ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

ISSUE RESOLUTION MATRIX FOR SC&A FINDINGS ON 

CARBORUNDUM SPECIAL EXPOSURE COHORT (SEC) 

PETITION-00223 AND THE NIOSH SEC PETITION

EVALUATION REPORT

Contract No. 211-2014-58081 

Prepared by

Robert Anigstein, PhD 

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

Original Date: April 25, 2016 

Updated: October 3, 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 – October 3, 2016

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.

INTRODUCTION

The present document summarizes and discusses the findings presented by Anigstein (2016) that 

arose from our review of “SEC Petition Evaluation Report: Petition SEC-00223 Report,” Rev.1 

(Jessen and Scalsky 2015) (ER). The seven findings in our previous report are presented as 

Issues 1–7 in this matrix. The matrix is current as of the last meeting of the Work Group on 

Carborundum Company on August 18, 2016. 

Status Summary

• Issue 1 (x-ray diffraction [XRD] apparatus): Closed by action of the Work Group on 

Carborundum Company. 

• Issue 2 (exposure to thorium): Closed as an SEC issue by action of the work group, In 

Abeyance as a site profile issue.

• Issue 3 (exposure to 90Sr in thickness gauges): Closed by action of the work group. 

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

Closed by action of the work group. 

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

operational period): Closed by action of the work group. 

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

[Eckerman and Ryman 1993]): Closed by action of the work group. 

• Issue 7 (dose calculations in “Example DR” not reproducible): Closed as an SEC issue 

by action of the work group, In Abeyance as a site profile issue.

Levels of Importance

We have defined four potential levels of importance for these issues: 

• 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 dose 

reconstructions, 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: 

• Issues 1, 3, 4, 5, and 6: N/A

• Issues 2 and 7: Medium
Carborundum SEC Issues Matrix 3 SC&A – October 3, 2016

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.

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 mR/h at the edge of the table. However, in a personal 

communication with the author of this matrix, Lubenau (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.a

NIOSH Response (6/08/2016) (Tomes 2016): 

NIOSH reevaluated dose from XRD. . . . NIOSH concludes that the exposure to a Rad 

Production Support personnel as specified in the DR methodology (10.8 R/yr shallow 

dose to skin and 115 R/yr to the hands and extremities) would be assigned to XRD 

technicians as a bounding estimate of dose.

Board Action (8/18/2016): During a meeting by teleconference, the Work Group on Carborundum 

Company concluded that Finding 1 is closed.

Status (8/18/2016): Closed.
Issue Resolution Matrix for SC&A Findings on Carborundum SEC Petition-00223 and the 

NIOSH SEC Petition Evaluation Report (continued)

Carborundum SEC Issues Matrix 4 SC&A – October 3, 2016

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.

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 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 (6/08/2016) (Tomes 2016): 

Based on available information, it appears that non-covered uranium work was performed 

for several years prior to the 2nd AWE period, and some thorium work may have been 

done in 1955. Any alpha emitting radionuclides in the air from both AEC operations in 

1959 (and contamination from previous non-covered work) are reflected in the reported

uranium (gross alpha) airborne radioactivity measurements. External dose from residual 

contamination would be insignificant in comparison to the doses assigned for the AEC 

contract work starting in 1959. 

SC&A Reply (8/18/2016): During a meeting by teleconference of the Work Group on Carborundum 

Company, Robert Anigstein (SC&A) agreed with NIOSH, but noted that the dose conversion factors 

(DCFs) for 232Th are significantly higher than those for 234U. Consequently, the internal doses to workers 

exposed to intakes of radioactive aerosols should reflect the possibility that some of the airborne activity 

was 232Th.

NIOSH Reply (8/18/2016): During the work group meeting, James Neton (NIOSH/DCAS) stated that 

NIOSH needs to give further thought on how to deal with this issue. 

Board Action: During the meeting, the work group concluded that Finding 2 is closed as an SEC issue 

but needs to be considered as a site profile issue. 

Status (8/18/2016): Closed as an SEC issue, In Abeyance as a site profile issue.
Issue Resolution Matrix for SC&A Findings on Carborundum SEC Petition-00223 and the 

NIOSH SEC Petition Evaluation Report (continued)

Carborundum SEC Issues Matrix 5 SC&A – October 3, 2016

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.

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 licensing documents related to the Industrial 

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

2 Ci 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, 90Y (t1⁄2 = 64 h), which emits ß rays with a maximum energy of 

2.28 MeV. 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.a 

NIOSH Response (6/08/2016) (Tomes 2016):

The 1952 New York Times reference that SC&A discussed in the report indicates the 

sources were used in the “coated products division plant” to automatically control the 

thickness of sandpaper. As part of a reorganization and modernization program, 

Carborundum opened a new plant in 1947 for its Coated Abrasives Division, one of four 

divisions of the company at that time. The plant was located in Wheatfield, NY, in Niagara 

County, not at the Buffalo Avenue complex headquarters in Niagara Falls. . . . One of the 

people interviewed for the Evaluation Report also said sandpaper was not made at the 

Buffalo Avenue Plant. . . .

NIOSH concludes the Sr-90 sources . . . were mostly likely at the Coated Abrasives 

Division Plant in Wheatfield, which is not a listed facility under EEOICPA. Therefore, 

assessment of dose from those sources is not applicable.

Board Action (8/18/2016): During a meeting by teleconference, the Work Group on Carborundum 

Company agreed that Finding 3 is closed.

Status (8/18/2016): Closed.

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, 

Rev. 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 had physical exams at the site, raising 

the possibility that medical x rays were performed on site.
Issue Resolution Matrix for SC&A Findings on Carborundum SEC Petition-00223 and the 

NIOSH SEC Petition Evaluation Report (continued)

Carborundum SEC Issues Matrix 6 SC&A – October 3, 2016

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.

Importance: Mediuma 

NIOSH Response (6/08/2016) (Tomes 2016): 

The example DR report reviewed by SC&A had a statement indicating “No medical x-ray 

doses were assessed.” The First Operational Period covers June 1943 through 

September 1943. The Evaluation Report (section 7.3.2) cites a reference that stated 

there were no health surveillance requirements for the 1943 work. SC&A mentioned a 

claimant indicated Carborundum required x rays during that time, and dose should be 

assigned whether or not required by the AEC. NIOSH agrees that dose from a single xray examination should be assigned in dose reconstructions for claimants with 

employment in 1943. 

SC&A Reply (10/03/2016): To be exact, Anigstein (2016) reported that the of a deceased 

Carborundum employee stated that had physical exams at the site, but the did not know if 

they included medical x rays.

Board Action (8/18/2016): During a meeting by teleconference, the Work Group on Carborundum 

Company agreed that Finding 4 is closed. 

Status (8/18/2016): Closed.

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.a 

NIOSH Response (6/08/2016) (Tomes 2016): 

The example DR report reviewed by SC&A had a statement on the last line indicating “No 

medical x-ray doses were assessed.” To clarify, the example DR Report did not say they 

were not applicable; they were just not provided with the example calculations. NIOSH 

agrees that x-ray doses are applicable, as indicated in ER section 7.3.2. 

Board Action (8/18/2016): During a meeting by teleconference, the Work Group on Carborundum 

Company agreed that Finding 5 is closed.

Status (8/18/2016): Closed.
Issue Resolution Matrix for SC&A Findings on Carborundum SEC Petition-00223 and the 

NIOSH SEC Petition Evaluation Report (continued)

Carborundum SEC Issues Matrix 7 SC&A – October 3, 2016

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.

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 (Eckerman and Ryman 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 (EDEs), 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 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.a 

NIOSH Response (6/08/2016) (Tomes 2016): 

NIOSH concurs with SC&A that the factors provided in TBD-6000 . . . for external dose 

from contamination and air immersion provide higher doses than the factors in the 

example DR, which were derived from Federal Guidance Report Number 12. Therefore, 

the methods will be revised to use the TBD-6000 factors.

Board Action (8/18/2016): During a meeting by teleconference, the Work Group on Carborundum 

Company agreed that Finding 6 is closed.

Status (8/18/2016): Closed.

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

NIOSH SEC Petition Evaluation Report (continued)

Carborundum SEC Issues Matrix 8 SC&A – October 3, 2016

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.

Importance: Medium

NIOSH Response (6/08/2016) (Tomes 2016): 

The doses provided by NIOSH were not precise best estimates. . . . NIOSH employed 

some efficiency measures in the example DR, some of which resulted in marginally 

higher dose. . . . NIOSH can provide an updated example dose calculation showing 

details of the annual dose calculations. However, SC&A also had comments on 

interpretation of data to estimate both internal and external doses. Those comments, 

while not at the level of a finding, should be resolved before NIOSH provides an updated 

example calculation.

As noted by SC&A, NIOSH used the higher exposure (R) organ DCFs for calculating 

certain doses from uranium metal when the lower personal dose equivalent DCFs (Hp10) 

factors should have been used. NIOSH agrees with SC&A’s comment on the appropriate 

factors to use for exposure to uranium metal. NIOSH also employed some efficiency 

measures that resulted in some other marginal overestimates.

. . .

The large discrepancy in the internal dose to the skin, liver, and kidneys is due to the 

NIOSH example DR incorrectly using solubility Type F as one of the possible solubility 

types for intakes from the 1943 uranium metal grinding work (Type S was correctly used 

for the lungs). NIOSH agrees with ER section 7.2.2.1 that only uranium solubility Types M

and S should be considered for the metal grinding work in 1943, thus the reported 

internal doses in the example DR for the skin, liver, and kidneys are too high. 

NIOSH Response (8/18/2016): During a meeting by teleconference of the Work Group on Carborundum 

Company, James Neton (NIOSH/DCAS) stated that NIOSH would address observations made by SC&A 

that would affect dose calculations. However, all participants agreed that these are site profile, not SEC, 

issues.

Board Action: During the meeting, the work group concluded that Finding 7 is closed as an SEC issue 

and should be considered to be a site profile issue. 

Status (8/18/2016): Closed as an SEC issue, In Abeyance as a site profile issue.

a This is the importance originally assigned to this issue—it is listed here to maintain continuity. Since the 

issue has been closed, the importance is no longer relevant.
Carborundum SEC Issues Matrix 9 SC&A – October 3, 2016

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.

References

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

Battelle-TBD-6000,” Rev. 1. Available at http://www.cdc.gov/niosh/ocas/pdfs/tbd/bat-6000-

r1.pdf

Anigstein, R. 2016. “Review of the Carborundum Special Exposure Cohort (SEC) 

Petition-00223 and the NIOSH SEC Petition Evaluation Report.” 

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. du Pont 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, Rev. 1. Available at 

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

Eckerman, K. F., and J. C. Ryman. 1993. “External Exposure to Radionuclides in Air, Water, 

and Soil,” Federal Guidance Report No. 12, EPA 402-R-93-081. Washington, DC: U.S. 

Environmental Protection Agency, Office of Radiation and Indoor Air. 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., E. Thomas, R. Clark, R. Medora, D. Mantooth, C. Barton, and L. McDowell-Boyer. 

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,” Rev. 1. 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. 

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

Robert Anigstein, SC&A, Inc. November 11, 2015. 
Carborundum SEC Issues Matrix 10 SC&A – October 3, 2016

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.

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

Petition Evaluation Reports,” Rev. 1, SCA-TR-TASK5-0002.

Tomes, T.P. (NIOSH/DCAS). 2016. “NIOSH Response to SC&A Findings on SEC-00223: 

Carborundum Company, Niagara Falls, NY.” Available at 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-carbco-060816.pdf