Office of Compensation Analysis and Support 

Technical Basis Document: Basis for Development of an 

Exposure Matrix for Bethlehem Steel Corporation, Lackawanna, 

New York; Period of Operation: 1949-1952 

Document Number: 

OCAS-TKBS-0003 

Effective Date: 7/27/2006 

Revision No.: 00 

Controlled Copy No.: ________ 

Page 1 of 41 

Subject Experts: Sam Glover, Dave Allen 

Approval: Signature on File Date: 07/27/06 

James W. Neton, Associate Director for Science 

Supersedes: 

ORAUT-TKBS-0001-Rev 01 

TABLE OF CONTENTS 

Section Page 

TABLE OF CONTENTS..........................................................................................................................1
 

Record of Issue/Revisions ......................................................................................................................3
 

1.0 Introduction ....................................................................................................................................4
 

2.0 Site Description and Operational History .......................................................................................5
 

2.1 Background of rolling operations conducted by AEC 1948-1952 ........................................... 5
 

2.2 Bethlehem Steel Corporation .................................................................................................. 7
 

2.3 Simonds Saw and Steel Co. ................................................................................................. 12
 

3.0 Estimation of Internal Exposure ...................................................................................................14
 

3.1 Health and Safety Laboratory Air Monitoring Program ......................................................... 14
 

3.2 Parameters affecting intake estimates and uncertainty at Bethlehem Steel ......................... 16
 

3.2.1 Breathing Rate ..............................................................................................................16
 

3.2.2 Exposure Duration ........................................................................................................16
 

3.2.3 Exposure Location ........................................................................................................17
 

3.2.4 Absorption Type ............................................................................................................17
 

3.3 Inhalation Exposure Dosimetry at Lackawanna .................................................................... 17
 

3.3.1 Method of analysis ........................................................................................................17
 

3.3.2 Evaluation of inhalation exposure for the 1949-1950 time period .................................19
 

3.3.3 Determination of inhalation exposure for the early 1951 time period ............................20
 

3.3.4 Determination of Inhalation Exposure for the late 1951 thru 1952 time period .............22
 

3.3.5 Determination of intakes to cobble cutters (1949 thru 1952) ........................................23
 

3.4 Evaluation of ingestion dose ................................................................................................. 26
 

3.5 Evaluation inhalation and ingestion due residual contamination .......................................... 29
 

3.6 Summary of internal dose guidance for Bethlehem Steel ..................................................... 30
 

4.0 Estimation of External Exposure..................................................................................................33
 

4.1 Evaluation of external dose from uranium dust..................................................................... 33
 

4.2 Evaluation of external dose from direct contact with uranium billets .................................... 33
 

4.3 Evaluation of external dose from residual contamination ..................................................... 36
 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 2 of 41 

5.0 Occupational Medical Dose .........................................................................................................36
 

6.0 Occupational Environmental Dose...............................................................................................36
 

7.0 References ..................................................................................................................................37
 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 3 of 41 

RECORD OF ISSUE/REVISIONS 

ISSUE 

AUTHORIZATION 

DATE 

EFFECTIVE 

DATE 

REV. 

NO. DESCRIPTION 

Draft 12/17/2002 0-A New document to establish the 

technical basis for the 

development of a radiation 

exposure matrix for Bethlehem 

Steel Corporation. Initiated by 

Jeri L. Anderson. 

03/31/2003 03/31/2003 00 First approved issue of ORAUTTKBS-0001. 

06/29/2004 06/29/2004 01 Approved issue of Revision 01. 

7/27/2006 7/27/2006 00 Approved issue of Revision 0 of 

OCAS-TKBS-003. This 

supersedes rev. 1 of the 

previous ORAUTTBKS-0001. 
 

1.0 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 4 of 41 

INTRODUCTION 

Technical Basis Documents and Site Profile Documents are general working documents that provide 

guidance concerning the preparation of dose reconstructions at particular sites or categories of sites. 

They will be revised in the event additional relevant information is obtained about the affected site(s). 

These documents may be used to assist NIOSH and its contractors in the completion of the individual 

work required for each dose reconstruction. 

This technical basis document (TBD) specifically addresses exposures incurred by workers as a result 

of a contractual agreement between Bethlehem Steel in Lackawanna, NY (a designated atomic 

weapons employer (AWE) facility) and the U.S. Department of Energy or its predecessors. Dose 

reconstructors should use the information in this TBD to evaluate the DOE derived occupational 

radiation dose for workers at Bethlehem Steel. These doses include external and internal radiation 

sources as well as occupationally required diagnostic x-ray examinations. 

Employment at an AWE facility is categorized as either (1) during the contract period (i.e., when the 

AWE was processing or producing material that emitted radiation and was used in the production of 

an atomic weapon), or (2) during the residual contamination period (i.e., periods that NIOSH has 

determined there is the potential for significant residual contamination outside of the period in which 

weapons-related production occurred). For contract period employment, all occupationally-derived 

radiation exposures at the facility must be included in dose reconstructions. NIOSH does not consider 

the following exposures to be occupationally-derived: 

• radiation from naturally occurring radon present in conventional structures; and 

• radiation from diagnostic X-rays received in the treatment of work-related injuries. 

For residual contamination period employment, only the radiation exposures defined in 42 U.S.C. § 

7384n(c)(4) (i.e., radiation doses received from DOE/AEC-related work) must be included in dose 

reconstructions. Radiation dose received from DOE/AEC-related work includes: (1) radiation from 

radon consistent with NIOSH’s policies for including such radiation in the contract period; and, (2) 

medical screening X-rays, but not diagnostic X-rays for the treatment of work-related injuries. It 

should be noted that: (1) under subparagraph A of § 7384n(c)(4), radiation associated with the Naval 

Propulsion Program is specifically excluded from the employee’s radiation dose; and, (2) under 

subparagraph B of this section, radiation from a source not covered by subparagraph A that cannot be 

reliably distinguished from radiation that is covered by subparagraph A is considered part of the 

employee’s radiation dose. This site profile covers only exposures resulting from nuclear weaponsrelated work. Exposures resulting from non-weapons related work, if applicable, will be covered 

elsewhere. 

Many sources of information were evaluated and utilized in the preparation of this TBD. These 

include transcripts of worker outreach meetings, worker interviews and comments, multiple reviews by 

EEIOCPA Advisory Board’s contractor SC&A, and information gathered at various Department of 

Energy record repositories including, but not limited to, the Environmental Measurements Laboratory 

(EML) and Hanford. 

This document is divided into the 6 sections. These are: 1) Introduction; (2) Site description and 

operational history; (3) Estimation of Internal Exposure; (4) Estimation of External Exposure; (5) 

Occupational Medical Dose; and (6) Occupational Environmental dose. 
 

 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 5 of 41 

In this document the word “facility” is used as a general term for an area, building or group of buildings 

that served a specific purpose at a site. It does not necessarily connote an “atomic weapons 

employer facility” or a “Department of Energy facility” as defined in the Energy Employee 

Occupational Illness Compensation Program Act of 2000 (42 U.S.C. § 7384l (5) and (12)). 

2.0 SITE DESCRIPTION AND OPERATIONAL HISTORY 

2.1 Background of rolling operations conducted by AEC 1948-1952 

Bethlehem Steel Corporation was one of several steel mills that contributed to the production of 

uranium metal rods used by Hanford for the production of plutonium. The principle means of 

producing uranium rods During World War II was an extrusion process conducted at Hanford. Rolling 

of uranium metal rods was investigated at Joslyn Manufacturing and Supply Co. during and after the 

war effort to evaluate methods to improve product quality and reduce losses of product during the 

manufacturing process. Another development that promised improvements in the production of 

uranium metal rods was the successful rolling of lead dipped uranium billets by Joslyn in 1948, which, 

according to the early AEC reports, were far superior to the Hanford materials in terms of blistering. 

Hanford stopped extruding uranium rods in 1948. Rolled uranium rods manufactured offsite of 

Hanford were found to be a less expensive process and possessed metallurgical advantages over the 

extrusion process (DOE 1997). 

As of 1947, postwar production of uranium was transferred to the US Atomic Energy Commission 

(AEC) New York Operations Office (NYOO). Safety aspects of these operations fell under the Health 

and Safety Laboratory (HASL) for the stated reason that many of these facilities were small and 

lacked the resources for evaluating worker health (AEC 1949b). HASL (later to be renamed the 

Environmental Measurements Laboratory) had responsibility for these programs until 1954 with the 

implementation of parallel production centers in St. Louis and Cincinnati and reorganization of 

uranium production responsibilities to other offices of the AEC (AEC 1958, p 10). 

During the time frame of 1947 to 1954, the period in which the TBD is concerned, NYOO had broad 

responsibility for the procurement and processing of uranium for weapons production. These 

responsibilities included acquisition of raw ore materials from Africa and other sites; all aspects of its 

storage; processing of the raw ore; preparation of uranium oxide; conversion to green salt (UF4); 

preparation of uranium metal billets; and the rolling of the billets into rods. The uranium metal was 

delivered as billets to two mills (as of 1949), Simonds Saw and Steel Company, Lockport, New York 

and Vulcan Crucible Steel Company, Aliquippa, Pennsylvania who rolled the billets into rods which 

were shipped to Hanford (AEC 1949a, p3). Joslyn Manufacturing and Supply Co. continued to 

provide additional capacity during start-up of the rollings at Simonds as ~150 tons of uranium per 

month was needed by Hanford (AEC 1948c, p 128). It is known that other rolling mills also 

participated in rolling operations during this early time period. Simonds Saw and Steel Co. later 

became the principle manufacturer of rods as Vulcan was unable to roll the larger billets coming from 

Mallinckrodt. 

During the war, permissible levels for natural uranium dust in air were set at 500 μg/m3

 for insoluble 

uranium compounds and 150 μg/m3

 for soluble compounds. After the war, the University of 

Rochester lowered its recommendation for soluble uranium compounds to 50 μg/m3

 on the basis of 

chemical toxicity, which is equivalent to 70 disintegrations per minute per cubic meter (alpha activity of

234U and 238U). The University based this level primarily on animal studies. The Medical Division of 

the New York Operations Office felt that a “maximum permissible level” was really unknown and 

should be based on human data. Therefore, 50 μg/m3

 level was referred to as the “preferred level” 

(AEC 1949b). Many AEC contractors used the term Maximum Allowable (air) Concentration (MAC) 
 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 6 of 41 

interchangeably with “preferred level” and often reported air-sampling results as multiples of the MAC 

(NLO 1952b; AEC 1953). As of 1949, NYOO did not recommend the use of respirators (AEC 1949a). 

Several operations conducted as part of the uranium processing at Bethlehem Steel are important to 

have a conceptual understanding of their impact on exposure during the activities conducted at the 

Lackawanna Plant. These include: 

Furnace heating: In some cases uranium was preheated in the furnace and then further heat treated 

in a lead or salt bath. 

Lead bath heating: Similar in nature to the furnace heating, uranium rods and billets were immersed 

in a molten lead bath to heat them to the desired temperature for rolling. The lead also served to 

provide a partial coating for reduction of uranium dust during the operations. 

Salt bath heating: Similar in nature to the furnace heating, a molten salt bath was used to heat the 

uranium rods and billets prior to rolling. This salt also provided a protective covering which 

significantly reduced the uranium oxide formation and airborne contamination levels during rolling. 

Centerless grinding: The canning process required a precision ground uranium piece. HW-19066 

describes the process of centerless grinding using a No. 3 Cincinnati Centerless Grinder using initial 

(rough) pass removing 0.005”-0.010” with finishing passes removing 0.001”-0.002”. The basic 

principle was for the cutting pressure of the grinding wheel to keep the rod in contact with the rest 

blade and the regulating wheel. The rotation of the regulating wheel causes the rod to rotate at a 

constant peripheral speed and the inclination of the regulating wheel axis moves the work from the 

front to the rear of the machine. The operation of grinding uranium required the use of a constant flow 

of coolant.. 

Hand grinding: Some reports indicate that grinding of the rods was a component of the work 

performed by the Lackawanna facility. Other facilities indicated the need to perform both centerless 

grinding and hand grinding of materials. Hand grinding may have been used to remove surface 

imperfections prior to rolling as well as cleanup of the slugs after they were sheared into 4” and 8” 

pieces. Since the product sent to Hanford included both rods and slugs, hand grinding was 

considered as a potential exposure source and data at Joslyn was evaluated to compare the source 

term with the assigned intake levels. 

Medart straightening: Uranium rods and in some cases slugs were straightened. In some cases 

this was done prior to centerless grinding, in others simply to improve the product straightness prior to 

shipment to Hanford where final machining was undertaken. 

Billet: Large cylinder of uranium metal up to 5” in diameter and up to 2 feet in length weighing 

between 125 to 500 pounds. 

Rod: Uranium billets were rough rolled and then finished rolled into long, thin rods. The rods were 

often the final product shipped to Hanford. 

Slug: Uranium rods were cut into 4” and 8” pieces called slugs (sometimes at Hanford, sometimes at 

a facility offsite to Hanford) which were dipped and canned for use in the reactors. 
2.2 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 7 of 41 

Bethlehem Steel Corporation 

Bethlehem Steel Corporation was one of the largest steel manufacturers in US history, with an annual 

output of material after World War II that exceeded twice the output of the entire country of Germany 

at that time (Leary 1987). Bethlehem Steel acquired the Lackawanna facility in 1922. While 

Bethlehem Steel had widespread holdings in ship building and other interests, only the facilities 

located in Lackawanna, NY are the subject of this TBD. Diagrams of the site are available (Leary 

1987) to provide a reference to the scale of this 1300 acre complex which employed approximately 

20,000 workers during this time period. 

The U.S. Atomic Energy Commission (AEC) contracted with Bethlehem Steel Corporation (BSC) to 

develop improved rolling mill pass schedules using a continuous rolling mill. These rollings were tied 

strongly to the design of the Fernald facility which was to be based on a continuous rolling mill 

technology such as that used at BSC whose design was to be developed by Birdsboro corporation 

(Summary 1951). Many documents associated with the development of the uranium rolling program 

and its progress have been obtained by NIOSH and its contractors and may be referenced for 

additional detail including, but not limited to HW-13168, HAN-21441, HAN-30471, HAN-30686, HAN30987, HAN-31429, HW-14816, HW-20548, GEH-17116, HAN-20104, HW-24222, HW-20548, HW22474, HW-22878, and a series of unnumbered Bethlehem Steel memos obtained from Hanford 

which are contained in the NIOSH Site Research Database (SRDB). 

Programmatic goals associated with these rollings were (HW-24849): 

•	 To evaluate the continuous rolling mill as a source of uranium rods for the plutonium 

production program at Hanford and Savannah River; 

•	 Information gained during these rollings would be used for the design of the Fernald plant; 

•	 Evaluate technological improvements leading to reduced oxidation of uranium metal by the 

use of lead bath and salt bath heating (using a combination of lithium and potassium 

carbonate salts) would reduce losses during rolling; and, 

•	 Evaluate the metallurgical implications of heat treatments to improve quality during 

irradiations. 

Review of the historical records show that BSC conducted this work under the oversight of HASL, 

Hanford Works, and National Lead of Ohio (DOE 1985). Records indicate that BSC participated in 

both experimental and production runs. The purpose of this program included the following: 

•	 Finish rolling of bars rough rolled at Simonds Saw or Aliquippa Forge (Summary 1951); 

•	 Comparison of lead bath and salt bath heating on product and process quality; 

•	 Heat treating rods and billets rolled or to be rolled at other facilities which in some cases also 

included grinding as part of this preparation; and, 

•	 Production runs of uranium rods from rough rolled rods. 

The uranium billets were prepared by Mallinckrodt Chemical in St. Louis, Missouri, shipped to the 

rough rolling mill and then shipped to Lackawanna in freight cars. The freight cars, which were 

spotted at the BSC plant, served as storage for the uranium billets during the week (Range 1976; 
 

 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 8 of 41 

ORNL 1980; DOE 1985). The rolling experiments generally took place on weekends because the 

mills were in full use 5 days per week. The work only involved the 10-in. bar mill and associated billet 

preparation and handling equipment (LaMastra 1976; Range 1976; Thornton 1977; ORNL 1980; DOE 

1985). Review of Hanford documents also shows that some activities involved only the heat 

treatment of metal rods and billets in the salt bath to get the proper grain structure in the metal 

preferred for irradiation of the material at Hanford. These grain structures, known as the alpha, beta 

and gamma phases, describe the metallurgical properties of the material and are not associated with 

radioactivity in this context. 

According to some accounts, material accountability practices for the project included collection of 

scale, residue, fine debris, and cropped ends. Worker accounts (6-19-2006) reported the use of 

vacuum cleaners to assist in the cleanup in many areas. These materials were packaged, and 

returned to the AEC which had a documented scrap recovery program (LaMastra 1976; Range 1976; 

ORNL 1980; DOE 1985). Radiological surveys in 1976 and 1980 of the original facility and 

equipment, which were still in existence, identified no residual contamination above natural 

background levels (LaMastra 1976; ORNL 1980; DOE 1985). 

A number of documents provide conflicting information regarding the time period during which the 

rollings occurred. Some references indicate that all work occurred between 1949 and 1951 

(Summary 1951; LaMastra 1976; ORNL 1980). However, other reports indicate that eight additional 

rollings occurred in 1952 (Bowman et al. 1952; Hershman 1952; NLO 1952a; DOE 1985), although 

they were reported to be production rollings. A letter from a labor representative in October 1979 

asserted that six to eight rollings took place in 1955 although no verification of these dates has been 

found (Kosanovich 1979, 2004). The work was transferred to the Fernald Plant around September 

1952 as it began pilot and then full scale operations (NLO 1952a; LaMastra 1976; Range 1976). 

Information obtained from the rolling experiments at BSC was used in the design of a rolling mill at the 

National Lead Company plant in Fernald, Ohio, which began production in 1953 (LaMastra 1976; 

Range 1976). Table 1 lists the dates of rollings at BSC for which documentation has been found. 

Several documents report that AEC personnel were present during all rolling operations and several 

site visit reports have been obtained that document these visits. AEC personnel conducted air and 

surface radioactivity monitoring and checked personnel involved in the rolling for contamination during 

some of these rollings (LaMastra 1976; ORNL 1980; DOE 1985). Some reports indicate that no 

records are available of these monitoring activities (LaMastra 1976; Range 1976; ORNL 1980). As of 

1976, it was believed that if monitoring records ever existed, they were not retained (LaMastra 1976). 

Uranium metal accountability records apparently were destroyed (Range 1976). Review of AEC 

historical records, however, has produced several documents containing air sampling data from the 

Health and Safety Laboratory (HASL) and National Lead Company for the rollings shown in Table 1. 

These documents are supplemented with data collected at other facilities conducting similar work and 

worker accounts to provide the basis for the estimates that follow (SC&A 2005a, p 46). The 

application of Simonds Saw and Steel data to supplement the Bethlehem Steel data was reviewed 

and found to be an acceptable approach (SC&A 2005a). This approach is described in detail later in 

this document. Many documents were available form the Hanford archives because the work was 

associated with improvements to the irradiation of uranium fuel for plutonium production. 

While the operations involving the processing of uranium were limited to the 10” continuous rolling mill 

and associated handling facilities (Figures 1 and 2), the time lapse and complexity of the site make 

clear evaluation of exposure potential by job title difficult. The 10” continuous rolling mill and 

associated localized bar material handling facilities were completed in 1947 with monthly capacity 

measured in thousands of tons of steel per month. The process was also known to create 

widespread contamination within the mill area during the processing of the uranium. Therefore all 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 9 of 41 

workers at Bethlehem Steel in Lackawanna will be evaluated as having a potential for internal and 

external exposure as if they worked in the rolling mill during these operations. These evaluations are 

explained in the following sections. 

Figure 1: 10-inch bar mill at Lackawanna circa 1950 (Walker 2005) 
Figure 2: Lackawanna continuous stand rolling mill diagram as provided by a retired employee and drafted by SC
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 11 of 

Table 1: Documented rollings at Bethlehem Steel Corporation, Lackawanna, New York 

Date Day 

Type or 

designation 

Billets 

rolled Bath type 

Air 

Sample 

Data 

Refere

April 26-27, 1951 Thurs., Fri. Experimental 

#1 

26 Lead/salt Y Summary 

AEC 19

Sheets 6191, 

July 29, 1951 Sunday Experimental 

#2 

24 Lead/salt Y Summary 

Sample sheets 642

August 27, 1951 Sunday Experimental 

#3 

32 Lead/salt Summary 

HW-22

September 30, 

1951 

Sunday Experimental 

#4 

43 Salt Y Sample she

HW 23

October 28, 1951 Sunday Lackawanna 

#5 

93 Salt Y HW-22

Sample sheets 

January 26-27, 

1952 

Saturday, 

Sunday 

Production 25 plus 4 

tons heat 

treated only 

Salt Y AEC 19

HW-23

HW-24849, H

Sample sheets 654

February 16, 1952 Saturday Production 120 

30 tons 

Salt HW 23

March 15, 1952 Saturday Production 218 Salt Y NLO 19

Sample sheets 

April 12, 1952 Saturday Production 222 Salt NLO 19

August 17, 1952 Sunday Production 157 Salt Bowman 

August 31, 1952 Sunday Production 219 Salt Bowman 

September 14, 

1952 

Sunday Production 303 Salt Y Schnei

Sample sheet IH3

IH36 

September 22, 

1952 

Monday Production 302 Salt Schnei

October 19, 1952 Sunday Production 60 tons Salt Hershman 

1951: Six rolling days, plus assume one January, February, March, May, June, November, Decerollings). There was no Experiment #6 at Lackawanna (cancelled after rough rolling). 1952: 10 rolling days, plus assume one for May, June, July, November, December (15 rollings)
 

2.3 

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Simonds Saw and Steel Co. 

Several companies participated in the uranium rolling production for Hanford as has been previously 

discussed. The data that exist for these companies may be useful for supplementing the dose 

reconstruction effort at Bethlehem Steel Corporation provided that the processes are similar and can 

be determined to represent bounding conditions for the assessment of dose. 

Simonds Saw and Steel began rolling uranium in February of 1948 and continued as a principal 

source of rolled uranium for several years as previously discussed in this TBD. An AEC visit to 

Simonds in October of 1948 collected a variety of air and urine samples from the workers prior to the 

implementation of any air control measures (AEC 1948a). The next visit (Dec 1, 1948), improvements 

included exhaust ventilation provided over each of the operating rolls, the central vacuum cleaner was 

to be discharged outside, and temporary enclosure was provided over the descaling device (AEC 

1948b). Simonds Saw and Steel data from the October 1948 (before ventilation changes) will be the 

only Simonds Saw and Steel data used to support the internal dose estimates for the Lackawanna 

facility. 

While a complete description of the Simonds Saw and Steel is the subject of a different TBD (ORAUTTBKS-0032), some discussion is warranted on why this represents a bounding condition. A visit by 

Hanford personnel to Simonds discusses the operation and layout of the facility in early 1949 (HW19066) after several health control measures had been implemented (HW-19066). The rolling mill 

facility was described in one of several large buildings constructed of steel and masonry with a dirt 

floor. The uranium rolling equipment was located at one end of the building on a steel plate platform 

about 2 feet above the floor. The report indicated that the equipment was previously used for rolling 

steel and was still occasionally used for that purpose. This differs markedly from the Bethlehem Steel 

situation where uranium rollings were conducted on a very limited scale amidst high volume steel 

rollings. The report provides detailed information on the processing of the uranium rods at Simonds 

and also verifies that the air sample collection data were obtained using the same methods as 

discussed by other HASL documents. Diagrams are available for the Simonds Saw and Steel facility 

in several AEC reports and are included in the Simonds Saw and Steel Technical Basis Document. 

An AEC New York Operations Office (NYOO) report of a visit to Simonds Saw and Steel Company in 

Lockport, New York, on October 27, 1948, describes occupational radioactive dust exposures 

between 8 and 190 times the MAC depending on the type of job performed (AEC 1948a). This report 

indicates a 10-hour workday. In addition, it states “...where the maximum amount of alpha was 

present, a concentration of more than 1000 times the preferred level, the beta activity of the same 

sample was less than 0.5 times the tolerance (40,000 beta disintegrations per cubic meter). For this 

reason it is felt that the exposure to beta emitting dust is of negligible consequence as compared to 

any concomitant alpha dust exposure” (AEC 1948a). This survey occurred during a production rolling. 

During experimental rollings, generally less than 50 billets were rolled. From the job analysis sheets, 

apparently 180 billets were rolled October 27, 1948 at Simonds. 

Simonds Saw and Steel represents a bounding case for Bethlehem Steel exposures to uranium 

based on the following: 

Size: Simonds was a smaller facility and the processes were close to one another. Air concentration 

data for general area samples would tend to be higher because of the cross-talk between locations. 

Also, contamination would have remained more localized and thus more available for resuspension 

and thus air concentration data from the much larger rollings quantity would have been greater. 
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•	 Material: Simonds Saw and Steel was processing bare metal uranium rods for the October 

27, 1948 and preceding rollings. This type of material is more susceptible to oxidation than 

lead bath heated or salt bath heated uranium and thus increases the uranium oxide dust 

production. All rollings which are known to have occurred at the Lackawanna plant were lead 

or salt bath heated. 

•	 Ventilation: Ventilation at Simonds Saw and Steel consisted of natural convection during the 

October 27, 1948 rolling except for a single small hood at the quench station (a process not 

used at the Lackawanna rolling mill) which was unable to contain significant loss of material 

from that operation (HW-19066). This localized source of ventilation would have had no 

impact on the 95% concentration data used for these estimates. Similar levels of 

contamination were observed at Joslyn Manufacturing and Supply Company during the rolling 

and machining of bare uranium rods (AEC 1952e). Furthermore, the general area samples 

collected at Simonds Saw and Steel were much higher than those at the Lackawanna facility, 

indicating that the ventilation at Simonds was not an effective mechanism for contamination 

reduction. 

•	 Process: Simonds Saw and Steel was more labor intensive and hands on than the process 

conducted at the Lackawanna plant. Some of the highest air concentration levels at Simonds 

were observed during operations involving the dragging of the rolled rods across the 

contaminated floor. The facilities at Lackawanna were state of the art (the 10” continuous mill 

was completed in 1947 (Leary 1985)) and were designed to reduce the amount of labor 

involved in the production process. 

•	 Air sampling: Air sampling data was collected and analyzed by the same organization (HASL) 

using the same methods as discussed in Section 3.1. Breathing zone samples collected at 

Simonds Saw and Steel on October 27, 1948 were taken during the worst part of the process 

for short durations (~1 minute) which provides an upper bound to the overall breathing zone 

estimates. 

•	 Rolling volume: Simonds Saw and Steel replaced Joslyn as the rolling mill of choice for the 

AEC program. Any rollings conducted at the Lackawanna rolling mill would have been small 

and experimental in nature in the 1949-1950 time frame. While rolling volume does not 

impact the breathing zone estimates, the amount of residual activity will be affected by the 

total amount of material rolled. Rolling volume would play an important part in determining 

total rolling time. 

•	 Capacity: The amount of material run at the Lackawanna plant was a small fraction of their 

actual capacity. The full application of a 10 hour day at these levels is a significant 

overestimate. 

Finally, Merrill Eisenbud stated the following in the May-June 1951 HASL monthly report (AEC 

1951a): “Dust samples were taken at the Bethlehem Steel Plant to evaluate continuous rolling of 

uranium. The lead bath results were comparable to those obtained at Simonds Saw and Steel 

during periods when no ventilation was used. For a second test, one set of rods was rolled after 

heating in a mixed salt bath. The air samples for this set were significantly lower than those for 

the lead bath test”. 
 

 

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3.0 ESTIMATION OF INTERNAL EXPOSURE 

3.1 Health and Safety Laboratory Air Monitoring Program 

The production of rods by US industrial facilities had been intended to be of short duration to support 

the war effort, however, it became apparent to NYOO in 1949 that these resources would be used for 

an indefinite period (AEC 1949b, p5). Concerns mounted over known exposures to radioactive 

materials which exceeded even war year standards promulgated by the University of Rochester. 

These levels were much higher than standards being proposed and which were eventually adopted. 

HASL implemented a program of air sampling at many of these facilities to evaluate and reduce the 

exposures to workers. These programs and mitigating ventilation plans for these facilities were 

discussed in the May 1948 NYOO monthly report (AEC 1948c, p140). 

From the early days of operation, the Health and Safety Laboratory (HASL) of the Atomic Energy 

Commission (AEC) relied on time weighted average exposure measurements to assess inhalation 

hazards in the workplace. A brief description of the HASL methodology, and its relation to ICRP 75, 

is provided below. 

A detailed description of the HASL methods and background on air monitoring and exposure 

assessment was provided in a 1973 write-up in the HASL manual (chapter B-04, The Application of 

Air Sampling in the Evaluation and Control of the Occupational Environment, AEC 1973). The 

detailed description of the concept of representative workplace monitoring was written by A.J. Breslin, 

Director, Health Protection Engineering Division, HASL. It should be noted that Mr. Breslin was one 

of the sample collection scientists for the Bethlehem Steel Corp uranium dust monitoring data. 

Breslin’s write-up provides a detailed discussion of the type of samples taken, how they were taken, 

how they were analyzed, and how the results should be interpreted. The discussion of sampling 

locations, designation of sampling sites and the job task analysis sheets contained in this document 

are consistent with the sampling strategy employed at both Simonds Saw and Steel (SSS) and 

Bethlehem Steel Corporation (BSC). Early HASL procedure manuals were primarily focused on the 

chemistry, so earlier versions of the text may not exist (personal communication, Dr. Isabelle 

Fisenne). The following text, excerpted from the HASL manual, provides a description of the various 

sample types that were used by HASL to evaluate representative exposure. 

Breathing Zone Samples- Typically, a worker performs a few operations in which he 

may come into close or direct contact with the hazardous material. Examples of these 

operations are operating a machine tool, charging a furnace, working at a chemical 

hood, changing the glove on a dry box, or any one of a hundred maintenance tasks 

that involve the dismantling of or entrance to equipment. At jobs such as these, dust 

concentrations are apt to be much greater than in the general area. Therefore, these 

activities may influence the average exposure far out of proportion to their duration. 

To measure accurately the concentration to which a worker is exposed while 

performing such a task, a breathing zone (BZ) sample must be collected. The 

sampling instrument is held in the vicinity of the worker’s breathing area for the 

duration of the task. It should be held as close to his nose as possible short of 

interfering with his freedom of movement, because in situations where dust is escaping 

from a small aperture, concentration gradients around a source can be sharp. In one 

uranium plant, samples collected one foot apart at certain operations have shown 

concentration differences of twenty-fold. On the other hand, a sample collected so 

close as to interfere with the worker’s movements is invalid because the job cannot be 
 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 15 of 41 

performed in the normal fashion. A small deviation in work habit may alter the dust 

concentration markedly. 

General Air Samples- Usually, the total time spent by a worker on operations 

requiring BZ samples constitutes a small fraction of the day. There are, of course, 

exceptions... Worker exposure during the balance of the work day may be 

characterized by samples collected of the general air (GA) in the area that he occupies. 

A GA samples is one that is collected at a fixed location during a sustained sampling 

period. To be meaningful, the sample must be collected within an occupied area but 

also it must be away from dust sources except those that may dominate the area. 

Customarily, the sampling instrument is placed at a height from four to six feet from the 

floor although in a heavily trafficked area, the instrument must be placed over the 

heads of the workers to avoid interference with the normal work routine.... 

Process Samples- There is yet another kind of air sample that is often useful, the 

process sample. It is used to identify sources of air contamination or to determine the 

relative strengths of two or more sources. Process samples are distinguished from BZ 

and GA samples by the fact that they are taken in and around process equipment at 

locations where employees normally are not exposed. For this reason they should 

never be used in the evaluation of occupational exposure. 

As an example, a process sample might be collected directly over a furnace to 

determine the amount of radioactivity that is carried by convection from the furnace to 

the room. The concentration at that point is not representative of an employee’s 

exposure. 

These sampling methods meet the most current recommendations from ICRP Publication 75 (ICRP 

1997) regarding the collection of representative samples for the purpose of determination of exposure. 

As indicated in the excerpts below from the HASL procedures manual, the BZ samples collected by 

HASL were held in a position to represent the breathing zone and are not associated with a fixed 

sampler. Because of this, the ICRP 75 recommendation that samples collected from area samplers 

be corrected to breathing zone would not be appropriate for these samples. General area (GA) 

samples were taken with the expressed purpose of evaluating non-localized releases to which an 

employee could be exposed during the course of the day. Finally, process samples (P) that were 

obtained during the measurement period were to assess source terms and are not indicative of 

concentrations to which workers may have been exposed. Further evidence of the breathing zone 

sampling location comes from typical operations at National Lead which states, “BZ (breathing zone) 

samples were collected by holding the sampling device in the immediate vicinity of the worker’s head, 

in front of the shoulder area.” 

Samples were collected on 1 1/8” disks of Whatman #41 filter paper which provide high efficiency 

collection of particles in the particle size range. These filters have a maximum flow rate of about 20 

L/min (0.020 m3

/min). The procedure for the collection of samples at Simonds Saw and Steel on 

October 27, 1948 is discussed by the HASL representative in the report (AEC 1948a). Further 

discussion of the counting methods employed by the HASL is contained in the procedure 

“Determination of Uranium in Air Dust Samples by Alpha Counting Methods” (AEC 1949c) and by 

direct account of one of the HASL laboratory employees (personal communication, Dr. Naomi Harley, 

2004). While the current standards for documentation of calibration of the counting and sampling 

equipment have changed significantly since the early days of industrial hygiene, the relative 

contribution to uncertainty in the measured air concentration associated with these factors is very 
3.2 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 16 of 41 

small compared to the large changes in air concentration as a function of time and location. While 

this TBD does not use time weighted averages to determine exposure to uranium dust, HASL 

reported very good agreement in comparing time weighted averages of exposure with results 

obtained from personal lapel-mounted air samplers after they became available in the late 1960s 

(Breslin 1967). This agreement provides additional support for the reliability of the data and the use of 

time-weighted average air sample results to estimate exposure. 

Parameters affecting intake estimates and uncertainty at Bethlehem Steel 

A number of parameters must be specified in order to determine radiation dose from inhalation and 

ingestion of uranium (e.g. breathing rate) and associated uncertainty with these estimates. The 

recommended default values from the ICRP in Publication 66, Human Respiratory Tract Model for 

Radiological Protection, shall be used unless otherwise specified. The following discussion 

addresses the parameters to be used for the reconstruction of internal dose at the Lackawanna, NY 

facility. 

3.2.1 Breathing Rate 

ICRP 66 provides for two distinct types of workers, light workers and heavy workers. Both represent a 

composite of various levels of exercise. These composites represent an average breathing rate of 1.2 

m3

/hr for light workers and 1.7 m3/hr for heavy workers. This document will assume a classification of 

all workers at BSC as heavy workers with a breathing rate of 1.7 m3

/hr as a claimant favorable 

assumption using standard nasal augmenter breathing pattern. 

3.2.2 Exposure Duration 

In order to determine the total amount of uranium inhaled it is necessary to multiply the airborne 

concentration by the breathing rate and the time the individual is exposed to that concentration. This 

gets even more complicated when it is realized that not only does the air concentration vary by 

location, but also by time. Also, many individuals will move about from location to location throughout 

the day including break rooms, bathrooms, lunch rooms, etc. HASL recognized this need and 

developed the methods to determine a time weighted exposure. Such a study was conducted at 

Simonds Saw and Steel. The individual tasks were timed at various locations, and these exposure 

times were combined with the air concentrations in the locations to obtain a time-weighted average air 

concentration. However, no such estimate was conducted at Bethlehem Steel. 

Without a time motion study of various tasks, it is necessary to develop a claimant favorable approach 

to determine the appropriate exposure location and duration. For lack of better information, each 

individual will be assumed to be exposed for the purposes of internal dose estimation, 100% of the 

time for each 10 hour day of uranium rolling. This value will be treated as a constant for purposes of 

uncertainty analysis to be discussed later. Further discussion of exposure time with respect to 

internal dose from residual contamination will be discussed later in this document. 

The number of exposure hours per year was determined by assuming twelve 10-hour workdays per 

year for 1949 and 1950. This assumption is conservative considering no documentation indicates any 

rollings took place during those years. If there were rollings, it is assumed they took place only on 

one weekend day per month. Reports from 1951 and 1952 indicate that, with the exception of the 

April 1951 (Summary 1951), January 1952 (HW-23399), February 1952 (HW-24849), August 1952 

(Bowman et al. 1952), September 1952 (Schneider and Yocce undated) and October 1952 rollings, 

activity occurred on only one weekend day per month. For 1951, an additional 10 hours was added to 

account for the additional weekday in April, resulting in thirteen 10-hour workdays. For 1952, in 
3.3 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 17 of 41 

addition to the ten documented rollings days, it was assumed that one rolling each took place in May, 

and June, July, November and December resulting in fifteen 10-hour workdays. Assumptions of 10 

hour work rolling days are very claimant favorable estimates based on review of documented rollings 

which occurred at Lackawanna. For estimates of non-rolling day exposure to residual contamination, 

50 weeks of five 10 hour work days minus the number of rolling days were used. Residual 

contamination is discussed in greater detail later in this document. All partial months shall be treated 

as full months of exposure. 

3.2.3 Exposure Location 

As mentioned previously in this document, the exposure location can be difficult to determine. This 

estimate accounts for location uncertainty by assuming everyone was exposed in an occupation 

equivalent to the 95th percentile of the area air concentration distribution or other bounding estimates 

of intake which is explained later in this document. 

3.2.4 Absorption Type 

The dose derived from inhaling radioactive material depends on the solubility of the material inhaled. 

The solubility is a parameter describing the rate at which the material is absorbed from the lungs into 

the bloodstream. The most likely form of airborne uranium at Bethlehem Steel is various uranium 

oxides. These oxides tend to be absorbed at rates that are between type M and type S parameters 

described in ICRP 66. The absorption type will affect the dose of organs; however, no one type is 

favorable to all organs. Type S (very insoluble) will cause higher doses to the respiratory tract than 

type M but lower doses to systemic organs. Therefore, since the true absorption likely falls between 

type M and type S, the most favorable solubility type for the case at hand will be used. 

Inhalation Exposure Dosimetry at Lackawanna 

3.3.1 Method of analysis 

The air sample data from Bethlehem Steel originally consisted of a total of 191 legible air sample 

results and 13 illegible results drawn and analyzed by the HASL. These samples were collected on 

various days of rolling in 1951 and 1952. Original records were reviewed by NIOSH and its Advisory 

Board to determine some of the values because of the poor quality of some of the copies of onion skin 

type records. The final data set used for the analyses below consisted of 204 total samples with only 

1 sample being considered illegible and thus not used. Additionally, 5 samples were quality control 

samples and were excluded from the analysis of air concentration. 

The samples were divided into time periods based on the technology being employed (lead bath or 

salt bath heating). The following general methods were applied for the analysis of all time periods 

with specific information being further discussed in individual sections. All valid results, including 

process samples, were sorted, log transformed, and plotted on a probability plot. The plot contained 

the z-score (number of standard deviations from the mean) on the X axis and the log transformed 

data on the Y axis. This allows for a linear regression to be performed on the data to determine the 

best fitting straight line. This technique provides a goodness of fit value (utilizing the R squared 

parameter) as well as an equation for the straight line. The slope of the line then is equal to the log of 

the Geometric Standard Deviation (GSD) and the Y intercept is equal to the log of the Geometric 

Mean (GM). 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 18 of 41 

No records of any air sampling are known to exist for the 1949-1950 time period at Lackawanna as 

was previously discussed. This period was evaluated using the data collected at Simonds Saw and 

Steel on 10/27/1948, prior to the implementation of any ventilation controls. 

Data from the 1951-1952 time period was divided into two periods to reflect changes that occurred in 

the processing technologies (e.g. the change from lead bath and salt bath heating to only using salt 

bath heating). These analyses are explained in detail below. Figure 3 provides a graphical 

presentation of all the measured air monitoring data at Bethlehem Steel which further validates the 

need to split the period. 

The significant reduction in exposure levels during the later period (October 1951 thru December 

1952) created a situation where source terms other than the rolling operation may have been the 

limiting air concentration. It was determined that the grinding operations provided the highest 

exposure estimates as explained in the following section. In summary, there are three periods used 

for evaluation of internal dose: (1) January 1949 to December 1950; (2) January 1951 thru 

September, 1951; and (3) October 1951 thru December 1952. Finally a special exposure scenario for 

workers who participated in the cutting of cobbles has been established and is described in Section 

3.3.5. 

Figure 3: Plot of all air monitoring results for natural uranium from Bethlehem Steel. dpm/m3 uranium 

30000 

25000 

20000 

15000 

10000 

5000 

0 

225 MAC (15750 dpm/m3) 

70 MAC (4900 dpm/m3

) 

May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 

1951 - 1952 
 

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3.3.2 Evaluation of inhalation exposure for the 1949-1950 time period 

No contemporary record of Bethlehem Steel processing uranium for the DOE or its predecessors prior 

to 1951 has been found by NIOSH. The sources of information which have been used to justify this 

period are the 1976 memo from ERDA (Range 1976) which provides details recalled by retirees of the 

AEC who had knowledge of the operations, a memo by a plant radiological control engineer 

(LaMastra 1976) who used the 1976 memo from Range as a source along with discussions with plant 

personnel, and a 1977 memo from Thornton as part of the ERDA resurvey program who based the 

times from a discussion with LaMastra. No documentation had been reviewed for the preparation of 

this memo by Range which is cited by other reports and dates were specified as being approximate. 

No records exist which document rollings at Bethlehem Steel during 1949-1950. Because of this, 

data from Simonds Saw and Steel will be used as a surrogate for the determination of dose for these 

years. The use of Bethlehem Steel data for uranium dust exposure assessment prior to 1951 is 

inappropriate because lead bath heating may not have been performed. Certainly salt bath heating 

was not being evaluated until 1951. The appropriateness of using Simonds Saw and Steel as a 

surrogate facility was discussed earlier in this document and was the subject of significant review by 

the Advisory Board on Radiation and Worker Health. 

The visit by HASL to Simonds Saw and Steel on October 27, 1948 collected 37 samples to evaluate 

the time weighted average exposure to various job categories at the plant. These included 22 

breathing zone samples and 15 general area samples. Several controls and a sample from the stack 

were also collected. The median length of time of collection for a breathing zone sample was 0.71 

minutes (range 0.5 to 2.5 minutes) while general area samples typically were collected for a much 

longer time (median 15 minutes, range 3 to 45 minutes). The changes in time were used by HASL to 

prevent severe dust loading of the filters in areas with high expected dust concentrations and 

increased sampling times to improve statistics associated with the counting in areas of expected low 

concentrations. 

The data from both plants includes various locations throughout the mill areas. Some of these 

locations represent higher air concentrations than others. Therefore, assigning the distribution may 

underestimate an individual’s intake for someone located in one of the higher air concentration area 

for extended periods of time. In order to prevent this from occurring, the 95th percentile of this 

distribution will be assumed for exposure estimates. This value will be assumed to be present in the 

breathing zone 100% of the time and be assigned as a constant. Figure 4 provides a plot of the 

distribution of uranium concentrations observed at Simonds Saw and Steel during this period of no 

ventilation. The 95th percentile of this distribution, 553 MAC (38,710 dpm m-3 of natural uranium), will 

be used as the basis for evaluation of inhalation exposure during this time period. 
 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 20 of 41 

Figure 4: Graph of the distribution and fit of uranium dust concentration data taken from Simonds Saw 

and Steel on October 27, 1948 (MAC=70 dpm m-3). 

1000000 

uranium dust concentration, dpm m-3

100000 

10000 

1000 

100 

10 

1 

-3 -2 -1 0 1 2 3 

95th percentile (553 MAC) 

.0 98

concentration e

2 

7.0 71 2.124(z) 

=

= +

R

z score 

3.3.3 Determination of inhalation exposure for the early 1951 time period 

As previously discussed, the air sample data from Bethlehem Steel consists of a total of 204 air 

sample results, drawn and analyzed by the Health and Safety Laboratory and National Lead. 

Personnel from National Lead, who conducted the last analysis, were originally from HASL and used 

the same approaches and time weighted averages. These samples were collected on various days of 

rolling in 1951 and 1952. Sample types included general area, breathing zone, and process samples. 

Of the 204 samples, one sample was illegible (after reviewing the original records) and 5 were quality 

control samples which were not used for these analyses. 

Evaluation of the data shows that changes in the process methods clearly impacted the air 

concentration data which was reflected in the monthly HASL reports and also reports of by Hanford 

personnel participating in the development. An early period from January 1951 to September 1951 

was identified in which lead and salt bath technologies were both being evaluated at Bethlehem Steel. 
 

1000000 

uranium dust concentration, dpm m-3 

100000 

10000 

1000 

100 

10 

1 

-1.0 -0.5 0.0 0.5 1.0 1.5 2.0 2.5 3.0 

95th percentile prior to augmentation (87 MAC) 

0.970 2 R 

(3.758 .3 013(z)) e) 3 concentration(dpm/m

=

+ =

z score 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 21 of 41 

It was further recognized that the number of breathing zone samples was a much lower fraction of the 

total as compared to the Simonds Saw and Steel measurements used to evaluate the 1949 to 1950 

time period. For this reason, a breathing zone sample surrogate (BZ-GA) was developed by 

evaluating the breathing zone to general air sample concentrations at Simonds Saw and Steel and 

applying this factor to the general air samples during this early 1951 period. Data analysis for this 

time period was then conducted using the same methods as previously discussed. Figure 5 shows a 

graphical analysis of data from this time period prior to augmentation. Figure 6 shows the analysis of 

the augmented data set (includes BZ-GA samples). The 225 MAC (15750 dpm m-3) air concentration 

represents the 95% level which shall be used for analysis of uranium air concentration during rollings 

days for this early 1951 period. 

Previous sections in this TBD discuss the role that the BSC Lackawanna rolling mill played in the 

development of continuous rolling experiments for Hanford and also for the comparison of lead and 

salt bath heating. Only the first four experimental runs conducted in 1951 were known to have used 

the lead bath heating. Air sampling was conducted on three of those experiments. While it is known 

that the salt produced a more effective coating for reducing oxidation hence uranium dust, the data 

has been evaluated together for determination of the 95% air concentration data. 

Figure 5: Graph of the distribution and fit of uranium dust concentration data, prior to augmentation 

with BZ-GA samples, taken at Bethlehem Steel from January 1951 thru September 1951 for only those 

samples obtained for the time (MAC=70 dpm m-3). 
 

 

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Figure 6: Graph of the distribution and fit of uranium dust concentration data taken at Bethlehem Steel 

from January 1951 thru September 1951 augmented to include BZ-GA samples (MAC=70 dpm m-3). 225 

MAC (1575 dpm m-3) is the air concentration level to be used for the assessment of rolling day intakes 

for this period. 

10000000

uranium dust concentration, dpm m-3

1000000 

100000 

10000 

1000 

100 

10 

1 

-0.5 0.0 0.5 1.0 1.5 2.0 2.5 3.0 

 95th percentile (225 MAC) 

0.976 2 R 

(4.006 .3 440 (z)) e) 3 concentration(dpm/m

=

+ =

z score 

3.3.4 Determination of Inhalation Exposure for the late 1951 thru 1952 time period 

The majority of uranium airborne contamination in the early period at Bethlehem Steel was caused by 

the actual rolling of uranium metal. However, after the salt bath furnace was utilized, airborne 

contamination from the rolling operations were greatly decreased. The median value of all the air 

samples collected in this period are slightly less than 0.2 MAC which raises the concern regarding 

previously minor sources of airborne contamination. These other sources would have to be distant 

from the rolling operations otherwise airborne contamination would be measured, at least partially, on 

the air samples taken near the rolling operations. 

Grinding of the uranium billets to remove surface imperfections was a documented operation at 

Bethlehem Steel for some of the rollings. A single process air sample was obtained for this operation. 

The air sample (70 MAC) was actually the highest recorded at Bethlehem Steel during the later time 

frame. This value was used to estimate the air concentrations for the later period at Bethlehem Steel. 
 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 23 of 41 

As with previous periods, it is assumed that the operators inhaled this concentration continuously for a 

10 hour work day on which uranium rolling occurred. Based on measurements conducted at the 

Joslyn Steel plant taken while grinding on uranium metal (both breathing zone and general air 

samples), air concentration ranged from 0.4 MAC to 17 MAC. Harris indicated that portable grinding 

operations result in an average daily concentration of 5.7 MAC. This indicates the 70 MAC 

concentration determined from a process sample provides an upper bound to the operation. 

While there may have been other sources of airborne contamination, however, it is likely that this 

estimate is a bounding estimate except for an exposure category of workers (cobble cutters) 

discussed below. For other sources to be bounding, they would have to produce greater than 700 

MAC-hours of exposure per day (70 MAC times 10 hours per day). This would require amy other 

operation to not only create higher air concentrations, but to do so routinely. The most likely routine 

source of elevated airborne activity that has been postulated at Bethlehem Steel is the cutting of 

cobbles (Transcript November 28, 2005). 

3.3.5 Determination of intakes to cobble cutters (1949 thru 1952) 

Cobbles are essentially bent rods that occur when a bar of metal misfeeds from one stand into the 

next. Based on BSC worker input, cobbles would have been removed from the mill in the most 

expeditious manner possible, utilizing an overhead crane whenever possible. This is confirmed in the 

documentation NIOSH reviewed on cobbles, which indicates that there is a fairly short time span 

between a cobble and the next sample passing through the stand. This was a result of workers 

cutting the cobbles at the stands only if it were necessary for their removal from the mill. The cobbles 

were then taken elsewhere for any additional cutting to return it to scrap (Transcripts for worker 

testimony 7-19-2006). Records from other rolling mills show that the AEC had an active scrap 

processing program to reprocess the uranium. Potential methods of cutting cobbles included torch 

cutting, power saw, and shears. Worker accounts from several meetings indicate that torch cutting 

was the method employed. NIOSH has previously expressed reservations that, while this practice 

might have been used to cut steel cobbles, it would not necessarily be the best method to cut 

uranium. This is due to the pyrophorric nature of uranium which would have a tendency to ignite while 

being cut with a torch. The worker’s recollections, however, will be accepted at face value and torch 

cutting of uranium will be assumed in NIOSH’s approach to estimating exposure to cobble cutters. 

Test and production records (summarized in Table 2) indicate that during initial testing, a higher 

percentage of cobbles occurred. This higher rate of cobbling is offset by the lower number of rods 

rolled. An evaluation of these records (Table 3) indicates the number of cobbles per day was 

relatively constant. During the production phase, when only salt bath preheating was done and during 

which time the estimate of exposure is the lowest, there were an average 3.6 cobbles per day. In a 

worker outreach meeting held June 19, 2006, several workers provided expert input regarding 

cobbles. The time required to cut cobbles varied between 5 minutes and an hour and cut in a similar 

time compared to steel. Information from worker accounts (Transcript November 28, 2005) also 

indicated that some cobbles are cut loose at the rollers and others are drug out of the mill using a 

crane and cut up elsewhere. It is likely the more extensively twisted cobbles would be the ones that 

are cut (at least initially) at the rollers and the remainder of the cutting to reduce the cobble to scrap 

would occur on the floor. Worker discussions further indicate that, while several individuals may have 

cut the cobbles at the rollers to most efficiently remove it with the assistance of the crane, a single 

worker would have completed the process on the floor. Analysis of the time per rod rolled during air 

monitoring shows that cobbling did not grossly impact the production rate, further indication of the 

efficiency of the removal process. 
 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 24 of 41 

The exposure to the cobble worker will be evaluated based on an average of 2 hours per day 

engaging in torch cutting of cobbles. The time is based on an average reported during worker 

interviews and compared to published values for the cutting of stainless steel with acetylene torch 

which reported cutting time for stainless steel ranging from 2 to 4.2 minutes (3.6 minute mean) per cut 

of a 5 cm stainless steel pipe of 0.4 cm wall thickness (Newton 1987). Air concentrations are based 

on expected sustainable levels of contamination of 600 MAC, which is higher than the largest air 

concentration documented at Bethlehem Steel and is higher than the air concentration used to 

evaluate exposures at Bethlehem Steel during the 1949 to 1950 time span. This air concentration is 

based on estimated bounding levels of sustainable airborne contamination concentrations over the 

course of this two hour period from torch cutting (SC&A 2005a and Transcript November 28, 2005). 

The value also corresponds well to the concentration observed during the cutting of stainless steel 

pipe with a torch (Newton 1987), although study design limits the conclusions that can be drawn from 

this comparison 

A 0.5 μm AMAD particle size will be used based on estimates from the torch cutting of other materials 

(Newton 1987). While not reported directly in the study, AMAD observed for torch cutting was 

approximately 0.5 to 1 μm AMAD (personal communication M. Hoover). 0.5 μm AMAD has been 

chosen as the most claimant favorable for dose evaluation. The remaining 8 hours of exposure will 

be evaluated based using 70 MAC as the concentration which is bounding of non-rolling operations 

during all the various operational phases at the mill as discussed above. While it is likely that these 

workers did not perform rolling operations, their known occupation in the mill and possible 

involvement in other dust generating tasks warrants consideration at the standard occupational level. 

Ingestion will be evaluated using the standard methods described for all workers. 

As described above, the cobble cutter model is intended to cover workers with sustained torch cutting 

exposures, and is not to be used for incidental or otherwise short-term work in this capacity. 

Discussions with BSC workers indicate that number of workers engaged in uranium cobble cutting is 

small (i.e. potentially limited to a few workers). In fact, one site expert indicated that he was the only 

person who cut uranium cobbles during the covered period. Because NIOSH follow-up on this 

assertion could not definitively establish that this may have been the case, dose reconstructors should 

evaluate each claim to determine if there was a potential that the worker could have been engaged in 

torch cutting of uranium. Likely job titles that should be considered include scrappers, scarfers, and 

laborers. The decision as to whether a worker cut cobbles should also consider any additional 

supporting information that may be available. This includes the computer assisted telephone 

interview (CATI) and additional claimant / worker interviews that may have been conducted. Dose 

reconstructors should exercise extreme care in making this judgment and, when the determination is 

ambiguous, the exposure scenario (i.e., general model or cobble cutter model) that provides the 

higher dose to the organ should be used in the dose reconstruction. 
 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 25 of 41 

Table 2: Summary of Uranium Cobbles at Bethlehem Steel Corporation 

Date 

Type or 

designation 

Billets 

rolled Bath type 

Air 

Sample 

Data 

Number of 

cobbles/rods 

rolled 

Cobbling 

rate 

observed 

Reference 

April 26-27, 

1951 

Experimental 

#1 

70 (many 

rolled in only 

1 or 2 stands 

to work on 

process). 26 

rolled for all 

stands for 

Hanford 

evaluation 

Lead/salt Y 2/26* 3.8% Summary 1951, Reichard 

1951 

Sheets 6191, and 6192 

July 29, 

1951 

Experimental 

#2 

24 Lead/salt Y Summary 1951 

Sample sheets 6425, 6436, 

6437 

August 27, 

1951 

Experimental 

#3 

32 Lead/salt 1/10* 10% Summary 1951 

AEC 1951b 

September 

30, 1951 

Experimental 

#4 

43 Salt Y 0/7* 0 Sample sheet 6539 

HW 23910 

October 28, 

1951 

Lackawanna 

#5 

93 Salt Y AEC 1951a 

Sample sheets 6532, 6533 

January 26­

27, 1952 

Production 25 plus 4 

tons heat 

treated only 

Salt Y 3/25 12% AEC 1952b 

AEC 1952c 

AEC 1952d, HW-23269 

Sample sheets 6543, 6544, 

6545 

February 

16, 1952 

Production 120 

30 tons 

Salt 1/120 0.8% HW 23697 

March 15, 

1952 

Production 218 Salt Y 3/204 1.5% NLO 1952b 

Sample sheets 6573, 6574 

April 12, 

1952 

Production 222 Salt 1/219 0.5% NLO 1952a 

August 17, 

1952 

Production 157 Salt 5/157 3.1% Bowman 1952 

August 31, 

1952 

Production 220 Salt 4/220 1.8% Bowman 1952 

September 

14, 1952 

Production 303 Salt Y - Schneider 

Sample sheet IH33, IH34, 

IH35, IH36 

September 

22, 1952 

Production 302 Salt - Schneider 

October 19, 

1952 

Production 60 tons 

(~240 billets) 

Salt - Hershman 1952 
 

3.4 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 26 of 41 

Table 3: Evaluation of Cobble rate at Bethlehem Steel Corporation 

Exposure 

rate 

(MAC*) 

Average 

number 

rods 

rolled/day 

Cobbling 

rate 

Cobbles/rolling 

day 

Experimental 

with lead/salt 

225 42 8% 3.5 

Experimental 

with salt only 

70 68 5% 3.5 

Production 

with salt only 

70 200 1.8% 3.6 

*MAC =Maximum air concentration=70 dpm for natural uranium 

Evaluation of ingestion dose 

Ingestion intakes can be most closely related to surface contamination values. Very few 

measurements exist for surface contamination. However, airborne contamination levels and surface 

contamination levels are generally related. To evaluate the relationship between air contamination 

and surface contamination, NIOSH reviewed the available air and surface contamination 

measurement at Simonds Saw and Steel and Bethlehem Steel. At Simonds Saw Steel these 

measurements were taken during a uranium rolling campaign on 10/27/48, while at Bethlehem Steel 

data were available for a rolling on 9/14/1952. The Bethlehem Steel surface contamination data were 

obtained by smears wiped over a 100 cm2

 area. As such, they represent only the removable portion 

of the contamination. The Simonds Saw surface contamination data were direct measurements that 

were made with a portable instrument called a Zeuto. This type of instrument has an active surface 

area that is 3 inches by 4 inches or approximately 75 cm2 

. 

Each rolling stand at both Bethlehem Steel and Simonds Saw were evaluated along with the shear at 

Bethlehem Steel. Stand #6 at Bethlehem Steel was not evaluated because the surface smear 

indicated no detectable activity. Where more than one sample was taken, the results were averaged. 

Table 4 shows the average air and surface contamination measurements for these locations. The 

surface contamination measurements at Simonds Saw were normalized to 100 cm2 

. 

The values for each point are plotted in Figure 7. A clear trend can be seen in the graph, which 

indicates that the surface contamination is proportional to the air contamination. It is also worthy of 

note that this relationship is internally consistent at the two facilities. That is, high airborne activity is 

predictive of high surface contamination levels and vice versa. This means that if any large particle 

surface contamination that does not add to the air concentrations exists, the fraction of surface 

contamination represented by this is consistent across locations and sites and concentrations. Using 

this relationship, a model was developed that relates the ingestion rate to air concentrations. 
 

 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 27 of 41 

Table 4: Air and Surface Contamination Values 

Air sample # Air concentration 

(dpm/m3

) 

Surf. Contamination 

location 

Surf. Contamination 

value (dpm/100 cm2) 

Simonds Saw Data 

L709 49000 

L710 75000 east roller 1 50000 

L711 22400 west roller 1 35000 

Average 48800 Average 42500 

L718 14800 

L719 23800 

L720 27900 

L721 943 

L722 836 

L723 418 west roller 2 15000 

average 11449.5 Average 15000 

Bethlehem Steel Data 

Q921 2076 

Q922 2973 Shear 679 

Q923 1080 Shear 404 

Average 2043 Average 541.5 

Q903 3 

Q905 10 Stand 1 2 

Average 6.5 Average 2 

Q906 10 

Q908 12 Stand 2 9 

Average 11 Average 9 

Q909 18 

Q911 14 Stand 3 6 

Average 16 Average 6 

Q912 13 

Q913 10 

Q920 6 Stand 4 5 

Average 9.7 Average 5 

Q914 12 

Q915 3 

Q919 12 Stand 5 9 

Average 9 Average 9 
100000 

Surface Contamination (dpm per 100 cm2 ) 

10000 

1000 

100 

10 

1 

Air Concentration (dpm per m3) 

1 10 100 1000 10000 100000
 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 28 of 41 

Figure 7: Graph of observed air concentration and surface contamination levels at Simonds Saw and 

Bethlehem Steel. 

The computer program RESRAD-BUILD contains a model for estimating ingestion intakes from 

surface contamination levels. The model contains a parameter for the ingestion rate that is expressed 

in units of m2

/hr, which expresses the amount of contamination ingested as a portion of the 

contamination contained in an effective area. This is intended to be a multiplier for removable surface 

contamination which can be used to arrive at an hourly ingestion rate. The default distribution used 

by RESRAD is a loguniform distribution between 2.8x10-5 and 2.9x10-4 m2

/hr with a mean of 1.1x10-4 

m2

/hr. This distribution is provided in NUREG/CR-5512 volume 1, while the development of this 

parameter is discussed in volume 3 of the same NUREG. 

Table 5 lists the average air concentrations and the average surface contamination levels (expressed 

in dpm/m2

) measured at Simonds Saw and Bethlehem Steel. It also lists the estimated hourly 

inhalation and ingestion rates inferred from these data. The hourly inhalation rate is based on the 

assumed 1.7 m3

/hr breathing rate. The hourly ingestion rate is based on the upper bound of the 

distribution provided in NUREG/CR-5512 of 2.9x10-4 m2

/hr. The table also included the calculated 
 

3.5 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 29 of 41 

ingestion rate as a fraction of the inhalation rate. This is simply the calculated ingestion rate divided 

by the calculated inhalation rate. 

Table 5: Calculated Inhalation and Ingestion Rates 

Air 

Concentration 

(dpm/ m3

) 

Surface 

Contamination 

(dpm/ m2) 

Hourly 

inhalation rate 

(dpm/hr) 

Hourly 

ingestion rate 

(dpm/hr) 

Fractional 

ingestion rate 

48800 5666667 82960 1643.33 0.019809 

11449.5 2000000 19464.15 580 0.029798 

2043 54150 3473.1 15.70 0.004521 

6.5 200 11.05 0.06 0.005249 

11 900 18.7 0.26 0.013957 

16 600 27.2 0.17 0.006397 

9 900 15.3 0.26 0.017059 

9.7 500 16.43 0.15 0.008824 

Average 0.013202 

Ingestion intakes at Bethlehem Steel will use the highest of these fractional rates (0.0298). This rate 

will be multiplied by the applicable inhalation rate to obtain the ingestion rate. In this way, the 

ingestion rate will change as the estimated conditions at the facility change. 

Evaluation inhalation and ingestion due residual contamination 

Residual contamination of the facility following rolling operations would have been present in the form 

of uranium oxide dust on the floor and other horizontal surfaces. No surface or airborne 

contamination surveys could be found from Bethlehem Steel during days in which only steel was 

processed. However, it was noted that uranium rolling occurred primarily on weekends because the 

10” continuous bar mill was being fully utilized for steel production during the week. 

The principal product of the continuous rolling mill at Bethlehem Steel, measured in thousands of tons 

per year, was steel. On days in which Bethlehem Steel was not rolling uranium, steel was being 

produced. The production of steel generates large quantities of dust and debris. As steel is rolled, a 

coating of this dust is likely to settle on top of any uranium contamination. This would act as a 

protective layer making it less likely that the uranium would be resuspended. However, it is possible 

that as uranium contamination is resuspended in the air, it settles back to horizontal surfaces and 

essentially forms a mixture of uranium and steel. This would allow uranium to continue to be 

resuspended but only as part of a mixture. The resuspension of material requires some mode of 

force, such as ventilation, foot or vehicular traffic, etc. It is likely the same type of forces exist whether 

the mill was rolling steel or uranium. It is therefore, likely that the same mass of material is 

resuspended at anyone time. As the steel debris builds up, this resuspended material is composed of 

fractionally less uranium and more steel. 

The dose from residual contamination was determined based on the above concepts which result in 

the resuspension of contamination. The uranium contamination was assumed to be diluted by 

additional rollings of steel in-between uranium rollings. For the purposes of this model, it has been 

assumed that an equal mass of steel is added to the uranium each day. This is a conservative 

estimate because the steel production was measured in thousands of tons per year while uranium 
 

 

3.6 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 30 of 41 

was rolled only on a limited basis (on the order a few hundred tons). The material available for 

resuspension one day after a uranium rolling would therefore be one part uranium and one part steel. 

On the following day, the material would be one part uranium and two parts steel and so on. 

While rolling operations could result in high localized air concentrations, air concentrations from 

resuspension of residual contamination would be more consistent throughout the area. Therefore, the 

median general air concentrations are used as the starting point. This value is then assumed to 

decrease in the days following uranium rolling as described above. The average air concentration 

due to resuspension of residual contamination can be estimated by the following expression. 

30 

dt / t ∫ 30 

1 ln(t)1 CAvg = CInt. * = CInt. * = CInt. * 0.117

29 29 

Where: 

CAvg. = the average air concentration through the 29 days following a rolling 

CInt. = the median general air concentration on the day of rolling 

t = the number of days following the day of rolling 

The median general area air sample concentrations for the three time periods are listed in table 6. 

Table 6: Median General Area Air Sample Concentrations 

Median general area air samples (MAC) 

Simonds Saw Steel 4.13 

Bethlehem Steel (early) 0.215 

Bethlehem Steel (late) 0.081 

The same method was used for ingestion, however, the initial concentration was replaced by the daily 

ingestion rate on rolling days. 

Summary of internal dose guidance for Bethlehem Steel 

The following tables summarize the data from the previous sections for the purpose of conducting 

internal dose estimates at Bethlehem Steel. The rolling data and residual contamination has been 

averaged over the applicable time frame to determine an intake rate per calendar day. These values 

should then be applied as a continuous chronic intake to determine dose. While the typical rolling 

schedule was one per month, several months do not follow this rule. However, for ease of calculation, 

residual periods were assumed to be 20 work days per rolling. Also, exposures shall be determined 

as full month time frames for any partial month worked to account for the slightly non-uniform rollings 

schedule (e.g. if a worker was employed for part of a month, use the entire month). 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 31 of 

Table 7: Summary of exposure values during rolling days 

Time Period Air 

concentration 

on rolling 

days 

Time 

(hours/day) 

Breathing 

rate 

(m3/hr) 

Inhalation 

during rolling 

days 

(dpm/day) 

Average 

inhalation 

rate on nonrolling 

(dpm/day) 

Ingestion 

during rollin

days 

(dpm) 

All workers except cobble cutters (5 micron particle size) 

1/1/1949 – 

12/31/1950 553 MAC 10 1.7 658,070 575 19,610 

1/1/1951 – 

9/30/1951 225 MAC 10 1.7 267,750 30 7,979 

10/1/1951 – 

12/31/1952 70 MAC 10 1.7 83,300 11.3 2,482 

Cobble cutters performing other duties (5 micron particle size). 

1/1/1949 – 

12/31/1950 70 MAC 8 1.7 66,640 575 19,610 

1/1/1951 – 

9/30/1951 70 MAC 8 1.7 66,640 30 7,979 

10/1/1951 – 

12/31/1952 70 MAC 8 1.7 66,640 11.3 2,482 

Cobble cutters during cutting (0.5 micron particle size) 

1/1/1949 – 

12/31/1950 600 MAC 2 1.7 142,800 

- - 

1/1/1951 – 

9/30/1951 600 MAC 2 1.7 142,800 

- - 

10/1/1951 – 

12/31/1952 600 MAC 2 1.7 142,800 

- - 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 32 of 41 

Table 8: Summary of inhalation exposure values for the periods 1949-1952 at Bethlehem Steel 

(not including cobble cutters) 

Time Period Number 

of rollings 

Total inhalation 

from rolling 

day exposure 

(dpm) 

Total Inhalation 

from residual 

contamination 

(dpm) 

Total 

Inhalation 

during period 

(dpm) 

Total 

Inhalation rate 

(dpm/ 

calendar day) 

1/1/1949 – 

12/31/1950 24 15,793,680 275,844 16,069,524 22,043 

1/1/1951 – 

9/30/1951 10 2,677,500 5,400 2,682,900 9,864 

10/1/1951 – 

12/31/1952 18 1,499,400 3,378 1,502,778 3,288 

Table 9: Summary of inhalation exposure values for the periods 1949-1952 at Bethlehem Steel 

for cobble cutters 

Time 

Period 

Number 

of 

rollings 

Total 

inhalation from 

rolling day 

exposure 

(dpm) 

Total Inhalation 

from residual 

contamination 

(dpm) 

Total 

Inhalation 

during period 

(dpm) 

Total 

Inhalation 

rate 

(dpm/ 

calendar 

day) 

Particle size 

(μm AMAD) 

1/1/1949 – 1,599,360 275,844 1,875,204 2,572 5 

12/31/1950 24 3,427,200 - 3,427,200 4,701 0.5 

1/1/1951 – 666,400 5400 671,800 2,470 5 

9/30/1951 10 1,428,000 - 1,428,000 5,250 0.5 

10/1/1951 – 1,199,520 3378 1,202,898 2,632 5 

12/31/1952 18 2,570,400 - 2,570,400 5,625 0.5 

Table 10: Summary of ingestion exposure values for the periods 1949-1952 at Bethlehem Steel 

for all workers 

Time Period Number 

of rollings 

Total ingestion 

during rollings 

(dpm) 

Total ingestion 

during from 

residual 

contamination 

(dpm) 

Total 

ingestion rate 

(dpm/ 

calendar day) 

1/1/1949 – 

12/31/1950 24 470,652 1,383,716 2,544 

1/1/1951 – 

9/30/1951 10 79,790 234,581 1,156 

10/1/1951 – 

12/31/1952 18 44,682 131,365 385 
4.2 

4.0 ESTIMATION OF EXTERNAL EXPOSURE 

No external dosimetry data is available for Bethlehem Steel. However, dose rates from submersion in 

a cloud of dust, direct exposure to uranium metal, and exposure to workers from skin contamination 

and reuse of their clothing are estimated below using the rolling information, residual contamination, 

and exposure rate constants for uranium materials. 

4.1 Evaluation of external dose from uranium dust 

Air concentrations derived in this document were combined with rolling times, number of rollings and 

the Dose Conversion Factors for 238U and the daughter radionuclides 234Th and 234mPa from Federal 

Guidance Report No. 12 (EPA 1993) to determine the external dose due to submersion in a natural 

uranium dust cloud. Only the skin is reported in Table 10 because all other doses were less than 1 

mrem. The maximum annual dose to the skin listed in Table 10 is applied to electron (E > 15 keV) 

annual dose in IREP using a constant distribution and assuming a chronic exposure. 

Table 10: Annual external dose due to submersion in air contaminated 

with natural uranium dust. 

Time Frame Annual Skin Dose* 

(Rem) 

1949 0.002 

1950 0.002 

1951 0.001 

1952 0.000 

* Dose values are rounded to nearest mrem 

Evaluation of external dose from direct contact with uranium billets 

External doses from exposure to a uranium source were evaluated using extended (semi-infinite 

plane) natural uranium source. Estimated surface dose rates of 230 mrad/hr at a depth of 7 mg/cm2 

and 2 mrad/hr at a depth of 1000 mg/cm2 were obtained from a search of the literature (Coleman, 

Hudson, and Plato 1983; U.S. Army 1989). Conservative values for the time workers were located 

relative to the source were based on descriptions of processes and different job types (AEC 1948b). 

A triangular distribution for electron exposure from uranium was determined in the following manner: 

•	 The minimum was estimated by assuming the worker was 1 meter from an extended uranium 

source for 1 hour (per 10-hour shift). The estimated dose rate for this scenario was 90 

mrad/hr (US Army 1989). 

•	 Survey data of the Simonds facility were used to estimate the mode. The highest value 

measured during those surveys was 15 mrad/hr (AEC 1949b). To be claimant-favorable, this 

dose rate was assumed for an entire 10-hour shift. 

•	 A maximum value was estimated by assuming the worker was 0.3 meter (1 foot) from an 

extended uranium source for 6 hours (150 mrad/hr) and 1 meter away for 4 hours 

(90 mrad/hr). 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 34 of 41 

Table 11 summarizes annual values for estimated external shallow dose due to electron exposure 

from uranium. The target organs for this type of exposure are the skin, male genitals, and breast. In 

the case of cancer of the male genitals or female breast cancer, additional evaluation might be 

needed to consider shielding and attenuation provided by clothing. 

Table 11: Estimated external shallow dose due to electron exposure from 

natural uranium source. 

Time Frame 

Annual Organ Dose 

(Rem) 

Min. Mode Max. 

1949 1.08 1.80 15.12 

1950 1.08 1.80 15.12 

1951 1.17 1.95 16.38 

1952 1.35 2.25 18.90 

The values in Table 11 are entered in IREP as the annual dose due to electrons (E > 15 keV) using a 

triangular distribution and assuming a chronic exposure for cases where the target organ is the skin, 

male genitals, or breast. 

The deep dose rate due to photon exposure (dose rate at 1,000 mg/cm2

) from natural uranium was 

estimated to be 2 mrad/hr (U.S. Army 1989). The estimated 2-mrad/hr deep dose rate from the 

uranium source is evenly divided between photons with energies E = 30-250 keV and E > 250 keV. 

Dose conversion factors DCFmin, DCFmax, and DCFAP, for 30-250 keV photons (NIOSH 2002) were 

used to calculate the doses listed in Table 12. Dose conversion factors DCFmin, DCFmax, and DCFAP, 

for E > 250 keV photons were used to calculate the doses in Table 13. The values in Table 12 and 

Table 13 are entered into IREP as organ doses due to the appropriate energy photons, using a 

triangular distribution and assuming a chronic exposure. 
 

 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 35 of 41 

Table12: Annual organ doses due to photons (30-250 keV) from natural uranium source for best 

estimate. 

Organ 

Annual organ dose (rem) 

1949 1950 1951 1952 

Min Mode Max Min Mode Max Min Mode Max Min Mode Max 

Bladder 0.004 0.113 0.121 0.004 0.113 0.121 0.005 0.122 0.131 0.005 0.122 0.131 

Red bone marrow 0.008 0.057 0.101 0.008 0.057 0.101 0.008 0.062 0.109 0.008 0.062 0.109 

Bone surface 0.046 0.110 0.182 0.046 0.110 0.182 0.050 0.119 0.197 0.050 0.119 0.197 

Breast 0.005 0.152 0.179 0.005 0.152 0.179 0.006 0.165 0.193 0.006 0.165 0.193 

Colon 0.007 0.096 0.103 0.007 0.096 0.103 0.007 0.104 0.112 0.007 0.104 0.112 

Esophagus 0.003 0.063 0.087 0.003 0.063 0.087 0.004 0.068 0.095 0.004 0.068 0.095 

Eye 0.000 0.113 0.131 0.000 0.113 0.131 0.000 0.123 0.141 0.000 0.123 0.141 

Ovaries 0.004 0.087 0.095 0.004 0.087 0.095 0.004 0.094 0.103 0.004 0.094 0.103 

Testes 0.004 0.131 0.136 0.004 0.131 0.136 0.005 0.142 0.148 0.005 0.142 0.148 

Liver 0.012 0.097 0.102 0.012 0.097 0.102 0.013 0.105 0.111 0.013 0.105 0.111 

Lung 0.015 0.090 0.103 0.015 0.090 0.103 0.017 0.097 0.112 0.017 0.097 0.112 

Remainder organs 0.011 0.080 0.087 0.011 0.080 0.087 0.012 0.087 0.094 0.012 0.087 0.094 

Skin 0.054 0.081 0.089 0.054 0.081 0.089 0.058 0.088 0.097 0.058 0.088 0.097 

Stomach 0.005 0.114 0.121 0.005 0.114 0.121 0.006 0.124 0.132 0.006 0.124 0.132 

Thymus 0.001 0.128 0.136 0.001 0.128 0.136 0.001 0.138 0.147 0.001 0.138 0.147 

Thyroid 0.001 0.131 0.136 0.001 0.131 0.136 0.001 0.142 0.148 0.001 0.142 0.148 

Uterus 0.005 0.092 0.100 0.005 0.092 0.100 0.006 0.099 0.108 0.006 0.099 0.108 

Table 13: Annual organ doses due to photons (>250 keV) from natural uranium source for best estimate. 

Organ 

Annual organ dose (rem) 

1949 1950 1951 1952 

Min Mode Max Min Mode Max Min Mode Max Min Mode Max 

Bladder 0.055 0.109 0.114 0.055 0.109 0.114 0.059 0.118 0.123 0.059 0.118 0.123 

Red bone marrow 0.060 0.090 0.110 0.060 0.090 0.110 0.065 0.097 0.119 0.065 0.097 0.119 

Bone surface 0.068 0.095 0.107 0.068 0.095 0.107 0.073 0.103 0.116 0.073 0.103 0.116 

Breast 0.066 0.112 0.135 0.066 0.112 0.135 0.072 0.121 0.147 0.072 0.121 0.147 

Colon 0.054 0.105 0.107 0.054 0.105 0.107 0.058 0.113 0.116 0.058 0.113 0.116 

Esophagus 0.054 0.092 0.105 0.054 0.092 0.105 0.059 0.100 0.114 0.059 0.100 0.114 

Eye 0.025 0.109 0.117 0.025 0.109 0.117 0.027 0.118 0.127 0.027 0.118 0.127 

Ovaries 0.052 0.102 0.115 0.052 0.102 0.115 0.056 0.110 0.125 0.056 0.110 0.125 

Testes 0.058 0.117 0.127 0.058 0.117 0.127 0.063 0.127 0.137 0.063 0.127 0.137 

Liver 0.059 0.106 0.108 0.059 0.106 0.108 0.063 0.115 0.117 0.063 0.115 0.117 

Lung 0.064 0.104 0.110 0.064 0.104 0.110 0.069 0.113 0.119 0.069 0.113 0.119 

Remainder organs 0.058 0.098 0.103 0.058 0.098 0.103 0.063 0.106 0.112 0.063 0.106 0.112 

Skin 0.075 0.104 0.108 0.075 0.104 0.108 0.081 0.112 0.117 0.081 0.112 0.117 

Stomach 0.058 0.110 0.115 0.058 0.110 0.115 0.063 0.119 0.125 0.063 0.119 0.125 

Thymus 0.044 0.111 0.126 0.044 0.111 0.126 0.047 0.120 0.137 0.047 0.120 0.137 

Thyroid 0.049 0.120 0.131 0.049 0.120 0.131 0.053 0.131 0.142 0.053 0.131 0.142 

Uterus 0.051 0.097 0.098 0.051 0.097 0.098 0.055 0.105 0.106 0.055 0.105 0.106 
4.3 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 36 of 41 

Evaluation of external dose from residual contamination 

The purpose of this section is to provide guidance for the evaluation of external dose from residual 

contamination and also dose associated with and the reuse of personal clothing between rollings. 

An estimate of surface contamination was calculated by using the terminal settling velocity of 0.00075 

m s-1 (TIB-0004, rev 2) multiplied by the rolling day concentrations and by the amount of time uranium 

was rolled in one year. The Simonds Saw and Steel concentration data was used for all years to 

simplify the calculations as it overestimates the later rolling data. This results in contamination of 

12,500,000 dpm m-2 (1,250,000 dpm 100 cm-2) which exceeds all the measured surface 

contamination levels. This value was then assumed to be constant thru all years of rolling. The 

residual contamination value was converted to dose using the dose coefficients for contaminated 

ground surfaces for U-238 and progeny Pa-234m and Th-234 from Federal Guidance Report No. 12 

(US EPA 1993). The doses from contaminated sources are in the following table. Doses were only 

listed for Skin, Bone Surfaces, and all other organs. The all other organ category is the highest other 

organ rounded up to the nearest mrem. The doses in Table 14 shall be entered into IREP assuming a 

photon energy range of 50% 30-250 keV and 50% >250 keV. 

Table 14: Annual dose from contaminated surfaces at Bethlehem Steel, 1949 to 1952. 

Skin 

(rem) 

Bone Surfaces 

(rem) 

All other organs 

(rem) 

All years 1.771 0.010 0.005 

The use of contaminated clothing following the rolling of uranium as discussed in worker interviews 

has been given careful consideration. Average dose data from contaminated clothing at Mallinckrodt 

indicate levels of 1.5 mrem/hour (AEC 1958). Bethlehem Steel doses were estimated using this as a 

bounding condition based on the types of materials handled and quantity of materials handled at 

Mallinckrodt. The dose rate was determined assuming the clothing was worn for two work weeks 

prior to cleaning. Therefore, the annual dose to the skin is determined by assuming 1.5 mrem/hour 

times 50 hours per week times 2 weeks per month times 12 months per year. This results in an 

annual dose to the skin of 1.8 rem per year which will be assigned a constant dose rate from electrons 

with an energy > 15 keV. 

5.0 OCCUPATIONAL MEDICAL DOSE 

This TBD assumes that all workers received an annual occupationally related diagnostic chest X-ray 

(Simonds 1948). The exposure geometry was assumed to be posterior-anterior (PA) (NIOSH 2002). 

Annual X-ray data from OTIB-0006, “Dose Reconstruction from Occupationally Related Diagnostic Xray Procedures” and associated instructions shall be used for the purposes of evaluating occupational 

medical dose at Bethlehem Steel. 

6.0 OCCUPATIONAL ENVIRONMENTAL DOSE 

Occupational environmental dose provides a mechanism to account for dose that has not been 

monitored or attributed to occupational exposure. The exposures of all employees of the Bethlehem 

Steel Corporation at the Lackawanna plant will be estimated based on the 95% air concentration at 

the rolling mill for a 10 hour day. This estimate precludes the use of environmental dose which would 
7.0 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 37 of 41 

be much lower than the exposures estimated. As such, no environmental dose shall be assigned to 

the workers at this facility. 

REFERENCES 

AEC 1948a: AEC (U.S. Atomic Energy Commission), Simonds Saw and Steel Company, 

Occupational Exposure to Radioactive Dust: Visit of October 27, 1948, New York Operations 

Office [p. 138, Simonds Saw and Steel Company.pdf]. 

AEC 1948b: AEC (U.S. Atomic Energy Commission), Simonds Saw and Steel Company, 

Occupational Exposure to Radioactive Dust: Visit of October 27, 1948, New York Operations 

Office [pp. 139-153, Simonds Saw and Steel Company.pdf]. 

AEC 1948c: AEC (U.S. Atomic Energy Commission). Simonds Saw and Steel Co. Occupational 

Exposure to Radioactive Dust, Visit of December 1, 1948. 

AEC 1949a: AEC (U.S. Atomic Energy Commission), Health Hazards in NYOO Facilities Producing 

and Processing Uranium: A Status Report- April 1, 1949, New York Operations Office, Medical 

Division, April 18. 

AEC 1949b: AEC (U.S. Atomic Energy Commission), Simonds Saw and Steel Company, Summary 

Report of Three Surveys, (October 27, 1948-February 15, 1949), New York Operations Office, 

Medical Division [p9. 250-252, Simonds Saw and Steel Company.pdf]. 

AEC 1949c: AEC (U.S. Atomic Energy Commission). Determination of Uranium in Air Dust Samples 

by Alpha Counting. NYOO-94, December 7, 1949. 

AEC 1949d: AEC (U.S. Atomic Energy Commission). Simonds Saw & Steel Co. Occupational 

Exposure to Radioactive Dust. Visits of May 2-20, 1949. 

AEC 1949e: AEC (U.S. Atomic Energy Commission). Results of Dust Samples Collected at Rolling 

Mill Area, Simonds Saw & Steel Co., July 6, 1949. 

AEC 1950a: AEC (U.S. Atomic Energy Commission). Simonds Saw and Steel Co. Occupational 

Exposure to Radioactive Dust January 6, 9, 10, 1950. February 1, 1950. 

AEC 1950b: AEC (U.S. Atomic Energy Commission). Simonds Saw and Steel Co. –Visits of 

February 13, 14, 17 and 20, 1950. April 16, 1950. 

AEC 1951a: AEC (US Atomic Energy Commission). Monthly Report of Field Activities, May –June 

1951. 

AEC 1951b: AEC (US Atomic Energy Commission). Continuous mill uranium rolling: Lackawanna 

Plant-Bethlehem Steel Company April 26, 27, 1951 by H.F. Reichard. May 18, 1951. 

AEC 1952a: AEC (U.S. Atomic Energy Commission), 1951-1952, “Air dust data from Bethlehem 

Steel Corporation’s Lackawanna Plant,” New York Operations Office, Medical Division, [pp. 4­

11, Bethlehem Steel Site Profile.pdf]. 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 38 of 41 

AEC 1953a: AEC (U.S. Atomic Energy Commission), Simonds Saw and Steel Company, 

Occupational Exposure to Uranium, New York Operations Office, Health and Safety Division, 

February 18 [p. 54, Simonds Saw and Steel Company.pdf]. 

AEC 1953b: AEC (US Atomic Energy Commission). Investigation of Dust Sources and Their Effect 

at a Rolling Mill. March 16, 1953. 

AEC 1958: Symposium on Occupational Health Experience and Practices in the Uranium Industry. 

October 15-17, 1958. 

Bolch, W.E., Farfan, E.B., Huh, C., Huston, T.E, 2001,: Influences of parameter uncertainties within 

the ICRP 66 respiratory tract model: particle deposition,” Health Physics, 81(4): 378-94. 

Bowman 1952: Bowman, H. T., Merrill, P. E., Schneider, C. A., and Yocco, A. S., 1952, Report on 

Trips to Bethlehem Steel Corporation, Lackawanna Plant, Buffalo, N.Y., Production Division of 

National Lead Company of Ohio, September 4 [p. 23, NY-Bethlehem Steel.pdf]. 

Breslin 1967: Breslin, A.J., Ong, L., Glauberman, H., George, A.C., LeClare, P. The Accuracy of 

Dust Exposure Estimates Obtained from Conventional Air Sampling. American Industrial 

Hygiene Association Journal. 1967. 

Coleman, R. L., Hudson, C. G., and Plato, P. A., 1983, “Depth-dose curves for 90Sr and natural and 

depleted uranium in mylar,” Health Physics, 44(4): 395-402. 

DOE 1982. DOE (US Department of Energy) Environmental Measurements Laboratory Procedures 

Manual. 1982. 

DOE (U.S. Department of Energy), 1985, FUSRAP Elimination Report for Bethlehem Steel 

Corporation, Lackawanna, New York [p. 64, Bethlehem Steel.pdf]. 

DOE (U.S. Department of Energy), 2001a, DOE Standard: Health Physics Manual of Good Practices 

for Uranium Facilities, DOE-STD-1136-2000, Change Notice No. 3, December 

http://tis.eh.doe.gov/techstds/standard/std1136/STD11362000.pdf. 

DOE (U.S. Department of Energy), 2001b, Preliminary Review of the Flow and Characteristics of 

Recycled Uranium Throughout the DOE Complex 1952-1999, Vol. 1, Project Overview, March 

http://tis.eh.doe.gov/legacy/reports/reports.html. 

DOE 1997 http://www.hanford.gov/doe/history/docs/rl-97-1047/index.pdf 

EPA (U.S. Environmental Protection Agency), 1993, External Exposure to Radionuclides in Air, 

Water, and Soil; Federal Guidance Report No. 12, Washington, D.C., September. 

Frey, H. C., and A. C. Cullen, 1995, “Distribution Development for Probabilistic Exposure 

Assessment,” Paper No. 95-94.02, Proceedings of the 88th Annual Meeting of the Air & Waste 

Management Association, San Antonio, Texas, June 18-23. 

HW-19066: Hanford Works. Rough draft-Health Problems Associated with Investigation of Off-Plant 

Uranium Rolling. F.E. Adley May 13, 1949. 
 

Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 39 of 41 

HW-22975: Hanford works . Experimental rolling of uranium: Lackawanna #3. HW-22975. Dec 13, 

1951. 

HW-22347: Hanford works. Trip Report: Visits to AEC New York Operations Office, Lackawanna 

Plant, Bethlehem Steel Company, Argonne National Laboratory August 24-29, 1951. HW22347. 

HW-23399: Hanford works. Trip Report: Development of a Uranium Rolling Process for Fernald. 

HW-23399. January 29, 1952. 

HW-23910: Hanford works. HW 23910 

HW-24849: Production Test 313-10506-M Irradiation of Alpha Canned Uranium Slugs from Rods Salt 

Bath Beta Heat-Treated at Lackawanna. HW-24849. June 27, 1952. 

Hershman, H.J., 1952, “Transmittal of the Monthly Progress Report for October, Monthly progress 

report for October 1952 covering activities at the Tonawanda Sub Office,” memorandum to 

R.J. Smith, October 21. 

ICRP (International Commission on Radiological Protection), 1994, Human Respiratory Tract Model 

for Radiological Protection, Publication 66, Pergamon Press, Oxford, England, p. 198. 

ICRP (International Commission on Radiological Protection), 1995, Age-dependent Doses to 

Members of the Public from Intake of Radionuclides: Part 4 Inhalation Dose Coefficients, 

Publication 71, Pergamon Press, Oxford, England, p. 299. 

ICRP 1997. ICRP (International Commission on Radiological Protection) ICRP 75, General Principles 

for the Radiation Protection of Workers. 

ICRP 2003. ICRP (International Commission on Radiological Protection). ICRP Supporting Guidance 

3: Guide for the Practical Application of the ICRP Human Respiratory Tract Model. Pergamon 

Press, Oxford, England. 

Kathren, R. L., V. E. Shockley, E. M. Thomas, and T. D. Taulbee, 2003, Technical Information 

Bulletin: Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedures, 

Revision 2, ORAUT-OTIB-0006, NIOSH Dose Reconstruction Project, Cincinnati, Ohio. 

Kosanovich, P. (Compensation Agent, L.U. 2603), 1979, letter to Robert Anderson (Bethlehem Steel 

Corporation), October 19 [p. 36, Bethlehem Steel Site Profile.pdf]. 

Leary 1987. From Fire to Rust: Business, Technology and Work at the Lackawanna Steel Plant, 

1899-1983. Leary, T.E., Sholes, E.C. Buffalo and Erie County Historical Society. 1987. 

LaMastra, A., 1976, “Investigation Report: Uranium Metal Rolling, 10” Bar Mill, Lackawanna Plant,” 

report to D. L. Webster, Bethlehem Steel Corporation, June 29. [p. 16, Bethlehem Steel.pdf]. 

Methner 2001. Methner, M.M., Feng, H.A., Utterback, D.F. Use of Historical Uranium Air Sampling 

Data to Estimate Worker Exposure Potential to Airborne Particulate in a Uranium Processing 

Facility. Applied Occupational and Environmental Hygiene. Vol 16 (12) 2001. 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 40 of 41 

Newton 1987. Newton, G.J., Hoover, M.D., Barr, E.B., Wong, B.A., Ritter, P.D. Colletion and 

Characterization of Aerosols from Metal Cutting Techniques Typically Used in 

Decommissioning Nuclear Facilities. Am. Ind. Hyg. Assoc. J. 48 (11) 922-932 (1987). 

NIOSH (National Institute for Occupational Safety and Health), 2002, External Dose Reconstruction 

Implementation Guideline, Revision 1, OCAS-IG-001, Office of Compensation Analysis and 

Support, Cincinnati, Ohio. 

NIOSH (National Institute for Occupational Safety and Health), 2004, Estimation of Ingestion Intakes, 

Revision 0, Technical Information Bulletin, OCAS-TIB-00?, Office of Compensation Analysis 

and Support, Cincinnati, Ohio. 

NLO (National Lead Company of Ohio), 1952a, Production Report on the Rolling of Two Hundred and 

Twenty-two Uranium Billets at Bethlehem Steel Corporation’s Lackawanna Plant on Saturday, 

April 12, 1952, Contract No. AT(30-1)-1156, April 28 [p. 1, NY-Bethlehem Steel.pdf]. 

NLO (National Lead Company of Ohio), 1952b, Production Report on the Rolling of Two Hundred an 

Eighteen Uranium Billets at Bethlehem Steel Corporation’s Lackawanna Plant on March 15, 

1952, Contract No. AT(30-1)-1156, March 21 [p. 37, Bethlehem Steel Site Profile.pdf]. 

NLO (National Lead Company of Ohio), 1952c, Air dust data from last rolling on September 14, 1952 

at Bethlehem Steel Corporation’s Lackawanna Plant, Health and Safety Division, September 

17 [pp. 12-15, Bethlehem Steel Site Profile.pdf]. 

ORNL (Oak Ridge National Laboratory), 1980, Preliminary Survey of Bethlehem Steel, Lackawanna, 

New York, March [p. 79, Bethlehem Steel.pdf]. 

Range, W., 1976, letter to David M. Anderson (Bethlehem Steel Corporation), Energy Research and 

Development Administration, June 7 [p. 71, Bethlehem Steel.pdf]. 

Schneider, C. A., and A. S. Yocce, no date, Report on Rollings and Bethlehem Steel Corporation, 

Lackawanna Plant, Buffalo, New York, Abstract, FMPC-79, [p. 35, Bethlehem Steel Site 

Profile.pdf]. 

Simonds (Simonds Saw & Steel Company), 1948, Hazard Identification, Evaluation, and Mitigation, 

[pp. 461-464, Simonds Saw and Steel Company.pdf]. 

Summary (Summary of Experimental Rollings Relating to Fernald Operations), 1951 [p. 20, 

Bethlehem Steel.pdf]. 

Thornton, W. T., 1977, “ERDA Resurvey Program – Bethlehem Steel, Lackawanna, NY,” report to 

R. H. Kennedy, Energy Research and Development Administration, March 16 [p. 75, 

Bethlehem Steel.pdf]. 

U.S. Army, 1989, Handbook of Safety Procedures for Processing Depleted Uranium, Chapter 3, 

Safety Considerations for Processing, Handling, and Testing of DU Components, AMC HDBK 

385-1.1-89, Department 

Additional communications and reviews that were used as data sources or guidance documents for 

preparation of this report include: 
Effective Date: 08/01/2006 Revision No. 00 Document No. OCAS-TKBS-0003 Page 41 of 41 

Deposition 2004a. Deposition of Stanley Tomasik Jr. March 29, 2004. 

Deposition 2004b. Deposition of Paul Kosanovich. April 5, 2004. 

SC&A 2004. Review of the NIOSH Site Profile for the Bethlehem Steel Plant, Lackawanna, NY. 

SCA-TR-TASK1-001. 

SC&A 2005. Letter report by SC&A regarding the Basis for Development of an Exposure Matrix for 

Bethlehem Steel Corporation, Lackawanna, New York; Period of Operation: 1949-1952, Rev. 

02 Draft. 

NIOSH 2004a. NIOSH comments on the SC&A Review of the Bethlehem Steel Site Profile December 

6, 2004. 

NIOSH 2005a. NIOSH comments on the SC&A Review of the Bethlehem Steel Site Profile Specific 

Responses to Findings, Observations and Procedural Non-Comformances. January 25, 2005 

Transcript November 28, 2005. NIOSH and SC&A conference call regarding Bethlehem Steel TBD 

comment resolution. 

Summary Notes June 19, 2006. Bethlehem Steel worker meeting. 

Personal communication. Mark Hoover (NIOSH) and Sam Glover (NIOSH). July 26, 2006.