Draft 

LINDE UTILITY TUNNEL-RELATED 

TBD ISSUES 

Contract No. 200-2009-28555 

Prepared by 

Stephen L. Ostrow, PhD 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 2012 

Disclaimer

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

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted. 
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Document No.: 

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S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No: 

0 – Draft 

Linde Utility Tunnel-Related TBD Issues Page 2 of 13 

Task Manager: 

_____________________ Date: ____________ 

Stephen L. Ostrow, PhD 

Supersedes: 

N/A 

Technical Contributor: 

 Nicole Briggs 

Project Manager: 

_____________________ Date: ____________ 

John Stiver, CHP Reviewer: 

 John Mauro, PhD, CHP 

Record of Revisions 

Revision 

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TABLE OF CONTENTS 

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

1.0 Introduction..........................................................................................................................5 

2.0 Utility Tunnel Timeline .......................................................................................................5 

3.0 Tunnel Occupancy Factors ..................................................................................................8 

4.0 References..........................................................................................................................12 
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

FUSRAP Formerly Utilized Sites Remedial Action Program 

LAPC Linde Air Products Company 

NIOSH National Institute for Occupational Safety and Health 

SC&A S. Cohen & Associates 

SEC Special Exposure Cohort 

SRDB Site Research Database 

TBD Technical Basis Document 

USACE U.S. Army Corps of Engineers 

wd work day 

WG Work Group 
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1.0 INTRODUCTION 

The Advisory Board on Radiation and Worker Health (ABRWH) Linde Work Group (WG) held 

a meeting in Cincinnati, Ohio, on January 30, 2012, to consider technical basis document (TBD)-

related issues identified in the course of considering Linde Special Exposure Cohort (SEC) 

Petitions 00107 and 00154. The first issue is to determine when different segments of the 

tunnels were built (“timeline”), and the second issue was to determine appropriate tunnel 

occupancy factors. The WG requested that SC&A conduct its own investigations into these 

issues and report back to the WG for further consideration. In the course of its investigations, 

SC&A examined documents, plot plans, and worker statements, and consulted with the National 

Institute for Occupational Safety and Health (NIOSH) for certain clarifications. 

 

2.0 UTILITY TUNNEL TIMELINE 

The utility tunnel complex consists of different segments constructed at different times, with 

sections still existing at the site. A continuing issue, which was identified during deliberations 

concerning SEC Petitions 00107 and 00154, concerns the segment construction timeline. This 

issue was explored by SC&A as one of the action items arising from the August 15, 2011, Linde 

WG meeting in Cincinnati; SC&A’s conclusions are documented in its report of October 11, 

2011 (SC&A 2011a), followed by a memo on October 17, 2011 (SC&A 2011b), which factored 

into the assessment affidavits from two former Linde workers received by SC&A subsequent to 

issuing SC&A 2011a. At its January 30, 2012, meeting, the Linde WG requested that SC&A reexamine the timeline. 

NIOSH articulates its position on the tunnel timeline in the Linde TBD (NIOSH 2011). Section 

2.3.5 describes the utility tunnel complex: 

The Linde site had a system of utility tunnels, constructed at different times, to 

carry steam, electricity, water, telephone lines, and other utilities from one part of 

the plant to another (LAPC ca. 1937 [1936], 1957, 1961; Coutts 2005). 

Documentary evidence shows that the first tunnel section was built in 1937 and 

ran from the powerhouse (Building 8) past the Tonawanda Laboratory (Building 

14, also called the Proving Laboratory) to Building 10... Another section of 

tunnel was constructed in 1957 near Buildings 57, 58, and 31 in the northeastern 

area of the Ceramics Plant, and an extensive addition to the tunnel system was 

done in 1961 when the 1937 and 1957 tunnels were linked by new tunnels that ran 

between Buildings 30 and 31 and then branched south to Building 8 and west past 

Buildings 70, 2, and 2A. The 1957 and 1961 tunnel sections ran through areas of 

soil that were contaminated by radium-bearing ore and were subject to radon 

infiltration from this source. 

Following the Linde WG’s directions, SC&A personnel met on February 2, 2012, to perform a 

detailed review of full-sized plot plans (LAPC 1936, 1957, and 1961) and other documents; 

SC&A confirmed with NIOSH prior to the meeting that these were the same (and only set) of 

drawings that NIOSH had as well. SC&A had previously examined these drawings and included 

reduced-sized versions in its October 11, 2011, report (SC&A 2011a). As discussed in that 
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SC&A report, and included therein as a figure, one of the former workers interviewed by SC&A 

at the May 2010 Niagara Falls ABRWH meeting had supplied a schematic plot plan of the site 

that he had annotated with the locations of all the utility tunnels. Using the three large plot plans 

and the annotated schematic, SC&A put together its own schematic drawing of the Linde facility 

(Figure 1), with the tunnels labeled according to what SC&A believes are their dates of 

construction. This drawing represents a simplification and consolidation of the tunnel 

construction assumptions used by NIOSH and presented by SC&A in its October 2011 report 

(SC&A 2011a). 

SC&A also considered worker statements, taken by NIOSH during interviews, regarding the 

tunnels, which provided valuable but somewhat inconsistent information; these statements were 

considered previously (SC&A 2011a), but are re-examined here. [Worker 6], who was the 

[redacted] at Linde, stated that the east-west tunnel that went from the Powerhouse (Building 8) 

to Buildings 1, 2, and 10 was built before 1953 (Murray 2010b). This description matches what 

appears in the 1936 plot plan (LAPC 1936) and the green portion of Figure 1 in this report. The 

worker statement continues to describe the north-south tunnel, which was built after 1956, that 

traversed the whole length of the facility to Buildings 30 and 31, and also had a branch that ran 

west to Building 70. This description matches the 1957 and 1961 drawings (LAPC 1957 and 

1961) and the blue and red portions of Figure 1. 
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However, one statement made by another worker, [Worker 1] (Murray 2010c), where he is 

paraphrased as saying “the tunnels were in place before he started working there in 1953,” 

appears to contradict this information. It is not clear, however, if [Worker 1] is referring to all 

of the tunnels or simply a portion. A subsequent affidavit by [Worker 1], quoted by SC&A in 

SC&A 2011b, states: 

In all of that time frame the Utility Tunnels from Building #10 to Junction box 

located north of the road way between Building #39 & Building #58 where an exit 

and entrance ladder existed and was in existence to the best of my knowledge and 

experience. In fact the tunnel had to be there in order for utilities such as 

Electricity, Steam, condensate, water, air pressure, telephone lines to supply these 

utilities to the Ceramics Plant Buildings 30, 31, 37, 38, & 39. 

It is noted that the worker uses the phrase “the tunnel had to be there,” rather than a formulation 

like “I personally saw it there.” Hence, his assertion appears to be a supposition, not a personal 

observation. In fact, as will be discussed later, an alternative theory to a tunnel supplying 

utilities is supplied by the presence of an aboveground trestle carrying utilities. 

SC&A reviewed each of the full-size drawings closely, paying particular attention to their fine 

details and notes. The oldest drawing, from 1936, clearly shows that some utility tunnels were in 

place in the southwest corner of the facility near Building 14 (Tonawanda Laboratory) and 

Buildings 2, 8, 10, and 11, well before the AEC operational period at Linde. 

SC&A then examined the 1957 drawing, which shows only the southeast corner of the facility. 

This plan presents all of the details of the tunnel section around Buildings 30 and 31. It was not 

readily apparent if this map represents a drawing of the tunnel section that was already in place 

in 1957, or if it represents construction plans for a tunnel section that was going to be built and, 

therefore, did not yet exist as of the date of the drawing (March 20, 1957). There are, however, 

some notations on the drawing that indicate that it is most likely a construction plan. Appearing 

throughout the drawing, there are notes describing “existing storm sewer,” “existing water lines,” 

and “existing sanitary sewers,” as well as descriptions and locations of “new” sanitary sewer 

lines, water pipes, etc. On this drawing, any pipes, lines, or small buildings (such as the 

“smoking shed”) that cross the location of the tunnel schematic are labeled as “to be removed,” 

which further indicates that, as of 1957, this tunnel had not yet been constructed. The 1957 

drawing confirms the existence of trestles (notes “existing trestles” to the west of Building 31), 

which SC&A assumes were used to supply utilities to the buildings at this part of the facility 

prior to the construction of the tunnels. 

SC&A then examined the third drawing, dated February 1, 1961, which shows the majority of 

the Linde facility and the entire tunnel complex. This drawing clearly labels portions of the 

tunnel that already existed, such as the L-shaped tunnel around Buildings 30 and 31, and clearly 

indicates the “new” tunnel portions connecting the 1936 and 1957 tunnels. This plan also 

expands on the use of the trestles, as presented here from Note #5 of LAPC 1961: 

The portion of the trestle from Bldgs. 30 and 31 South to the dogleg, between 

tracks #3 and #4, shall be maintained until the tunnel is in service. At junction 
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Box #6, east to Bldg. 31, west to Bldg 30 and when the trestle crosses the tunnel 

running west from junction box 7, the lines on the trestle shall have to be 

supported during construction period. When the tunnel is completed and the lines 

installed therein this portion of the trestle can be removed. 

Following review of the available drawings, SC&A created Figure 1, which shows schematically 

its view of when different portions of the utility tunnel complex were constructed. SC&A 

contacted NIOSH (Chris Crawford) for clarification during its review session. He stated that 

when NIOSH requested Linde utility tunnel maps from Praxair (the current operator of the Linde 

site), they specifically sent “construction drawings.” He also drew SC&A’s attention to a memo 

(already known to SC&A) from Shaw Environmental (Coutts 2005) under an Army Corps of 

Engineers FUSRAP (Formerly Utilized Sites Remedial Action Program) contract, which 

discusses the utility tunnels. The following is an excerpt from that memo, which mentions the 

dates of construction: 

The 97-inch tunnel between Junction Boxes #6 and #7 and the 80-inch tunnel 

between between #7 and #9 were constructed in 1961. The nearby building 

Building 31 tunnel set was constructed 4 years earlier and removed during 

remedial action in EA-M and EA-E due to fixed interior contamination.

SC&A concludes from its latest review of the utility tunnels that the evidence supports the 

assumption that the only tunnel section that was in place before 1957 was the 1936 portion, 

represented by the green lines in Figure 1. The evidence leading to this conclusion includes the 

testimony by former Linde worker, [Worker 6], the construction notes on the 1957 and 1961 

drawings (LAPC 1957 and 1961), the existence of the trestles to supply utilities to Buildings 30 

and 31, Praxair’s description of the maps as “construction drawings,” and the notes in the Shaw 

Environmental memo (Coutts 2005). 

3.0 TUNNEL OCCUPANCY FACTORS 

In order to reconstruct doses at different time periods for Linde personnel who might have been 

exposed to radiation while in the utility tunnels, NIOSH made certain assumptions about 

personnel occupancy factors. The Linde TBD (NIOSH 2011) presents the assumption in several 

places; for example, Section 2.3.5 states: 

The utility tunnels would have been routinely accessed by inspectors and 

maintenance personnel throughout the site history. There is only limited 

information on the number of hours a worker might have worked in these tunnels 

but, according to USACE (2002b), approximately 2 months a year are currently 

needed for annual maintenance (sump pumps replacement, condensate pump 

repair, lighting repairs, etc.). The report also provides an estimate of effort 

required for tunnel inspection each year. This estimate is supported by worker 

interviews (Murray 2010a, 2010b, and 2010c). There were stairwells from the 

tunnel up to Buildings 2, 8, 14, and 30 (Building 30’s access was by means of a 
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ladder at Junction Box 6), but it was not general practice for employees to use 

them to get from one building to the other, and the practice was not condoned by 

the company (Murray 2010c). However as a favorable to claimant assumption, it 

is assumed that all other personnel may have used the tunnels for transit. A 

transit occupancy time of 10 minutes per workday (wd) is assumed. 

TBD Section 6.4 states the assumptions more succinctly, dividing the personnel into two classes: 

It is assumed that trade workers and laborers worked in these tunnels doing 

maintenance for 8 hr/wd (2 months of the year) and for the other 10 months, a 

transit time of 10 min/wd using the tunnels to get between buildings. For all other 

workers, only the transit time of 10 min/wd should be applied year-round. 

SC&A examined USACE 2002b cited in the TBD quotation above, which is a report prepared 

for the U.S. Army Corps of Engineers under the FUSRAP program, assessing the dose from 

surface contamination within the Linde utility tunnels. Section 2.2, “Tunnel Access,” provides 

information on activities carried out within the tunnels and associated occupancy times: 

The tunnel is frequently accessed for inspections and maintenance activity. Two 

workers spend approximately 24 hours per month inspecting the entire tunnel for 

repairs and to support the annual steam line startup each winter. If repairs are 

identified, maintenance is scheduled based on the critical nature of the repair. 

Light to moderate maintenance activities may include sump pump replacement, 

condensate pump repair, lighting repairs, etc. These types of repairs usually 

occur on a monthly cycle and involve approximately four workers, one day each 

month. 

Approximately two months each year are necessary for annual maintenance 

activities that are more time consuming and complex. These scheduled activities 

include intrusive work such as concrete drilling to repair or hang brackets and 

concrete chiseling to repair the tunnel walls. It is estimated that four workers will 

spend an average of 60 days in the tunnel performing such heavy maintenance 

activity. Praxair staff also indicated plans for a large-scale structural repair 

project to improve the overall condition of the tunnel and to preserve the 

structural integrity of the network. The project may also include isolating and 

closing some older sections. The structural repair project is estimated to require 

seven months to complete and will involve at least four workers. Based upon the 

contamination information and discussion with Praxair staff, it was decided to 

limit the time period in that section to 30 days. 

NIOSH relies on this information to support its assumption of 2-months per year exposure to 

tunnel workers. However, as the TBD itself notes, the Army Corps of Engineers estimate was 

based on then (2002) current practices and not on historical practices that Linde workers may 

have engaged in; the latter may have entailed more than 2 months per year exposure. 
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In order to try to assess potential exposures to personnel in the tunnels, SC&A examined worker 

statements for relevance to time spent in the tunnels; most references to occupancy time, 

however, were made in passing in discussions of other matters, and are anecdotal and 

incomplete. Several pertinent examples are presented below. [Worker 1], who is quoted in 

Section 2.0 of this report, said in an interview conducted by NIOSH (Murray 2010c): 

Every week a millwright and an electrician would do a walk-through looking for 

leaks and other problems, and examining sump pumps... The walk-through took 

about an hour. He did not do the walk-through every week. 

There were stairwells from the tunnel up to Bldgs. 14, 2 and 30. But it was not 

general practice for employees to use them to get from one building to the other, 

although he did recall more than one instance in which employees used the 

tunnels to get from their buildings to the cafeteria during inclement weather. He 

stressed that this was not a normal practice, nor was the practice condoned by the 

company. 

These quotations support that personnel used the tunnels for work purposes and also for 

convenience purposes, although the latter use was neither usual nor condoned. 

SC&A interviewed four former Linde workers during an ABRWH meeting in Niagara Falls, 

New York, in May 2010; the focus was on the utility tunnel complex, which had become a topic 

of interest during SEC petition deliberations. The workers were given the opportunity to 

comment on SC&A’s draft report (the discussions were not recorded verbatim, but paraphrased 

by SC&A) and their comments were incorporated into the final version, which was issued in 

May 2010 (SC&A 2010). Several quotations relevant to tunnel occupancy have been extracted 

from that report and are presented here: 

[Worker 1]: Another comment. It was brought to my attention that the tunnel 

was not generally accessible. That is a fallacy. 

[Worker 1]: They said the tunnel was restricted and unauthorized personnel 

were not allowed, but they never said who was not authorized. 

[Worker 4]: I went in there all the time. 

[Worker 2]: It was also a good place to hide from your foremen and take a nap 

there. 

[Worker 2]: Between [production] batches, people went to sleep [in the tunnel]. 

Anyone who worked at Linde had access to the tunnel. 

In addition, [Worker 1] provided a two-page statement, dated May 19, 2010 ([Worker 1] y 

2010), presenting feature-by-feature details of the utility tunnels. The statement ends with a 

comment on the occupancy of the tunnels: 
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The utility tunnel was used by personnel as long as I was employed, during 

inclement weather it was used like a subway, nice and warm etc. to get to the 

cafeteria and various offices for all employees. There was no policing only sign 

stating no Unauthorized Personnel. It never stated who were the authorized...I 

recall some old time chemical operators who worked for the silicone division tell 

me that on the midnight shift they grabbed some shuteye between batches or to 

hide from the foreman in the utility tunnel where access was gained by using the 

stairwell in Building #14. As for the two months a year, this is someone’s pipe 

dream; some jobs alone took six to eight months to complete. 

These above quotations support the assumption that personnel went into the tunnels, but, with the 

exception of the last, do not furnish quantitative information on durations – some jobs alone took 

six to eight months to complete, – which is considerably in excess of NIOSH’s assumption of 

2 months per year (on the average). His statement about some personnel sleeping in the tunnel, 

however, is hearsay, since he neither did it himself nor witnessed others doing it. 

SC&A also examined another statement from [Worker 1], an affidavit of November 10, 2006, in 

which he recounts his long job history at Linde ([Worker 1] 2006). In the course of his writings, 

he mentions his experience with the tunnels: 

Many job assignments were in the utility tunnel. On steam, condensation lines, 

steam traps, replacing various gaskets in steam line flanges were necessary...One 

large job we had was removing all the rusted steel unit strut supports and 

replacing it with stainless steel unit strut. 

Later in his statement, he said: 

Also as a [redacted] many job assignments placed me back in all the same 

building contaminated with radiation. One job performed every week on the 

preventative maintenance program, was to walk the Utility tunnel with another 

craftsman and inspect all steam, condensate lines, electrical conduit switch boxes, 

N2 lines, exhaust fans, sump pumps and look for other problems. 

Again, these quotations establish that the tunnel was routinely accessed for work-related 

purposes, some periodic and some episodic. Occupancy times are not quantified, however. 

After reviewing relevant portions of the Army Corps of Engineers report (USACE 2002b) and 

the worker statements, SC&A finds that the NIOSH tunnel occupancy assumptions appear 

reasonable, but their support is far from conclusive, since they are primarily based on the 

USACE report, which presents information for operations in 2002, but does not discuss historical 

operations in the tunnels. 
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4.0 REFERENCES 

Coutts 2005. Coutts, P., Shaw Environmental, Inc., Memo, Data Collection Request #026 – 

Utility Tunnel Exterior Characterization in Excavation Areas D2 and M South, Contract 

DACW41-01-D-0031, DN01, January 7, 2005. (SRDB Ref. ID: 82865) 

LAPC (Linde Air Products Company) 1936. Layout Utility Tunnel, Tonawanda, A-63905, 

Rev. B, New York. (SRDB Ref ID: 91456) 

LAPC (Linde Air Products Company) 1957. Location Plan, 57′′ & 80′′ Utility Tunnels & Sewers 

for Northside of Property, Tonawanda, NY, A-360164, Rev. E, Tonawanda, New York. 

December 19. (SRDB Ref ID: 91457) 

LAPC (Linde Air Products Company) 1961. Location Plan, Tonawanda, New York, A-437867, 

Tonawanda, New York. February 1. (SRDB Ref ID: 91458) 

[Worker 1] 2006. Affidavit by [Worker 1], November 10, 2006. 

[Worker 1] 2010. Statement by [Worker 1], May 19, 2010. 

Murray, B., 2010a. “Linde Ceramics Plant (11/01/1947 through 12/31/1953),” documented 

communication with [Name redacted; Privacy Act information] (former Linde Ceramics Plant 

employee), Oak Ridge Associated Universities Team, Oak Ridge, Tennessee, March 4, 2010. 

[SRDB Ref ID: 80052] 

Murray, B., 2010b. “Linde Ceramics Plant (11/01/1947 through 12/31/1953),” documented 

communication with [Name redacted; Privacy Act information] (former Linde Ceramics Plant 

employee), Oak Ridge Associated Universities Team, Oak Ridge, Tennessee, March 15, 2010. 

[SRDB Ref ID: 80055] 

Murray, B., 2010c. “Linde Ceramics Plant (11/01/1947 through 12/31/1953),” documented 

communication with [Name redacted; Privacy Act information] (former Linde Ceramics Plant 

employee), Oak Ridge Associated Universities Team, Oak Ridge, Tennessee, March 15, 2010. 

[SRDB Ref ID: 80056] 

NIOSH 2011. An Exposure Matrix for Linde Ceramics Plant (Including Tonawanda 

Laboratory), ORAUT-TKBS-0025, Rev. 2. July 15, 2011. 

SC&A 2010. Linde Worker Interview Notes, Niagara Falls, New York May 19–21, 2010. May 

27, 2010. 

SC&A 2011a. Linde Work Group Meeting on Special Exposure Cohort (SEC) Petition 00154, 

Cincinnati, Ohio, August 15, 2011 – SC&A Action Items, October 11, 2011. 

SC&A 2011b. SC&A Memo: Follow-up to the October 11 Action Item Report, October 17, 

2011. 
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USACE (U.S. Army Corps of Engineers) 2002b. Dose Assessment for the Existing Surface 

Contamination Within the Linde Utility Tunnel Complex, FUSRAP Linde Remedial Action, 

Tonawanda, New York, Buffalo, New York; January 2002. [SRDB Ref ID: 49892]