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

FROM: Robert Anigstein and John Mauro, SC&A 

SUBJECT: Response to NIOSH Report: “GSI Dose Estimation Comparison” 

DATE: February 12, 2013 

SC&A Response to NIOSH Report: “GSI Dose Estimation Comparison” 

On February 4, 2013, Dave Allen (2013) transmitted a report comparing NIOSH and SC&A dose 

estimates for General Steel Industries (GSI). The same day, Paul Ziemer (2013), Chairman of 

the ABRWH Work Group on TBD-6000, sent an e-mail message asking if SC&A will be able to 

provide responses to this and another document in time for the February 21 meeting. This memo 

is our response to Allen’s report. The following discussion is keyed to Allen (2013) and follows 

the same sequence as Allen. Allen’s intent was to present a historical account of the 

development of the dose estimates—we will bring the SC&A dose estimates up to date while 

reviewing Allen’s presentation, thus deviating somewhat from Allen’s framework. 

1 Exposures During “Radium Era”: 1953–May 21, 1962 

In a table on p. 1, Allen (2013) lists estimated exposures of radiographers during the “Radium 

Era” (i.e., 1953–May 21, 1962 [date when GSI procured 60Co radiography sources to replace

226Ra]). The table compares the NIOSH results to the SC&A 226Ra exposure estimate that we 

derived from first principles. However, this was but one of three exposure estimates that we 

developed for radiographers during the Radium Era, which are listed below: 

1. Time and motion study of a radiographer handling the 226Ra sources and staying in the 

radiographer’s office inside the concrete block radiographic facility in the No. 6 

Building during radiographic exposures, which yielded an exposure rate of 9.69/y 

(listed in Allen’s table); 

2. Extrapolation of radiation exposure records for —who performed 

radiography part-time on weekends—to a full-time radiographer. Mr. received 

a dose of 9.1 rem during 18 calendar quarters. An estimated range of work shifts that 

he spent performing radiography over the course of a year yielded a range of 9.1– 

20.5 rem/y to a full-time radiographer (a rounded range is cited in a footnote to Allen’s 

table). 

3. The statement on the AEC license application that the applicable AEC dose limits for 

each time period were never exceeded (NRC 2009a, p. 26), which implies that the dose 

rates could have been as high as 15 rem/y in 1953–1954, and 12 rem/y in 1955–1962 

(only the latter value is cited in Allen’s footnote). 

Allen (2013) next compared SC&A and NIOSH estimates of exposures to sources used by St. 

Louis Testing Laboratories (SLTL) on the GSI site. The SC&A value was presented by 

Anigstein (2011a), who assigned an annual exposure of 2.669 R to a GSI worker remaining at 

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the boundary of the exclusion zone set up by SLTL. An additional exposure of 133 mR was 

assigned, based on an excursion into the exclusion zone while the radiographer was assumed to 

take breaks. However, we later learned from a former administrator of SLTL, that the 

source was retracted into its shield whenever the radiographer left the area (Anigstein 2011b). 

Therefore, the limiting exposure should be 2.669 R/y.1 At the same time, we learned that the 

SLTL activities at GSI did not begin until 1963, past the end of the Radium Era. Consequently, 

these exposures, although presented during an earlier phase of our studies, should not be 

included in exposure assessments during this period. Later in his report, Allen took note of this 

last observation. 

By the same token, the exposures of the layout man resulted from the operation of the New 

Betatron, which was not installed until late 1963, and should likewise not be included in the 

Radium Era assessments. This is also noted in a later part of Allen’s report. 

Allen (2013) next presented a table entitled “Others – Radium Era.” The table correctly cites the 

SC&A assessment of exposures outside the radiographic facility in No. 6 Building; however, we 

disagree with Allen’s derivation of an annual exposure from 226Ra radiography outside the 

facility that he ascribed to SC&A. That value is based on all of the 226Ra radiography being 

performed in an open area, which we do not believe was the case. The same comment on the 

previous table with respect to the SLTL sources applies here. Finally, we note that the table 

includes the betatron operator and the layout man, who are also listed in the previous table. 

2 Exposures Following the Radium Era 

Allen (2013) designated the period from the end of the Radium Era until the end of AEC 

operations as the “Cobalt Era.” This era needs to be subdivided, since it comprises three distinct 

periods—pre-SLTL operations, SLTL operations prior to the New Betatron, and New Betatron 

operations—each of which experienced significantly different limiting exposures. Allen lists 

exposures from the GSI-owned 60Co sources—we agreed with the exposures calculated on the 

basis of the survey of the radiographic facility performed by the Nuclear Consultants Corp., but 

disagreed with the exposures from performing 60Co radiography in open areas, since this was an 

infrequent scenario that should not be used to calculate annual exposures. 

2.1 Period Preceding SLTL Operations: May 22—December 31, 1962 

During the period after the Radium Era but prior to SLTL operations—May 22 to December 31, 

1962—SC&A recommended that the limiting exposure be that of the betatron operator—1.35 

R/y—as listed by Allen in each of his four tables. 

1

 Allen (2013) erroneously ascribed a rate of 2.771 R/y to SC&A—in fact, Anigstein (2011a) cited this value (in units 

of “mrem”) but ascribed it to Allen (2011). In the subsequent discussion, whenever a time period encompasses a fraction 

of a calendar year, the recommended annual exposures should be prorated to the actual period of exposure. 

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2.2 Exposures from SLTL Sources: January 1–September 30, 1963 

The highest exposures during the period January 1–September 30, 1963, were from the highactivity 60Co and 192Ir sources by SLTL to perform radiography at GSI. As discussed in 

section 1, above, the limiting exposure in this scenario should be 2.669 R/y. As stated earlier, 

the SLTL work did not begin until 1963. Since we do not know the exact date, the claimantfavorable assumption is that it began on January 1, this limiting exposure rate should be assigned 

to all GSI workers during the period January 1–September 30, 1963. 

2.3 Exposures from New Betatron: October 1, 1963–June 30, 1966 

The next period for which doses or exposures need to be assigned is from the installation of the 

New Betatron in late 1963 until the end of the covered period. The September 1963 edition of 

GSI General Steel Industries Magazine shows a photograph of the New Betatron Building under 

construction (SC&A 2008). Presumably, this issue was prepared in August or later. It is 

unlikely that the New Betatron was put in service before October 1, 1963, which would be a 

claimant-favorable date for the start of operations. Further indirect evidence for this starting date 

is the summary record of external exposure of for 1963 (Attachment 1). During 

the first 3 calendar quarters, his quarterly doses ranged from 0–15 mrem. Since he performed 

radiography only on a part-time, weekend basis, it was likely that he did little radiography during 

this period. However, in the 4th quarter, which began on October 1, the dose jumped to 

100 mrem, which suggests a marked increase in his radiographic activities. 

Further information on radiographic activities in the 4th quarter can be inferred from the film 

badge dosimetry data that NIOSH obtained from Landauer, the vendor who supplied and 

processed the film badges. The first weekly report included in these records, which is for the 

week starting Monday, January 6, 1964, lists doses to Mr. and to 17 other GSI workers. 

The report states that there were seven reports to date for each of these workers, implying that 

they had been issued six film badges prior to the ones listed in that report. We thus infer that the 

Landauer dosimetry program began during the week of November 25, 1963. Since Mr. ’ 

cumulative dose is left blank in the report, we can infer that each of these six previous badge 

reports had readings below the MDL, which was 10 mrem for the Landauer badges. Thus, to 

accumulate 100 mrem during the 4th quarter, would have to have had at least one film 

badge prior to the Landauer dosimetry program. This increase in his work schedule would 

indicate an increase in radiographic operations at GSI, which, according to the accounts of 

former workers, occurred when the New Betatron was put into service. 

From the assumed date of installation of the New Betatron until the end of the covered period— 

October 1, 1963–June 30, 1966—the limiting exposure rate should be 9.20 R/y. We calculated 

this rate for the layout man working in No. 10 Building, just outside the New Betatron Building 

(Anigstein and Olsher 2012). This value was cited by Allen (2013), first under “Radiographers – 

Cobalt Era,” then again under “Others – Cobalt Era.” The following tables summarize the 

differences between the NIOSH and SC&A estimates of limiting exposures connected with 

betatron operations. 

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c 

Table 1. Annual Doses to Betatron Operators 

Exposure Neutron dose Beta dose to skin (rads) 

Year (R) (rem) Hands and forearms Other skin 

SC&Aa DCAS SC&A DCAS SC&A DCAS SC&A DCAS 

1953-1957 1.35 0.734 0.48 0.050 33.4 25.9 6.27 2.27 

1958 1.35 0.734 0.48 0.050 32.1 25.9 6.22 2.27 

1959-1960 1.35 0.734 0.48 0.050 30.9 25.9 6.18 2.27 

1961 1.35 0.763 0.48 0.056 34.2 29.5 6.30 2.47 

1962 1.35 0.702 0.48 0.043 27.2 21.8 6.04 2.04 

1963 1.35 0.586 0.47 0.019 13.9 7.0 5.56 1.23 

1964 1.35 0.558 0.46 0.013 10.7 3.5 5.45 1.03 

1965 1.35 0.554 0.46 0.012 10.2 3.0 5.43 1.00 

1966b

 0.68 0.275 0.23 0.006 4.8 2.4c 2.71 0.97c 

Source: Anigstein and Mauro (2012) 

Note: SC&A values from Anigstein and Olsher (2012)
 

a
 Maximum exposure, assuming hypothetical 30-keV residual radiation from betatron behind operator’s back 

b During contract period: January 1–June 30 

As listed by Allen (2012)—should be prorated for 6-months of exposure in 1966 for consistency with exposure to 

photons and doses from neutrons 

Table 2. Annual Doses to Layout Men 

Exposure Neutron dose Beta dose to skin (rads) 

(R) (rem) Hands and forearms Other skin 

SC&A DCAS SC&A DCAS SC&A DCAS SC&A DCAS 

9.20 4.483 0.46 0.148 4.20 1.02 2.45 0.54 

Source: Anigstein and Mauro (2012) 

Note: SC&A values from Anigstein and Olsher (2012). See text for applicable periods. 

We note that Allen (2013) agreed to accept the SC&A estimates of doses to the skin. However, 

there is disagreement on photon and neutron doses. 

3 Areas of Agreement 

NIOSH and SC&A agree that the layout man represents the bounding scenario during the 

operation of the New Betatron (not during the entire “Cobalt Era,” as stated by Allen, 2013). As 

Allen points out, both groups agree that radium radiography constitutes the bounding scenario to 

radiographers during the Radium Era. 

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4 Unresolved Issues 

4.1 Layout Man 

As shown in Table 2, the SC&A estimate of the exposure of the layout man is more than twice 

the NIOSH estimate, while our estimate of the neutron dose is more than three times that of 

NIOSH. Allen (2013) disagrees with our calculations, claiming that our betatron shot scenario 

would have led to exposures in the control room that would exceed the film badge dosimetry 

records of the betatron operators. That conclusion is inconsistent with our analysis and with 

observations regarding film badge dosimetry for the reasons discussed below. 

[Allen (2013) fails] to account for the unnumbered control badge (not Badge No. 

001: Betatron Ctl) that was included with each batch of film badges sent to GSI by 

Landauer. As an integral part of any personal dosimetry program, the control badge 

is stored in the same location as the film badges of off-duty workers. It is returned to 

Landauer along with each batch of film badge dosimeters, where all the films are 

developed in a single batch and read with an optical densitometer. The control badge 

determines the background—in the terminology of an analytical laboratory, it 

constitutes a blank. According to Joseph Zlotnicki, CHP (former Landauer official, 

currently a member of the SC&A staff), “The assigned dose is determined by 

subtracting two numbers that are derived from the density on the user film and the 

density on the background or ‘blank.’ . . . Thus, any doses in the film badge 

dosimetry report represent the doses received by the worker while wearing the 

badge, not while it was stored in the rack.” (Anigstein and Olsher 2012) 

Therefore, Allen’s (2013) assumption that the film badge dosimetry reports include the exposure 

of the film badge while it was stored in the rack is incorrect. To the extent that the control badge 

might have been exposed to stray betatron radiation while the operator was wearing his badge, 

the dosimetry records might actually understate the doses to the workers. 

Our calculation of the exposure of the layout man comprises 22.11 mR per 8-h shift from 

betatron radiation and 0.53 mR from the activated steel. This yields an annual exposure of 

8.98 R from stray radiation from the betatron and an additional 0.22 R from activated steel. With 

the same shot geometry, we calculated an exposure rate of 0.339 mR/h at the operator’s desk in 

the control room. This results in an annual exposure of the betatron operator of 0.46 R, assuming 

he sat at the desk in the control room during the entire part of his shift that the betatron was in 

operation. Thus, his weekly exposure, averaged over 50 weeks, would be 9.2 mR, less than the 

MDL of the film badge. In reality, especially during the “long shots,” he may have left the 

control room through a back door. Such a scenario is plausible if we note that the operator was a 

member of the betatron team that was also responsible for processing the exposed films, and that 

the room directly behind the control room is marked “Processing Area” on the floor plan in 

Figure 1. This is consistent with the account of the late a GSI betatron operator, 

who said the exposed films were processed in the betatron building. Thus, the operator may 

have spent part of the time during betatron exposures away from the control room. 

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Figure 1. Drawing of New Betatron Building Showing Desk in Control Room (NRC 2009b) 

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We therefore believe that our estimated exposure of the layout man of 9.2 R/y is a realistic and 

claimant-favorable bounding value. This value was presented to the Advisory Board at the 

June 20, 2012, meeting in Santa Fe, New Mexico. 

4.2 Radium Radiography 

Allen (2013) correctly summarizes the SC&A exposure analysis of the radiographer using 226Ra 

sources described in paragraph 1 of section 1 of this memo. We would rephrase his reference to 

our use of “worst case” parameters: we would characterize the parameters as being claimant 

favorable yet realistic, the regulatory requirement for assumptions used in dose reconstructions. 

However, our exposure analysis based on time and distance, as well as the one based on 

extrapolating the doses of a part-time radiographer to one occupied full time with such work, 

serve only to buttress our recommendation that the bounding exposures should be equal to the 

AEC limits. These limits were 15 rem/y prior to 1955 (which Allen failed to mention) and 12 

rem/y in 1955 and subsequent years—up to the end of the Radium Era. We disagree with 

Allen’s assertion that “Based on a statement GSI made to the AEC that no one had exceeded the 

annual limit and the average was below 25% of that limit, the maximum dose can be established 

as falling between 3 R/yr and 12 R/yr.” We interpret GSI’s statement that no one exceeded the 

annual limit to imply that someone’s dose might have been at the limit. Since there is no way of 

knowing who that person was, the AEC limit represents the bounding value. The average dose is 

immaterial—the decision to compensate a claimant must be based on the real individual, not an 

imaginary statistical average individual. 

We further disagree with NIOSH’s adopting our calculated exposures of workers outside the 

radiography room as a basis for dose reconstructions. Anigstein (2011b) calculated doses 

outside the steel door to the radiography room to check limiting doses to nonradiographers 

calculated by Allen (2011). It was not our intention to endorse the assignment of different doses 

to different classes of GSI workers, although we admit that citing that calculation in that report 

may have implied as much. From the time of our earliest review of the GSI site profile (SC&A 

2008), we have questioned the division of GSI workers into two categories by NIOSH. We 

believe that the limiting exposures of 15 rem/y in 1953–1954, and 12 rem/y in 1955–1962 should 

be assigned to all GSI workers. This is the SC&A position that was presented to the Advisory 

Board on June 20, 2012 and reiterated in response to questions from board members at its 

meeting in Knoxville, Tennessee, on December 11, 2012. This position is confirmed in the 

following excerpt from Issue 11 of the Appendix BB issues matrix: 

[NIOSH] 1/13/12: Allen [(2012)] stated that, in assessing doses from betatron 

operations, dose reconstructors will choose the most favorable exposure scenario 

(i.e., betatron operator or layout man) in each case. 

SC&A Response (7/28/12): We agree that the most favorable exposure scenario 

should be applied in all dose reconstructions. The same procedure should be 

extended to reconstructing the doses from external exposure to sealed sources. If 

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such instructions are included in the revised Appendix BB, we will recommend that 

this issue be closed. [Italics added] 

Since these are the only exposures for which there is a factual basis, it is SC&A’s position that 

doses derived from these exposures should be assigned to all workers, not just known or 

presumed radiographers. This was the basis on which we supported NIOSH’s assertion that they 

can reconstruct doses to all workers during this period. 

Otherwise, NIOSH would need to track each worker’s job assignment and activities. For 

instance, was he the one who was taking measurements inside a tank hull while it was being 

radiographed with a betatron, as recounted by the late ? Was he the draftsman 

(not likely to be considered a radiographer by dose reconstructors) who was in the betatron 

shooting room during a radiographic exposure? Such incidents would most likely be bounded by 

the 12–15 R/y limiting exposures, but not necessarily by exposures from other scenarios. 

Likewise, how can NIOSH assign any doses to workers whose job assignments placed them in 

locations that were not in the proximity of the radium sources? Since the New Betatron Building 

was not erected until after the Radium Era, the scenario in which workers in No. 10 Building 

were exposed to stray betatron radiation is not applicable. Since not many workers would have 

reason to be in or in the proximity of the Old Betatron Building, which was about 250 ft from the 

nearest other building, stray betatron radiation from the old betatron is likewise not a basis for 

assigning doses to such workers. 

Discussions among Advisory Board members during the Knoxville meeting indicated that at 

least some believed that the limiting doses would be assigned to all workers during the Radium 

Era, not just to the small number of known radiographers. Furthermore, using different exposure 

scenarios in dose reconstructions of different workers is inconsistent with the policy enunciated 

by Allen (2012), who stated, 

Betatron operator dose is intended to apply to anyone working in the betatron 

building. Because little information is available for the location of most workers, 

these doses will apply to all workers at GSI. For the same reason, the layout worker 

dose is intended to apply to all workers. . . . Dose reconstructors will choose the 

most favorable set of doses for the given case. [Italics added] 

There is no reason why workers employed during the Radium Era should be treated differently 

from those employed during the period when the New Betatron was in operation. 

4.3 Exposure to SLTL Sources 

It is our position that an exposure of 2.67 R/y from SLTL radiography should be assigned to all 

GSI workers from January 1 to September 30, 1963, whereas NIOSH would assign this exposure 

only to GSI radiographers, assigning approximately one-half this value to other workers. Since 

there was no need for GSI radiographers to be involved in this operation, there is no reason they 

would have a higher exposure than other workers. GSI employees that were most likely to 

remain in the vicinity of these operations would have been those involved in the production and 

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testing of the castings—supervisors, metallurgists, layout men, etc.—and perhaps chippers, 

grinders, and welders who repaired any defects uncovered by the radiographs. Since the 

identities and even the categories of these workers are unknown, all workers should be assigned 

this exposure. 

5 Summary and Conclusions 

NIOSH and SC&A agree on who are the maximally exposed individuals during each era. There 

is, however, substantial disagreement on the doses to be assigned to GSI workers. SC&A 

believes that all workers should be assigned the same doses in a given era. NIOSH is 

inconsistent in this respect, assigning lower doses to nonradiographers prior to New Betatron 

operations, but the maximum doses—either those modeled for the layout man or the betatron 

operator, whichever is the most claimant-favorable—during New Betatron operations. 

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References 

Allen, D. 2011. “Battelle-TBD-6000 Appendix BB General Steel Industries: Dose Estimates for 

Portable Radiography Sources.” http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsidpradsrc0811.pdf 

Allen, D. 2012. “Battelle-TBD-6000 Appendix BB General Steel Industries: Dose Estimates for 

Betatron Operations.” 

Allen, D. 2013. “GSI Dose Estimation Comparison.” 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsidec-0112.pdf 

Anigstein, R. 2011a. “Review of NIOSH Report on Portable Radiography Sources at GSIAugust 2011.” http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsi-portradsrc-091511.pdf 

Anigstein, R. 2011b. “Update on the Use of Sealed Radioactive Sources at General Steel 

Industries.” http://www.cdc.gov/niosh/ocas/pdfs/dps/gsidp102011.pdf 

Anigstein, R., and J. Mauro. 2012. “Review of ‘Addendum to Dose Estimates for Betatron 

Operations White Paper’.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-comts-nbtronadd-032512.pdf 

Anigstein, R., and R. H. Olsher. 2012. “Response to ‘Battelle-TBD-6000 Appendix BB General 

Steel Industries: Dose Estimates for Betatron Operations’.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scarespon2dcasgsi.pdf. 

Nuclear Regulatory Commission (U.S.) (NRC). 2009a. “General Steel Industries Byproduct 

Materials License for Cobalt-60 Sealed Source (Budd Company Model 41706) not to exceed 

1 curie, w/handwritten notes.” ADAMS acquisition number ML093451452. 

Nuclear Regulatory Commission (U.S.) (NRC). 2009b. “Letter to James Mason from L. A. 

Kieber Regarding an Area Radiation Survey That Was Made of the Radiographic Exposure 

Facility in Granite City, Illinois,” ADAMS acquisition number ML093412940. 

S. Cohen & Associates (SC&A). 2008. “Review of ‘Site Profiles for Atomic Weapons 

Employers That Worked Uranium and Thorium Metals - Appendix BB: General Steel 

Industries,’ Battelle-TBD-6000, Appendix BB, Rev. 0.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsisp-r1.pdf 

S. Cohen & Associates (SC&A). 2012. “Issue Resolution Matrix for SC&A Findings on 

Appendix BB to TBD-6000,” Second Update: July 28, 2012. 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-apxbbim-r2.pdf 

Ziemer, P. 2013. < @comcast.net> “FW: Products for TBD-6000 WG” February 4, 

2013, personal e-mail to Robert Anigstein, SC&A, Inc., CC: John Mauro, John Stiver, Ted Katz. 

Response to “GSI Dose Estimation Comparison” -10- SC&A –February 12, 2013
 

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Attachment 1 

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