust and condensate accumulated in the [ventilation] ducts as a 

normal part of the analytical lab process. Heat could set off the dust, but this was a normal thing. 

There would be a pop, and the workers had to stop and clean the area. It happened 

periodically—more than once over a 3-year period. 

MEDICAL 

[The interviewees, collectively, provided their characterization of how medical monitoring was 

performed historically at the Electro-Met facility, as follows.] 

An interviewee recalled that medical services were located in a neighboring building, separated 

from the Area Plant. A nurse was routinely available; an interviewee thinks they had one right 

there in the Area Plant. There was a nurse assigned to the area also. Workers saw them quite 

frequently. A worker saw the doctor more at Electro-Met than at his later workplaces. 

A physical examination was required once or twice a year with x-rays (chest). Workers 

submitted urine samples during this physical. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

[Electro-Met extended a high level of care for a worker with a chronic condition.] The doctor at 

Electro-Met sent the worker to a prominent medical facility in an effort to diagnose the problem. 

The doctor sent him there and Electro-Met paid him while he was gone. There was a care that 

was expressed, even though they didn’t figure it out at that time. 

RADIOLOGICAL RECORDS 

Interviewees were not aware of any documents or records related to the historical operations and 

potential exposure conditions at Electro-Met. The Medical Department may have kept records. 

An individual was involved with the claims process for at least five Energy Employees or their 

survivors. They were not able to retrieve any of the radiation records for these individuals. 

Records were destroyed, inadequate, or unavailable. 

WASTE MANAGEMENT 

[The interviewees, collectively, provided their characterization of how radioactive and 

hazardous waste was handled historically at the Electro-Met facility, as follows.] 

Cleaning of the surfaces may have generated some waste. There was no waste in the sense of 

lousing the material up. 

Acid solutions of uranium were collected in a container. They were neutralized to pH 7, and the 

precipitate was filtered. The uranium was in the precipitate. The small amount of waste 

handling was done at the lab sink. The interviewee does not remember if the liquid went into the 

sink or was poured into another container, but does recall filtering it. 

They had a dump area outside Niagara Falls going toward Lockport; it was less than half a mile 

from the plant. The waste from the uranium processing was dumped there, as well as waste from 

other operations. Another dump was located near Lake Ontario. There were railroad tracks 

running right up by the building. Waste was put on flatbeds and sent to the dump—the one 

behind the plant or the one on Lake Ontario. This is where they dumped all this stuff. The 

facilities are still there where they dumped the waste. 

They tried to keep the piles separate, in case they might need to go back and use it again. They 

thought it didn’t have a use at the time, but they have dug up a lot of material from the waste 

dumps. Sometimes waste was reprocessed for other uses. 

SEC PETITIONERS’ COMMENTS 

Basis for Petition 

One petitioner chose to include the entire Electro-Met population in the petition, rather than only 

those individuals who worked in the Area Plant. Electro-Met was a very small plant, and 

workers were walking into areas with uranium even if they didn’t work there all the time. For 

example, maintenance was in and out of the building where uranium was processed. They would 
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walk around the furnace areas. The petitioner felt that everyone who was exposed should be 

included in the SEC group. 

The original timeframe for Petition SEC-00132 was from 1952 to 1959, based on an employment 

record provided by Dow Chemical for the survivor. When discussing the time period with 

NIOSH, they said to limit the petition to the time when they were actually doing the [uranium] 

work. They recommended a cutoff date of December 1953. In the evaluation report, they cut it 

off in June 1953. The contract ended in June 1953, so NIOSH’s timeframe does not allow for 

any cleanup period beyond the end of the contract period. If there was a cleanup effort, the 

contamination would be stirred up, perhaps even more than it was during production. 

There was no evidence that there was a period of cleanup. There was certainly residual 

contamination. In fact, in the evaluation report, NIOSH indicates that there were contamination 

surveys in August 1953 and contamination was present. Ending the class in June 1953 does not 

make sense. Workers should be given at least some time beyond the contract because of the 

residual contamination. 

Petitioners have referenced an article that was published in USA Today. The article indicated 

that the Electro-Met facility was lacking meaningful records and had dust concentration levels at 

many times the limit of the time. Another document, called “The Legacy of the Manhattan 

Project at Niagara Falls,” was also provided to the Department of Labor (DOL). “The Legacy of 

the Manhattan Project” mentions that Electro-Met reprocessed filings from Simonds Saw and 

Steel, including uranium filings and thorium. There was a series of articles called the “The 

Bomb that Fell on Niagara.” It included an article on Human Radiation Experiments. These 

articles mentioned a dump site near the Pine Avenue area. There was a permanent dump site, 

which is the only hill in Niagara. 

A petitioner’s information about the absence of records and monitoring was specific to [a family 

member’s] case. General information about work conditions and monitoring came from USA 

Today articles and similar types of information. 

A primary basis for the petition is lack of records. No dosimetry records are available for an 

individual who was stationed in the uranium facility. The individual either did not wear a 

dosimeter or [the records] were destroyed. 

For supporting documentation, a petitioner had letters from the retirement service stating that 

[the Energy Employee’s] records had been destroyed. There were no existing records whether 

the Energy Employee had ever worn a dosimeter or not. NIOSH asked a petitioner if [the 

Energy Employee] had ever worn a dosimeter. The petitioner wrote a letter to Dow Chemical 

requesting [the worker’s] dosimeter records. They wrote back saying the records were 

destroyed. The petitioner had to write to Dow Chemical a second time requesting dosimetry 

records and was told there were none. 

There are errors and details missing from the worker’s employment record from Dow Chemical. 

For example, the worker’s time at two other facilities was not on the record. The petitioner was 
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able to locate a coworker of [the family member] who verified that he worked at another facility 

for a period of time. 

Even NIOSH has acknowledged that there were not a lot of records. There were air sampling 

records for 1948 and 1949, and limited records for other periods of time. NIOSH says the data 

are sufficient enough to render a decision. How, with such a limited amount of records, can they 

assign a dose? How does one explain the cancers that occurred? 

The articles referenced in the petitions indicate there was a lack of any real meaningful 

ventilation system. Documentation states that Electro-Met failed to even vacuum work areas, 

despite being “persistently instructed” by the AEC to do so. When AEC medical officials 

suggested that the AEC could pay for new ventilation, the higher-ups balked at the time. It was 

felt that it would only be a few more years before federal facilities would be built to take over the 

work done at Electro-Met, and that the system was cost prohibitive. 

Even when the operation was on standby, there was exposure to residual contamination. There 

was a focus on production. The area was not cleaned up properly. The buildings looked like old 

factories; the windows were black and it was awful. Even in 1952–1953, according to the 

evaluation report, significant uranium surface contamination was present. The area was 

definitely not cleaned up to perfection, leaving some material behind. Nowadays, if you view 

the site from the fence, it looks like a pile of rubble with a metering hose and vent pipes. 

As discussed in a letter related to the SEC petition for another AWE facility, a reform to the SEC 

program is needed. How can you use limited data or incomplete data and a computer program to 

come up with an exposure? 

The burden of proof is so difficult unless you are a scientist. The claimants have an 

insurmountable burden of proof, since they do not have access to the records they need. The 

records and reports put out by NIOSH are difficult to analyze, technically complex, and not 

understandable. You need to be a scientist to understand and come up with proof. The burden of 

proof has clearly been placed on claimants and petitioners. The burden of proof should be on the 

government instead. 

Claims Process 

Individual people are not being listened to, and individual situations are not taken into account. 

Individual claims don’t seem to be handled on an individual basis. No one seems to be interested 

in the specific circumstances of an individual worker. They just put information (like a job title) 

into the computer and get a result out. 

It is not claimant favorable to assume that a worker was not exposed based on a job title. [The 

Energy Employee] is not here to speak for himself and tell you what he did. [Survivors] don’t 

know exactly what he did. Did administrative workers have to go into [radiological] work areas 

to collect time cards and deliver paychecks? Did they have to go into areas and ask workers 

about vacation? Were they asked to sweep dust off the floor because it needed to be done? 
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Details like this would affect an individual’s exposure, and there is just no way to know the 

information. 

There are a lot of assumptions being made in dose reconstruction. NIOSH doesn’t address 

monitoring or exposure to the support staff who intermittently visited the uranium area. Were 

there air concentration measurements for other areas of the plant [outside the Area Plant]? 

It is very difficult to get the medical/hospital records to support a claim, particularly for 

survivors. For example, an Energy Employee went to see the plant doctor, the Union Carbide 

doctor in Niagara Falls, for care related to his cancer. The [Electro-Met] plant was taken over by 

another company after Union Carbide. The employee’s survivors contacted the new company to 

request the Energy Employee’s medical records; however, they indicated his records were no 

longer available. 

If a cancer is considered secondary or metastatic, NIOSH/DOL does not consider it in dose 

reconstruction. [Given the scarcity of medical records], how do they know the cancer didn’t start 

there? 

An individual has been involved with several claims for family members and friends. Two of 

the claimants died of [redact] cancer, and they received full compensation after partial dose 

reconstructions. Two other claimants, who worked in the same departments for much longer 

periods of time, were denied compensation for other cancers. One worker who was compensated 

for [redact] cancer only worked there for [redact] months. The interviewee does not understand 

why one family member, who worked at Electro-Met for a few years, was assigned over 

100 rem, while another family member, who worked in the same departments through the entire 

covered period and beyond, was assigned less than 10 rem. 

It seems if a worker had [redact] cancer, it doesn’t matter when, where, or for how long the 

individual worked at the site, the worker receives compensation. For other cancers, including 

bladder, colon, and liver cancer, the workers are not being compensated. And bladder cancer is 

on the list of 22 cancers for an SEC. 

In one family, one sibling was compensated as a survivor, but another sibling was not 

compensated, because he was not under the age of 18 when his father died. 

[The process of filing a claim and a petition] was extremely frustrating and confusing. The 

process has been going on for 8 years, since the time the claim was originally filed. Why does it 

take years to go through the process? What takes so long? Why is it so difficult? The 

claimant/petitioner has been made to jump through all sorts of hoops. It seems like they send 

you on wild goose chases just to keep you busy, and then the information they asked for isn’t 

important when you get it. It is difficult to find the correct person to talk to. It feels like NIOSH 

tries to wear you down so you give up and quit. 

Initially, a claimant/petitioner was asked to provide Medical Records. Last year, they just noted 

that there was a [health condition that had not been addressed previously]. They asked for 

additional medical information associated with this condition. Because they waited 7 years to 
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request these records, the doctor was no longer available and the medical records (now over 

10 years old) had been destroyed. If they had asked for the additional records when the claim 

was first filed, the medical records would have been available. 

When a second cancer was discovered in the medical file, [a claimant] was told they were going 

to redo the dose reconstruction. The second dose reconstruction had a much lower probability of 

causation (POC)—it was about one-fourth of the value from the previous dose reconstruction. 

The claimant asked NIOSH about the reduction in the POC. They were told that the second dose 

reconstruction was a more realistic way of doing it, so the new numbers were more accurate. 

The interviewee doesn’t think it is claimant favorable to ever lower the dose reconstruction dose. 

It feels like the numbers are being manipulated to control the outcome (POC). 

Petition Process 

A petitioner doesn’t think there have been any Worker Outreach meetings for Electro-Met. 

There are none listed on the website for Electro-Met. 

A petitioner is aware of the petition areas on the NIOSH website and believes the petition on the 

website is complete. There were no worker affidavits associated with the petition. 

There was a particular woman at NIOSH that was very helpful to a petitioner navigating the 

process. She told them what to do and said she was available to answer any questions. She 

made sure they had the right forms. 

NIOSH did not interview the petitioners when they evaluated the petition. No one called during 

the evaluation process to discuss the petition. A petitioner received notice by FedEx that they 

approved the petition for review. 

Upon completion of the petition evaluation report, petitioners received a written report. No one 

spoke with them about it. A petitioner received a letter from NIOSH with the evaluation report 

attached. [NIOSH] indicated that the evaluation report had been completed and was being 

submitted to the Advisory Board. In the letter, it indicated that they would contact the petitioner 

at a later date to explain the details in the report, but there had been no additional contact. 

NIOSH did not explain the method for assigning a bounding dose and what this means. 

The [petition evaluation] report is difficult to read. It seems to go back and forth. It seems to go 

in one direction that favors the petition (e.g., agreeing that they don’t have monitoring records), 

but then it changes gears (e.g., badge data for a similar job title is sufficient). There are lots of 

“but” and “however” statements. 

NIOSH responded to concerns about blow-outs (mentioned in the petition) by saying there were 

no records supporting the occurrence of blow-outs. 

The Advisory Board denied a request to postpone the presentation [of the evaluation report] on 

Electro-Met, but assured the individual that there would be additional opportunities to provide 

information. Individuals could call in during the meeting and provide comments. During the 
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NOTICE:

comment period, a caller asked why the petition was denied. The Advisory Board indicated that 

it would be a while before the petition was considered, because they were going to have an 

independent agency look at it. The caller was told that additional information could still be 

submitted. 

A petitioner was listening in on a meeting when a representative from NIOSH said that only a 

small percentage of cancers are caused by radiation. This overlooks the fact that workers didn’t 

even know they were working with radiation or chemicals. Doctors questioned [a family 

member] about his risk factors for multiple myeloma. The only factors he had were being male 

and working with radiation (which he didn’t know). How can science figure out the causes and 

risk factors when the patients themselves don’t have knowledge of their exposure? 

MISCELLANEOUS COMMENTS 

 Initially, a laboratory worker didn’t know what they were working with. They were 

given the procedures and followed them like a cake recipe. They found out what they 

were working with when the bomb went off in Nagasaki. 

 Another interviewee said that the analytical chemists had the training to know the basic 

hazards of the material and to know the proper ways to handle it. They did not know all 

of the dangers, but they were trained as chemists and worked willingly. 

 There is lot of variation among people regarding the sensitivity of their bodies and their 

fear of radiation. No one really understands how it all works. It’s very difficult to look 

back—that was now almost 70 years ago—and decide if something back then caused a 

problem that’s happening now. 

 An interviewee said they were trained well at Electro-Met. Some well-known people in 

the field were involved with the Electro-Met projects. They had a very experienced and 

well-known metallurgist. 

 There were some chemicals in the analytical laboratory. Bunsen burners were used to 

heat stuff. Some of the gauzes that were used to handle samples had asbestos. That was 

a normal practice at the time for chemistry labs, even in high school and universities. 

That was before we knew about mesothelioma. Not all forms of asbestos result in 

mesothelioma. 

 An interviewee indicated all coworkers died from cancer at a young age. 

 Stainless steel hoods and gloveboxes were developed later. They learned from the 

experience of the milk industry that had to maintain sanitary conditions.