Draft White Paper 

REVIEW OF NIOSH WHITE PAPER 

ON PORTABLE RADIOGRAPHY SOURCES AT GSI 

Contract Number 200-2009-28555 

Prepared by 

Robert Anigstein 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

September 2010 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted. 
 

 

 

 

 

 

 

 

 

 

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S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Document Description: 

White Paper: Review of NIOSH 

White Paper - GSI 

Effective Date: 

Draft – September 27, 2010 

Revision No. 0 (Draft) 

REVIEW OF NIOSH WHITE PAPER ON 

PORTABLE RADIOGRAPHY SOURCES AT GSI 

Page 2 of 14 

Task Manager: ___________________ Date: 

Robert Anigstein, PhD 

Supersedes: 

N/A 

Project Manager: _________________ Date: 

John Mauro, PhD, CHP 

Reviewer: 

John Mauro, PhD 

Record of Revisions 

Revision 

Number 

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Date Description of Revision 

0 (Draft) 09/27/2010 Initial issue 

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Review of NIOSH White Paper on Portable Radiography Sources at GSI 

In a NIOSH White Paper, Allen (2010) reviewed the portable radiography sources used at the 

General Steel Industries, Inc. (GSI) steel foundry in Granite City, Illinois, during the period that 

GSI was under contract to the Atomic Energy Commission (AEC) (1953–1966). Much of the 

information is from AEC licensing documents and correspondence which are posted on the 

Nuclear Regulatory Commission's Web site, and which can be accessed through ADAMS, the 

NRC document retrieval system. On May 20, 2010, during the course of the 69th meeting of the 

Advisory Board on Radiation and Worker Health, the Board, together with the Work Group on 

TBD-6000, tasked SC&A with reviewing the NIOSH White Paper. The Board recognized that 

such a review would require a review of the AEC documents. We have accordingly reviewed 

the White Paper and have a number of comments, observations, and findings. 

1. SEQUENTIAL REVIEW 

We will first present a sequential review of the White Paper, discussing each issue in the same 

sequence as presented by Allen (2010). The author first presented a discussion of the 

background of the White Paper and a timeline of the use of portable sources at GSI. These were 

followed by a discussion of the strength of the sources mentioned in the AEC documents—the 

two 60Co sources with initial activities of 260 and 280 mCi, and the two 500-mg (~500-mCi) 

sources of 226Ra—and the calculated exposure rates at a distance of 1 foot. We have verified this 

information and found it to be correct. Our comments on the rest of the White Paper are 

presented in the following subsections, which have the same headings as the corresponding 

sections in the White Paper. 

1.1 Additional Sources 

1.1.1 250 kVp X-ray Machine 

One radiation source discussed in the White Paper is the 250 kVp x-ray machine. Since it was 

not licensed by AEC, it is not cited in the AEC documents. Allen (2010) stated: 

Another difference is that the isotopic sources emit radiation in all directions, 

while the x-ray machine would emit a directional beam. While x-raying 

equipment, the beam would always be pointed at the material so the beam is 

always effectively shielded by the material being examined. 

The above statement implies that the x-ray machine would result in little or no exposure to the 

workers. The author implicitly assumed that the beam was sufficiently collimated so that the 

entire beam was intercepted by the metal object being radiographed. Although modern medical 

x-ray machines are required to be collimated so that the cross-section of the beam does not 

exceed the area of the film, in order to reduce the radiation exposure of the patient, this was not 

necessarily the case for an industrial radiography unit in the 1950s and 1960s. X-ray machines 

from a previous era (early decades of the 20th century) were not even shielded, exposing the 

operator who stayed near the machine to a significant dose of radiation. 

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Two 250-kV x-ray machines are listed in an auction notice involving the liquidation of the GSI 

Granite City facility (Rabin 1973). One is described as a “GE x-ray, model OX-250, industrial 

size,” while the other was an “Andrex x-ray unit, model A1652 . . . 250 kV 8 mA directional 

unit.” We can infer the tube current of the G.E. machine from Beatty and Clark (1955), who 

used a G.E. model OX-250 industrial x-ray unit operating at 250 kV and 15 mA to irradiate 

laboratory mice. Although they cited the dose rate administered to the mice, the source-toreceptor distance was not listed, so this report cannot be used to directly calculate the output of 

the unit. However, the dose rate can be calculated from the published dose rate of another x-ray 

tube, if we can derive a relationship between the dose rate, the tube potential, and the current. 

According to Cosslett and Nixon (1960), the power of the x-rays generated by bremsstrahlung 

from a thick target is given by 

P = power in x-ray beam
 

I = tube current 

k = constant (depends on units) 

V = tube potential 

Z = atomic number of target 

This equation can be used to derive the dose rate of G.E. model OX-250 from the dose rate and 

other operating parameters of the ISOVOLT 225 M2/0.4-3.0 (GE 2004), if we assume that both 

tubes have targets made of the same metal (i.e., tungsten) and that the dose rate is proportional to 

the power, by the following relationship: 

RX = dose rate at 1 m from G.E. model OX-250 

= 18.42 Sv/h 

IX = tube current in G.E. model OX-250 

= 15 mA 

VX = tube potential in G.E. model OX-250 

= 250 kV 

RI = dose rate at 1 m from ISOVOLT 225 M2/0.4-3.0 at maximum tube potential and 

current

 = 12.93 Sv/h 

II = maximum tube current in ISOVOLT 225 M2/0.4-3.0 

= 13 mA 

VI = maximum tube potential of ISOVOLT 225 M2/0.4-3.0 

= 225 kV 

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Because the ISOVOLT tube output is rated for an inherent filtration of 1 mm Be, the output of 

the OX-250 unit could be somewhat less than listed above due to greater filtration. Nevertheless, 

we see that the output, which is estimated to be approximately 30 rem/min, is significant. It falls 

between the exposure rates from the 25-MeV betatron (160 R/min at 3 ft from the target) and an 

80-Ci 60Co source (1.76 R/min at 1 m, based on a value of Γ = 1.32 R h-1 Ci-1 m

-2). 

Although the operator of the x-ray machine normally stayed in the betatron control room during 

exposures, the machine was operated in an open area: the betatron shooting room. There were 

no safety interlocks that could prevent someone from entering the shooting room while the 

machine was on. There were at least two reports of the machine being activated while workers 

were in the shooting room performing other duties. One or more workers were reportedly 

exposed when the machine was turned on without the area being cleared (SimmonsCooper 

2006). 

We agree with Allen's statements that the x-ray machine produced radiation that was less 

penetrating than that from the 60Co or 226Ra sources, and that it was used less frequently. 

However, we do not agree that the exposures to the x-ray machine are necessarily bounded by 

the exposures to the small (260–280 mCi) 60Co sources. 

1.1.2 Iridium-192 and 60Co Sources Used by St. Louis Testing 

According to Paul Sinn, former administrator of St. Louis Testing, his company utilized a 50-Ci 

192Ir source as well as a 10-Ci 60Co source at GSI (Dr. Robert Anigstein . . . 2007). The 60Co 

source may have been stronger than any 60Co source used at GSI during the period of AEC 

operations. Even if GSI did posses a high-activity 60Co source during this period, it would have 

most likely been used inside the betatron shooting room, as was the 80-Ci source procured under 

an AEC license in 1968.1 However, the St. Louis Testing sources were used outdoors on the GSI 

property. Mr. Sinn stated that his men set up an exclusion area boundary where the exposure 

rate was 2 mR/h, and that “two radiographers working 12-hour shifts kept the secured area under 

constant surveillance.” Mr. Sinn later explained that he meant that there was one radiographer 

on each shift. He added that the sources were always inside a 4-in-thick casting that was being 

radiographed.2

 With only one radiographer on duty, there would have thus been times when the 

area was unattended while he took necessary breaks. Some GSI workers could have intruded 

into the exclusion area and received exposures from these sources that were greater than those 

from the 260 and 280 mCi 60Co sources possessed by GSI. We therefore do not agree that the 

exposures of GSI workers to radioactive sources used by St. Louis Testing would be bounded by 

their exposures to the sources used by GSI. 

1

 Some former workers recall a high-activity 60Co source being at GSI prior to 1968. 

2

 Paul Sinn, September 27, 2010, private communication with Robert Anigstein, SC&A, Inc. 

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1.2 Radium Sources (1953 to 1962) 

Allen (2010) discussed the use of two 226Ra sources at GSI prior to the acquisition of the 60Co 

sources on May 21, 1962.3

 The exposure scenarios that he developed were based on the account 

of , a former GSI radiographer, who recounted his recent conversation with “the 

” who told him it was common practice to perform 60Co radiography 

in open areas of the plant, and to rope off a perimeter at 11⁄2 times the distance to a safe level of 

radiation (Neal R. Gross 2009). Allen assumed that the “safe level” was 2 mR/h, which 

corresponds to the dose limit of 2 mrem/h for an unrestricted area that is specified in 

10 CFR 20.1301. Applying the inverse-square law, he derived an exposure rate of 0.89 mR/h at 

the perimeter. He further assumed that the radiographer remained at the perimeter for the 

duration of the radiographic exposure, and that the total duration of such exposures was equal to 

30% of a work shift. This 30% “utilization factor” is based on the initial AEC license 

application, which states that “[a] maximum of 30% of each shift is used for actual exposure” 

(NRC 2009c, p. 12). Based on these assumptions, Allen estimated the annual exposure of 

radiographers to be 868 mR. We agree that such an exposure would have been experienced by a 

worker whose only duty was to monitor the exclusion area while radiography was in progress, 

and who remained at the perimeter of this area. It does not account for the exposure of an actual 

radiographer who would have removed the source from its shielded container, positioned it for 

the radiographic exposure, placed the film in position once the source was in place, and reversed 

the procedure at the end of the exposure.4 

By assuming that some nonradiographers also remained at the perimeter, except when they 

occasionally walked inside this boundary, Allen estimates their annual exposure to be 1,353 mR. 

His assumption that radiographers always remained at the perimeter, while nonradiographers 

sometimes approached nearer to the source, leads to the paradoxical conclusion that 

nonradiographers had higher exposures than radiographers. 

We do not believe that it is reasonable to extrapolate Mr. 's account to the practices used 

for 226Ra radiography prior to 1962. First, Mr. had stated that he began work at GSI at 

about the end of 1963 or the beginning of 1964. His first film badge report is for the week of 

 1964—we assume that that is when he began working as a radiographer. This would be 

consistent with statements from Mr. and other workers that it was the practice at GSI to 

first assign new employees in the NDT department to working with the Magnaflux (a magnetic 

testing device), later progressing to radiography. Mr. later identified the supervisor as 

.

5

 Mr. s first film badge report is for the week of 1964. However, 

in its application to the AEC for a renewal of its byproduct materials license (NRC 2009b, p. 8), 

GSI identified Mr. as a who had several months of experience with the betatron 

and radium, indicating that he probably started work in late 1961 or early 1962. According to 

3

 Allen cites this date on the basis of information in the AEC compliance inspection report (NRC 2009a). 

However, in a letter to AEC, Gordon McMillin, vice-president and general manager of the GSI Commonwealth 

Division (i.e., the Granite City foundry) reported the acquisition date as April 24, 1962, which is most likely correct. 

4

 It is reasonable to assume that the film was positioned and removed while the source was in position. 

Otherwise, the film would be fogged by the source being moved to and from the casting. 

5

 September 20, 2010, private communication with Robert Anigstein, SC&A, Inc. 

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Mr. Mr. . Thus, the description of

60Co radiography in open areas of the plant is based on a second-hand account that cannot be 

independently corroborated. Furthermore, there is no basis for extrapolating the practice 

described by Mr. to 226Ra radiography performed years earlier. 

The scenario developed and assessed by Allen (2010) is also not supported by available 

information on the use of 226Ra sources at GSI. In the following two subsections, which do not 

correspond to section headings in the White Paper, we first discuss the limited information on 

radiography using 226Ra sources at GSI and then analyze and discuss possible exposures of 

workers from such a procedure. 

1.2.1 Available Information on Use of 226Ra Sources at GSI 

The only descriptions of practices in the use of radium as a radiographic source at GSI are in the 

initial application for an AEC Byproduct Materials License, submitted on March 7, 1962 (NRC 

2009c). In the cover letter, L. A. Kleber, vice-president, manufacturing, of GSI, states: The 

State of Illinois has requested that we take immediate steps to discontinue the use of our radium 

sources using the fishpole technique. Further in the application is the statement: 

To date, we have used quite satisfactorily two 500 mg radium sources. These 

have been used with a fish pole technique with little radiation exposure to our 

personnel. (NRC 2009c, p. 8) 

There is little information on radiation safety practices related to the use of radium sources prior 

to the date of the AEC application. Prior experience of GSI workers in performing radiography 

and their radiation exposures are summarized in the following statement, which appears in the 

application for Amendment 1 to the AEC license: 

Up to this time February 1, 1963 no formal written tests have been given. Most of 

the present radiographers have worked with radium, cobalt, and a 24 M.E.V. 

Betatron for 2 - 15 years. They are competent in manipulation of all equipment 

and cognizant of health physics. During this period the exposure limits published 

by the A.E.C. at the applicable time were followed. They were never exceeded 

and averaged under 25%. (NRC 2009b, p. 26) 

The only other document pertaining to the history of radiation exposures at GSI prior to 1963 is 

an Occupational External Radiation History, AEC Form 4, for a former GSI 

employee ( 2009). That form, dated March 19, 1962, prepared by the Nuclear 

Consultants Corporation, presents Mr. total external radiation exposure at GSI from 

February 2, 1953, until the date of the report, based on “Record.” There is no indication of how 

the doses listed on the form were determined. 

It appears that the Nuclear Consultants Corporation and its president, Wilfred R. Konneker, PhD, 

CHP, were only retained by GSI at the time of the initial application for an AEC license. We 

base this conclusion on the following excerpt from the cover letter to the initial AEC license 

application, dated March 7, 1962: We have retained Dr. Konneker and his group at Nuclear 

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Consultants Corporation to assist us in establishing our health physics program (NRC 2009c, 

p. 3). This statement also calls into question whether there was any health physics program prior 

to the use of 60Co under the AEC license. 

The initial AEC license application includes a detailed description of a concrete block building 

constructed specifically for radiography using sealed sources (NRC 2009b, p. 8). There is no 

indication if there was any such structure during the period that 226Ra sources were used. There 

is likewise no record or any mention of any measurements of radiation levels inside or outside 

this room from exposed 226Ra sources. The following operating procedure, described in the 

application, could apply only to the 60Co sources: The operator of the radiographic units will be 

some 25 to 35 feet away from the exposed sources and will operate behind 4 inches of armor 

plate steel. Such a procedure could not be carried out using the fishpole technique. It cannot 

therefore be assumed that the 226Ra sources were used inside a shielded structure; furthermore, 

these sources were apparently not stored in a secure location, as witnessed by the fact that one 

source was taken home by a worker 

 An illustration of such a source is shown in Figure 1. 

Since Ra, x-ray machines, and betatrons were not subject to 

AEC regulations, the AEC was not involved in the use of radiation 

at GSI prior to 1962. Even if GSI had voluntarily adhered to AEC 

radiation protection regulations, despite the fact that they did not 

apply to 226Ra sources, 10 CFR 20, “Standards for Protection 

Against Radiation,” did not go into effect until February 1957, so 

there were no AEC regulations to adhere to prior to that time. 

The State of Illinois did exercise some oversight over the use of 

226Ra sources, as evidenced by the fact that the application for the 

use of 60Co sources was triggered by the State's request that GSI 

discontinue the use of radium with the fishpole technique. We 

made several inquiries to the State of Illinois, including a request 

under the Illinois Freedom of Information Act, which elicited the 

responses that the state had no records pertaining to radiation 

sources at General Steel Industries, Inc., under that name nor under its earlier name of General 

Steel Castings Company. 

We also requested and obtained copies of Illinois radiation safety regulations of that era. The 

earliest rules that we received were promulgated on April 18, 1961, under “An Act relating to 

radiation protection and prescribing functions, powers and duties relating to the uses of sources 

of ionizing radiation which are or may be detrimental to health,” approved July 17, 1959 (Illinois 

1961). Although the Illinois Department of Public Health was “assigned the task of registering 

radiation installations, identifying radiation hazards and appraising the risk of radiation from xrays” in 1957 (A History Public Health in Illinois - 1950s), there is no record of the department's 

having enforcement powers until the passage of the 1959 law, or of its issuing any rules or 

regulations until April 18, 1961. 

Article XI: “Industrial Radiographic Installations,” of the 1961 Illinois rules and regulations 

restricts and regulates the use of radiation sources in open areas (Illinois 1961). It is likely that a 

Figure 1. Radium 

Industrial Radiography 

Source (ca. 1940s) 

(ORAU 1999) 

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period of months would have elapsed before these rules could be implemented throughout the 

state. Thus, the request by the state that GSI discontinue the use of 226Ra using the fishpole 

technique, cited in GSI's March 7, 1962, AEC Byproduct Materials License application, was 

most likely part of the initial enforcement program and not a change of policy. There was most 

likely no state or federally supervised radiation safety program at GSI prior to issuance of the 

AEC license in 1962, nor any effective in-house program, despite claims to the contrary in the 

excerpt from the license application cited on page 7 of this review. Not only was the radium 

source that a worker took home not stored in a secure location, it was most likely not marked or 

labeled as a radioactive source. 

1.2.2 Potential Exposures From 226Ra Radiography Using the Fishpole Technique 

Figure 2. Source Being 

Removed from its Shield 

("pig") (ORAU 1999) 

Figure 3. Fishpole 

Radiography 

(ORAU 1999) 

Figure 4. The “Fishpole” 

Technique (Hellier 2001)
 

Figures 2–4 illustrate the early use of the fishpole technique for 

industrial radiography using 226Ra. In none of the illustrations does 

the worker stand behind a shield. The distance from the worker's 

torso to the source appears to range from 1–2 m. Although we 

cannot construct a plausible bounding exposure scenario for the 

exposure of a worker performing 226Ra radiography with the fishpole technique, we can perform 

a sample calculation to indicate the potential exposure from such a source. 

At a distance of 1 m, the exposure rate from a 500-mCi 226Ra source is 412.5 mR/h, assuming a 

point source, no attenuation or scatter, and a value of Γ = 0.825 R h-1 Ci-1 m

-2 (0.5 Ci × 0.825 = 

0.4125 R/h). According to a “Compliance Inspection Report” dated November 2l, 1962, Robert 

Ripley, GSI Radiation Protection Officer, informed the inspector that about 10 radiographic 

exposures using 60Co sources were made per shift (NRC 2009a, p. 3). Let us assume the same 

frequency for the earlier 226Ra radiography. Absent any detailed knowledge of the technique, we 

will assume that the radiographer is exposed to the unshielded source for a total of 1 minute 

during each exposure—this includes the time it took to remove the source from its shielded 

container, carry it to the steel casting, and the time to replace it in the shield. Thus, the exposure 

duration is 10 min per shift, or about 68 h/y. The annual exposure would be 28 R/y. Our sample 

calculation, which addresses only a part of the procedure, shows that the exposure could be more 

than 30 times higher than the 868 mR/y estimated by Allen (2010). None of the former GSI 

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workers who provided information to NIOSH or to SC&A gave any accounts of the practice of 

226Ra radiography at GSI—few of them were even employed at GSI during that period. We thus 

have no detailed knowledge of either the duration of the worker's exposure to the source or the 

actual distance of the source to the worker's body. The purpose of the sample calculation is to 

demonstrate that the exposure could be far higher than estimated by Allen. 

In the absence of any documentation that the fishpole radiography was performed in a restricted 

area and that nonradiographers were excluded from the vicinity, we believe that such workers 

could also have received substantial exposures during the time the source was used outside its 

shield. 

We further observe that industrial radiography using the fishpole technique is currently 

prohibited (unless specifically authorized) by the radiation safety regulations of the States of 

Delaware, Georgia, Iowa, Massachusetts, New Mexico, North Dakota, and West Virginia, and 

totally prohibited in Minnesota. This observation, coupled with the action taken by Illinois, is a 

strong indication that the technique is not considered safe, and that the resulting radiation 

exposures cannot be bounded by those from the use of small 60Co sealed sources. The latter 

sources were in a shielded housing and exposures were performed by an operator using a 

remotely controlled mechanical device from behind a shield wall. 

1.3 Cobalt Sources (1962 to 1966) 

Allen (2010) describes a radiation protection survey of the concrete block building housing the 

60Co sources that was performed by Wilfred R. Konneker, president of the Nuclear Consultants 

Corporation. While Allen correctly cites the measurements reported from the survey, we 

disagree with some of his conclusions regarding the exposures to GSI workers from these 

sources. 

The highest reading outside the secured area (i.e., the concrete block building housing the 

sources) was 1.2 mR/h at a height of 1 m above the floor. According to the survey report, the 

level could be reduced to 1⁄4 if the partial occupancy factor were applied to this unrestricted area 

(NRC 2009e, p. 6). The exposure would be further reduced by the 30% utilization factor cited 

on page 6 of this review. Thus, the maximum likely exposure of an individual working 65 hours 

per week, 50 weeks per year, would be 292 mR/y (1.2 mR/h × 0.25 × 0.3 × 65 h/wk × 50 wk/y = 

292 mR/y). This exposure is in addition to exposures to other sources of radiation, including the 

betatron, during the remaining 6 hours of each 8-hour shift. This exposure should be assigned to 

nonradiographers in a claimant-favorable dose reconstruction. 

The maximum level at 1 m above the floor inside the radiographic facility was 1.15 mR/h. The 

maximum likely exposure of a radiographer would be 1.12 R/y, using the same work hours and 

the same 30% utilization factor. 

Allen (2010) lists an annual exposure to a nonradiographer as 1,170 mR, based on the maximum 

exposure rate and a 30% utilization factor, and annual “doses” of 224 mR to a nonradiographer 

and 254 mR for a radiographer based on average exposure rates in the unrestricted and restricted 

areas, as cited in the survey report. Our estimate of the nonradiographer's annual exposure is 

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30% higher than the “average” value presented by Allen, while our estimate of the radiographer's 

exposure is more than 4 times higher than Allen's. The survey reports do not indicate how the 

average levels were determined. Since there is no assurance that the workers would have 

occupied the “average” locations, we believe that the exposures based on the maximum levels at 

1 m above the floor in each location and the occupancy factor for locations outside the facility, 

estimated by the surveyor, should be used for a claimant-favorable assessment. 

Allen also calculates annual doses to a crane operator and to a worker on the roof, assuming that 

the sources were shielded by a casting. Since the size and shape of the casting and its position 

with respect to the sources may not be representative of the castings radiographed over the 

course of a year, a claimant-favorable assessment should utilize the measurements made with no 

casting in place, which are 50–100% higher. That said, the occupancy factors for the crane and 

for the roof directly above the source were very small. According to the initial license 

application: 

The large overhead crane is never operated over the area where the 

radiographers' room is located except to place the castings to be radiographed 

into the room. . . . Since the occupancy factor in this position is virtually zero we 

consider this to be an unrestricted area. (NRC 2009c, p. 12) 

In an internal memorandum, Robert W. Ripley, the GSI Radiation Protection Officer, states that 

the maximum occupancy of the area of the roof above the radiographic facility is estimated to be 

24 man-hours per year (NRC 2009b, p. 10). Therefore, the bounding doses cited by Allen 

(2010), based on 100% occupancy, are implausible. These two exposure scenarios make no 

significant contribution to the radiation exposures of GSI workers. 

1.4 Summary 

In the summary section, Allen (2010) lists bounding estimates of annual doses from sources 

other than the betatron apparatus, induced activity from betatron radiography, and uranium 

metal. The annual doses to radiographers during 1953–1962 are listed as 868 mrem, and to 

“others working near radiography area” as 1,353 mrem. These values are based on the exposures 

discussed in Section 1.2.2 of this review, where we presented our findings which disagree with 

these conclusions. 

For 1962–1966, Allen (2010) listed the dose to radiographers as 1,170 mrem/y. This dose is 

based on the exposure rate on the exterior wall of the room, a location occupied by workers other 

than radiographers. Our calculation, presented on page 10 of this review, yields an exposure of 

1.12 R/y, which fortuitously results in approximately the same dose as cited by Allen in his 

“Summary” section. The dose to “others working near radiography area” is listed as 1,347 

mrem/y, based on an assumed scenario in which 60Co radiography was performed outside the 

radiographic facility and workers walked through the exclusion area.6

 These are much higher 

than the dose corresponding to an exposure of 292 mR/y which we calculated, based on the 

workers' occupancy of a location outside the radiography facility, as shown on page 10 of this 

review. Allen assigned doses to the overhead crane operator and to individuals working on the 

6 See discussion on page 6 of this review. 

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roof based on scenarios which disregard the very low occupancy factors for these locations. We 

agree that the doses assigned to these workers are bounding, but we question whether they are 

realistic. 

2. FINDINGS AND DISCUSSION 

Our most significant finding is that Allen (2010) does not present a limiting scenario for 

estimating bounding doses to radiographers and other workers during the “radium era” (1953– 

1962). 

We believe that NIOSH should address possible exposures from the 250 kVp x-ray machines. 

Although, under proper operating conditions, the exposures of radiographers would be bounded 

by those from the betatron, the incidents of the machine being activated while workers were in 

the shooting room should be further investigated and evaluated. 

NIOSH should also address possible exposures of GSI workers to high-activity sources used by 

St. Louis testing in open areas of the GSI property due to possible incursions of workers into the 

exclusion area. 

We believe that, under proper operating conditions, the exposures of radiographers to the 60Co 

sources listed on the AEC license during the covered period (1962–1966) would also be bounded 

by those from the betatron. However, NIOSH should evaluate the reported incident(s) when a 

source failed to retract into its shield, resulting in unexpected exposures to personnel in the 

vicinity. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
 

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References 

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Hellier, C. 2001. Handbook of Nondestructive Evaluation. New York: McGraw-Hill. 

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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. 
 

 

 

 

 

Effective Date: 

September 27, 2010 

Revision No. 

0 – Draft 

Document Description: White Paper: 

Review of NIOSH White Paper - GSI 

Page No. 

Page 14 of 14 

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SimmonsCooper, LLC. 2006. "GSI Affidavit Testimony," August 11, 2006. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi081106.pdf 

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.