Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

PARTIAL REVIEW OF THE REVISED 

NIOSH PETITION EVALUATION REPORT FOR THE 

ELECTRO-METALLURGICAL CORPORATION, 

PETITION SEC-00136 

Contract No. 200-2009-28555 

SCA-TR-SEC2012-0010, Revision 0

 (Addendum to SCA-TR-SEC2010-0010) 

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 

February 2012 

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 predecisional 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: 

February 21, 2012 

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0 – Draft 

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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. 

Document No. 

SCA-TR-SEC2012-0010 

(Addendum to 

SCA-TR-SEC2010-0010) 

Effective Date: 

Draft – February 21, 2012 

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Revision No. 

0 – Draft 

Partial Review of the Revised NIOSH Petition 

Evaluation Report for the Electro-Metallurgical 

Corporation, Petition SEC-00136 

Page 2 of 12 

Task Manager: 

________________________ Date: ___________ 

William C. Thurber 

Supersedes: 

N/A 

Project Manager: 

________________________ Date: ___________ 

John Stiver, MS, CHP 

Reviewer(s): 

 John Mauro, PhD, CHP 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 02/21/2012 Initial issue – Addendum to SCA-TR-SEC2010-0010. This addendum is a partial 

review of a revised SEC Petition Evaluation Report and NIOSH white paper. 
Effective Date: 

February 21, 2012 

Revision No. 

0 – Draft 

Document No. 

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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. 

TABLE OF CONTENTS 

1.0 Introduction......................................................................................................................... 4 

2.0 Identification of Area Plant Employees.............................................................................. 5 

3.0 Ability to Calculate Bounding Doses for the “Early Operations” ...................................... 6 

4.0 References........................................................................................................................... 7 

Attachment A: Updated Electro-Met Issues Matrix for SEC-00136............................................. 8 
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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. 

 

1.0 INTRODUCTION 

On February 7, 2012, in anticipation of the February 14, 2012, meeting of the Atomic Weapons 

Employer (AWE) Work Group, the National Institute for Occupational Safety and Health 

(NIOSH) issued a revised evaluation report (ER) on Petition SEC-00136 relating to workers at 

the Electro-Metallurgical Company (Electro-Met). In that ER, NIOSH recommended that a 

Special Exposure Cohort (SEC) be granted for the early years, due to a lack of adequate air 

sampling data, and that the entire Electro-Met site should be covered by the SEC. At the request 

of the Work Group, SC&A did its best to review the February 7, 2012, ER and presented a 

verbal summary of its preliminary findings at the Work Group Meeting. SC&A expressed 

concern that there appears to be evidence that internal doses in the early years could, in fact, be 

reconstructed due to the availability of a considerable amount of bioassay data in the early years, 

which compared favorably with the bioassay data in the later years. SC&A also expressed 

concern that should an SEC be granted, it appears that the scope of the SEC could be limited to 

workers in the Area Plant and not extend to the entire Electro-Met facility. During the meeting, 

in response to SC&A’s concerns, NIOSH referred to a May 16, 2011, report (NIOSH 2011) that 

was described as providing information arguing that it was difficult to limit the scope of the SEC 

to only the Area Plant. The May 16, 2011, NIOSH report did not address the issue of whether 

internal doses prior to December 1947 could be bounded. 

SC&A was not aware of the existence of the May 16, 2011, report, and as a result, SC&A was 

requested to review the report and complete its review of the February 7, 2012, revised ER. We 

were requested to provide the Work Group with a written report on these matters as soon as 

possible, so that these matters could be thoroughly discussed at the upcoming Advisory Board 

meeting scheduled for March 28–29, 2012, in Oakland, California. This report is provided in 

response to this request. We note that, given the limited time available, SC&A did not conduct a 

complete review of the ER dated February 7, 2012. However, SC&A did re-examine its findings 

prepared in response to the original NIOSH ER dated July 2009 and compared these findings 

with the new ER. SC&A also reviewed the May 16, 2011, NIOSH report. SC&A’s original 

findings were presented in SC&A 2010, which was updated1

 to Revision 1 in SC&A 2011, dated 

May 2011. Detailed comments on each of the SC&A findings based on currently available 

information are included in Attachment A. 

Based on the limited review, SC&A continues to believe that there are two over-arching issues 

that require further examination: 

 The ability to identify and differentiate employees who worked in the Area Plant where 

Atomic Energy Commission (AEC)/Manhattan Engineer District (MED) activities were 

conducted as compared to employees who worked in the commercial operations that 

constituted the majority of the activities at Electro-Met 

 The ability to calculate bounding doses for the “early operations” from August 13, 1942, 

through December 31, 1947 

1

 The only difference between Revision 0 and Revision 1 was the inclusion of additional interviews in the 

later document. 
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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. 

Each of these two issues is discussed below. 

2.0 IDENTIFICATION OF AREA PLANT EMPLOYEES 

This issue was originally raised as Finding 1 by SC&A (SC&A 2010, SC&A 2011). The Area 

Plant, where AWE activities were conducted, was built by Electro-Met under MED contract 

specifically to convert green salt to uranium metal and to remelt the uranium and cast it into 

ingots for fabrication elsewhere. The Area Plant was a fenced and guarded limited-access 

facility erected in a corner of the Electro-Met site separate from the commercial activities. The 

Area Plant had a total of about 67 employees, with a staffing breakdown as follows [Site 

Research Database (SRDB): 8912]: 

Operators: 28 

 Head Remelt Operators – [redacted] 

 Furnace Operators – [redacted] 

 Head Reaction Operators – [redacted] 

 Bomb Toppers – [redacted] 

 Green Room Operators – [redacted] 

 Bomb Unloading and Chipping – [redacted] 

 Repairman Furnace Parts – [redacted] 

 Sawman – [redacted] 

 Handyman – [redacted] 

Supervisors: [redacted] 

 General Foreman – [redacted] 

 Foreman – [redacted] 

 Shift Foreman – [redacted] 

Other Staff: [redacted] 

 Repairman – [redacted] 

 Storeroom Attendant – [redacted] 

 Store Keeper – [redacted] 

Janitors: [redacted] 

Guards: [redacted] 

Office Personnel: 11 

Laboratory: [redacted] 

 Chemists – [redacted] 

 Technician – [redacted] 

 Lab Handyman – [redacted] 

 

In response to the SC&A finding, NIOSH contacted the Department of Labor (DOL), who 

opined “that they do not feel they can place workers in specific buildings” (NIOSH 2011). 

NIOSH accepted the DOL opinion, as reflected in the revised ER dated February 7, 2012. 

However, it is not apparent that this issue has been investigated as thoroughly as it should be. 

SC&A believes that a considerable amount of documentation exists in the SRDB that should be 

examined before NIOSH can reach a definitive conclusion that workers in the Area Plant cannot 

be defined as a distinct group from workers in the commercial facilities. 
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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. 

For example, SRDB 8912 (Appendix C), covering the period November 1948 through January 

1949, lists 47 workers by name, job description, start date for work in Area Plant, date 

transferred from Area Plant or laid off, and date transferred to Area Plant, rehired, or recalled. 

The list includes guards, janitors, and people involved in production operations. 

SRDB 8887 lists results of 78 bioassay samples by worker name (with some workers sampled 

more than once) from July 26 through September 8, 1944. The same document lists beta doses 

for a named remelt furnace operator, a billet packer, a green salt mixer, and a remelt operator. 

SRDB 11547 lists the results of about 1,700 film badge measurements (with some workers 

sampled more than once) by name and job description taken in 1948 and 1949. SC&A has not 

had sufficient time to determine how many individual workers are included in this group. 

SRDB 35738 (1949) provides results for the 43 urinalysis results for named workers with job 

descriptions. 

This list is not exhaustive, but is indicative of the large amount of information that could be 

analyzed to more rigorously address this concern. 

Since the Area Plant was a guarded, fenced, secured area, access from the main plant was limited 

to a few service personnel on an occasional basis. Information in Blatz 1949 (pdf pg. 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. 

3.0 ABILITY TO CALCULATE BOUNDING DOSES FOR THE “EARLY 

OPERATIONS” 

In the revised ER (February 2012), NIOSH documented that it was possible, based on extensive 

air monitoring, to bound internal doses during the period of “later operations” from January 1, 

1948, through June 30, 1953. NIOSH concluded that a similar bounding calculation was not 

possible for the early period stating: 

NIOSH has determined that neither the bioassay nor the early limited air 

sampling data are sufficient to bound internal dose at Electro Metallurgical for 

the August 13, 1942 through December 31, 1947 portion of the class under 

evaluation. 

SC&A has alternative logic to suggest regarding bounding internal doses for the early period. 

SC&A accepts the NIOSH conclusion that internal doses can be bounded for later operations. 

However, as discussed in SC&A 2010 and 2011, NIOSH has obtained a total of 111 urinalysis 

results from 48 different employees, collected during 1944 and 1949, with approximately half of 

the results being recorded as zero. The 1944 results comprise 60% of the measurements. These 

results are non-specific as to job category, but at least in some cases, job descriptions can be 

assigned based on other sources. In SC&A 2010, SC&A compared the bioassay results from the 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE: 

early and later operations and demonstrated that the results were not statistically different. If 

results for bioassay for the two periods were not statistically different and doses can be bounded 

for later operations, then the logic suggests that doses can be bounded for the early period, as 

well, using the air sampling results from later operations. This argument is buttressed by the fact 

that bioassays during the period of later operations were taken during a standby period and thus 

would represent lower excretion levels. In addition, the limited air sampling data available from 

the early operations do not show higher results than from the later operations (see NIOSH 2011). 

4.0 REFERENCES 

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. 

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. 

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. 

NIOSH 2009. SEC Petition Evaluation Report, Petition SEC-00136 – Electro Metallurgical 

Corporation. National Institute for Occupational Safety and Health (NIOSH), Cincinnati, Ohio. 

July 21, 2009. 

NIOSH 2011. NIOSH Update on Electro Metallurgical, May 16, 2011 Working Group Meeting. 

Prepared by Sam Glover (NIOSH). National Institute for Occupational Safety and Health 

(NIOSH), Cincinnati, Ohio. 

SC&A 2010. Review Of NIOSH Petition Evaluation Report For Petition Sec-00136 Dated July 

21, 2009, Electro-Metallurgical Corporation. Contract No. 200-2009-28555. SCA-TRSEC2010-0010, Rev. 0. SC&A, Inc., Vienna, Virginia. April 12, 2010. 

SC&A 2011. Review Of NIOSH Petition Evaluation Report For Petition Sec-00136 Dated July 

21, 2009, Electro-Metallurgical Corporation. Contract No. 200-2009-28555. SCA-TRSEC2010-0010, Rev. 1. SC&A, Inc., Vienna, Virginia. May 5, 2011. 

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. 

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.
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 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT A: UPDATED ELECTRO-MET ISSUES MATRIX FOR SEC-00136 

(Reference SC&A 2011 for detailed discussion of these findings.) 

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. 

SC&A Comment – 2/16/12: In their May 16, 2011, report (NIOSH 2011), NIOSH reported that DOL had 

indicated they could not place workers in individual buildings. It is not clear to what extent DOL reviewed relevant 

information in the SRDB. The staff at the Area Plant was small – about 67 people. Of these, only 28 (or 42%) were 

operators with the highest expected exposures. Guards, office personnel, and laboratory staff combined made up 

about the same percentage of the total staff. The exposures of this group should be relatively low, as compared to 

the operators. Workers’ names and periods worked are available for many workers. It would seem that with a few 

days effort, DOL should be able to develop a comprehensive list of those who worked in the Area Plant on a regular 

basis. It is probably not possible to identify support personnel who occasionally entered the Area Plant; however, 

their exposures should be minimal. As noted in SC&A 2011, this group would include electricians who worked 

about 2 days per month and pipefitters who worked 2 or 3 days per year. 

Status: 

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 uraniumbearing 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).

SC&A Comment – 2/15/12: According to the revised ER: 

Electro Met was also contracted to conduct research into ore processing (ore beneficiation 

program) as part of its initial contract. Minimal documentation is available, but from all 

indications this program was conducted for a short time beginning in April 1945 and concluding 

in August 1945 using small quantities of low-grade African ore (MED, 1945).* Very little specific 

information is available regarding the facilities and activities associated with these materials. 

However, based on the detailed material transfer forms and summary research reports, it is 

believed that only very small quantities were used at Electro Met during the period of 

performance. No specific information is available to NIOSH regarding operational exposure 

levels or clean-up. By employing a wet process involving chemical leaching, the exposure 

potential from these processes was low (Ore Beneficiation, 1945a; Ore Beneficiation, 1945b). 

NIOSH has not located any documentation indicating that there were other sources of radiation at 

Electro Met during the later part of period under evaluation (i.e., January 1, 1948 and June 30, 

1953). 

SC&A is satisfied with this explanation and concludes that the source term is adequately represented by processing 

green salt into uranium ingots. 

* This reference could not be located on the reference list of the revised Evaluation Report. 
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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. 

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

relevant documentation has been evaluated. 

SC&A Comment – 2/16/12: The start date was modified to August 1942 to reflect the start date of the MED 

contract, and the end date was fixed at June 30, 1953, the end date of the contract. This resolution is satisfactory, 

since this was a DOE facility where evaluation of residual contamination is not required. However, we note that the 

Electro-Met TBD (DCAS-TKBS-0007) states in Section 5.0 that no external doses will be calculated prior to April 

1943. The ER and the TBD should be reconciled. 

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.) 

SC&A Comment – 2/16/12: NIOSH has concluded in the revised ER that internal doses cannot be constructed 

prior to January 1948. Originally, NIOSH had proposed to back extrapolate to early operations where air 

monitoring data were limited by assuming that exposures during early operations were bounded by the 95th

percentile obtained from post-1947 operations. SC&A believes that another approach can be taken to bound 

exposures prior to January 1948.

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. 

SC&A Comment – 2/16/12: NIOSH modified text in Revised ER to indicate that “little” information was 

available. This resolution is satisfactory. 

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. 

SC&A Comment – 2/16/12: This finding relates to how dose reconstructions are performed. It is not related to an 

SEC determination as to whether or not dose reconstructions can be performed.

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. 

SC&A Comment – 2/16/12: This is a dose reconstruction issue, not an SEC issue. 

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. 

SC&A Comment – 2/16/12: This is a dose reconstruction issue, not an SEC issue.
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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. 

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 TBD-6001 (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. 

SC&A Comment: As noted, this 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. 

SC&A Comment – 2/16/12: Additional reviews by NIOSH and SC&A have not uncovered evidence of blowouts. 

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

SC&A Comment – 2/16/12: SC&A was advised that, since the Area Plant was an AEC facility, evaluation of 

exposures during the residual period is not required.

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. 

SC&A Comment – 2/16/12: The Electro-Met TBD (DCAS-TKBS-0007) and the Revised ER eliminated any 

discussion about comparing actual and calculated excretion rates.

Finding 13: The approach taken to bound external photon exposure values in Table C.4 of TBD-6001, 

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. 

SC&A Comment – 2/16/12: NIOSH concluded in the revised ER (see Table 7-1) that it is possible to reconstruct 

external doses during the early operations. As stated in Section 7.3.4.1 of the revised ER, “NIOSH has obtained 

sufficient personnel dosimetry records to reconstruct occupational photon and beta dose for the covered period.” 

NIOSH does not explain why, although the significant dosimetry is only available beginning in June 1948, external 

doses can be constructed prior to that date, while a comparable argument cannot be made with regard to internal 

dose.

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. This is a dose reconstruction issue, not an SEC issue. 

SC&A Comment – 2/16/12: This issue has been discussed by NIOSH and SC&A at various meetings and a 

consensus was reached that photofluorography was practiced only at larger AEC facilities. 
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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. 

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%. 

SC&A Comment – 2/16/12: The same data were included by NIOSH in DCAS-TKBS-0007, so the differences 

have not been resolved. While this is a dose reconstruction rather than an SEC issue, some mechanism is needed to 

insure that these concerns are investigated before TKBS-0007 is used for dose reconstruction. It is not clear that 

such a mechanism exists since TKBS-0007 has received no independent review. 

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. 

SC&A Comment – 2/16/12: The TBD did not make any distinction between doses to the hands and arms as 

compared to other skin areas. However, there is one caveat that must be considered in using the values in Table 3 of 

TKBS-0007 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 3.65:1. SC&A believes that this is a dose reconstruction issue rather than an SEC issue. 

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. 

SC&A Comment – 2/16/12: NIOSH has determined that they cannot reconstruct internal doses prior to December 

1947. SC&A has suggested an alternative approach to bounding internal doses for the early operations. SC&A 

believes that this finding has not been resolved.

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. 

DCAS 2011. Technical Basis Document for the Electro Metallurgical Company, Niagara Falls, 

New York. DCAS-TKBS-0007, Rev. 00. Supersedes Battelle-TBD-6001 Appendix C. 

Division of Compensation Analysis and Support (DCAS), National Institute for Occupational 

Safety and Health (NIOSH), Cincinnati, Ohio. February 15, 2011. 

NIOSH 2009. SEC Petition Evaluation Report, Petition SEC-00136 – Electro Metallurgical 

Corporation. National Institute for Occupational Safety and Health (NIOSH), Cincinnati, Ohio. 

July 21, 2009. 
Effective Date: 

February 21, 2012 

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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. 

NOTICE: 

NIOSH 2011. NIOSH Update on Electro Metallurgical, May 16, 2011 Working Group Meeting. 

Prepared by Sam Glover (NIOSH). National Institute for Occupational Safety and Health 

(NIOSH), Cincinnati, Ohio. 

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. 

Ore Beneficiation 1945a. Status of Low Grade African Ore Beneficiation Program. Memo to 

General L.R. Groves, October 24, 1945. SRDB Ref ID: 91908. 

Ore Beneficiation 1945b. Status of Low Grade African Ore Beneficiation Program. War 

Department United States Engineer Office. 6 December 1945. SRDB Ref ID: 91957. 

SC&A 2011. Review Of NIOSH Petition Evaluation Report For Petition Sec-00136 Dated July 

21, 2009, Electro-Metallurgical Corporation. Contract No. 200-2009-28555. SCA-TRSEC2010-0010, Rev. 1. SC&A, Inc., Vienna, Virginia. May 5, 2011.