Draft 

ISSUE RESOLUTION MATRIX FOR SC&A FINDINGS ON 

CARBORUNDUM SPECIAL EXPOSURE COHORT (SEC) 

PETITION-00223 AND THE NIOSH SEC PETITION 

EVALUATION REPORT 

Prepared by 

Robert Anigstein, PhD 

SC&A, Inc. 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

April 25, 2016 

DISCLAIMER 

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
Carborundum SEC Issues Matrix 2 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

INTRODUCTION

This document summarizes and discusses the findings presented by SC&A, Inc. (2016) that 

arose from a review of SEC Petition Evaluation Report: Petition SEC-00223 Report, Revision 1 

(Jessen and Scalsky 2015; hereafter referred to as the “ER”). The seven findings in SC&A’s 

report are presented as Issues 1–7 in this matrix. 

Status Summary

 Issue 1 (x-ray diffraction [XRD] apparatus): Open

 Issue 2 (exposure to thorium): Open

 Issue 3 (exposure to strontium-90 [90Sr] in thickness gauges): Open

 Issue 4 (failure to assign doses from medical x rays during the first operational period): 

Open

 Issue 5 (“Example DR” failed to assign doses from medical x rays during second 

operational period): Open

 Issue 6 (inappropriate and incorrect use of Federal Guidance Report [FGR] No. 12 

[EPA 1993]): Open

 Issue 7 (dose calculations in “Example DR” not reproducible): Open

Level of Importance

We have assigned four levels of importance to these issues, which we define in the following 

manner: 

 High: Information presented in the ER is insufficient or questionable, impacting the 

ability of the National Institute for Occupational Safety and Health (NIOSH) to 

reconstruct doses. 

 Medium: NIOSH dose reconstruction (DR) methodology presented in the ER is 

scientifically incorrect or inconsistent with generally accepted DR procedures. 

However, there is sufficient information in the ER or elsewhere to allow this issue to be 

resolved in a scientifically correct and claimant-favorable manner. 

 Low: Technical improvements are needed to improve the accuracy of DRs, but these 

are unlikely to have major impacts in most cases.

 N/A: Not applicable because the issue was closed by action of the Work Group or 

SC&A recommends that the issue be closed or be in abeyance.

We have assigned the following levels of importance to these issues: 

 Issue 1: High

 Issue 2, 3, 4 5, and 7: Medium

 Issue 6: Low
Carborundum SEC Issues Matrix 3 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

Issue Resolution Matrix for SC&A Findings on Carborundum SEC Petition-00223 and the 

NIOSH SEC Petition Evaluation Report 

Issue 1: NIOSH Failed to Prescribe a Methodology to Assess Doses to Skin of Hands and 

Forearms from X-Ray Diffraction (XRD) Apparatus 

SC&A Finding: The ER does not present a detailed, quantifiable, verifiable description of how NIOSH 

intends to assess doses to operators of XRD equipment. The ER cites Lubenau et al. (1969) to suggest 

that the dose rates would not exceed 2 milliroentgens per hour at the edge of the table. However, in a 

personal communication with the author of this matrix, (2015) stated that the dose rates on top 

of the table, where the operator might place his hands and forearms, would “surely be higher.” The ER 

refers to a methodology adopted by NIOSH to limit the exposures to such an apparatus at Sandia 

National Laboratory—Livermore (Guido et al. 2007), but then observes that “the method was site-specific, 

based on detailed accounts of the equipment and technical factors; however, the same level of detail has 

not been found for Carborundum.” Nevertheless, the ER then presents a set of assumptions which, 

according to NIOSH, would allow it to apply the Sandia methodology to Carborundum. (According to a 

former operator of XRD equipment at Carborundum who was interviewed by SC&A, there was no positive 

interlock that would prevent the operation of the equipment with an unshielded port.) Absent a more 

detailed discussion and/or an example calculation, we cannot determine how NIOSH intends to bound the 

doses from XRD at Carborundum. 

Importance: High 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open 

Issue 2: NIOSH Failed to Address Thorium as a Possible Radiation Source 

SC&A Finding: The ER cites information on the use of thorium at Carborundum obtained during an 

interview with a former worker but makes no further mention of this material except in citing two 

documents in Table A1-1, “Data Capture Synopsis for Carborundum Company.” The former worker, who 

was interviewed by the author of this matrix on January 11, 2016, reported that he produced fuel pellets 

made from ThO2 and ThC. This apparently took place prior to the second operational period. The use of 

thorium at Carborundum needs to be further investigated. If these pellets were weapons related, there 

would be reason for NIOSH to inform the U.S. Department of Energy and the U.S. Department of Labor 

that the period of covered operations needs to be extended. 

In any case, the work areas were potentially contaminated with thorium, inasmuch as, in the latest 

interview, the former worker said that the thorium was provided as a powder and confirmed that spills 

were likely. Since there is no record of a cleanup prior to the second operational period, workers 

employed during that period could have been exposed to residual thorium contamination. Such 

exposures should be addressed in evaluating doses during the second operational period. 

Importance: Medium 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open
Carborundum SEC Issues Matrix 4 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

Issue 3: NIOSH Failed to Account for the Use of 90Sr in Thickness Gauges at Carborundum 

SC&A Finding: The 1952 acquisition of five thickness gauges by Carborundum for quality control in the 

manufacture of sandpaper was reported in the New York Times (Freeman 1952). However, NIOSH was 

unaware of this information. Atomic Energy Commission (AEC) licensing documents related to the 

Industrial Nucleonics Corporation, the supplier of these gauges, indicate that such devices can contain as 

much as 2 curies of 90Sr (AEC 1964). Strontium-90 that has been allowed to age for a month or more is in 

secular equilibrium with its short-lived progeny, yttrium-90 (90Y) (t1⁄2 = 64 h), which emits ß rays with a 

maximum energy of 2.28 mega-electron volts. Thus, although both 90Sr and 90Y are almost pure ß 

emitters, the high-energy 90Y ß rays create a strong source of bremsstrahlung x rays, which can 

contribute to doses from penetrating radiation, in addition to posing a radiation hazard to the skin of a 

worker. NIOSH needs to obtain more information on the use of such sources at Carborundum—failing 

that, it needs to adopt a strategy for assigning doses to potentially affected workers. 

Importance: Medium 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open

Issue 4: NIOSH Failed to Assign Doses from Medical X Rays During the First Operational Period 

SC&A Finding: NIOSH decided not to assign medical x rays during the first operational period on the 

basis of internal correspondence at du Pont, a wartime government contractor, that said that the grinding 

of uranium at Carborundum did not require medical supervision (Daniels 1944). This is irrelevant to 

routine physical examinations, which might have included medical x rays. According to DCAS-IG-003, 

Revision 1 (DCAS 2010), doses from screening x rays are to be assigned if they were part of a required 

annual physical examination, not because they were related to a particular job assignment. The ER is 

inconsistent in prescribing the assignment of medical x rays during the second operational period but not 

the first. Furthermore, one of the petitioners stated that his father had physical exams at the site, raising 

the possibility that medical x rays were performed on site.

Importance: Medium 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open 
Carborundum SEC Issues Matrix 5 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

Issue 5: “Example DR” Failed to Assign Doses from Medical X Rays During the Second 

Operational Period 

SC&A Finding: According to the ER, “NIOSH will assume that pre-employment, annual, and termination 

PA radiographic chest X-ray screenings were performed for workers during the second operational 

period.” However, “Example DR,” a document in support of the ER that is posted on the Division of 

Compensation Analysis and Support (DCAS) restricted website, explicitly states that no medical x-ray 

doses were assessed to the hypothetical worker who was employed during both operational periods. This 

inconsistency needs to be resolved. 

Importance: Medium 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open 

Issue 6: Inappropriate and Incorrect Use of FGR 12 

SC&A Finding: The ER used several scenarios described in Battelle-TBD-6000 (Allen 2011; hereafter 

referred to as “TBD-6000”) to estimate internal and external doses from intakes of uranium dust and from 

exposure to uranium metal. However, NIOSH used FGR 12 (EPA 1993) to calculate doses from 

submersion in a cloud of radioactive dust and from exposure to contaminated surfaces instead of using 

the values listed in TBD-6000 Tables 3.9 and 3.10. The photon dose coefficient from a surface 

contaminated with uranium is entered in “Methodology.xlsx,” a document in support of the ER that is 

posted on the DCAS restricted website. This value is only ~29% of the value in Table 3.10. This 

procedure is inconsistent with the use of TBD-6000 for other pathways and for DRs at other work sites. 

Furthermore, it is not scientifically correct, since NIOSH does not have a prescribed method of deriving 

organ dose equivalents from effective dose equivalents, the dosimetric quantities listed in FGR 12. 

However, in the case of Carborundum, the external doses from penetrating radiation displayed in 

“Methodology.xlsx” for the residual periods are a few millirem per year (mrem/y) (not <1 mrem/y, as 

stated in the ER), so these discrepancies are not highly significant. 

Doses to the skin from nonpenetrating radiation from uranium-contaminated surfaces are on the order of 

a few hundred millirem during the first few years of the first residual period. Consequently, the value 

derived from FGR 12 skin doses that is entered in “Methodology.xlsx,” which is only ~72.5% of the value 

in TBD-6000 Table 3.10, could affect the outcome of a DR. 

Importance: Low 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open 
Carborundum SEC Issues Matrix 6 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

Issue 7: Dose Calculations in “Example DR” Are Not Reproducible

SC&A Finding: SC&A audited doses to four of the five organs presented in “Example DR.” Our audit 

exhibited significant differences in both internal and external doses. NIOSH did not show details of its 

calculations—“Example DR” simply listed annual intakes and external dose rates during the relevant 

periods and the final organ doses but did not present the details of the intermediate calculations used to 

obtain these doses. Consequently, it was not possible for us to identify the reasons for the different 

results. The ABRWH procedures for reviews of NIOSH SEC petition evaluation reports recommend that 

NIOSH include in its evaluation a demonstration that it is feasible to reconstruct individual doses for the 

cohort, including sample DRs (SC&A 2006). Until we can verify the results of sample DRs, we cannot 

conclude that NIOSH can reconstruct doses to Carborundum workers. 

Importance: Medium 

NIOSH Response: 

Board Action: 

Status (4/25/16): Open 
Carborundum SEC Issues Matrix 7 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

References 

Allen, D., 2011. Site Profile for Atomic Weapons Employers that Worked Uranium Metals, 

Battelle-TBD-6000, Revision 1, Division of Compensation Analysis and Support, National 

Institute for Occupational Safety and Health. Available at 

http://www.cdc.gov/niosh/ocas/awedocs.html#b6000

Atomic Energy Commission (U.S.) (AEC) 1964. “Byproduct Material License, Licensee:

Industrial Nucleonics Corporation, License Number: GL 136 (D65).” FOIA request via NRC 

Public Document Room: 8304010153 830131, PDR FOIA, STEPHAN82-619 PDR. 

Daniels, C.E., 1944. “T-Metal Fabrication,” letter to Dr. G.H. Gehrmann, Medical Director, 

E. I. duPont de Nemours and Company, Incorporated. October 11, 1944. [SRDB Ref. ID 

21831] 

Division of Compensation Analysis and Support (DCAS) 2010. Radiation Exposures 

Covered for Dose Reconstructions under Part B of the Energy Employees Occupational 

Illness Compensation Program Act, DCAS-IG-003, Revision 1, National Institute for 

Occupational Safety and Health. October 5, 2010. Available at 

http://www.cdc.gov/niosh/ocas/pdfs/dr/oc-ig3-r1.pdf

EPA 1993. External Exposure to Radionuclides in Air, Water, and Soil, Federal Guidance 

Report No. 12, EPA 402-R-93-081, K.F. Eckerman and J.C. Ryman, U.S. Environmental 

Protection Agency, Office of Radiation and Indoor Air, Washington, DC. September 1993. 

[SRDB Ref. ID. 11997]. Available at https://www.epa.gov/sites/production/files/2015-

05/documents/402-r-93-081.pdf

Freeman, W.M., 1952. “New Way Devised to Make Abrasives: Carborundum’s Process Joins

Use of Beta Rays with Fully Automatic Controls.” New York Times, June 8. Available at 

http://query.nytimes.com/mem/archive/pdf?res=9B0DE4D6103CE53ABC4053DFB066838964

9 EDE

Guido, J., et al., 2007. “SEC Petition Evaluation Report Addendum: Sandia National

Laboratories – Livermore, Petition SEC-00059-Addendum.” Available at

http://www.cdc.gov/niosh/ocas/pdfs/sec/sandiaca/snleradd.pdf

Jessen, K., and E. Scalsky 2015. SEC Petition Evaluation Report: Petition SEC-00223 Report, 

Revision 1, Oak Ridge Associated Universities. June 3, 2015. Available at 

http://www.cdc.gov/niosh/ocas/pdfs/sec/carbco/carbcoer-223-r1.pdf

Lubenau, J.O., J.S. Davis, D.J. McDonald, and T.M. Gerusky 1969. “Analytical X-Ray 

Hazards: a Continuing Problem,” Health Physics 16, 739–746. [SRDB Ref. ID 142196] 

 2015. “Re: Radiation exposures from x-ray diffraction,” personal email to 

Robert Anigstein, SC&A, Inc. November 11, 2015. 
Carborundum SEC Issues Matrix 8 SC&A – April 25, 2016 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution. 

SC&A, Inc. 2006. Board Procedures for Review of Special Exposure Cohort Petitions and 

Petition Evaluation Reports, Revision 1, SCA-TR-TASK5-0002. 

SC&A, Inc. 2016. Review of the Carborundum Special Exposure Cohort (SEC) Petition-00223 

and the NIOSH SEC Petition Evaluation Report, SC&A-TR-SEC-2016-0001, Revision 1, 

R. Anigstein. January 27, 2016.