Draft 

ADVISORY BOARD 

ON RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Review of the Linde Ceramics Plant 

Special Exposure Cohort (SEC) Petition 00107 

and the NIOSH SEC Petition Evaluation Report 

Contract No. 200-2009-28555 

SCA-SEC-TASK5-0006 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

June 2009 

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. 
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Document No. 

SCA-SEC-TASK5-0006 

Effective Date: 

 Draft – June 18, 2009 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of NIOSH 

Dose Reconstruction Program Revision No: 

 0 – Draft 

Review of the Linde Ceramics Plant Special 

Exposure Cohort (SEC) Petition 00107 and the 

NIOSH SEC Petition Evaluation Report 

Page 2 of 57

Task Manager: 

_____________________ Date: ____________ 

Stephen L. Ostrow, PhD 

Project Manager: 

_____________________ Date: ____________ 

John Mauro, PhD, CHP 

Supersedes: 

N/A 
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4 

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

1.0 Introduction..........................................................................................................................8 

1.1 Scope and Purpose of SEC Review .........................................................................8 

1.2 Technical Approach and Review Criteria................................................................8 

1.3 Background Information..........................................................................................9 

1.4 Organization of the Report.....................................................................................10 

2.0 Overview of the SEC Petition 00107 and the NIOSH Evaluation Report.........................11 

3.0 Assessment of NIOSH’s Ability to Reconstruct Exposures during the Residual 

Period .................................................................................................................................14 

3.1 Introduction............................................................................................................14 

3.2 Internal Exposure...................................................................................................14 

3.2.1 Bounding Radon Exposures.......................................................................15 

3.2.2 Bounding Internal Doses............................................................................18 

3.2.3 Application of Bounding Approach...........................................................23 

3.3 External Exposure..................................................................................................24 

4.0 References..........................................................................................................................29 

Appendix A: Comparision of An Exposure Matrix for Linde Ceramics Plant (Including 

Tonawanda Laboratory), ORAUT-TKBS-0025, Revision 01 To Revision 00 .................33 

Appendix B: Memorandum from SEC Petitioner to SC&A.........................................................53 

LIST OF TABLES 

Table 1. Summary of Findings....................................................................................................... 6 

Table 2. Summary of Linde SEC 00107 Petition Issues and NIOSH Responses........................ 11 

Table 3. Air Concentrations Measured During 1948–1949 Clean-up of Building 30................. 21 

Table 4. Decontamination Factors for Building 30 during 1948–1949 Cleanup......................... 22 

Table 5. Comparison of Dose Conversion Factors for Various Organs from Inhalation of 

Alpha-Emitting Radionuclides (30 years after intake).................................................. 23 

Table 6. Summary of 1949 Post-Decontamination Survey Results for Building 30................... 26 
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

or the Board 

AEC Atomic Energy Commission 

AP Anterior-posterior 

AWE Atomic Weapons Employer 

BNI Bechtel National, Inc. 

CDC Centers for Disease Control and Prevention 

CFR Code of Federal Regulations 

Ci Curie: unit of activity 

D&D Decontamination & Decommissioning 

DF Decontamination Factor 

DOE Department of Energy 

DOL Department of Labor 

dpm Disintegrations per Minute 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ER (SEC Petition) Evaluation Report 

FR Federal Register 

FUSRAP Formerly Utilized Sites Remedial Action Program 

GM Geometric Mean 

GSD Geometric Standard Deviation 

HASL Health & Safety Laboratories 

ICRP International Commission on Radiological Protection 

IREP Interactive RadioEpidemiological Program 

L Liter 

LAPC Linde Air Products Company 

LOD Limit of Detection 

MAC Maximum Allowable Concentration 

MED Manhattan Engineering District 

mg Milligram 

mR milli-Roentgen 

mrep milli-Roentgen Equivalent Physical 
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NIOSH National Institute for Occupational Safety and Health 

NYOO New York Operations Office (of the Atomic Energy Commission) 

ORAUT Oak Ridge Associated Universities Team 

ORNL Oak Ridge National Laboratory 

pCi pico-Curie 

R Roentgen: unit of exposure 

rad unit of absorbed dose 

rem unit of dose equivalent 

SC&A S. Cohen & Associates 

SEC Special Exposure Cohort 

SRDB Site Research Database 

SRQD (NIOSH) Site Research Query Database 

TBD Technical Basis Document 

TIB Technical Information Bulletin 

μR Micro Roentgen 

WLM Working Level Month: measure of radon exposure
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EXECUTIVE SUMMARY 

The Advisory Board on Radiation and Worker Health (the Board or ABRWH) directed SC&A to 

perform a review of the Linde SEC Petition 00107 (SEC-107 2008) and NIOSH’s response to it 

in its SEC Petition Evaluation Report (NIOSH 2008a). The petition called for adding the worker 

class, defined as “All employees who worked at the Linde Ceramics Plant in Tonawanda, New 

York, during the applicable covered residual radiation period from January 1, 1954, through July 

31, 2006.” NIOSH qualified the petition on July 1, 2008, and produced its evaluation report on 

November 3, 2008, in which it asserted the following: 

Based on its research, NIOSH has obtained air monitoring data, soil sampling 

data, and radiation contamination survey data specific to the Linde site, which 

can be used to bound exposures to all members of the proposed class. Based on 

its analysis of these available resources, NIOSH found no part of the class under 

evaluation for which it cannot estimate radiation doses with sufficient accuracy. 

SC&A examined the petition, the NIOSH evaluation report, and a number of supporting 

documents, primarily to assist the Board in assessing the degree to which NIOSH can “estimate 

radiation doses with sufficient accuracy,” using the criteria of 42 CFR 83. This report presents 

the results of SC&A’s investigations with regard to this matter. Our findings are summarized in 

Table 1. The table gives only a short description of each finding, and the main body of this 

report (cited in the table) should be consulted for a full explanation. All findings relate to the 

reconstruction of internal exposure. We have no findings related to external, occupational 

medical, or environmental exposures. 

Table 1. Summary of Findings 

No. Internal/ 

External Section Description 

1 I 3.2.1 

“Bounding Radon Exposures” 

The observation that data taken after decontamination of 

Building 31 were higher than before decontamination calls into 

question the quality of the radon measurements. This finding 

is supported by a statement made by the authors of Bechtel 

1982 that the radon data from Building 31 were 

“unconfirmed,” again indicating concerns about data quality. 

2 I 3.2.1 

“Bounding Radon Exposures” 

Use of the geometric mean (GM) rather than the 95th percentile 

as the appropriate exposure metric needs to be justified for use 

in a bounding calculation, particularly since measurements 

taken in 1976 are used to characterize the entire residual period 

beginning in 1954. Use of 1976 data for a much earlier period 

needs to be justified by demonstration of equivalent (or less 

contaminated) radiological conditions. 

3 I 3.2.1 

“Bounding Radon Exposures” 

Use of measurements taken in 1981 to characterize radon 

exposures up to 28 years earlier may not be bounding. Use of 

such data needs to be technically justified. 
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No. Internal/ 

External Section 

Table 1. Summary of Findings 

Description 

4 I 

3.2.2.1 

“Exposure During General 

Building Occupancy” 

The NIOSH assumption that a single air sample taken in the 

1970s can be used to bound plausible internal exposures to 

uranium, Th-230, and Ra-226 for over 50 years beginning in 

1954 is highly questionable. 

5 I 

3.2.2.1 

“Exposure During General 

Building Occupancy” 

NIOSH assumes that the geometric standard deviation (GSD) 

of the lognormal distribution is 5, when guidance in Battelle 

2007 recommends a value of 10 for site-wide estimates. The 

placement of the single sample on the lognormal distribution 

could lead to substantial errors and cannot be reliably done. 

6 I 

3.2.2.1 

“Exposure During General 

Building Occupancy” 

NIOSH’s use of a constant air concentration, rather than an 

exponentially declining concentration, is not claimant 

favorable and is not consistent with the guidance in ORAUTOTIB-0070. Back extrapolation needs to be technically 

justified by examination of potential site-specific changes in 

residual contamination. 

7 I 

3.2.2.3 

“Exposure During Building 

Renovation” 

The process selected to establish the pre-decontamination dust 

level does not appear to be claimant favorable, based on the 

cited data source (Heatherton 1950). 

8 I 

3.2.2.3 

“Exposure During Building 

Renovation” 

The assumed decontamination factor of 8 is based on pre- and 

post-decontamination values taken in different areas. 

Examination of the full dataset suggests that the differences in 

the potential internal exposures between the early and later 

decontamination activities may be negligibly small. 

9 I 

3.2.2.3 

“Exposure during Building 

Renovation” 

It is not clear that the bounding approach used in the SEC00107 Petition Evaluation Report is more claimant favorable 

than that proposed in TBD-6001. 

10 I 

3.2.2.3 

“Exposure During Building 

Renovation” 

The mix of alpha-emitting radionuclides in the airborne dust 

needs to be quantified for renovation activities, taking into 

consideration that raffinates might have been present. 

11 I 

3.2.3 

“Application of Bounding 

Approach” 

NIOSH needs to explain how internal exposures should be 

apportioned among the various exposure scenarios. 
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1.0 INTRODUCTION 

1.1 SCOPE AND PURPOSE OF SEC REVIEW 

During the meeting of the Advisory Board on Radiation and Worker Health (the Board or 

ABRWH) held in Albuquerque, New Mexico, on February 19, 2009, S. Cohen and Associates 

(SC&A) was directed by the Board to perform a review of the Linde Special Exposure Cohort 

(SEC) Petition-00107 (SEC-107 2008) and the NIOSH SEC Petition Evaluation Report (ER) 

(NIOSH 2008a), which responds to that petition (ABRWH 2009, pg. 117). This report presents 

the results of our review of the Linde SEC Petition and the NIOSH ER. 

The scope of this review addresses specific issues of concern raised in the petition and NIOSH’s 

response to these concerns, as given in the ER. In addition, SC&A identified issues that we 

believe need to be addressed, but were not explicitly identified by petitioners: 

• Documents that were referenced in the petition 

• Documents referenced/cited in the ER and site profile (also known as the TBD) 

• Documents contained in the NIOSH Site Research Query Database (SRQD) 

The purpose of this review is to provide the Board with an independent assessment of issues and 

concerns that surround the petition and NIOSH’s response and proposed methods for 

accommodating these issues/concerns. Findings identified in SC&A’s review are intended to 

provide the Board with an overview of potential issues that may impact the feasibility of dose 

reconstruction. Following a formal, multi-step issues resolution process, any unresolved findings 

may then be used by the Board for determining whether radiation doses can be estimated with 

sufficient accuracy, as defined in 42 CFR §83.13(c)(1); since this final determination lies within 

the purview of the Board and occurs at the end of a formal issues resolution process, SC&A does 

not draw conclusions from its findings in this report with respect to whether doses can be 

reconstructed with sufficient accuracy. 

1.2 TECHNICAL APPROACH AND REVIEW CRITERIA 

The approach used by SC&A to perform this review follows the protocols described in the draft 

report prepared by SC&A entitled, Board Procedures for Review of Special Exposure Cohort 

Petitions and Petition Evaluation Reports, Revision 1 (SC&A 2006b), and the Report to the 

Working Group on Special Exposure Cohort Petition Review (SC&A 2006a). The latter is a set 

of draft guidelines prepared by a Board-designated work group for evaluation of SEC petitions 

performed by NIOSH and the Board. The former is a set of draft procedures prepared by SC&A 

and approved by the Board for use by SC&A on an interim basis (ABRWH 2006, pg. 132). The 

procedures are designed to help ensure compliance with Title 42, Part 83, of the Code of Federal 

Regulations (42 CFR 83) and implement the guidelines provided in the report of the working 

group. 
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Key review criteria identified in the report of the work group include the following: 

• Timeliness 

• Fairness 

• Understandability 

• Consistency 

• Credibility and validity of datasets, including pedigree of the data, methods used to 

acquire the data, relationship to other sources of information, and internal consistency 

• Representativeness and completeness of the exposure data with respect to the area of the 

facility, the time period of exposure, the types of workers, and processes covered by the 

data 

The individual criteria have differing degrees of applicability depending on the details of a 

particular SEC petition and evaluation report. 

The work group guidelines also recommend that NIOSH include in its SEC evaluation a 

demonstration that it is feasible to reconstruct individual doses for the cohort, including sample 

dose reconstructions. 

SC&A’s implementation of the SEC review process includes the following steps: 

(1) Conduct a critical review of the petition and relevant reports, documents, and data that 

are enclosed and/or referenced in the petition/reports 

(2) Interview petitioners, claimants, workers, etc. Note that this was done as part of the site 

profile review process and SC&A did not find it necessary to perform additional 

interviews in support of this report 

(3) Identify additional issues/concerns that emerged from SC&A’s document review, which 

are independent of those stated in the petition 

(4) As part of the SEC review, develop a technical position for issues identified in the 

petition, as well as SC&A’s independent findings 

SC&A’s report with its findings will subsequently undergo a multi-step issues resolution 

process. Resolution includes a transparent review and discussion of draft findings with members 

of the Board’s working group, petitioners, claimants, and interested members of the public. This 

resolution process is intended to ensure that each finding is evaluated on its technical basis in a 

fair and impartial manner. 

1.3 BACKGROUND INFORMATION 

The NIOSH Linde Site Profile (NIOSH 2008b) presents extensive background information on 

the history and operations of the Linde plant; a brief summary is presented here for the purpose 
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of orientation. In October 1942, the Linde Ceramics Plant, located in Tonawanda, New York, 

was contracted by the U.S. government to develop appropriate facilities and methods to perform 

large-scale processing of domestic and African uranium ores for the Manhattan Engineer District 

(MED) as part of its mission to develop nuclear weapons. The Linde site was selected for the 

MED contract because of its experience in the ceramics business, which involved processing 

uranium to produce salts used to color ceramic glazes. The operational period at Linde 

continued until 1949. Beginning in 1949, the Linde site underwent decontamination and 

cleanup, and in 1954, the site was released for private use. The post-1954 era at the Linde site is 

known as the residual period, and it is during this time that the various buildings at the site 

began to undergo renovation and remediation; the SEC 00107 petition is concerned with this 

time period. In 1976, Oak Ridge National Laboratory (ORNL) performed a radiological survey, 

and in 1980, Linde was designated as a FUSRAP (Formerly Utilized Sites Remedial Action 

Program) site. Linde then underwent two periods of FUSRAP remediation, from 1988–1992 and 

in 1996. All of the uranium processing buildings except Building 31 were demolished during 

this remediation period (NIOSH 2008a). 

It should be noted that the SEC petition in question, SEC 00107, covers the residual time period, 

from January 1, 1954 through July 31, 2006. A previously approved SEC petition covers the 

time period from October 1, 1942, through October 31, 1947. 

1.4 ORGANIZATION OF THE REPORT 

Following this introductory section, Section 2 of the report presents an overview of SEC Petition 

00107 and identifies the issues that it raises, and also presents a summary of NIOSH’s evaluation 

report responding to the petition. Section 3 constitutes SC&A’s assessment of the petition and 

NIOSH’s response, and Section 4 contains a list of documents referenced in this report. The 

body of the report is followed by two appendices. Appendix A is a table presenting for reference 

purposes a line-by-line comparison of the Revision 01 and Revision 00 versions of the site 

profile (there was also a Rev. 00 PC-1 version between them), and Appendix B contains a memo 

and attachments from an SEC petitioner to SC&A related to the concentration of African ore 

feedstock during the operations period.
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2.0 OVERVIEW OF THE SEC PETITION 00107 AND THE NIOSH 

EVALUATION REPORT 

On July 1, 2008, NIOSH qualified SEC Petition 00107 (the petition under consideration here) for 

the Linde Ceramics Plant with the following petitioner class definition: 

All employees who worked at the Linde Ceramics Plant in Tonawanda, New York, 

during the applicable covered residual radiation period from January 1, 1954 

through July 31, 2006 (NIOSH 2008a, pg. 3). 

NIOSH performed an evaluation of the petition in November 2008 and determined that there is 

sufficient data to estimate the radiation doses to workers during the residual period. Section 3.3 

of NIOSH 2008a states the following: 

Based on its research, NIOSH has obtained air monitoring data, soil sampling 

data, and radiation contamination survey data specific to the Linde site, which 

can be used to bound exposures to all members of the proposed class. Based on 

its analysis of these available resources, NIOSH found no part of the class 

under evaluation for which it cannot estimate radiation doses with sufficient 

accuracy. 

NIOSH’s conclusion in the preceding quotation is highlighted here in bold for emphasis. The 

authors of the petition raised numerous concerns and issues relating to both external and internal 

radiation exposures incurred by workers at Linde during the residual period. Table 2 

summarizes these issues, along with NIOSH’s response to those issues in the evaluation report. 

Due to the fact that many of the issues interconnect and overlap, as they are restated in several 

different places in the petition, often in somewhat differing language, SC&A identified nine 

distinct issues raised. We are not addressing them on a point-by-point basis, because our review 

of the NIOSH ER and related materials allows SC&A to assess them from the point of view of 

the adequacy of the information available to estimate the internal and external exposures to 

workers during the residual period; this is the underlying concern. As noted in Table 2, NIOSH 

did not address the issue of document destruction raised in the Petition in its ER. The 

investigation of this issue could be complex and may delay consideration of the significant 

number of technical issues analyzed in this report. In the interest of a timely initiation of the 

process of comment resolution, we are submitting this review of technical issues, while 

continuing to pursue the issue of document destruction, starting with a further interview with 

petitioners. 

Table 2. Summary of Linde SEC 00107 Petition Issues and NIOSH Responses 

Linde Petition Issue NIOSH SEC Evaluation Report 

1. Inability to evaluate the precise grade 

levels of the pitchblende African ore 

processed at Linde during its operational 

period from 1942–1953. 

Table 5-2. Types of Material used in the Operation of the Linde 

Ceramics Plant (pg. 15). 
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Linde Petition Issue 

Table 2. Summary of Linde SEC 00107 Petition Issues and NIOSH Responses 

NIOSH SEC Evaluation Report 

2. The deficient, unreliable, and incomplete 

dosimetry data available to NIOSH for 

Linde residual radiation workers. 

“No personnel bioassay monitoring data has been identified for 

Linde Ceramics workers during the residual period; however, 

NIOSH does have access to survey data, including air monitoring 

data for both the decontamination activities at Linde (conducted 

just prior to the start of the residual radiation period) and several 

distinct, major investigations during the residual radiation period. 

The residual period surveys include soil characterizations, 

building surveys, and air sampling results” (pg. 19). 

3. The destruction of Linde documents 

described in an affidavit. 

Not specifically addressed by NIOSH in the ER. 

4. Internal exposure to uranium dust during 

renovation/construction activities. 

“It is reasonable to assume that this renovation work could have 

resulted in elevated airborne radioactivity; however, specific 

assessment of the potential dose associated with this work has not 

been included in ORAUT-TKBS-0025. For the purposes of this 

evaluation and assessing the ability to bound radiological 

exposures for members of the proposed worker class, the 

renovation work will be compared to the operational period D&D 

work, which is included and assessed in ORAUT-TKBS-0025” 

(pg. 22). “Heatherton (1950) documents the results of air dust 

samples collected during six different kinds of D&D operations 

conducted in Building 30” (pg. 23). 

5. Internal dose exposure estimates that rely 

on air concentration data for the residual 

radiation period are unreliable, due to a 

tendency to underestimate internal dose 

exposure. 

“Based on available Linde D&D survey data and residual 

radiation surveys conducted in association with FUSRAP 

activities, NIOSH has the necessary data to support bounding 

internal exposures for uranium, uranium progeny, and radon 

during the residual period. Radioactive operations terminated at 

the end of the operational period and source term materials were 

removed from the site. The application of this survey data will 

result in overestimates of exposures and doses during the general 

activities and will result in conservative [sic] estimates of 

exposure during the highest-risk activities at Linde Ceramics 

during the period evaluated in this report” (pg. 24). 

6. Raffinate-related exposures were not 

evaluated in the site profile. 

“Waste materials (raffinates) were transported offsite (to Lake 

Ontario Ordnance Works and/or Ashland) prior to the end of 

operations. Therefore, workers outside the operational period 

would have had minimal exposure potential to these materials in 

their concentrated form. To determine the exposure potential 

from residual surface contamination on the site, a review of 

available isotopic data was conducted. Isotopic data from soils 

and sediments on site are summarized in Attachment One of this 

evaluation report and can be used to determine exposure from 

uranium progeny” (pg. 23). 

7. Exposure from contaminated burlap bags 

in the storage area of Building 30. 

(Includes possible exposure from radium 

and radon gas, and pro-actinium, 

actinium, and thorium from the African 

ore stored in those bags.) 

This issue is not specifically addressed by NIOSH in the ER, but 

it has been addressed by NIOSH and the Board in Work Group 

meetings and discussed in Attachment E of Revision 1 of the 

Linde Site Profile (NIOSH 2008b). 
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Linde Petition Issue 

Table 2. Summary of Linde SEC 00107 Petition Issues and NIOSH Responses 

NIOSH SEC Evaluation Report 

8. Air concentration data used are based on 

results of random air samples in general 

area and breathing zones, but not in 

continuous area sampling in high risk or 

high dose areas. 

“Based on available Linde D&D survey data and residual 

radiation surveys conducted in association with FUSRAP 

activities, NIOSH has the necessary data to support bounding 

internal exposures for uranium, uranium progeny, and radon 

during the residual period. Radioactive operations terminated at 

the end of the operational period and source term materials were 

removed from the site. The application of this survey data will 

result in overestimates of exposures and doses during the general 

activities and will result in conservative estimates of exposure 

during the highest-risk activities at Linde Ceramics during the 

period evaluated in this report (January 1, 1954 through July 31, 

2006)” (pg. 24). 

9. Failure to account for vanadium tailings 

from concentrated sludge in 15%–20% 

black uranium oxide, yellow cake 

concentrated sludge containing 10%–15% 

U3O8, and incineration of burlap and 

paper bags. 

See issues 6 and 7. 

Issue to note: Redesignation of the Linde site 

(Buildings 30, 31, 37, and 38) as a DOE 

facility. “Consequently, the NIOSH defined 

residual radiation time period for Linde 

workers employed in these buildings is now 

eliminated from compensation coverage under 

Part B of EEOICPA. Any Linde worker who 

began working at the Linde facility in one of 

these buildings after 1953 is no longer eligible 

for compensation.” 

Not specifically addressed by NIOSH in the ER. 

One additional issue will be addressed here. Appendix B contains a memorandum of June 4, 

2009 ([Name Redacted] 2009), to SC&A from a Linde SEC petitioner, attaching four 

memoranda from 1944, and asserting that, contrary to NIOSH’s assumption in its site profile of 

8%–12% U3O8 content for African pitchblende feedstock, “65% Belgian Congo ore was 

processed at Linde during the operational time period.” After examining how NIOSH 

reconstructed exposures for the residual period, SC&A observes that, regardless of the validity of 

the petitioner’s assertion, estimated radon levels in the residual period are based on actual 

measurements, not on calculations from assumed feedstock concentrations, and, thus, the 

feedstock concentration issue does not appear to be germane to the SEC evaluation issues and 

will not be addressed further in this report. This issue may become relevant if NIOSH decides to 

use indirect means, such as ore composition or data from other sites, to address the radon 

measurement issues raised in this review.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

3.0 ASSESSMENT OF NIOSH’S ABILITY TO RECONSTRUCT 

EXPOSURES DURING THE RESIDUAL PERIOD 

3.1 INTRODUCTION 

The SEC Petition raises a number of issues (summarized here in Table 1) related to 

reconstructing internal and external exposures to workers during the residual period. No issues 

were raised with respect to occupational medical or environmental exposures. The internal and 

external exposure information and estimation procedures are discussed and assessed in the 

following two subsections. It should be noted that NIOSH provides guidance for reconstructing 

doses during the residual period in the 2 1/2 pages of Section 6.0 of its Linde site profile (NIOSH 

2008b). 

3.2 INTERNAL EXPOSURE 

There is clearly a measure of subjectivity involved in deciding whether sufficient information is 

available for NIOSH to do bounding calculations, per EEOICPA and 42 CFR § 83.13(c)(1), 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.” In the case of SEC-00107 for the Linde Ceramics Plant, NIOSH has stated that bounding 

internal exposures for the residual period can be calculated: 

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 proposed class under plausible circumstances during the specified 

period (NIOSH 2008a, pg. 3). 

However, we note that the NIOSH estimation of the maximum internal dose associated with 

general building occupancy is based on a single air concentration measurement taken 22 years 

after the beginning of the residual period. 

In another SEC petition (SEC-00079), for the Dow Madison Plant, NIOSH concluded that doses 

could not be reconstructed, stating that, “NIOSH lacks sufficient personal and workplace 

monitoring data to adequately determine the potential intake of thorium radionuclides, making 

reconstruction of internal thorium doses infeasible” (NIOSH 2007, pg. 3). 

In justifying its position that reconstruction of internal thorium doses at the Dow plant is 

infeasible, NIOSH notes the following (NIOSH 2007, pg. 14): 

Some thorium air monitoring results have been identified as well as information 

on thorium source quantities handled at Dow Madison through July 1, 1960 

(Dow, 1957; Dow, 1959; AEC, 1960). While the air monitoring data and source 

term information are suitable to define work processes, these data are not 

adequate to reconstruct with sufficient accuracy potential doses received from 

exposure to thorium. In general, only one sample result is available for a 

sampling location, representing a single sampling campaign during the covered 
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period. NIOSH does not have enough documentation to ensure that all conditions 

that could affect exposure levels were similar to those represented by the 

available air monitoring data. 

In the case of Dow Madison, NIOSH had multiple air monitoring samples and source term data, 

but determined that dose reconstruction was not feasible while, in the case of Linde, NIOSH 

determined that a bounding analysis could be conducted based on a single air sample. NIOSH 

should address this apparent inconsistency in the decision-making process. It should be noted, 

however, that the analogy is not exact, since the Dow time period that was granted an SEC was 

during actual thorium alloying operations, which were complex, and not during the residual 

period. 

The ensuing discussion on bounding internal exposures at Linde during the residual period 

considers two intertwined issues: 

• Whether or not adequate information exists to perform plausible bounding calculations, 

both in terms of number of samples and adjustment of the data for back extrapolating 

over a long period of time 

• Whether or not the approach taken by NIOSH in the SEC-00107 Petition Evaluation 

Report is indeed bounding 

3.2.1 Bounding Radon Exposures 

 

The SEC-00107 Petition Evaluation Report, Section 7.2, “Evaluation of Bounding Internal 

Radiation Doses,” states the following (NIOSH 2008a): 

ORAUT-TKBS-0025 assessed fifty-five measurements of radon progeny 

concentration that were taken in 1976 and 1981 in the Tonawanda site buildings, 

which were used in MED/AEC work (ORNL, 1978, pp. 17 and 84; Bechtel, 1982, 

p. B-24). The 1981 survey results were more comprehensive and yielded 

significantly higher concentrations; thus, the 1976 results were not used to assess 

radon exposure during the residual period. As discussed in ORAUT-TKBS-0025, 

Building 31 had the highest radon progeny concentration. Based on the 

assessment of the dose, as discussed in ORAUT-TKBS-0025, applying a maximum 

exposure scenario using worst case conditions, radon exposures in all cases 

during the period evaluated in this report period can be bounded using the 

method defined in ORAUT-TKBS-0025. 

The radon exposure during the residual period was 0.201 WLM/yr, as described in Section 6.1 of 

ORAUT-TKBS-0025 (NIOSH 2006). This value is the geometric mean (GM) of 12 

measurements taken in 1981 in Building 31; the geometric standard deviation (GSD) was 1.89. 

The calculated GM was verified in the current review. A description of the radon sampling 

methods is not provided in the source document for the measurements (Bechtel 1982). 

The NIOSH position in the SEC-00107 report is that these radon exposures are representative of 

the maximum exposure scenario using worst-case conditions and can, therefore, be assumed 
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bounding. However, NIOSH has not provided robust arguments that the reported values capture 

the worst case. We recognize that NIOSH chose the more conservative of two available radon 

surveys made during the residual period to estimate radon exposures. As stated in ORAUTTKBS-0025, “The 1981 survey was more comprehensive and yielded significantly higher 

concentrations, so the 1976 results were ignored” (NIOSH 2006, pg. 73). One possible inference 

from the preceding statement is that the 1976 survey missed sampling high radon areas. It is 

certainly possible that the 1981 survey was also incomplete and not a bounding representation of 

the radon levels. 

It is important to note that Building 31 was decontaminated between the time of the 1976 ORNL 

radon survey and the 1981 survey (Bechtel 1982, pg. 11). In spite of the decontamination work, 

radon levels were higher in 1981. The authors of Bechtel 1982 raise questions about the quality 

of the radon survey reported in that document, noting the following: 

Information from FB&DU [i.e., Appendix B] includes some unconfirmed data on 

radon and radon daughter concentrations in Building 31. A review of this data 

determined that it could not support a conclusion that Building 31 requires 

further remedial action consideration (Bechtel 1982, pg. 12). 

We also note that the proposed basis for bounding radon exposures relies on the GM of the 

limited database taken at one point in time. SC&A had previously commented on this in its 

review of ORAUT-TKBS-0025 (Rev. 00), as summarized in Finding 11 from that document 

(SCA 2006c): 

Finding 11. Unless there is good reason to believe that a given worker was 

exposed to the full distribution of the measured concentrations and could not have 

experienced protracted exposures to higher than average radon concentrations, it 

may be more appropriate to use the upper 95th percentile as the default exposure 

level. NIOSH’s use of the GSD approach may not address very high, short-term, 

episodic exposures; short-term exposure during incidents; and radon intakes 

during the performance of tasks with a potential for high transient air 

concentrations. 

To develop additional perspective on the proposed radon exposure level of 0.201 WLM/yr for 

the residual period, we also examined exposures during the operational period. The following is 

noted in Section 3.5.1 of NIOSH 2006: 

After the end of African ore processing, concentration in the main ore processing 

building, Building 30, was assumed to remain at the 10-pCi/L level that was 

measured during the second period of domestic ore processing until the end of 

cleanup of Building 30. Concentrations in other Ceramics Plant buildings were 

also assumed to be 10 pCi/L until the end of cleanup in those buildings. Because 

the locations of many workers are likely to be unknown, it was assumed that all 

workers were exposed to 10 pCi/L of radon from November 1, 1947, through July 

7, 1954. 
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A value of 10 pCi/L is equivalent to 0.48 WLM/yr, assuming an equilibrium factor of 0.4. 

During the period February 25, 1944, through June 6, 1946, 289 radon samples were collected. 

No other radon data have been uncovered for the balance of the operational period (i.e., through 

July 7, 1954). The value of 10 pCi/L was based on the following rationale (NIOSH 2006, 

Section 3.5.1): 

During Ceramics Plant preproduction and initial production (which involved only 

domestic ore processing), the only source of radon was African ore processing at 

Tonawanda Laboratory. The indoor and outdoor radon concentrations to which 

Ceramics Plant workers were exposed were assumed to equal the outdoor 

concentration from Tonawanda Laboratory work. No direct measurement of this 

was available. An estimate was made based on the lowest measured indoor 

concentrations at the Ceramics Plant during African ore processing. These were 

viewed as indicating the upper limit to the outdoor concentration because outdoor 

air was drawn indoors for ventilation. Approximately 20% of the measurements 

in the Ceramics Plant ore processing building yielded results of 10 pCi/L or less, 

with most of these results at or near 10 pCi/L. Therefore, 10 pCi/L was taken as 

the estimated outdoor concentration. 

As stated by NIOSH, the value of 10 pCi/L is based on the lowest measured indoor 

concentrations at the Ceramics Plant during processing of African ores. The value was carried 

forward for the balance of the operational period from November 1, 1947, through July 7, 1954, 

for purposes of dose reconstruction (ORAUT-TKBS-0025, Table 3-5). 

 

It is not apparent why radon measurements made in the 1970s and 1980s can be considered 

representative of the radon concentrations in the 1950s. Based on the discussions provided 

above, we do not believe that NIOSH had made a scientifically sound case for the proposed 

approach to bounding radon exposures during the residual period. In summary, we have made 

the following findings about NIOSH’s approach: 

Finding 1: The observation that data taken after decontamination of Building 31 were 

higher than before decontamination calls into question the quality of the radon 

measurements. This finding is supported by a statement made by the authors of Bechtel 1982 

that the radon data from Building 31 were “unconfirmed,” again indicating concerns about 

data quality. 

Finding 2: Use of the GM rather than the 95th percentile as the appropriate exposure metric 

needs to be justified for use in a bounding calculation, particularly since measurements taken 

in 1976 are used to characterize the entire residual period beginning in 1954. Use of 1976 

data for a much earlier period needs to be justified by demonstration of equivalent (or less 

contaminated) radiological conditions. 

Finding 3: Use of measurements taken in 1981 to characterize radon exposures up to 

28 years earlier may not be bounding. Use of such data needs to be technically justified. 
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Taking guidance from the approach of ORAUT-OTIB-0070, it would seem that the most 

claimant-favorable and scientifically valid approach for quantifying the radon concentrations 

during the residual period would be to use data taken just prior to the residual period as 

representative of the radon concentration at the beginning of the residual period. These levels 

could be assumed to remain constant during the residual period, or assumed to decline at a rate 

that is consistent with the measurements made at the end of the residual period. 

3.2.2 Bounding Internal Doses 

As described by NIOSH in Section 7.2.1 of SEC-00107 (NIOSH 2008a): 

Since NIOSH did not locate urinalysis, chest counting, or other bioassay 

monitoring data for the period under evaluation [the residual period], internal 

exposure must be determined based on radiological source term and area 

monitoring data. Potential internal exposures from uranium and progeny for the 

class under evaluation can be divided into the following exposure scenarios: 

1) exposure during general building occupancy (no renovation or remediation 

activities), 2) exposure from outdoor soil contamination, 3) exposure during 

building renovation, and 4) exposure during site remediation (FUSRAP). 

Evaluation of exposures for scenario one (general building occupancy) is based 

on methodology contained in ORAUT-TKBS-0025. 

3.2.2.1 Exposure during General Building Occupancy 

In its review of the Linde site profile, SC&A had commented on the limited availability of data 

during the residual period noting the following: 

Observation 13: Inappropriate Application of Residual Contamination Data 

(Section 5.1.2) – Data used for reconstructing potential missed internal and 

external doses during years of residual contamination are not representative of 

actual conditions. For example, 1976 Building 30 air concentration data were 

used for missed internal dose estimation for the entire residual period...(SCA 

2006c). 

This comment remains valid. 

The single air sample was assumed to be from a lognormal distribution with an assigned GSD of 

5, presumably based on guidance provided in Battelle-TIB-5000 (Battelle 2007). However, we 

note in that document (Section 2.1.2.5) that a GSD of 5 is recommended for data describing a 

single process, while a GSD of 10 is recommended for data describing an entire site. Since the 

datum from ORNL 1978 is used to characterize the entire site, NIOSH should provide an 

explanation as to why a GSD of 5 was appropriate for a bounding calculation. Moreover, a 

single sample cannot be reliably located on a probability distribution, and substantial errors could 

be introduced by this assumption. 

 
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Building 30 was determined to be the most contaminated building on the Linde site during the 

1976 ORNL survey (ORNL 1978) and, consequently, NIOSH selected an airborne dust sample 

from this building as the bounding value for the residual period. However, it should be 

emphasized that the airborne uranium concentration of 1.9 × 10-2 pCi U/m3 was based on only 

one measurement. NIOSH does not provide convincing arguments that, because this single air 

sample was taken from the most-contaminated building in a 1976 survey, the results are 

bounding for the period from 1954 through mid-2006 for all workers except those involved in 

renovation/remediation. 

We note that, in justifying the availability of sufficient data to bound internal exposure, NIOSH 

took a different approach for the Madison Plant of Dow Chemical Company. As described in 

SEC-00079, Addendum 2, NIOSH assumed that air concentrations of thorium at Dow Madison 

existing at the end of operations in 1961 declined exponentially to air concentrations measured 

during cleanup in 2006. Use of exponential decline is consistent with the guidance provided in 

ORAUT-OTIB-0070. The exponential decay approach may be bounding for all worker 

exposures at Linde during the residual period prior to 1976, as compared to the constant 

concentration approach taken in SEC-00107. It may also be bounding for some cases if the 

worker exposure included time periods before and after 1976. It should be noted, however, that 

disturbances, such as cleaning, washing, painting of surfaces, etc., may render the exponential 

decay approach not conservative at all. We further note that airborne concentrations were 

measured near the end of the operational period during decontamination of the Step III Plant 

(Klevin 1954). The average dust level was 78 dpm/m3

, with a minimum of 1 dpm/m3 and a 

maximum of 720 dpm/m3. These data could be considered as a starting point for estimating dust 

levels during the residual period. In short, a technically supportable estimate of the diminution 

of residual contamination due to the various factors operative at the Linde plant is an essential 

element necessary for the use of back extrapolation. 

In summary, we have made the following findings regarding the NIOSH approach for the 

bounding general building occupancy exposures during the residual period: 

Finding 4: The NIOSH assumption that a single air sample taken in the 1970s can be used 

to bound plausible internal exposures to uranium, Th-230, and Ra-226 for over 50 years 

beginning in 1954 is highly questionable. 

Finding 5: NIOSH assumes that the GSD of the lognormal distribution is 5, when guidance 

in Battelle 2007 recommends a value of 10 for site-wide estimates. The placement of the 

single sample on the lognormal distribution could lead to substantial errors and cannot be 

reliably done. 

Finding 6: NIOSH’s use of a constant air concentration, rather than an exponentially 

declining concentration, may be not be claimant favorable and is not consistent with the 

guidance in ORAUT-OTIB-0070. Back extrapolation needs to be technically justified by 

examination of potential site-specific changes in residual contamination. 
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3.2.2.2 Exposure from Outdoor Soil Contamination 

The author(s) of the SEC-00107 Petition Evaluation Report determined that soil contamination 

was not an issue, noting that a soil pile on the site was recommended for unrestricted use 

(NIOSH 2008a, Section 7.2.1.2). This position is supported by information presented in Section 

6.1 of ORAUT-TKBS-0025, where data are provided on outdoor air contamination 

measurements for U-238, Ra-226, and Th-230 taken during 2000–2004 showing that airborne 

concentrations are two to four orders of magnitude below the limits in 10 CFR 20. Thus, 

outdoor exposures are not important contributors to the dose, and SC&A did not spend time 

looking further into this exposure pathway. 

3.2.2.3 Exposure during Building Renovation 

According to worker recollection, renovation work was conducted on Building 30 during the 

period 1962 through 1970, although specific dates and process details are unknown (NIOSH 

2008a, pg. 22). The approach taken in the SEC-00107 Evaluation Report to estimate inhalation 

dose during renovation in the residual period was to use data obtained from prior renovation of 

the same building during the 1948–1949 cleanup period and scale the results to the later time 

period. A basic premise of this model is that the 1948–1949 cleanup reduced contamination to 

such levels that airborne dust generated during subsequent building renovation in 1962–1970 

was proportionately reduced. NIOSH needs to provide convincing arguments that, during 

residual period renovation, workers would not uncover pockets of contamination during 

equipment and wall removal that were not decontaminated previously. 

The SEC petition states the following regarding the 1948–1949 cleanup activities: 

The vacuum cleaning operation was selected as an activity that is representative 

of the renovation work in Building 30 from 1962 through 1970, as that work was 

described by former workers. The vacuum cleaning was a dusty operation 

commensurate with what could reasonably be expected to result from renovation 

activities. The vacuum cleaning operation provided the additional benefit of 

having the highest number (17) of samples for a given operation. The mean 

measured alpha concentration in Building 30 during D&D is 84 dpm/m3

. The 

estimated median concentration is equal to the measured mean. The GSD is 2.46, 

calculated by assuming the measured maximum to be the 95th percentile value of a 

lognormal distribution (Battelle-TIB-5000, p. 17). (SEC-00107, Section 7.2.1.3) 

The dust concentration data were obtained from Table V of Heatherton (1950), who reported 

average and maximum exposures of 1.2 and 5.3 maximum allowable concentration (MAC), 

respectively, for vacuum cleaning operations. NIOSH assumed that cleanup in 1948–1949 

would reduce the air concentration during the 1962–1970 renovation by the amount that the 

surface activity was reduced during the course of the 1948–1949 cleanup. Klevin et al. 1954, 

Table IX,1 reported that the contact β/γ dose was reduced from 30 mrep/hr before 

decontamination to 3.6 mrep/hr after decontamination, resulting in a decontamination factor 

1

 NIOSH identified Plant A in Klevin et al. 1954 as Linde Building 30. 
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(DF) of about 8. Thus, exposure during renovation was fixed by NIOSH at a median value of 

10.4 dpm/m3 (84 dpm/m3 ÷ 8 DF) with a GSD of 2.46. This is equivalent to 31 pCi/calendar-day 

for a 40-hr work-week (10.4 dpm/m3 × 9.6 m3/workday × 1 pCi/2.22 dpm × 250 workdays/365 

calendar days). 

NIOSH states that vacuum cleaning was selected as representative of renovation work in 

Building 30 during 1962–1970, without indicating why this process was chosen in preference to 

other processes documented during the 1948–1949 cleanup. Other processes produced higher 

dust concentrations and, since the purpose of the SEC-00107 Report is to produce bounding 

results, justifying the basis for process selection is important. Dust loadings taken from general 

area sampling during various cleanup operations are compared in Table 3 (based on Table V of 

Heatherton 1950). It is apparent that selection of any of the other processes would have been 

more conservative. However, the larger question is whether any of the measurements in Table 3 

are illustrative of plausible circumstances for developing sustainable air concentrations during 

that portion of the residual period when renovations were conducted. All are reflective of 

transient operations. 

Table 3. Air Concentrations Measured During 1948–1949 Clean-up of Building 30 

Air Concentration (MAC alpha dust) Process Number of 

Measurements min. max. avg. 

Vacuum cleaning 17 0.1 5.3 1.2 

Removing concrete floor with pneumatic hammer 6 4.2 25 10 

Flame cleaning 6 1.7 13 6.6 

Sandblasting 5 7.0 49 22 

One-half hour after sandblasting 3 1.0 1 1 

 

Klevin (1954) reports that 40 general area air samples (presumably taken in 1954 during the 

decontamination of the Step III Plant [Building 38]) averaged 78 dpm/m3, with a maximum 

value of 720 dpm/m3 and a minimum value of 1 dpm/m3. While the average airborne 

concentration of 78 dpm/m3

 is similar to the value of 84 dpm/m3 observed during vacuum 

cleaning operations in Building 30, no details are available in Klevin 1954 as to the nature of the 

Step III Plant decontamination operations. Klevin (1954) does note that “These dust 

concentrations, much lower than those found during the previous decontamination operations in 

Step I and Step II, demonstrate the results of good supervision of the cleanup operations.” 

 

Review of Klevin et al. 1954 suggests that the decontamination factor of 8 may be overstated. It 

appears that the pre-contamination value of 30 mrep/hr is the worst spot on the floor in the East 

Area of Building 30 (Klevin et al. 1954, Table I), while the post-decontamination value of 

3.6 mrep/hr is the high value reported for the West Area of the building. Thus, the 

decontamination factor was based on measurements in different areas of Building 30 that might 

have had differing proclivities for decontamination. A comparison of all the decontamination 

data is presented in Table 4, based on data from Tables I and II in Klevin et al. 1954. In this 

table, we have calculated the decontamination factors for average and high contact exposure 

measurements. For pre-decontamination characterization, we have selected data for the worst 

spot on the floor or the worst spot on the wall (whichever was higher) from Table I of Klevin et 

al. 1954. 
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Table 4. Decontamination Factors for Building 30 during 1948–1949 Cleanup 

Average High 

Area Pre-Decon 

(mrep/h) 

Post-Decon 

(mrep/h) 

Decon 

Factor 

Pre-Decon 

(mrep/hr)

Post-Decon 

(mrep/hr)

Decon 

Factor 

Shipping & Receiving N/A 1.0 --- 9.0 1.5 6.0 

Step I 

Moore 0.33 0.44 <1 3.5 2.0 1.8 

West 0.11 0.39 <1 3.6 3.6 1.0 

East 0.4 0.44 <1 30.0 3.0 10 

Main Balcony 0.1 0.27 <1 3.8 1.2 3.2 

Step II 

Main 0.4 0.33 1.2 20.0 2.2 9.1 

Balcony N/A 0.48 --- 5.0 2.1 2.4 

It can be discerned from Table 4 that the “average” values show little or no reduction in 

contamination. Decontamination factors of 1 to 10 were calculated based on the “high” values, 

with the average of the “high” decontamination factors being 4.8. This is about 60% of the value 

proposed by NIOSH. 

The use of 10.4 dpm/m3

, based on average air concentrations (from vacuum cleaning) during 

cleanup and a decontamination factor of 8, appears to be at odds with guidance provided in 

TBD-6001 (Battelle 2006); although, as we have discussed previously, this guidance is confusing 

(SCA 2008). The authors of TBD-6001 (Battelle 2006, Table 6.2) propose using 20.7 pCi/ 

calendar day, with a GSD of 5 for the residual period at facilities where uranium was refined. 

Without running a hypothetical IMBA/IREP case, it is not possible to decide whether assuming 

an intake of 31 pCi/calendar day (GSD - 2.46) is more claimant favorable than an intake of 

20.7 pCi/day (GSD-5). Both possibilities are based on very limited data. 

We note that the data in Heatherton 1950 are based on “MAC’s total alpha dust.” NIOSH does 

not provide any basis for estimating how the alpha counts are distributed among various 

radionuclides. Since the uranium was chemically separated from the ore at Linde, U-238 was 

not in equilibrium with its chemically different progeny. The ratio of Th-230 and Ra-226 to 

U-238 would be expected to vary from location to location, depending on specific unit 

operations at each location. NIOSH needs to address this issue. The dose to specific organs can 

vary widely, depending on the particular radionuclide and the type of lung absorption assumed, 

as shown in Table 5 (ICRP no date). Discussion in Section 3.2.2.1, “Exposure During General 

Building Occupancy,” indicates that widely differing ratios of Th-230/U and Ra-226/U have 

been reported in ORNL 1978 and USACE 2004. NIOSH needs to define the radionuclide mix 

for the period of building renovation. 
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Table 5. Comparison of Dose Conversion Factors for Various Organs from Inhalation of 

Alpha-Emitting Radionuclides (30 years after intake) 

Organ Dose Conversion Factor (Sv/Bq) 

Radionuclide Absorption 

Type 

Bone 

Surface Lungs Brain Colon Pancreas 

U-234 M 2.4E-06 1.6E-05 6.1E-08 7.4E-08 6.1E-08 

U-234 S 2.2E-07 4.0E-05 5.2E-09 2.0E-08 5.2E-09 

Th-230 M 1.0E-03 1.7E-05 1.0E-06 1.0E-06 1.0E-06 

Th-230 S 8.2E-05 3.9E-05 8.3E-08 9.7E-08 8.3E-08 

Ra-226 M 7.8E-06 1.7E-05 2.9E-08 5.7E-08 2.8E-08 

 

In summary, we have the following findings about the proposed bounding estimates for the 

renovation period: 

Finding 7: The process selected to establish the pre-decontamination dust level does not 

appear to be claimant favorable, based on the cited data source (Heatherton 1950). 

Finding 8: The assumed decontamination factor of 8 is based on pre- and postdecontamination values taken in different areas. Examination of the full dataset suggests that 

the differences in the potential internal exposures between the early and later 

decontamination activities may be negligible. 

Finding 9: It is not clear that the bounding approach used in the SEC-00107 Petition 

Evaluation Report is more claimant favorable than that proposed in TBD-6001. 

Finding 10: The mix of alpha-emitting radionuclides in the airborne dust needs to be 

quantified for renovation activities, taking into consideration that raffinates might have been 

present. 

3.2.2.4 Exposure During Site Remediation 

NIOSH proposed the same approach for site remediation as for building remediation. FUSRAP 

activities occurred at Linde from 1988–1992 and again in 1996. The comments summarized in 

Section 3.2.2.3 apply to the selected treatment of exposure during site remediation. 

 

3.2.3 Application of Bounding Approach 

NIOSH does not provide any explanation as to how the internal exposures from general building 

occupancy, building renovation, and site remediation are to be apportioned during the residual 

period. 

Finding 11: NIOSH needs to explain how internal exposures should be apportioned among 

the various exposure scenarios. 
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3.3 EXTERNAL EXPOSURE 

Although the majority of the Linde SEC-00107 issues pertain to internal exposures, NIOSH also 

evaluated potential external exposures received during work performed at Linde in the residual 

period. NIOSH states the following regarding the methods for bounding external doses in 

Section 7.3.1 of the ER: 

As previously discussed in this report, the indoor radiological conditions (as 

reported in ORNL 1978) were reviewed and determined to be comparable to the 

1950 post-decontamination conditions. ORAUT-TKBS-0025 assesses the external 

dose from uranium and progeny, based on Building 30, the primary uranium 

processing building and the building determined in 1976 to be the most 

contaminated on the site. Because this method applies a maximum external 

exposure scenario for any work at the Linde Ceramics site during the period 

evaluated in this report, this method can be applied as a bounding approach for 

reconstructing external dose for the proposed worker class evaluated in this 

report. 

Section 6.2 of NIOSH 2006 (ORAUT-TKBS-0025) states the following: 

Because the radiation levels seemed to remain fairly constant, and because the 

levels were fairly low, the Tonawanda Laboratory post-cleanup exposures, based 

on Building 30 contamination levels, were used to estimate the external exposure 

rate. No adjustments for changes in work hours were made. Table 6-2 

summarizes the results. The radiation energy distributions were assumed to be 

the same as those during the operational period. 

Table 6-2 of NIOSH 2006 lists NIOSH’s bounding estimate of external exposure to penetrating 

radiation during the residual period as 0.068 R/yr, with a lognormal GSD of 3. NIOSH’s 

bounding estimate of external exposure to non-penetrating radiation is 0.326 rem/yr, with a GSD 

of 3. 

Although it is not clear how NIOSH derived its estimates of external dose, it appears that they 

used data from two radiological surveys of Building 30, which include Heatherton 1950 and 

ORNL 1978. NIOSH chose to use the survey data from Building 30, since that building was 

determined to be the most contaminated building on the Linde site. The first survey, published 

in Heatherton 1950, presents the results of a 1949 radiological survey performed before and after 

decontamination of Building 30. The results of that survey are summarized here as Table 6 and 

represent total beta plus gamma radiation dose rates measured in various parts of Building 30 at 

both contact and 3 feet from surfaces. Table 6 shows that there were hundreds of external dose 

rate measurements made in all areas of the building. NIOSH describes some of their analysis of 

the 1949 data in Section 6.2 of NIOSH 2006: 

The beta dose rate at 3 feet above the ground that corresponds to the adopted 

value of gamma exposure rate was estimated as 4.38 × 10-1 mrem/hr, which is 

4.66 times the gamma rate where 4.66 is the ratio of beta mrem/hr at 3 feet to 
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gamma mR/hr at 3 feet for the floors and walls in Building 30 after 

decontamination (Table 4-1).2

 It is assumed that the GSD for the beta dose rate 

would be the same as for the photon dose rate.

In order to evaluate the bounding external doses presented in Table 6-2 of NIOSH 2006, SC&A 

performed hand calculations using the data in Table 6. From looking at the final survey results 

for the Moore Area, the mean beta-gamma dose rate at 3 feet is seen as 0.13 mrep/hr, with the 

highest reading at 0.4 mrep/hr. We consider the Moore Area mean dose rate of 0.13 mrep/hr at 

3 feet useful for evaluating external exposure rates in Building 30, because the means of all the 

different areas presented in Table 6 at 3 feet range from 0.09 to 0.2 mrep/hr. Inspection of the 

original data reported by Heatherton (1950) revealed that, following decontamination in 1949, 

91% of the readings (366 of 403 readings) in the Moore Area were less than 1 mrep/hr. Using 

the Moore Area as the example area, and assuming 2,000 hours per year, the mean beta-gamma 

dose rate of 0.13 mrep/hr translates to 0.26 rep/yr. Applying the beta-gamma ratio of 4.66, the 

gamma dose estimate using the Moore Area data is about 0.056 rep/yr. This can be compared to 

the external penetrating dose estimate of 0.068 R/yr that was adopted by NIOSH for use in 

reconstructing the external doses during the residual period. 

The second and later survey, published in ORNL 1978, presents the results of a 1976 

radiological survey performed in various buildings of the Linde site. Hundreds of external 

measurements of both the beta-gamma dose rates (mrad/hr) and the direct external gamma 

exposure rate (μR/hr) were taken. Figure 17 of ORNL 1978 shows all of the direct gamma 

readings taken at 1 meter, which exceeded 20 μR/hr, with a high reading of 63 μR/hr. Figure 17 

is reproduced below as Figure 1. The mean of these 91 measurements that exceeded 20 μR/hr is 

approximately 29 μR/hr. This value is an overestimate of the actual mean, since it does not take 

into account all of the values below 20 μR/h. Using this value in the example calculation, and 

assuming 2,000 hours per year, the external gamma dose estimate is 0.058 R/yr, as compared to 

NIOSH’s value of 0.068 R/yr. These hand calculations confirm NIOSH’s statement that the 

1950 conditions in Building 30 are similar to those in 1976. 

The comparisons of external exposure rate measurements made following decontamination 

activities in 1949, and then again in 1976, reveal that NIOSH has selected a claimant-favorable 

and scientifically sound value for reconstructing external doses during the residual period. 

2

 Table 4-1 of ORAUT 2006 presents some statistical analysis of the 1949 survey data using the program 

LOGNORM4. 
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Table 6. Summary of 1949 Post-Decontamination Survey Results for Building 30 

(Heatherton 1950) 

Initial survey (mreps/hr)a Final survey (mreps/hr)b

# of 

Readings % <1.0 Lowest Highest Mean # of Readings % <1.0 Lowest Highest Mean 

contact 124 81 0.1 9 0.73 0 1.5 1 

Shipping & receiving at 3' 0 0.3 0.2 

Step I

contact 86 40 0.2 3.5 1.3 403 91 0 2 0.44 Part I Moore Area 

at 3' 0.08 0.43 0.33 0 0.4 0.13 

contact 264 83 0 3.6 0.41 1153 95 0 3.6 0.39 Part II West Area 

at 3' 0 0.3 0.1 0 0.4 0.11 

contact 250 80 0 30 0.63 1020 97 0 3 0.44 Part III East Area 

at 3' 0 1 0.4 

contact 78 31 0.3 2.8 1.2 Moore Balcony at 3' 0.2 0.6 0.4 

contact 135 77 0 3.8 0.4 499 99 0 1.2 0.27 West Balcony at 3' 0 0.3 0.1 0 0.2 0.09 

contact 65 58 0 4 0.9 Upper East Balcony at 3' 

contact 94 48 0 20 1.1 Lower East Balcony at 3' 0.1 0.8 0.4 

Pachuca tanks and contact 128 74 0 2.6 0.84 

comp. room at 3' 0 0.6 0.27 

contact 88 34 0 20 2.2 1057 96 0 2.2 0.33 Step II - Floor at 3' 0 1 0.4 0.6 0.12 

contact 387 87 0 2.1 0.48 Step II - Balcony at 3' 0.4 

a Taken from Table III of Heatherton 1950. Results after the building was vacuum cleaned and flushed. 

0.14 

b Taken from Table IV of Heatherton 1950. Results after decontamination and each area cleaned and flushed with water. 
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26 

25 

24 

26 30 30 30 23 

26 22 30 28 22 22 

34 63 37 22 22 21 

26 37 37 24 22 20 20 20 

20 19 

20 22 18 

17 

20 22 22 16 

22 15 

20 14 

24 26 24 20 20 20 13 

12 

20 11 

20 35 20 10 

20 23 25 26 20 23 48 48 9 

41 38 8 

20 36 41 51 41 33 51 51 7 

30 30 30 30 36 36 35 51 35 63 61 20 6 

38 23 20 20 20 56 35 20 5 

20 20 20 30 20 4

22 23 30 3 

20 20 35 20 2 

23 33 1 

A B C D E F G H I J K L M 

Figure 1. External Gamma Readings (in μR/hr) 

of 20 μR/hr or Higher at 1 Meter in Building 30 

(Re-typed from Figure 17 of ORNL 1978) 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Radiation Exposure to Ore-Containing Burlap Bags 

During an SC&A technical call that took place on February 13, 2008, a Linde worker described 

possible exposures of Linde workers in the 1950s to African ore-containing burlap bags that may 

have been left near the workers’ lunch area. The worker also explained that the Linde workers 

may have stood near and rested on these bags during their lunch breaks (SC&A 2008b). This 

issue, popularly referred to as the “burlap bag issue” and included in the SEC petition under 

Issue 9, was extensively analyzed and modeled by both NIOSH and SC&A during the Linde Site 

Profile review and resolution process. Both parties determined that, if this scenario needed to be 

addressed in future dose reconstructions involving Linde site workers, plausible and bounding 

external exposures to those individuals could be estimated. As such, the burlap bag issue was 

closed. In fact, Appendix E of the latest version of the Linde site profile (NIOSH 2008b) 

discusses at length the evolution of the burlap bag issue. After reviewing the history of the issue 

and performing a dose assessment calculation, the appendix concludes the following: 

Based on the weight of the available evidence (tabulated below), it is unlikely that 

two pallets of uranium ore (which was last processed at Linde in 1946) would 

have been in Building 30 in 1951 (5 years after the cessation of processing of 

uranium ore). The current external exposure model for the period in question 

incorporates uncertainty in the external dose assignment by application of a 

lognormal distribution with a GM of 1.85 and a GSD of 4.04. This assumed 

distribution (with a 95th-percentile value of 18.5 R/yr) accounts for possible 

deviation of the actual worker exposure of the magnitude that would result from 

the assumption that two pallets of uranium ore were in Building 30 in 1951

(NIOSH 2008b, App. E, pg. 4). 

SC&A concludes that this issue is resolved. In addition, if it is determined at a later date 

that external exposure to burlap bags was plausible during the residual period, 

scientifically valid external dosimetry models can be used to place a plausible upperbound on such exposures. 
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4.0 REFERENCES 

10 CFR 20. Title 10, Part 20, of the Code of Federal Regulations. Standards for Protection 

Against Radiation. 

42 CFR 82. Title 42, Part 82, of the Code of Federal Regulations. Methods for Radiation Dose 

Reconstruction Under the Energy Employees Occupational Illness Compensation Program Act 

of 2000; Final Rule. 

42 CFR 83. Title 42, Part 83, of the Code of Federal Regulations. Procedures for Designating 

Classes of Employees as Members of the Special Exposure Cohort Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal Register/ Vol. 69, 

No. 104/Friday, May 28, 2004, p. 30764. 

ABRWH 2006. Transcript of the 38th Meeting of the Advisory Board on Radiation and Worker 

Health, held at the Marriott Metro Center, Washington, DC, on June 16, 2006. U.S. Department 

of Health and Human Services, Centers for Disease Control and Prevention, National Institute 

for Occupational Safety and Health. 

ABRWH 2009. Transcript of the 61st Meeting of the Advisory Board on Radiation and Worker 

Health, held at the Doubletree Hotel, Albuquerque, NM, on February 19, 2009. U.S. 

Department of Health and Human Services, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health. 

AEC 1960. Compliance Inspection Report: Dow Chemical Co. Site, Madison, Illinois; U.S. 

Atomic Energy Commission; August 4, 1960; SRDB Ref ID: 29268. 

ACE Buffalo (U.S. Army Corps of Engineers Buffalo District) 2004a. Former Linde Site 

Frequently Asked Questions, Formerly Utilized Sites Remedial Action Program (FUSRAP), 

March. [Linde Air and Ceramics, NY\12-06-04-DataCapture\030001720.pdf] 

Battelle 2006. Site Profiles for Atomic Weapons Employers that Refined Uranium and Thorium. 

Document Number: Battelle-TBD-6001, Revision: F0. Effective Date: December 13, 2006. 

Battelle 2007. Default Assumptions and Methods for Atomic Weapons Employer Dose 

Reconstructions. Battelle-TIB-5000, PNWD-3741, Revision: 00, April 2, 2007. 

Bechtel 1982. Preliminary Engineering Evaluation of Remedial Action Alternatives; Bechtel 

National Inc. (Bechtel); November 1982; SRDB Ref ID: 14704. 

[Name Redacted] 2009. Memo from [Name Redacted], Linde Ceramics SEC Petitioner, SEC00107, to John Mauro and Steve Ostrow (SC&A), “Feed Material Memoranda for Linde 

Ceramics Facility 1944,” June 4, 2009. 
Effective Date: 

 June 18, 2009 

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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. 

Dow 1957. Exemption of Thorium Contained in 4% Magnesium Alloys from Licensing 

Requirements under Part 40; Dow Chemical Company draft memorandum; July 12, 1957; 

SRDB Ref ID: 29271. 

Dow 1959. Letter from Dow Chemical Company to U.S. Atomic Energy Commission; August 

28, 1959; SRDB Ref ID: 29270. 

Eisenbud, M., 1954, memorandum to Paul B. Pew, Linde Air Products Company, July 12. 

SRDB 35732. 

Elliott, L.J. 2006. Letter to Peter M. Turcic, Office of Compensation Analysis and Support, 

National Institute for Occupational Safety and Health, Cincinnati, Ohio, February 23. SRDB Ref 

ID: 48222. 

Ferry, J.L. 1944. Memo from John L. Ferry, Captain, Medical Corps, to Major J. E. Vance, The 

Area Engineer, Madison Square Area, New York, “Processing of High Grade Ores at the Linde 

Air Products Co.,” February 22, 1944. 

Hadlock, C. 1944. Memo from Canfield Hadlock, Major, Corps of Engineers, to the Area 

Engineer, Tonawanda Area, Tonawanda, New York, “Experimentation on High-grade Ores at 

the Linde Air Products Company,” February 26, 1944. 

Harris, W. B. 1954. "Decontamination of Linde Air Products Co., Contract No. AT-(301) GEN165, Radiation Survey of April 11-15, 1954," memorandum to R. L. Kirk, U.S. Atomic Energy 

Commission, New York Operations Office, April 23. SRDB Ref ID: 11142. 

Heatherton, R.C. 1950. Decontamination and Survey of Uranium Refinery Plant, NYO-1536; 

December 14, 1950; SRDB Ref ID: 29822. 

HHS (Health and Human Services) 2005. Designating a Class of Employees from Linde 

Ceramics Plant, Niagara Falls, NY, December 8. SRDB Ref ID: 48223. 

Holmes, A.R. 1944b. Untitled letter to E. L. Van Horn (U.S. Engineer Office), Linde Air 

Products Company, Tonawanda, New York, November 14. SRDB Ref ID: 12382. 

Howland, J.W. 1946. "Possible Hazards at Linde Ceramics and Electro-Metallurgical Plants," 

memorandum to the Area Engineer, U.S. Engineer Office, Rochester, New York, November 19. 

SRDB Ref ID: 9849. 

ICRP (International Commission on Radiological Protection) no date. ICRP Database of Dose 

Coefficients: Workers and Members of the Public. International Commission on Radiological 

Protection. CD-ROM. 

ICRP (International Commission on Radiological Protection) 1994. Human Respiratory Tract 

Model for Radiological Protection. ICRP Publication 66, Pergamon Press: Oxford, England. 
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. 

Klevin, P.B., 1954. Letter from Paul B. Klevin, Health & Safety Laboratories, to H. Haywood, 

Linde, May 4, 1954, p. 20 of SRDB Ref. ID: 35732. 

Klevin, P.B., W.B. Harris, and H.I. Blatz 1954. Decontamination of Buildings Used for 

Processing Alpha Emitters, select pages only; April 29, 1954; SRDB Ref ID: 14830; OSA Ref 

ID: 105687 pp. 67–68. 

NIOSH (National Institute for Occupational Safety and Health) 2004. Estimation of Ingestion 

Intakes, OCAS-OTIB-009, Revision 0, Office of Compensation Analysis and Support, 

Cincinnati, Ohio, April 13, 2004. 

NIOSH (National Institute for Occupational Safety and Health) 2005. An Exposure Matrix for 

Linde Ceramics Plant (Including Tonawanda Laboratory), ORAUT-TKBS-0025; Rev. 00. May 

31, 2005. 

NIOSH (National Institute for Occupational Safety and Health) 2006. An Exposure Matrix for 

Linde Ceramics Plant (Including Tonawanda Laboratory), ORAUT-TKBS-0025; Rev. 00 PC-1; 

January 19, 2006; SRDB Ref ID: 22268. 

NIOSH (National Institute for Occupational Safety and Health) 2007. SEC Petition Evaluation 

Report: Petition SEC-00079. Dow Chemical Co. (Madison Site), Rev. 0. Submittal Date: April 

13, 2007. 

NIOSH (National Institute for Occupational Safety and Health), 2007a, Radiation Exposures 

Covered for Dose Reconstructions Under Part B of the Energy Employees Occupational Illness 

Compensation Program Act, OCAS-IG-003, Rev. 0, Office of Compensation Analysis and

Support, Cincinnati, Ohio, November. [SRDB Ref ID: 35987] 

NIOSH (National Institute for Occupational Safety and Health) 2008a. SEC Petition Evaluation 

Report, Petition SEC-00107: Linde Ceramics Plant, Submittal Date: November 3, 2008. 

NIOSH (National Institute for Occupational Safety and Health) 2008b. An Exposure Matrix for 

Linde Ceramics Plant (including Tonawanda Laboratory), ORAUT-TKBS-0025, Rev. 01, 

November 4, 2008. 

ORAU (Oak Ridge Associated Universities Team) 2003, Technical Information Bulletin: Dose 

Reconstruction from Occupationally Related Diagnostic X-ray Procedures, NIOSH Dose

Reconstruction Project, ORAUT-OTIB-0006, Rev. 02. 

ORAUT (Oak Ridge Associated Universities Team) 2005d, Technical Information Bulletin: 

Analysis of Coworker Bioassay Data for Internal Dose Assignment, ORAUT-OTIB-0019, Rev 

01, Oak Ridge, Tennessee, October 7. [SRDB Ref ID: 19438] 

ORAUT (Oak Ridge Associated Universities Team) 2005, Technical Information Bulletin: 

Estimation of Radium-226 Activity in the Body from Breath Radon-222 Measurements, NIOSH 

Dose Reconstruction Project, ORAUT-OTIB-0025, Rev. 00, April 5. 
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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:

ORAUT (Oak Ridge Associated Universities Team) 2008. Dose Reconstruction During 

Residual Radioactivity Periods at Atomic Weapons Employer Facilities. ORAUT-OTIB-0070, 

Rev. 0, March 10, 2008. 

ORNL 1978. Formerly Utilized MED/AEC Sites Remedial Action Program—Radiological 

Survey of the Former Linde Uranium Refinery, Tonawanda, New York, W-7405-ENG-26; Oak 

Ridge National Laboratory (ORNL); May 1978; SRDB Ref ID: 14620. 

SC&A 2006a. Report to the Working Group on Special Exposure Cohort Petition Review, Draft, 

January 16, 2006. 

SC&A 2006b. Board Procedures for Review of Special Exposure Cohort Petitions and Petition 

Evaluation Reports, Revision 1. SCA-TR-TASK5-0002, June 12, 2006. 

SC&A 2006c. Review of the NIOSH Site Profile for the Linde Ceramics Plant and Tonawanda 

Laboratory, Tonawanda, New York. SCA-TR-TASK1-0014, July 14, 2006. 

SC&A 2008a. Draft Review Of Battelle-TBD-6001, Site Profiles For Atomic Weapons 

Employers That Refined Uranium And Thorium. Rev. FO, SCA-TR-TASK1-0026, December 

13, 2006. 

SC&A 2008b. “Linde Burlap Bag Issue – Technical Call Notes,” Notes from the Linde Working 

Group conference call taken by S. Ostrow, S. Cohen & Associates. February 13, 2008. 

SEC-107 2008. Linde Ceramics SEC Petitions: SEC00106, November 1, 1947 through 

December 31, 1953; SEC00107, January 1, 1954 through July 31, 2006 – Linde Ceramics 

Facility, Tonawanda, New York, March 19, 2008. 

Thomas, W.G. 1944. Letter from W.G. Thomas, Captain, Corps of Engineers, Operations Unit, 

to A.R. Holmes, The Linde Air Products Company, February 17, 1944. 

Turcic, P.M. 2007. “Linde Ceramics Plant,” EEOICPA Circular No. 07-07, U.S. Department of 

Labor, Washington, DC. SRDB Ref ID: 40373. 

Turcic, P.M. 2008. Memorandum to [Name Redacted], U.S. Department of Labor, Washington, 

DC. May 21. 

USACE 2004. Air Monitoring Data. U.S. Army Corps of Engineers, Buffalo, New York. 

SRDB Ref. ID: 14703. 

Van Horne 1944. Memo from E. L. Van Horn, Captain, Corps of Engineers, Area Engineer, to 

Major Canfield Hadlock, Office of the Area Engineer, Tonawanda Area, Tonawanda, N.Y, 

“Experimentation on High-grade Ores at the Linde Air Product Company,” February 26, 1944. 
Effective Date: 

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APPENDIX A: COMPARISION OF AN EXPOSURE MATRIX FOR LINDE CERAM

(INCLUDING TONAWANDA LABORATORY), ORAUT-TKBS-0025, REVISION 01 TO 

Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

Publication Record Additional information on 

revisions to Document 01 

Approved revision to chrevision (Rev. 00 PC-2-

A) as a result of formal incorporate (1) change iDOL interpretation of ato Ceramics Plant, (3) rWorking Group commeimplementation instructperiod October 1, 1942 Incorporates formal intecomments. Constitutes 

document. Training reqTask Manager. Initiated 

1.0 Introduction Rev. 01 has additional language 

indicating disclaimers to 

designations of DOE/Atomic Weapons Facilities. 

N/A In this document, the w

general term for an area

buildings that served a sdoes not necessarily conemployer facility” or a [DOE] facility” as definOccupational Illness Co[EEOICPA; 42 U.S.C. § EEOICPA defines a DOstructure, or premise, in

which such building, str... in which operations by, or on behalf of, the (except for buildings, stor operations ... pertainPropulsion Program)” [Accordingly, except for Nuclear Propulsion Profacility that performs or of any nature whatsoeve

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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

encompassed by EEOICFor employees of DOE the DOE facility definiteligibility for a dose recprerequisite to a compemembers of the Special compensation decision on a section of the statuPerformance of Duty.” 7384n(b)] says that an ibe determined to have sperformance of duty for compensation program was at least as likely as the facility [where the edetermined in accordanof causation1] guidelinesubsection (c) ...” [42 Uthe statute nor the proba(nor the dose reconstruc82) define “performancemployees with a cover“duty” to nuclear weapoThe statute also includefacility that excludes “bpremises, grounds, or oExecutive Order No. 12(42 U.S.C. 7158 note), pNuclear Propulsion Pro7384l(12)]. While this Nuclear Propulsion Facunder the Act, the sectiowith the compensation demployees with cancer entitled “Exposure in thdoes not contain such an statute requires NIOSH derived radiation expos

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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

dose reconstructions for including radiation expoNuclear Propulsion Proand external occupationconsidered valid for increconstruction. No effoeligibility of any fractiofor inclusion in dose rechowever, does not consto be occupationally der• Background radiation, naturally occurring radostructures • Radiation from x-rays injuries or illnesses or fUnder EEOICPA, emplcategorized as either (1) period (i.e., when the Aproducing material that used in the production oduring the residual contperiods that NIOSH has potential for significant the period in which weaoccurred). For contract occupationally derived covered facilities must breconstructions. This inrelated to the Naval Nucany radiation exposure of commercial radioacticoncurrently manufactuduring the covered periothe following exposures (NIOSH 2007a): • Background radiation, naturally occurring rado

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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

structures • Radiation from x-rays injuries or illnesses or fFor employment during period, only the radiatio42 U.S.C. § 7384n(c)(4received from DOE-relain dose reconstructions. are not reconstructed ducontamination period (Nnoted that under subpar7384n(c)(4), radiation aNuclear Propulsion Profrom the employee’s radonly applies to those AWduring the residual contunder subparagraph B oradiation from a source A that is not distinguishdocumentation from radsubparagraph A is consradiation dose. This sitexposures resulting from work. Exposures resulting from if applicable, will be co

1.1 Purpose Added to Rev. 1 

Also disclaimers on infeasibility of dose reconstruction prior to 

1947 

This site profile documematrix for workers at th

Linde Ceramics Plant faProducts Company (LAYork. NIOSH has determinedand Human Services hafeasible to reconstruct i“Atomic weapons emplLinde Ceramics Plant frOctober 31, 1947, and w

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

number of work days agdays either solely under combination with work parameters (excluding arequirements) establisheemployees included in tSubsequent correspondethat the Tonawanda Labbuildings on the Linde Sdesignation (cohort). Rexposure (including mebeen determined to be fFor any claim referred temployee, (1) who was period, but because of lthis period, is not a memwho is a member of the not defined as a specifie(and so is not eligible foEEOICPA without a dowill continue to attempt reconstruction for the exon external and medical However, because of th2005) that it is infeasiblinternal dose during the through October 31, 194period are considered p

1.2 Scope Added to Rev. 1 This document covers b

information in this site p

operational and residuabelow. DOL has determcontamination period fois also applicable to the 2008). Although cleanuPlant continued into Julcovered period for this f

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1953 exposures are also EEOICPA, but this periexposure period. Becau

potential at the Ceramic1954 (January 1 through the immediately previouinformation on reconstrfrom January 1 through operational period sectiinstructions in this docudose at the Ceramics Pl(as defined by DOL as pertain to exposures sta7, 1954 is used as the dedecontamination period on the date of the final sis documented in a memYork Operations Office that asserts that the decothe contract were fulfill

Section 2.0 describes thhistory. Sections 3.0 aninternal and external ex1954, respectively. Secoccupational medical exinformation on exposurcontamination period afannotations, indicated bto identify the source, juthe associated informati7.0. Attachment A contains analyzing exposures of Attachment B lists codethe LAPC records. Attasources on uranium proAttachment D provides assessment for Novemb

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Attachment E provides consequences from uranon the site during the po

2.6 Additional Narrative on 

Decontamination During 

MED/AEC contract period doesn’t appear in Rev. 1 

This document assumes the end date of the Ceramics Plant cleanup period to be the date of 

turnover of the four Ceramics Plant production buildings to Linde for its use. This date is sometimes stated as 1953 (see, for example, ACE Buffalo 2004a, Response to Question 4). However, Harris (1954) indicates that the decontamination of Building 38 was not complete as of April 1954. For dose reconstruction, it is assumed that turnover did not occur until December 31, 1954. 

3.0 Change in estimation of Internal 

exposure to remove dates prior 

to 11-1-1947. Also change in last sentence. 

This section develops parameters for reconstruction of doses due to internal exposures 

from October 1, 1942, the assumed start date of MED work at Linde, until December 31, 1954, the assumed date of initial cleanup completion and building turnover from MED/AEC to Linde. .....Continued lower level exposures to uranium progeny and to radon are assumed, because some radioactive waste was disposed on site and because initial cleanup was not completed until the end of 1954; however, for the Ceramics Plant, the uranium exposures would have dominated during the 1947 to 1954 period. 

This section develops pof doses due to internal 

1947, until July 7, 1954NIOSH has concurred, reconstruct internal exp1947 (HHS 2005). ...Continued lower-leveprogeny and to radon wradioactive waste was dbecause initial cleanup end of 1954; however, furanium exposures woupost-1946 period. 

3.1 Detail from Rev. 00 removed 

from Rev. 01, including dose 

reconstruction standards. 

As of this writing, the pre-1947 operational period intakes are reserved. Therefore, the pre-1947 

information is provided only as a description of what the likely upper bound exposures might have been, and is not currently planned for use in Linde dose reconstruction. Document No. ORAUT-TKBS-0025 Revision 00, Effective Date: 05/31/2005 Page 28 of 94 for the pre-1947 period, the MAC would have been 

After the ore processingperiod. It was assumed 

0.1 MAC at the Tonawain 1946 until December of later air concentratioconcentration data from exposures would have bperiods. 

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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

assumed to be based on inclusion of uranium’s alpha emitting progeny. Although short-term exposures might have exceeded 300 MAC, it is very unlikely that long-term exposures would have. A review of the predicted urinalyses, kidney burdens, and lung burdens, indicate that it is highly unlikely that an individual would have sustained exposures like these for any length of time. Evidence of sustained exposure to the more soluble uranium compounds might have shown up in the medical urinalyses, as increases in proteins and glucose in the urine (note that other conditions can also account for these increases). The assumption of air concentrations at 300 MAC seems adequate to provide a quick estimate of exposure, and although the Type F uranium bioassay results are high, they do not seem inconceivable for some workers during this early period. However, it is also likely that Linde workers were exposed to a mixture of uranium absorption types. The analysis of radium exposures in Section 3.8 is partially based on the assumption of alpha activity air concentrations of 300 MAC during Linde’s ore processing period. After the ore processing, Linde began a standby period. It was initially and arbitrarily assumed that exposures decreased to 1 MAC during the standby period at the Ceramics Plant, and that exposures decreased to 0.1 MAC at the Tonawanda Laboratory after cleanup in 1946 until the end of cleanup at the Ceramics Plant in 1954. Based on reviews of later air concentrations at Linde, and reviews of air concentration data from other sites, it is believed that most workers’ exposures would have been much lower during these periods. The standby period at Linde Ceramics was assumed to end on September 14, 1947. Rehabilitation of the Step III process was assumed 

The standby period at Lto end on September 14

Step III process was ass15, 1947, and continue 

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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text ORAUT-TKB

to begin on September 15, 1947 and continue through October 31, 1947. Intakes from the standby and rehabilitation periods are eserved. Beginning November 1, 1947 at Linde Ceramics, workers were assumed to be exposed to 33 MAC and it was assumed this exposure continued through cleanup in 1954. Uranium progeny are not included in this later period, because only refined uranium was used and because the dose from intakes of contamination left from earlier work would have been insignificant compared to the dose to uranium during operations. To simplify calculations, it assumed that the workweek was 40 hours long during all years, although it is likely that the workweek for many was in excess of 40 hours especially during the earlier years. The assumed air concentrations are sufficiently large to account for any differences in actual hours 

exposed. Dose reconstructions should assume International Commission on Radiological Protection (ICRP) 

Publication 66 default parameters for particle deposition (ICRP 1994). 

3.2.1 Rewording of sentence Note that it is possible that the January 1948 

determination level of 0.1 mg/L is a typographical error, because this is the same as the determination level reported for (nonradioactive) fluoride urinalysis, and because there seems to be no change in the format of the numbers reported. 

The January 1948 deterassumed to be a typogra

the same as the determi(nonradioactive) fluoridthere seems to be no chreported numbers. 

3.2.1 Additional data in Rev. 01 NA Analysis of Coworker B

Dose Assignment (ORA

general process used foassigning doses to indivresults. Bioassay resultanalyzed in accordance 

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(Attachment D). The represented in Tables 3-1 urinalysis results should internal exposure to the available. Where indivithe coworker data inclusummarized in Tables 3estimate internal exposuclaimants. 

3.3 Disclaimer on Radium in Rev. 

01 

All radium compounds are lung absorption Type M. Radon breath analyses have been used to 

provide information on the amount of radium in the body and are available for some Linde workers. Assignment of radium exposures when radon breath analyses are not available or cannot be interpreted is addressed below in Section 3.4. 

HHS has determined, anit is not feasible to reco

prior to November 1, 19on radon exposure prior provided only as a basis and is not intended to bwhich reconstruction of determined to be infeas

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3.4 Data on Uranium Progeny in 

Rev. 00 deleted and replaced by 

disclaimer in Rev. 01. 

In the absence of data on exposures to uranium progeny, their intake rates are determined by 

assuming secular equilibrium. Table 5 lists equilibrium-based ratios for uranium progeny of particular interest in dose reconstruction. Absorption types for their likely chemical forms are also shown. The intake ratios provide reasonably realistic estimates of intakes of progeny due to dust from African ore. The uranium activity fractions overestimate relative intakes of most progeny when the dust is from preprocessed domestic ore. They may underestimate intakes of progeny when the dust is from filter cakes or waste products that contain uranium progeny, but very little uranium. The ratios in Table 5 are for use for the entire 1943–1946 production period for all workers, even though only about 70% of the ore processed was African ore (see Section 2.3.2) and many workers handled only refined uranium materials. This, along with the claimant-favorable assumptions made in the estimation of worker dust exposures, is judged to provide sufficient overestimation to balance any underestimation associated with the handling of waste products. Note that the uranium fractions are applied when the activity of uranium is known. The activity fractions for gross alpha are applied to data measured as alpha activity. 

Ceramics Plant 1943 tTonawanda Laborator

HHS has determined, anit is not feasible to reco

prior to November 1, 19

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3.4 More detail on production and 

cleanup in Rev. 01 

Ceramics Plant 1947–1949 Step III Production, 

and Subsequent Initial Cleanup

During this period, refined uranium materials were handled. None of the progeny listed in Table 5 

would have been present in significant quantities, compared to the uranium at the Ceramics Plant. 

Ceramics Plant 1947 t

and Subsequent Initia

During this period, refinhandled. None of the ubeen present in significauranium materials but, tprogeny potentially preresuspended during decdecommissioning (D&Dpostoperations period wbounding activity ratios presents bounding indooDocument No. ORAUT01 Effective Date: 11/0use for dose reconstructNovember 1, 1947, throin this table were the hithe indoor and storm se

3.5 Disclaimer on Radon added to 

Rev. 01 

HHS has determined, anit is not feasible to reco

prior to November 1, 19on radon exposure prior provided only as a basis and is not intended to bwhich reconstruction of determined to be infeas

3.5.1 Detail on analysis methodology 

not carried through to Rev. 01 

To simplify, this analysis assumes that workers, who were likely to spend the majority of their time 

N/A 

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in process areas, or in boxcars (where some of the highest radon levels were measured, about 200 times tolerance), or whose jobs were unknown, were exposed to 99.3 pCi/L of radon for 2,040 hours (12 work-months) per year prior to standby. Workers who did not work or have their offices in the process buildings are assumed to have been exposed to 22.4 pCi/L of radon prior to standby. Because a job in current times might not be in or near a process area, does not mean the same held true 60 years ago. Nurses, some stenographers, launderers and seamstresses, and some clerical workers had jobs or locations that put them in contact with the uranium and progeny (Homes 1944b). The initial period of African ore processing was followed by a second period of domestic ore processing. Thirteen measurements of radon concentration during the domestic ore processing were available. The GM of the measurements, assuming the <LOD values were equal to the LOD, was 9.1 pCi/L. To estimate exposure during this domestic ore processing period, both indoor and outdoor radon concentrations were assumed to be 10 pCi/L. 

3.5.1 Pre-1947 Radon rates deleted 

from table in Rev. 01 

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3.6 Pre-1947 Inhalation Intake 

Estimates of Particulates 

Removed from Rev. 01 

3.6 Different constants in alpha 

fraction of uranium resulting in difference in annual inhalation intake calculations 

For example, the annual uranium inhalation intake due to chronic exposure at 0.1 MAC is estimated 

by multiplying the air concentration of 7 dpm/m3

by the alpha fraction of uranium, 0.402; the ICRP 66 (ICRP 1994) recommended breathing rate of 1.2 m3/h; and the assumed 2000 work-hours per calendar year. This results in an annual chronic inhalation intake of 6.75E+03 dpm, which is equal to a daily intake rate of 18.5 dpm/day. For the assumed exposure at 33 MAC, no alpha activity is apportioned to progeny, so the daily uranium intake would be 1.52E+04 dpm/day. 

For example, the annuadue to chronic exposure 

by multiplying the air c

the alpha fraction of uraPublication 66 (ICRP 1rate of 1.2 m3/hr, and th

per calendar year. This inhalation intake of 8..2

to a daily intake rate of 

In the case where inhalafrom air concentrationsbe considered. NIOSH ingestion rate, in terms workday, can be estimaconcentration in dpm pe0.2, so the uranium ingeconcentration of 7 alpha 

0.563 dpm/wd. To adjucalendar day, 0.685 dpm250 wd/yr and divided b0.469 dpm/d. In accordf1-value used for inhalaused for ingestion dose 

3.7 Ingestion Intake Estimates at 

Tonawanada Laboratories have 

different computation. 

In the case where inhalation intakes are calculated from air concentrations, ingestion intakes are also 

to be considered. NIOSH (2004) indicates that the ingestion rate, in terms of dpm for an 8-hour workday, can be estimated by multiplying the air concentration in dpm per cubic meter by a factor of 0.2, so the uranium ingestion rate based on an air concentration of 7 alpha dpm/m3 would be 

0.563 dpm/workday. To adjust this to ingestion intake per calendar day, 0.563 dpm/workday is 

multiplied by 250 workdays per year and divided by 365 days per year, which equals 0.385 dpm/day. For the assumed exposure at 33 MAC, no alpha activity is apportioned to progeny, so the daily uranium intake would be 316 dpm/day. In accordance with NIOSH 2004, the f1-value used for inhalation dose calculations is to be used for ingestion dose calculations. 

3.8 Consideration of Bioassay Data 

removed from Rev. 01. 

Predicted uranium urinalysis results, provided in Table 10, were calculated for the last day of 

N/A 

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assumed chronic intake periods of 30 and 60 days, 0.5 years, 1 year and extended annually thereafter through the end of operations, assuming the estimated inhalation and ingestion intakes of natural uranium were based on a uranium air concentration of 33 MAC. A cursory review of the highest uranium urinalysis data from facilities that handled uranium in large quantities (Mallinckrodt, Harshaw, Hanford, ORNL, K-25, Paducah, and Portsmouth) indicates that results exceeding 10 mg/L are rare and that most results are less than 1 mg/L. At the Ceramics Plant, where the first Linde uranium bioassays were performed after standby, [Redact] of the available urinalysis results exceeded 1 mg/L. Subsequent results from these individuals were much lower. From November 1947 through January 1950, most Linde uranium urinalyses (about 95%) were less than 0.1 mg/L, but it is notable that exposures would likely have been lower during this period than in the earlier days of operations. The predicted results in Table 10 do not seem inconsistent with the limited Linde urinalyses. 

Table 10. Predicted uranium urinalyses from Ceramics Plant assumed inhalation and ingestion chronic uranium intake from November 1, 1947 to December 31, 1954 based on 33 MAC in air.

Bioassay Type M Type S 

date dpm/d mg/L dpm/d mg/L 

12/--/1948 566 0.3 18 0.01 12/--/1948 661 0.3 20 0.01 5/--/1949 853 0.4 28 0.01 11/--/1948 961 0.5 36 0.02 11/--/1949 1,013 0.5 48 0.02 11/--/1950 1,022 0.5 57 0.03 11/--/1951 1,026 0.5 64 0.03 11/--/1952 1,028 0.5 70 0.03 11/--/1953 1,031 0.5 74 0.03 11/--/1954 1,033 0.5 77 0.04 12/--/1954 1,033 0.5 78 0.04 *Mass results assume natural uranium exposure 

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Given a chronic exposure to uranium and its alpha emitting progeny at 300 MAC, the activity fraction of Ra-226 would be 0.196, which means that the chronic inhalation rate would be 2.7E+04 dpm/d. This gives a whole-body activity of 2.6E+05 dpm at one year, and about 4.0E+05 dpm at 4 years (calculated using IMBA Expert (OCAS), Version 3.2.20). The Ra-226 body activity was estimated using the largest breath radon result found for Linde, 2.2 pCi/L, by multiplying the radon result by a conversion factor of 2.52E+05 pCi/(pCi/L) (ORAUT 2005). This gives a body activity of 5.5 E+05 pCi, which is equal to 1.2 E+06 dpm, and is within a factor of 3 of the estimated intake from a 4-year chronic exposure to 300 MAC. Because other Linde radon breath analyses are lower, and because a chronic exposure scenario may not best represent a worker’s exposure pattern, the assumption of 300 MAC chronic exposure was believed to be adequate for reconstructing doses in the pre-1947 research and production period, but at this time this period is reserved. 

3.8 Occupational Internal Dose 

Reconstruction Assumptions and Summary Disclaimer 

added in Rev. 01. 

HHS has determined, anit is not feasible to reco

prior to November 1, 19

3.8 Summary table for 00 starts at 

1942, Rev. 01 starts at 1947. 

4.0 ESTIMATION OF EXTERNAL 

EXPOSURE, 1942–1954 

Dislaimer for pre-1947 data in Rev. 01 

Because of the SEC det

it is infeasible to adequaduring the period Octob31, 1947, dose estimateconsidered partial dose 

4.0 Additional statement on 

measurement assumptions for 

For the purpose of calcuexposure geometries are 

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Beta Radiation in Rev. 01 anteriorposterior (AP). 

4.1.1 Differing titles, subparagraph 

(typo?) 

4.1.1 Post-production Radiation in Building 30

Little information was available on radiation levels in Ceramics Plant buildings during periods of 

nonproduction. Estimates for these periods were based on measurements made after the end of production in Building 30, the main processing building. 

4.1.1 Preproduction, 1

4.1.2.3 Cleanup section placed at end of 

section in Rev. 01 

4.1.2.2 New information in Rev. 01 for 

“Gamma” 

Film badges were proviof the MED (presumabl

Rochester). 

4.1.3 Standby Section only in Rev. 01 4.1.3 Standby, 1946 to 

Little information is avaactivities during the stan

the onsite staff consisteof management and janwhom worked primarily and guards. For dose reduring standby was clasgeneral worker, and wohave been spent in an obuildings, and outdoorsstandby period, each woassumed to have been afactors in Table 4-13. 

Measurements were mainterest. The results wefour of the locations and 

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for the other two locatiodumping grill) (Howlandumping grill was one ospots in the plant, the exconsidered typical of thbeen encountered upon standby. Instead, the infor a production buildinTable 4-1 before vacuum Outdoor gamma and beto the indoor rates based in the discussion of the gamma and beta radiatiwere assumed to be zerTable 4-13 summarizes radiation rates based on Because there would hahandling of radioactive workers in this period, band forearms was taken to the remainder of the 

4.4 External Dose Reconstruction 

Summary, October 1, 1942, to July 7, 1954, disclaimer in Rev. 

01 about dosages prior to Oct. 31, 1947 

Because of the SEC det

it is infeasible to adequaduring the period Octob31, 1947, dose estimateconsidered partial dose 

5.0 Occupational Medical 

Exposure disclaimer on dose 

estimates prior to Oct. 31, 1947 

Because of the SEC det

it is infeasible to adequaduring the period Octob31, 1947, dose estimateconsidered partial dose 

5.1.1 Bases of Assumptions. Slightly 

different wording on one sentence under “Applicability” 

Therefore, the general assumption for dose reconstruction is that all employees were subject to 

the same chest x-ray imaging requirements. 

Therefore, the general areconstruction is that al

the same chest x-ray req

5.1.1 Bases of Assumptions “Period.” Production work at the Ceramics Plant is assumed Production work at the 

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Different dates between Rev. 00 and Rev. 01 

to have ended on June 30, 1949; cleanup work is assumed to have ended on December 31, 1954. 

have ended on June 30, assumed to have ended 

5.1.3 X-ray Dose Reconstruction 

Guidelines. Markedly different 

wording in introductory paragraphs

Dose reconstruction should be based on information specific the subject to the extent that it 

is available and adequate. The guidelines in this section are for use when the records for an individual worker are not available or are incomplete. The guidelines are for use only to the extent that they are not inconsistent with the worker's records. For example, if the medical records are complete and indicate a lower or higher examination frequency than stated in the assumptions provided above, the data in the medical records should be used. X-ray doses shall be determined in accordance with the latest revision of the project technical information bulletin, Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedures (current version is ORAU Team 2003) when applicable. 

Dose reconstruction shospecific to the subject to 

available, adequate, and screening examinations (i.e., dose from x-ray exresult of occupational inin dose reconstructions)section are for use when worker are not available guidelines are for use onnot inconsistent with thexample, if the medical indicate a lower or highthan stated in the assumdata in the medical recodoses shall be determinlatest revision of the probulletin, Dose ReconstrRelated Diagnostic X-Rversion is ORAUT 2005

6.0 Estimation of Exposures from

Residual Contamination after 

1954 (1953 in Rev. 01) 

Different dates. 

This section develops parameters for reconstruction of doses due to internal and external 

exposures of Ceramics Plant and Tonawanda Laboratory workers after December 31, 1954, the assumed completion date of cleanup at the Ceramics Plant. Both facilities were on Linde’s Tonawanda, New York, site. Initial cleanup of the Tonawanda Laboratory is assumed to have been completed on December 31, 1946. Tonawanda Laboratory workers’ radiation exposures from January 1, 1947 to December 31, 1954 are discussed in Sections 3.0 and 4.0. The assumed Ceramics Plant initial cleanup date is December 31, 1954. Beginning on January 1, 1955, It is assumed that 

This section develops pof doses due to internal 

Ceramics Plant starting Laboratory starting Januof the Tonawanda Labocomplete on December Tonawanda Laboratory from January 1, 1947, tdiscussed in Sections 3.It was assumed that beg

Tonawanda Laboratory exposed to residual con

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Item Description Comment ORAUT-TKBS-0025 Rev. 0 Text 

NOTICE

wever, th

ORAUT-TKB

Linde employees could have been exposed to residual contamination for 2000 hours per year. 

6.1.2 External Beta and Gamma 

Exposure different dates 

The total number of readings ≥25 μR/h reported by 

BNI was 16. The net readings (after subtraction of 8 μR/h to correct for background) had a GM of 

94.0 μR/h and a GSD of 3.95. This was taken as an estimate of worker exposure rate when outdoors. This estimate was assumed to apply from January 1, 1955 to the present (2005). 

The total number of rep

16. The net readings (acorrect for background) GSD of 3.95. This was worker exposure rate wwas assumed to apply sTonawanda Laboratory Ceramics Plant. 

Attachment C Not in Rev. 0 Attachment C 

Data Sources on UranConcentrations in Lin

Attachment D Not in Rev. 0 Attachment D 

Linde Uranium CowoNovember 1947 to Jan

Attachment E Not in Rev. 0 Attachment E 

Focused Assessment oUranium Ore Bags on 

Operations Period 
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APPENDIX B: MEMORANDUM FROM SEC PETITIONER TO SC&A 

Memorandum 

To: John Mauro and Steve Ostrow 

From: [Name Redacted], Linde Ceramics SEC Petitioner SEC00107 

Re: Feed Material Memoranda for Linde Ceramics Facility 1944 

Date: June 4, 2009 

The 2006 and 2008 Linde Site Profiles indicate that L-30 Belgian Congo pitchblende ore processed at 

Linde is estimated to have contained between 8 and 12% uranium ore (U3O8).3

 The following four 

attached memoranda, dated February 17, 1944, February 22, 1944, February 26, 1944, and March 6, 

1944, all indicate that 65% Belgian Congo ore was processed at Linde during the operational time period. 

These memoranda should be evaluated along with the following references listed in the Linde Site 

Profiles. 

1. Pilot Plant Operations on African Ore – Wiesendanger, dated May 26, 1944: Laboratory research 

on the extraction of uranium from African pitchblendes had indicated satisfactory methods using 

high grade African ore (25% and 75% U3O8) 

2. E.O. Brimm: Processing of African Ores, dated May 7, 1943: 1300 pound sample of Katanga 

ore was tested in Building 14 with a U3O8 assay content of 68.8% and also a lower grade Belgian 

Congo pitchblende with the percent of U3O8 at 24.8% 

Furthermore, NIOSH has based its radon exposure model on 13 radon measurements from domestic ore 

processing in 1944. This data ignores the African ore processing. Moreover, Dr. Joseph Guido from 

ORAU wrongly stated at the January 8, 2008 Linde Working Group meeting that African ore processing 

ceased after 19444

, when African ore was processed in 1946.5 Does NIOSH’s reliance on data that can 

only account for domestic ore processing significantly reduce the ability to account for radon progeny? 

 3 L-30 African pitchblende ore; estimated to contain 8%–12% U3O8: (Aerospace 1981, Table B-1) 

4

 Linde Working Group meeting January 8, 2008, at pages 31–32 

5

 Linde processed domestic ore at 110% capacity for 52 tons of black oxide per month until December 

1943; Belgian Congo ore [10% and 6%] from December 1943 through November 1944 at 162% capacity for 52 tons 

of black oxide per month; Spring 1944 225% design capacity; after November 1944 changes in production design 

resulted in an increase of uranium extraction from ore from 95 to 98%; from December 1944 through January 1946 

capacity was at 150%; February 1946 3% African ore [10,250 tons] to July 1946 at 110% capacity yielding 2428 

tons of black oxide. Manhattan District History, Book VII Feed Materials, Special Procurement, and Geographical 

Exploration -Volume 1 – Feed Materials and Special Procurement, Section 7.6 through 7.8 
Effective Date: 

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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.