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TO: Advisory Board on Radiation and Worker Health, Work Group on TBD-6000 

FROM: Robert Anigstein and John Mauro, SC&A 

SUBJECT: Review of NIOSH Response Paper: July 10, 2015 

DATE: September 11, 2015 

Review of “Responses to Sanford Cohen & Associates Review of Battelle-TBD-6000 

Appendix BB (General Steel Industries, Rev. 1),” Response Paper 

Background 

On June 23, 2014, David Allen (NIOSH/OCAS) issued a revision of Appendix BB to TBD-6000 

(Allen 2014). On December 10, 2014, SC&A issued a review of the revised appendix that 

included nine findings (Anigstein and Mauro 2014). Allen (2015a, 2015b) issued two papers 

responding to our findings. We subsequently replied to Allen’s response papers (Anigstein and 

Mauro 2015a, 2015b). In the process of preparing our replies, we found another issue, which 

became Finding 10. 

On February 5, 2015, the Work Group on TBD-6000 met by teleconference. Based on NIOSH 

responses to the SC&A findings, the work group members unanimously agreed that NIOSH had 

agreed to resolve the issues reflected in Findings 1, 3, 4, 7, 8, and 9, and that these findings can 

therefore be closed. On July 10, 2015, Allen (2015c) issued a Response Paper that was intended 

to address the four SC&A findings on Appendix BB, Rev. 1, that remained unresolved. The 

present memo is our reply to this Response Paper. The findings are discussed in the order in 

which they were presented by Allen—the titles are those used by Allen. 

Finding 2: Betatron Operator Beta Doses 

Skin Doses from Uranium 

Allen (2015c) began the discussion of doses to the skin of betatron operators from β rays emitted 

by uranium, using the year 1953 as an example, by citing our previous values for the years 1952– 

1957 (Anigstein and Mauro 2013, 2014). In reviewing the calculations that led to these skin 

doses, we observed that the dose rate from the side of the uranium metal (i.e., the curved surface 

of the cylindrical slab) had been calculated using a ß spectrum that comprised contributions from 

the short-lived progenies of natural uranium—234Th, 234mPa, 237Pa, and 231Th—as well as the 

photoactivation products 237U and 239U. This led to an overestimate, since the concentrations of 

these uranium isotopes would decrease exponentially over the 4-in thickness of the slab, and 

would further fall off at the edge. Consequently, we repeated the MCNPX simulations, using a β

spectrum comprising only the short-lived progenies of natural uranium in secular equilibrium 

with their parents. The results of the simulations of the dose rates at the surface of the uranium 

ingot were increased to account for the Putzier Effect—a 10–15-fold increase in the short-lived 

progenies. Although we had previously used a multiplier of 12.5—the midpoint of the 10–15 

range cited by Putzier (1982)—we increased the multiplier to 15 to be consistent with the 

NIOSH analysis, which produced higher, more claimant-favorable results. 

Review of NIOSH Response Paper: July 10, 2015 -1- SC&A – September 11, 2015 
 

 

We also reviewed the calculated β dose rate from the face of the uranium slice, which did include 

contributions from 237U and 239U. Since each uranium slice was assumed to be exposed four 

times to the betatron beam (to account for four overlapping shots, as reported by the former GSI 

betatron operators), the slice had been assumed to be irradiated continuously for 4 hours prior to 

being handled by the operators. To be consistent with the intermittent irradiations developed by 

Allen (2015b) for assessing the dose rates from irradiated steel, we averaged the concentrations 

of 237U and 239U over the four 15-min setup periods following each of the four 1-h radiographic 

exposures. We also took this opportunity to perform a new simulation of the rate of creation of 

these photoactivation products. Instead of a 6.5-in diameter, 5-mm-thick uranium disk that was 

used in the previous analysis to improve MCNPX scoring efficiency and to bias the 

concentrations of the photoactivation products by confining the metal to the center of the 

betatron beam, we performed a more realistic analysis, using an 18-in diameter uranium slice 

with a thickness of 1 mm. Because the high-energy photons that constitute the betatron beam 

would undergo <10% attenuation over this depth, the production of the photoactivation products 

would be relatively uniform in this layer, thus eliminating the need to extrapolate the surface 

concentration using an assumed exponential profile. The calculated, time-weighted-average 

specific activities of the photoactivation products at the front surface of the uranium slab are 

listed in Table 1. 

Table 1. Residual Nuclides in Uranium: Sources of External Exposure to Beta Radiation 

a 

Nuclide Half-life TWA sp. act.a 

(Bq/g) 

U-237 6.75d 3.3 

U-239 23.45m 1077.5 

Time-weighted average: specific activity averaged over exposure duration of betatron operator 

The simulation of skin doses from the front face of the uranium slice utilized a combined β

spectrum comprising the short-lived uranium progenies as well as the β spectra of 237U and 239U. 

The relative intensities of the β emissions from the latter isotopes were derived from the timeweighted-average specific activities listed in Table 1. The calculated skin doses from exposure 

to a uranium slice are presented in Table 2. 

Skin Doses from Irradiated Steel 

Allen (2015c) calculated the doses to the skin of the betatron operator from ß rays emitted from 

irradiated steel using the exposure scenario we had proposed earlier (Anigstein and Mauro 2014) 

but modified the activity concentrations of the photoactivation products by modeling intermittent 

exposures to the betatron beam. The “long” shots lasted 1-h, with 15-min intervals between 

exposures. The “short” shots consisted of 3-min exposures with 12 min in between. The shots 

were repeated until the activation products were in complete equilibrium, which essentially 

constituted an infinite number of shots. Except for accounting for the intervals between shots, 

the scenario is even less realistic than the original bounding scenario proposed by SC&A, in 

which the steel was irradiated continuously for 30 h. According to the NIOSH scenario, the 

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casting would never leave the betatron shooting room. Nevertheless, we accept this scenario as 

being bounding and claimant favorable. 

Table 2. Dose Rates to Skin from External Exposure to Beta Radiation from Uranium Slice 

Location Orientation Dose Rates to Skin

 (mrad/h) 

Front 81.1 

Contact Side 1,173.7 

Average 627.4 

Front 65.2 

Cloth Side 919.7 

Average 492.4 

Front 15.7 

1 ft Side 55.5 

Average 35.6 

Front 1.7 

1 m Side 8.2 

Average 5.0 

Average for bare skin 316.2 

Average for other skin 20.3 

We previously verified NIOSH’s mathematical derivation of the intermittent exposure algorithm 

(Anigstein and Mauro 2015a). We now independently applied the algorithm to the betatron 

operator’s skin dose from irradiated steel and found that Allen’s (2015c) values are either the 

same or higher by <1%, mostly due to different assumptions about the betatron beam intensity. 

These differences are trivial and claimant favorable. We consequently agree with Allen’s results 

for doses to the skin of the betatron operator from irradiated steel, which are based on an 

amalgam of SC&A’s original MCNPX calculations and derivations of activity concentrations, 

and NIOSH’s intermittent exposure algorithm. 

Skin Doses from Uranium and Steel 

Our earlier analyses of skin doses from uranium assumed a total of six uranium radiographs per 

shift. Since each radiograph took 75 min—a 15-min setup time and a 60-min exposure—six 

shots took 7.5 h. As pointed out by Allen (2015c), this is inconsistent with the steel radiography 

scenarios, which are assumed to consume the entire 8 h of the shift. We consequently increased 

the duration of the uranium scenarios to 8 h/shift. The final results of the updated skin dose 

assessment are listed in Table 3. 

Comparing these doses to Allen (2015c, Table 1), we note that the SC&A doses are lower, 

primarily due to our revised calculations of doses from uranium: the annual doses to the hands 

and forearms are 7%–18% lower, while the doses to the skin on the rest of the body are 1%–12% 

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lower. Although Allen’s results are claimant favorable, NIOSH may wish to adopt the more 

realistic values listed in Table 3. 

Table 3. Annual Doses to Skin of Betatron Operators from Beta Radiation (rads) 

Year Annual number of shifts Hands and forearms Other skin 

Uranium Steel Uranium Steel Total Uranium Steel Total 

1952a

–1957 54.7 351.6 27.67 1.53 29.20 1.77 1.05 2.82 

1958 45.8 360.4 23.19 1.57 24.76 1.49 1.07 2.56 

1959-1960 42.2 364.1 21.34 1.59 22.93 1.37 1.08 2.45 

1961 48.4 357.8 24.50 1.56 26.06 1.57 1.07 2.64 

1962 35.2 371.1 17.79 1.62 19.40 1.14 1.10 2.25 

1963 9.6 396.7 4.84 1.73 6.57 0.31 1.18 1.49 

1964 3.5 402.7 1.78 1.75 3.53 0.11 1.20 1.31 

1965 2.6 403.7 1.30 1.76 3.05 0.08 1.20 1.29 

1966b 0.8 202.3 0.41 0.88 1.29 0.03 0.60 0.63 

a

 Doses for 1952 must be prorated to reflect start of covered operations: October 1, 1952 

b

 During contract period January 1–June 30 

Finding 10: Betatron Operator Gamma Dose 

Finding 10 (Anigstein and Mauro 2015a) stated: 

Allen (2014 Table 9) lists dose estimates for the skin of the hands and forearms of 

the betatron operator during 1952–1963 as 1,300 mrem/y. This value is based on 

the hypothetical 30-keV residual photon radiation from the betatron apparatus 

after shutdown and was calculated in terms of effective dose rates, which are 

incompatible with the dose conversion factors listed in OCAS-IG-001 (OCAS 

2007). 

In response to this finding, Allen (2015c) pointed out that Appendix BB, Rev. 1, uses the 

betatron operator photon exposure scenario only to calculate limiting doses to the skin of the 

hands and forearms, which appears to be the case. He accepted our proposed limiting value of 

204.5 mrad/week air kerma in the PA orientation (Anigstein and Mauro 2015a), which 

corresponds to an MDL of the film badge dosimeters of 10 mrem/week, accounting for the 

shielding of the film by the worker’s torso. Allen proposed to use this air kerma rate, together 

with the maximum air-kerma-to-skin-dose conversion factor for photons, Eγ <30 keV 

(0.654 rem/rad [OCAS 2007]) to calculate the dose to the skin on the back and sides. However, 

he assigned only one-half of this dose to the skin on the hands and forearms, since he assumed 

that the worker’s hands were at the side of the body only one-half of the time and in front of the 

body the rest of the time. He assigned an additional dose of one-half the MDL of the film 

badge—5 mrem/week or 0.25 rem/y—to account for the time the hands were in front of the 

body. The skin on the anterior portion of the body, other than the skin of the hands and 

forearms, would be assigned a dose of 0.5 rem/y. 
 

 

Although we agree that the worker would not always have his hands at his sides, we do not agree 

that his hands and forearms would have been completely shielded by his torso during one-half of 

the time he was working. That would only happen if his hands and forearms were held close 

together, which cannot be assumed to occur during one-half of his activities. For example, 

Figure 1, reproduced from SC&A (2008, Figure 19), shows a betatron operator (on the left in the 

photograph) positioning the betatron, holding his left hand and forearm above his shoulders and 

his right arm at the side of his body. Although some shielding of the hands and forearms by the 

torso may have occurred during some unknown portion of the setup period, in the absence of 

more specific information, we recommend that NIOSH assigns bounding doses to the skin of the 

hands and forearms of 6.687 rem/y (10.225 rad × 0.654 rem/rad = 6.687 rem). We agree with 

the assignment of 0.5 rem/y to the skin on the anterior portion of the body, other than the hands 

and forearms, since the dose to that skin would be approximately the same as the dose recorded 

by the film badge dosimeters. 

Finding 5: Adding Betatron Operator Dose to Radium Radiography Dose 

Finding 5 (Anigstein and Mauro 2015a) pointed out that radiographers during the Radium Era 

(1952–1962) utilized the betatron as well as 226Ra sources to perform radiography, and that 

workers should be assigned some fraction of the β and neutron doses calculated for betatron 

operators in addition to the photon doses from radiography utilizing radium sources. Since GSI 

reported that “a maximum of 30% of each shift is used for actual exposure [to sealed sources] 

[NRC 2009a, p. 12, italics added],” the radium exposures may have taken less than 30% of the 

time on some shifts, allowing the radiographers more time to work on the betatron. We 

originally recommended that NIOSH should make the bounding assumption that a radium 

radiographer spent 70% of each shift in the Old Betatron Building during 1952–1962. 

Allen (2015c) responded that radiography using radium would require 15 minutes setup time 

between shots, the same that was assumed for the “long” shots using the betatron. Assuming 10 

exposures per shift, this would add 150 min (2.5 h) to the exposure time. Since the exposures are 

assumed to take up 30% of each shift, or 2.4 h, this would leave only 3.1 h (8 − 2.4 − 2.5 = 3.1), 

or 38.75% of an 8-h shift, available for work in the betatron. 

We disagree with this assumption for several reasons. The most important evidence, and the 

only available evidence that has a direct bearing on this issue, is the interview with 

, a former radiographer—the only source of first-hand information on radium radiography 

at GSI—in which he reported that he spent 50%–60% of each shift during which he worked as a 

radiographer in the betatron building. His film dosimetry records—the only available records 

from GSI during the Radium Era—prorated to account for his part-time work as a radiographer, 

are consistent with the agreed-upon estimates of external exposures of a worker performing fulltime radiography during this era. Consequently, we recommend that the upper end of the 

reported range, 60%, be used as a plausible upper bound to the occupancy of the betatron 

building. 

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Figure 1. Betatron Radiography of the Axle of a Power Shovel Cast at GSI 

(Courtesy of ) 

There are no relevant data that would support the assumption of 15 min between shots. Mr. 

 reported taking 12–15 s to transport the radium source from the lead pig, which was kept 

inside the radiography room, and position it for the exposure. It would not have taken much 

longer to position and remove the films, which would have been also stored nearby. It was not 

necessary to develop each film prior to exposing the next one. According to the Atomic Energy 

Commission’s (AEC) “Compliance Inspection Report” (NRC 2009b), , the GSI 

 reported that the exposures ranged from 1 to 70 min. Assuming 2.4 h of 

exposure and 10 shots per shift, the average shot took 0.24 h ([8 × 0.3] ÷ 10 = 0.24) or ~14 min. 

The longer shots provided ample time to develop the previously exposed films, which could be 

processed in batches. Since a typical casting was larger than one x-ray film, it took several 

exposures to radiograph one casting. There was no need to transport the casting between shots— 

repeat shots could have been taken in quick succession: position the film, position the radium 

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source, wait for the exposure to finish. This procedure bears no relationship to betatron 

radiography, which involved using electrical controls to move and aim the betatron apparatus 

and retiring to the control room to set the controls for the next shot. GSI workers have reported 

that the castings radiographed with the betatron tended to be large and complex, requiring a 

significant setup time. The very reason that the betatron was installed at GSI was to radiograph 

hulls of Army tanks and other castings that were too large for the isotope sources (226Ra and later 

60Co). 

Allen (2015c) disagreed with our assumption that the radiographer working with radium should 

be assumed to have participated in all the betatron radiography of uranium during a given year. 

Our reason is the same as the reason for assuming that a single worker was involved in all the 

uranium radiography in the first place. Since GSI workers worked in shifts, one could argue that 

the same worker did not necessarily participate in all the uranium work. Nevertheless, since one 

worker could have been involved in all this work, it has been agreed that the GSI dose 

assessments would assume that one worker did, in fact, participate in all the uranium 

radiography. This assumption is equally valid if such a worker were absent from the betatron 

building working with radium for perhaps 40% of the time. This assumption is thus plausible, 

claimant favorable, and consistent with the rest of the agreed-upon dose assessment 

methodology. 

The triangular distributions of external photon doses during the Radium Era that have been 

adopted by the Work Group on TBD-6000, NIOSH, and SC&A are derived from the calculated 

exposures to 226Ra sources and the AEC exposure limits. Since these did not incorporate the 

exposures to the hypothetical residual radiation from the betatron, we agree with Allen’s (2015c) 

recommendation that photon doses to the skin from such radiation, discussed in Finding 10, 

should be added to the radium radiographer’s skin dose in proportion to the time he spent in the 

betatron building. 

Finding 6: Layout Man Beta Dose 

Perhaps the most complex of the remaining dose reconstruction issues for GSI workers is the 

assessment of doses to the skin of the layout man from irradiated steel. This is partly due to the 

variable nature of the work of the layout man and to the varied description of that work by 

former GSI workers. The most recent SC&A analysis (Anigstein and Mauro 2014) used a 

simplified scenario which assumed 30 h of continuous irradiation of the steel that ended 15 min 

prior to the exposure of the layout man. The layout man received a new casting every 75 min 

and worked on it continuously until the next casting arrived. Long and short shots were 

differentiated by the steel being irradiated at either 6 or 9 ft, respectively. The ratio of long:short 

shots was approximately 36:64, the same as the ratio of irradiation times devoted to the two 

types of shots. 

Allen (2015b) proposed a scenario based the layout man’s exposure to photon radiation from 

irradiated steel, first described by SC&A (2008, Section 2.1.4). He assumed that the layout man 

spent his entire shift marking up one casting, except for being interrupted to spend 15 min 

marking up a freshly irradiated casting. He assumed that such an activity occupied 10% of his 

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shift. In both the single-casting and interrupting-casting scenarios, he assumed that 90% of the 

time was devoted to castings that had been exposed to short shots and 10% to long shots. 

As we stated earlier: 

At that time [2008], our intent was to describe and calculate a set of scenarios, 

based on available information, to present examples of calculations of doses from 

irradiated steel. . . Since the exposures of the layout man to direct penetrating 

radiation from irradiated steel were trivial compared to direct exposure to the 

penumbra of the betatron x-ray beam and radiation scattered from the casting 

being radiographed in the New Betatron Building, we did not attempt to refine 

this calculation. . . Unlike the case for γ rays, the β radiation from irradiated steel 

made a potentially significant contribution to the dose to the skin of the layout 

man. (Anigstein and Mauro 2015a) 

Since NIOSH chose to adopt our 2008 photon exposure scenario to model the β dose to the 

layout man, we re-examined our earlier assumptions as to how they would affect the present 

analysis. In principle, we agree that Allen’s (2015b) approach is a reasonable alternative to 

calculating the β doses to the skin of the layout man. Although the description of a single casting 

being continuously shuttled back and forth between the betatron and the layout man is not 

realistic, it could be used in a bounding calculation. We agree with the application of Allen’s 

intermittent exposure algorithm to model the buildup and decay of photoactivation products in 

steel. However, we do not agree with one of the parameters used in Allen’s calculations. 

Allen (2015b) assumed that it took the layout man the same amount of time to mark up the 

defects from long and short shots. The reason we believe that the long shots took longer is that 

the steel was much thicker. If the same size film was used for both types of shots, the film from

long shots represented a greater mass, hence a greater likelihood of defects. This was confirmed 

by Don Piper, who participated in the February 5, 2015, work group meeting. As Allen 

correctly reported, Mr. Piper said that submarine missile tubes had fewer defects. However, 

Allen mistakenly described the tubes as being thick. According to a declaration filed by the late 

 (2006), a former GSI worker, the missile tubes were produced for Polaris 

submarines. When John Harrop, an SC&A Associate, who served as an engineering officer on 

Polaris submarines, was asked if the tubes were at the lower end of the range of 

5–18 in cited by Mr. Piper, CDR Harrop explained that the function of the tubes was to launch 

the missiles using compressed air.1

 The rocket propellant did not ignite until the missile was 

100 ft in the air; consequently, there was no need for a thick-walled tube. He said the missile 

tubes were definitely less than 5 in thick, which qualifies them as thin metal. Mr. Piper also said 

“the bigger the casting . . . had [sic] more defects.” 

This conclusion is further buttressed AFS (n/d): 

1

 CDR John K. Harrop, U.S. Navy (retired), private communication with Robert Anigstein, SC&A, Inc., September 10, 

2015. 

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Below are descriptions of defect types and their correct terminology. . . 

6. Upon x-ray, you observe a cavity in the middle of your casting. Defect: Axial 

Shrinkage—All metal shrinks as it solidifies. Axial (or centerline) shrinkage, 

most often plate-like in shape, occurs when the metal at the center of the casting 

takes longer to freeze than the metal surrounding it. The defect is partly a 

function of the section thickness designed into the casting. 

It is finally confirmed by our colleague William C. Thurber, an experienced metallurgist, who 

wrote: “I think, in general, the larger and more complex the casting the greater will be the 

probability for some of these . . . defects to occur” (Thurber 2015). 

It is difficult to quantify the relative time spent on short and long shots. The lowest ratio would 

be 1:1—no difference between the short and long shots, as assumed by Allen (2015c). The 

upper end of the range might be the relative duration of long:short shots, including setup time, 

which is 75:15 min, or 5:1, since that is the ratio of the production rate of the individual shots. A 

reasonable estimate would be the average of these two ratios, or 3:1. If we assume that there 

were n long shots during a given time period and 9n short shots, but that the long shots took 3 

times as long to mark up, then the fraction of time spend on the long shots would be 

 or 25%, the remaining 75% being spent on short shots. 

We compared the β skin doses to the layout man using the various proposed scenarios. First, we 

recalculated the doses from the scenario first described by Anigstein and Mauro (2014), applying 

the intermittent exposure algorithm. The resulting does are lower than from the continuous 

irradiation in our original calculation, but higher than those obtained by Allen (2015b). We then 

applied the scenarios described by Allen, but assumed that the layout man spent 25% of his time 

on long shots, the remainder on short shots. The results are listed in Table 4. 

Table 4. Annual Doses to Skin of Layout Man from Beta Rays Emitted by Irradiated Steel 

Skin on: Dose (rad/y) 

SC&A-1a SC&A-2b NIOSH-1c NIOSH-2d e New

Hands and 

forearms 1.89 0.278 0.807 0.264 0.405

Rest of body 1.14 0.178 0.463 0.147 0.224

a

 Scenario described by Anigstein and Mauro (2014) 

b

 SC&A-1, recalculated using intermittent exposure algorithm 

 Scenario proposed by Allen (2014) 

d

 Scenario proposed by Allen (2015b) 

e

 NIOSH-2 recalculated by SC&A, using betatron beam intensity based on MCNPX simulations and assuming 25% of 

time spent marking up long shots 

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c
 

 

 

We recommend that NIOSH adopt the “New” values, which are based on a plausible 

interpretation of the betatron operations at GSI and on metallurgical knowledge, and are claimant 

favorable. We note that these doses are significantly less than the β skin doses to the layout man 

listed in Appendix BB, Rev. 1 (Allen 2014). 

Conclusion 

We conclude that NIOSH has achieved a reasonable resolution of the issues involving Finding 6, 

with the only outstanding difference being the relative amount of time that the layout man spent 

marking up long vs. short shots.2

 We note that our recommended β dose to the skin on hands 

and forearms of the layout man represents about 4% of his total skin dose, while our value of the 

β dose to the skin on the rest of the body represents about 2%. Thus, this issue plays a relatively 

minor role in the overall reconstruction of doses to the skin from this exposure scenario. 

2

 As pointed out by (2015), Allen (2015c, p. 6) transposed the distances for long and short shots. This is an 

editorial error—the correct distances were used in the NIOSH analyses. 

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References 

Allen, D. 2014. “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals: 

Appendix BB – General Steel Industries,” Battelle-TBD-6000, Appendix BB, Revision No. 1. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r1.pdf 

Allen, D. 2015a. “Responses to Sanford Cohen & Associates Review of 

Battelle-TBD-6000 Appendix BB (General Steel Industries, Rev. 1),” Response Paper. 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsiappbbr1-010815.pdf 

Allen, D. 2015b. “General Steel Industries Layout man Beta Skin Dose,” Response Paper. 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsilaybeta-010815.pdf 

Allen, D. 2015c. “Discussion of Remaining Issues to Sanford Cohen & Associates Review of 

Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 1): Response Paper.” 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsiappbb-071015.pdf 

American Foundry Society (AFS). n/d. “Identifying Casting Defects.” 

http://www.afsinc.org/content.cfm?ItemNumber=6944 

Anigstein, R., and J. Mauro. 2013. “Review of Skin Dose Calculations for General Steel 

Industries.” Memo to Advisory Board on Radiation and Worker Health Work Group on TBD6000. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiskindose-120513.pdf 

Anigstein, R., and J. Mauro. 2014. “Review of ‘Site Profiles for Atomic Weapons Employers 

that Worked Uranium Metals Appendix BB – General Steel Industries,’ Revision 1.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiapbbr1-121014.pdf 

Anigstein, R., and J. Mauro. 2015a. “Review of ‘Responses to Sanford Cohen & Associates 

Review of Battelle-TBD-6000 Appendix BB (General Steel Industries, Rev. 1),’ Response 

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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.
 
 

 

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Review of NIOSH Response Paper: July 10, 2015 -12- SC&A – September 11, 2015 

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.