Draft 

ISSUE RESOLUTION MATRIX FOR 

SC&A FINDINGS ON APPENDIX BB TO TBD-6000

S. Cohen & Associates 

1608 Spring Hill Road 

Suite 400 

Vienna, VA 22182 

Original Date: May 2, 2008 

NIOSH Responses: June 19, 2008 

Reissued: December 8, 2009 

Updated: July 25, 2011 

Disclaimer 

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

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

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

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

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

information only and that premature interpretations regarding its conclusions are unwarranted.
 INTRODUCTION

The present document presents an update of the issues arising from the SC&A review of 

Appendix BB to “Site Profiles for Atomic Weapons Employers that Worked Uranium and 

Thorium Metals” (Allen and Glover 2007). It is current as of the last meeting of the Advisory 

Board on Radiation and Worker Health (ABRWH) Work Group on TBD-6000 in Hebron, 

Kentucky, on October 12, 2010. A separate issues matrix pertaining to SC&A findings on the 

General Steel Industries (GSI) Special Exposure Cohort (SEC) petition and the corresponding 

National Institute for Occupational Safety and Health (NIOSH) evaluation report (ER) was 

issued in October 2009.1 We have updated the SEC issues matrix, including the latest 

developments on those issues, and are distributing it as a separate document simultaneously with 

the present matrix. Although the two SC&A reports that form the bases of these matrices have 

different objectives, there is considerable overlap between the two sets of issues and hence the 

two matrices. 

Time Line of Appendix BB Issues Matrix

 June 25, 2007: NIOSH issued Appendix BB to “Site Profiles for Atomic Weapons 

Employers that Worked Uranium and Thorium Metals” (Allen and Glover 2007). 

 March 17, 2008: SC&A (2008) issued a review of Appendix BB. Errata sheets 

correcting two tables in the report were sent out on March 20, and a revised version that 

complied with the Privacy Act was released on April 21. 

 May 2, 2008: SC&A distributed the “Issue Resolution Matrix for SC&A Findings on 

Appendix BB” which listed 13 issues. These issues were taken from the list of 13 

findings2 presented in the executive summary of our review of Appendix BB (SC&A 

2008). 

 June 19, 2008: NIOSH responded to the 13 issues, inserting its responses in the boxes 

labeled “NIOSH Response.” 

 December 16, 2009: The ABRWH Work Group on TBD 6000/60013 met in Hebron, 

Kentucky, and recommended action items to NIOSH regarding the Appendix BB 

issues. 

 April 24, 2010: Paul Ziemer, Chair of ABRWH Work Group on TBD-6000, issued a 

memo summarizing the action items from the December 16, 2009, work group meeting 

(ABRWH 2010). We have summarized each action item pertaining to Appendix BB in 

the box labeled “Board Action.” 

 1

 Three versions of the matrix were distributed to the ABRWH Work Group on TBD 6000/6001: (1) the 

initial matrix on October 2, (2) NIOSH responses to the issues, distributed by NIOSH on October 9, and (3) SC&A's 

reply to the NIOSH responses, on October 12. 

2

 The “findings” in the earlier report are presented as “issues” in the present document. 

3

 In March 2010, this work group was divided into two separate work groups—Advisory Board Work 

Group on TBD 6000 and Advisory Board Work Group on TBD 6001. 

Draft Appendix BB Issues Matrix 2 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
 October 08, 2010: Allen (2010) prepared the “Path Forward for GSI Appendix and ER 

Review” in which he presented the proposed NIOSH responses to several of the 

Appendix BB issues. We have summarized these responses in boxes labeled “Path 

Forward” in the appropriate locations in the matrix. 

 October 12, 2010: The Work Group on TBD-6000 met in Hebron, Kentucky. The 

work group asked SC&A to update both the Appendix BB and the GSI SEC issues 

matrices to reflect work group recommendations and the NIOSH responses in the “Path 

Forward.” 

 July 23, 2011: SC&A updated the matrix, appending an observation or reply to each 

relevant issue in the appropriate location in the matrix. We also listed the current status 

of each issue. 

Status Summary

 Issues 3 and 13: In Progress—NIOSH and SC&A have agreed in principle—we are 

awaiting the new NIOSH analysis to confirm that the revisions are implemented. 

 Issue 10 (work hours): Closed —Dr. Ziemer noted that the Work Group, NIOSH, and 

SC&A are in agreement. 

 Issue 12 (surface contamination and resuspension): Transferred to TBD-6000. 

 Issues 1, 2, 4–9, 11, and 13: Open. 

Level of Importance

We have assigned three levels of importance to these issues, which we define in the following 

manner: 

 High: Capable of having a significant impact on individual dose reconstructions and 

hence on the probability of causation (POC) for the claimants. 

 Medium: Could alter the POC for some individuals. 

 Low: Recommended technical improvements in the accuracy of dose reconstructions, 

but unlikely to have major impacts in most cases.

We have assigned the following levels of importance to these issues: 

 Issues 1, 3–9, and 11: High

 Issue 2 (extending covered period to Jan. 1, 1952): Medium

 Issue 10 (closed), and Issue 12 (transferred): Levels of importance irrelevant 

 Issue 13 (use of correct and consistent units of dose and exposure): Low 

Draft Appendix BB Issues Matrix 3 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Draft Appendix BB Issues Matrix 4 SC&A –Updated July 25, 2011 

This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 

NOTICE: 

Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000

Issue 1: Completeness of Data Sources 

SC&A Finding: The authors of Appendix BB have not utilized some key information on the GSI Granite 

City site. For example, they failed to note the presence of two betatrons, housed in two different 

buildings, as indicated in the reports by Murray and Uziel (1992), and Murray and Brown (1994), and as 

was brought out at the General Steel Industries Worker Outreach Meeting on August 21, 2006. Other 

examples of incomplete utilization of available data are presented in the context of other findings 

discussed below. 

NIOSH Response (6/19/08): The information was used in the preparation of the appendix though it was 

admittedly not well documented. The presence of a second betatron likely would not change the modeled 

exposure (since a worker could be in proximity to only one at a time), but information that has been 

refined since the earliest discussions might affect the modeled dose. However, NIOSH has obtained film 

badge results for the betatron operators and is in the process of comparing this data to the modeled 

doses. 

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items: (4/24/10) (ABRWH 2010): 

 Concerning Landauer report on Picker X Ray film badge records, NIOSH is still awaiting a report 

back from Landauer. (Reference: p. 125 of the 12/[16]/09 transcript.) 

 NIOSH is to evaluate new source term information (that had been identified by the petitioner) to 

determine if Appendix BB needs to be updated/revised. (Reference: p. 125 of the 12/[16]/09 

transcript.)

SC&A Observation (7/23/11): Regarding possible Picker X-Ray film badge records: During a telephone 

conversation with Robert Anigstein (SC&A), the late [redacted], former betatron supervisor, hypothesized 

that since GSI purchased x-ray film from Picker, they might have obtained their film badges from that 

company before switching to Landauer in November 1963. This hypothesis was buttressed by our 

learning that Picker had, in fact, offered film badge dosimetry services, and that there were currently one 

or more file cabinets labeled “Picker” at Landauer. However, the Atomic Energy Commission (AEC) 

licensing records indicate that film badges during 1962–1963 were provided by the Nuclear Consultants 

Corporation (no longer in business). There is no evidence of a film badge dosimetry program at GSI prior 

to 1962. 

Status (7/23/11): Open.

Issue 2: Period of Covered Employment 

SC&A Finding: Appendix BB states that the covered activities took place in 1953–1966. It is plausible 

and claimant favorable to assume that this work began in 1952. We base this assumption on Atomic 

Energy Commission “Correspondence Reference Form,” with a hand-corrected date of December 5, 

1952, that has a summary titled, “Regarding ingots of uranium metal furnished to General Steel Castings 

Co. for betatron testing.” Since the Army installed the first betatron in Granite City in January 1952, an 

event that was reported in a local newspaper, it seems likely that Mallinckrodt would have taken 

advantage of this facility at an early date. 

NIOSH Response (6/19/08): NIOSH uses the official covered period established by the Department of 

Labor, and does not have the authority to amend that covered period. It is our understanding that this 

information was available at the time the period was established for GSI however, we will forward the 

information to the DOL for their consideration. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Board Action (12/16/09: Discussed at meeting of the Work Group on TBD-6000/6001. 

Action item (4/24/10) (ABRWH 2010): 

 NIOSH to confirm that DOL received information concerning a possible start date for the covered 

period (1952 rather than 1953). (Reference: p. [151] of the 12/[16]/09 transcript.) 

SC&A Reply (7/23/11): We have not seen any further communication regarding receipt by DOL of 

information from NIOSH. We have since found an announcement by the U.S. Army on January 13, 1952, 

regarding the installation of a betatron at GSI in Granite City, Illinois, reported in the New York Times on 

the following day. The assumed 1953 starting date is based on a single AEC memo, which is cited by 

DOE in qualifying the site for inclusion in FUSRAP. DOE would have had no incentive to determine if the 

starting date could have been 1952, since that would not have affected the eligibility of the site for 

FUSRAP. DOL should be informed that it is at least equally likely that AEC started utilizing the GSI 

betatron in 1952 as in 1953. 

Conclusion: An additional year of covered employment may affect the POC for some claimants. 

Status (7/23/11): Open. 

Issue 3: Underestimate of Betatron Beam Intensity 

SC&A Finding: The authors assume a betatron beam intensity of 100 R/min (without the aluminum 

beam-flattening compensator) at a distance of 3 ft from the target. They cite an interview with Jack 

Schuetz as the source of information that the betatron beam had a “design maximum” output of 100 

R/min. This value is inconsistent with the material furnished by Schuetz (2007), which lists outputs of up 

to 282 R/min. It is also inconsistent with the Allis-Chalmers acceptance criteria for the betatron tubes, 

which required a minimum output of 220 R/min at 25 MeV. We find that assigning an uncompensated 

intensity of 250 R/min at 3 ft is reasonable and claimant favorable. 

NIOSH Response (6/19/08): To be clear, Mr. Schuetz indicated 

“Tubes manufactured in the early 1950s produced outputs between 125-150 R/M, the 1960s 

between 200-275 R/M and by the late 1970s, between 300-375 R/M @ 25 Mv. These levels 

were only obtainable in my laboratory machine with varying percent reductions depending on 

individual field locations and whether in-house maintenance personnel or my trained service 

engineers installed the tubes.” 

Mr. Schuetz then went on to list the last 7 tubes purchased by GSI in a table. The shipping dates ranged 

from 12-29-1969 to 5-31-1973. The output at 25 Mv ranged from 260 to 282. At the 8/11/2006 worker 

outreach meeting, operators recalled values of 100 R/M from the old betatron and 250 R/M from the new 

betatron. Based on worker accounts, NIOSH concluded that the old betatron, which dated from the early 

1950's could only develop 100 R/m in use at GSI, while the new betatron could develop 250 R/m. This 

information, along with other refined information and possible issues with uranium [activation], could 

affect the modeled dose, but NIOSH has obtained film badge results for the betatron operators and is in 

the process of comparing this data to the modeled doses. 

However, as indicated in the SC&A review, NIOSH has obtained film badge results for betatron operators. 

We are in the process of comparing this data to the modeled estimates provided by both the appendix 

and SC&A.

Path Forward (10/08/10) (Allen 2010): NIOSH proposes using a value of 100 R/min for the old betatron 

machine and 250 R/min for the new betatron machine. This is in keeping with recollections of former GSI 

radiographers that indicate the old betatron had a lower output.

Draft Appendix BB Issues Matrix 5 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Board Action (10/12/10): Paul Ziemer, Chair of TBD-6000 Work Group, confirmed that NIOSH and 

SC&A agreed that the unmodulated output of the new betatron should be modeled as 250 R/min at 3 ft 

from the internal betatron target, which is reduced to approximately 160 by the aluminum beam-flattening 

compensator. It was also agreed that the output of the old betatron should be modeled as 100 R/min, 

with the compensator in place. 

Status (7/23/11): In progress, pending completion of revised NIOSH dose assessments. 

Issue 4: Underestimate of Stray Radiation from Betatron 

SC&A Finding: Appendix BB understates the stray radiation during the operation of the betatrons. Our 

calculations show higher dose rates in the control rooms than the 0.72 mrem/h cited in the Appendix. We 

calculated effective dose rates of 208 mrem/h on the roof, which was occasionally occupied by 

maintenance workers, 22 mrem/h in a restroom, and up to 51 mrem/h in other areas accessible to 

workers while the betatron was in operation. The Appendix ignores neutrons generated in the betatron 

target, which make a minor but potentially significant contribution to the effective doses. 

NIOSH Response (6/19/08): As indicated in the SC&A review, NIOSH has obtained film badge results 

for betatron operators. We are in the process of comparing this data to the modeled estimates provided 

by both the appendix and SC&A. The data includes an area dosimeter from the Betatron control room. 

Path Forward (10/08/10) (Allen 2010): 

New Betatron Building:

 Develop exposure scenarios for betatron x-ray examination, “shooting scenarios” (shooting angle, 

duration of exposure, time between exposures, etc.); 

 Develop scenarios for potential worker exposures during betatron operations “worker scenarios” 

(working on the roof, occupying the rest room, etc.); 

 Develop a model of the betatron building using new dimension information and “calibrate” the 

model using the 80 Ci Co-60 source survey; 

 Determine dose rate at various locations associated with “worker exposure scenarios” from each of

the “shooting scenarios” and include the betatron control room as one location; and, 

 Combine dose rates from various combinations of “shooting scenarios” into realistic combinations 

consistent with a heavy utilization but not to exceed 10 mrem per 168 hours in the betatron control 

room. 

Old Betatron Building:

 Similar path forward for the Old Betatron except “worker exposure scenarios” change and there is no 

“calibration” survey.

SC&A Reply (7/23/11): Before assuming that the dose inside the betatron control room did not exceed 

10 mrem per 168 hours, NIOSH needs to establish the following: 

 Was film badge No. 001, called “BETATRON CTL,” in fact kept in the betatron control room? 

 Since there were two betatrons operating at the time, in two separate buildings, do we know which 

of the two control rooms housed this badge? 

Absent any records or worker testimony, we do not agree that this is a correct, claimant-favorable 

assumption on which NIOSH should base its exposure model. 

We also question the assumed MDL of 10 mrem, based on the following observations by Joseph 

Zlotnicki, CHP (former Landauer official, currently member of SC&A staff): 

Draft Appendix BB Issues Matrix 6 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Following is my opinion regarding the Landauer film dosimetry MDL for high energy photons. 

(>250 keV). 

While a film dosimeter can readily measure 10 mrem of low energy photons, it is a much more 

difficult task once the photon energy reaches a few hundred keV or above. The over-response of 

the film emulsion to x-rays around 40 keV by a factor of 30 was a blessing and a curse for film 

badge dosimetry and was one of the reasons that film has largely been replaced. 

It is very difficult to say what the MDL would be for high energy photons, but it almost certainly 

was higher than 10 mrem, even on a good day. Below are some of the factors that one would 

need to consider in deriving the MDL. Note that some items are systematic and some vary day to 

day and person to person: 

 Film type 

 Base fog (age since manufacture and storage conditions) 

 Processing 

 Storage during the issuance period 

 Background radiation levels 

 Storage and handling of background, calibration and control film 

 Densitometer calibration, sensitivity and step size per density unit 

 Calibration methods, energy and lowest dose point 

 Rounding and truncation preference 

 Film holder design 

 Wear location on body (backscatter) 

As can be seen, there are numerous sources of variation. Based on my experience, a single click 

(i.e. the smallest quantum of dose) on a good densitometer would have been on the order of 15 

mrem for high energy photons. Remember, the assigned dose is determined by subtracting two 

numbers that are derived from the density on the user film and the density on the background or 

“blank.” The subtraction was probably done in terms of dose, not density, however. In other 

words, the density on the two films being compared was converted to dose and subtracted in the 

dose, not density, domain. 

Other film system reviews have recommended using 40 mrem as the MDL, including the National 

Research Council report on atmospheric testing and ORAU reports on DOE sites. This might be 

a little high for Landauer’s system, but 20 mrem to 30 mrem might be a better choice than 10 

mrem for high energy photons.

Board Action: 

Status (7/23/11): Open

Issue 5: Failure to Assess Other Radiography Sources 

SC&A Finding: The authors acknowledge the use of other radiography sources, notably 60Co, but 

dismiss the doses from these sources, stating that the doses from the betatron would be more limiting. 

As shown in our analysis, an 80-Ci 60Co source produced a dose rate of up to 960 mrem/h on the roof of 

the New Betatron Building, and rates of 12–16 mrem/h in other locations outside the building. 

Furthermore, stray radiation from a 250-mCi 60Co source that was used in a lightly shielded structure 

could have produced dose rates in accessible areas of 9–17 mrem/h. 

These rates are one to three orders of magnitude higher than the stray radiation cited in the Appendix. 

Draft Appendix BB Issues Matrix 7 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

NIOSH Response (6/19/08): As indicated in the SC&A review, NIOSH has obtained film badge results 

for betatron operators. We are in the process of comparing this data to the modeled estimates provided 

by both the appendix and SC&A. The data includes operators that indicated they used the sources. 

Path Forward (10/08/10) (Allen 2010): 

GSI Co-60 sources (1962 on)

 Develop worker exposure scenarios–both radiography room and open area radiography 

 Radiographers reported to wear film badges when working with isotopes 

 Divide film badge readings into normal and incident readings (assume over 100 mr in a week is an 

incident) 

 Determine frequency and amount of incident exposures and distribution of remaining doses. 

 Reconcile “normal” film badge readings with radiographer exposure scenarios 

 Add incident exposure based on frequency and amount of incidents 

X-ray Machines

 X-ray machine usage described as being infrequent. 

 Radiographers wore film badges during betatron operations and source operations (when film 

badges were issued). A natural assumption is that they would have worn them for x-ray machine 

operations as well. 

 Photon beam from an x-ray machine is directional and pointed at a piece of equipment being 

examined. It is not realistic to believe it would be routinely pointed at a nearby individual. 

 Develop model to determine exposure rate from machine photon leakage and backscatter from 

steel. Compare dose rates to other sources to determine if further analysis is necessary. 

Ra-226 sources

SC&A presented a model for exposure from a 500-mg Ra-226 source using a fishing pole technique. In 

the model it is assumed the radiographer holds the source for the duration of the exposure. The 

technique is sometimes performed in that manner but cannot be performed for very long durations 

because variance in the position of the source will affect the clarity of the radiograph. Therefore, the 

technique requires the radiographer to hold the source very steady for the duration of the exposure. The 

fishing pole technique can also be used as a technique to move the source from the shielded container 

and placing it in a location for the x ray. In both cases, a one minute duration is not unrealistic. 

A former GSI worker remembered seeing a pole he believed to be the fishing pole for radiography and 

estimated its length to be 12 feet. The purpose of the pole is to increase the distance between 

radiographer and source. The estimate of the source being 1 meter from the radiographer leaves nine 

feet remaining and defeats the purpose of using a pole. It is more realistic to believe the radiographer is 

in the middle of the length of pole or near the opposite end from the source. The middle of the pole would 

represent a six foot distance and the calculation performed by SC&A would change from 28 rem per year 

to approximately 7 rem per year. Also, the calculation assumes one person performs all the radiography 

at the site. It is likely that duties were shared and this dose can be at least divided by two to represent at 

least two radiographers. 

St. Louis Testing Sources

St. Louis Testing was contracted to perform some radiography at GSI. The individual that indicated he 

did this work discussed using a 10 curie Co-60 source outdoors to examine Westinghouse casings. He 

indicated the exposures took one week and a half a day (180 hours). He also indicated a boundary was 

delineated at the 2 mr/hr point and 2 radiographers kept the area under constant surveillance. Lastly, he 

indicated that 10 of these exposures were performed over a six month period. For a typical work week of 

65 hours, a GSI employee would be on site for approximately 69.6 hours of each exposure. If at the 

radiography boundary the entire time, it would equal 139 mrem of dose per shot. Multiplying that by 10 

shots equals 1.39 rem of dose over that six month period. The other radiography remembered by the St. 

Draft Appendix BB Issues Matrix 8 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Louis Testing employee was the use of a 50 curie Ir-192 source to perform some repair shots in the repair 

area. The individual indicated that the Ir-192 showed more detail than the betatron and implied this 

wasn’t used a lot because it caused more castings to be rejected. 

The 50 curie Ir-192 source would produce a dose rate approximately 1.8 times higher than a 10 curie Co60 source reducing the duration of the exposure necessary to expose the film. Repair shots would 

concentrate on a particular area rather than the overall casting. This would allow the source to film 

distance to be reduced and further shorten the duration of the shot. Lastly, the St. Louis Testing 

employee implied few shots were performed with this source. Even though the source was stronger, the 

2 mr/hr boundary would still be the standard used to delineate an area. Taken together, these pieces of 

information imply that number and duration of Ir-192 shots should be less than the Co-60 shots while the 

same 2 mr/hr boundary would be used. It should therefore be a bounding estimate to double the 1.39 

rem estimate of the Co-60 source to account for dose from the Ir-192 source. 

SC&A Reply (7/23/11): There are no data on radiation exposures from April 1962, when the two 60Co 

sources were procured, until mid-November 1963, when the Landauer film badge monitoring began. 

Since the latter date coincides with the installation of the new betatron (transferred from the closed GSI 

facility in Eddystone, Pennsylvania), exposure conditions were most likely different during the Landauer 

period. For instance, the expanded use of the betatrons might have led to a decrease in the use of 

sealed sources and thus a lower frequency of incidents. Consequently, it would be inappropriate to apply 

a model based on the frequency of incidents during the Landauer period to an earlier time. 

We agree that workers would not routinely be exposed to the direct beam from the x-ray machines. 

However, [redacted], a former GSI betatron operator, reported at least one incident in which the x-ray 

machine was activated with workers in the room (Anigstein 2010b). [Redacted], non-radiographers not 

wearing film badges could also have been accidentally exposed in this or other incidents of which neither 

NIOSH nor we have any knowledge. 

Allen (2010) is incorrect in characterizing the calculation of exposures of radiographers from 226Ra 

sources, performed by SC&A (Anigstein 2010a), as a model. As stated in our report, “Although we 

cannot construct a plausible bounding exposure scenario for the exposure of a worker performing 226Ra 

radiography with the fishpole technique, we can perform a sample calculation [italics added] to indicate 

the potential exposure from such a source.” We agree that one former worker recalled walking past the 

area used for the sealed-source radiography and seeing a pole leaning against the wall that he estimated 

to be 12-ft long, which he assumed was used in the fishpole technique. More reliable information was 

provided by [redacted], who performed such radiography. He stated that the pole was 4–6 ft long, and 

that the exposed source was 4–6 ft from his body (Anigstein 2010b). [Redacted] was interviewed after 

Anigstein (2010a) performed the sample calculation. Given the range of distances recalled by 

[redacted], we believe that a claimant-favorable distance would be 142 cm (122 [= 4 ft] + 10 [distance 

from skin to center of torso] = 142). 

There is no basis for dividing the exposure among two radiographers. If 10 exposures were performed 

per shift, these could be accommodated by one worker using a single source if the average exposure was 

less than, say, 45 minutes. If the exposures were longer, the same worker could set up one exposure, 

then use the second radium source to set up another exposure in a different location. Distributing the 

work among two radiographers is not based on factual data and is not claimant favorable. 

We do not agree with the estimated exposures of GSI workers from radiography performed by St. Louis 

Testing. As stated by Anigstein (2010a, PA-cleared version): 

Mr. Sinn [of St. Louis Testing] later explained that he meant that there was one radiographer on 

each shift. . . With only one radiographer on duty, there would have thus been times when the 

area was unattended while he took necessary breaks. Some GSI workers could have intruded 

into the exclusion area and received exposures from these sources that were greater than those 

from the 260 and 280 mCi 60Co sources possessed by GSI. 

Board Action: 

Draft Appendix BB Issues Matrix 9 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Status (7/23/11): Open

Issue 6: Neglect of Skin Dose 

SC&A Finding: Appendix BB ignores the skin dose from beta radiation from activated steel. Our 

analysis yielded doses of about 2 rads/y to bare skin from beta radiation from irradiated steel. 

NIOSH Response (6/19/08): As indicated in the SC&A review, NIOSH has obtained film badge results 

for betatron operators. We are in the process of comparing this data to the modeled estimates provided 

by both the appendix and SC&A. The modeled beta dose and photon dose are linked and so the beta 

dose can adjusted to the film badge data by using the model.

SC&A Reply (7/23/11): Although Allen (2010) discussed plans for modeling the activation of steel, the 

“Path Forward” does not mention calculation of skin dose. 

Board Action: 

Status (7/23/11): Open

Issue 7: Underestimate of Exposure to Activated Betatron Apparatus 

SC&A Finding: Appendix BB assigns an initial exposure rate of the betatron operator of 15 mR/h from 

activation products in the betatron apparatus, based on a measurement reported by Schuetz (2007) at 

6 ft (183 cm) from the betatron target. This exposure rate would apply only if the operator were located 

6 ft from the betatron during the setup period. Such an assumption is inconsistent with the calculation of 

dose rates from the handling of irradiated steel or uranium, which assumes that the betatron operator 

spent one half of the setup time at a distance of 1 ft (30 cm) from the metal and the rest at 1 m. 

Assuming, as we did, that his distance from the betatron target ranged uniformly between 3 and 6 ft (61–

183 cm) would double his exposure rate. 

NIOSH Response (6/19/08): As indicated in the SC&A review, NIOSH has obtained film badge results 

for betatron operators. We are in the process of comparing this data to the modeled estimates provided 

by both the appendix and SC&A.

Path Forward (10/08/10) (Allen 2010): A former Allis-Chalmers employee indicated that the betatron 

machine exhibited residual radioactivity causing an exposure rate of about 15 mr/hr in front of the 

machine six feet from the target. He further indicated that dose rate diminished to near zero within 

15 minutes and that identical measurement behind the machine showed 1% of the forward readings. To 

investigate the source of this exposure, activation of several components was explored, as well as the 

possibility of some residual current in the accelerator causing this effect. No viable explanation for this 

phenomenon has yet been discovered. However, the Allis-Chalmers employee did not state the 

conditions that were associated with these measurements. If little air movement occurred it could be 

possible that the 15 mr/hr exposure rate was caused by air activation. Under those conditions, the 

activated air would exhibit the highest concentration where the beam was exposing the air and low 

concentrations behind the machine. The half-life of N-13 is approximately 2 minutes while that of O-15 is 

approximately 10 minutes. This does not necessarily correlate well with the dose rate diminishing to zero 

within 15 minutes. However, considering that some air movement would dilute the concentration and 

lower the dose rate, it appears to be a possible explanation for this dose rate measurement. 

Air activation would cause an external dose from the air, not the machine. Operators exposed to this 

would be exposed in an isotropic geometry. The 511 keV photon would be easily detectable by the film 

badges worn by the operators. Therefore, residual radiation coming from the machine will not be 

considered a source of radiation exposure for the radiographers. Instead, air activation will be considered 

in the scenarios. 

Draft Appendix BB Issues Matrix 10 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

SC&A Reply (7/23/11): We do not agree that air activation can account for the residual radiation from 

the betatron after shutoff that was measured by Jack Schuetz when he was employed by Allis-Chalmers. 

As was discussed by Robert Anigstein (SC&A) at the October 12, 2010, work group meeting, SC&A had 

calculated the exposure of the betatron operator from air activation, obtaining an estimated exposure of 

6 μR per shift. It is not plausible that the 15 mR/h reported by Mr. Schuetz could be due to air activation. 

We disagree with the decision, reported by Allen (2010), not to consider the residual radiation from the 

betatron as a source of exposure of the radiographers. We note that Mr. Schuetz’s account is 

collaborated by the betatron instruction manual (Allis-Chalmers 1951), which warns users not to touch the 

betatron doughnut for at least 15 min after the machine is turned off, stating that the tube becomes 

“intensely radioactive” while generating x rays. Although our MCNPX analysis could not replicate this 

phenomenon, our simplified model of the betatron most likely did not include all materials in the doughnut 

tube nor in the magnets and surrounding structures. Thus, the analysis does not invalidate Schuetz’s 

data. 

The fact that elevated exposures were, for the most part, not found in the film badge dosimetry data also 

does not invalidate these observations. SC&A (2010) stated: 

The response of film badges worn by GSI workers was highly dependent on the energies and 

angles of incidence of the photon radiation. This issue assumes particular significance when the 

exposure is in the posteroanterior (PA) orientation, as was the case for at least part of the time 

that the betatron operator was setting up the exposure of a steel casting and was exposed to 

residual radiation from the betatron apparatus. He would have his back to the instrument when 

he was marking the casting, using the remote controls to adjust the position of the betatron, and 

measuring the distance to the casting. According to ICRP (1997, table A.22), the ratio between 

the directional dose equivalent at a depth of 10 mm at 180° to that at 0° [H'(10,180°):H'(10,0°)] 

ranges from zero (i.e., < 0.005) for photon energies E ≤ 30 keV to 0.62 at E = 10 MeV.

Board Action: 

Status (7/23/11): Open

Issue 8: Underestimate of Work Hours 

SC&A Finding: The authors [Allen and Glover (2007)] assume that the GSI employees worked an 

average of 2,400 h/y. This estimate is contrary to the recollection of the workers, who remember working 

50–80 h/week. The consensus estimate was 65 h/week, or 3,250 h/y. Such a value is reasonable and 

claimant favorable, and should be adopted as a default value for dose reconstruction. 

NIOSH Response (6/19/08): As indicated in the SC&A review, NIOSH has obtained film badge results 

for betatron operators. We are in the process of comparing this data to the modeled estimates provided 

by both the appendix and SC&A. Since the film badges measure the dose received over the course of a 

week, the amount of time taken to receive that dose would no longer be relevant. 

Path Forward (10/08/10) (Allen 2010): Operators provided an estimate of typical work hours different 

than that utilized by the appendix (3250 hrs per year). The path forward addresses revising the model 

taking all new information into account and including the operator’s estimate of work hours.

Board Action (10/12/10): Paul Ziemer, Chair of TBD-6000 Work Group, noted that there is agreement 

on the length of the work week among NIOSH, the WG, and SC&A. 

Status (10/12/10): Closed 

Draft Appendix BB Issues Matrix 11 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Issue 9: Mischaracterization of Steel Work Practices

SC&A Finding: According to Appendix BB, “The overall estimate for Betatron x-ray of steel is: 30 

minutes setup with no dose; one hour Betatron x-ray exposure due to skyshine at 0.72 mR/hr; and, 30 

minutes takedown.” Such a description is at variance with a report prepared by former GSI workers that 

indicates repeated exposures of the same casting, with 12–15 minutes between exposures. Since both 

the steel and the betatron were activated from previous exposures, there was no setup period with no 

dose. Furthermore, most exposures were of a few minutes’ duration, which reduced the time in the 

control room, where the exposure rates were relatively low, and increased the number of times during the 

day that the operators were exposed to the steel and the betatron. 

NIOSH Response (6/19/08): As indicated in the SC&A review, NIOSH has obtained film badge results 

for betatron operators. We are in the process of comparing this data to the modeled estimates provided 

by both the appendix and SC&A. Since the film badges measure the dose received while performing this 

work, the exact exposure scenario is no longer important. 

Path Forward (10/08/10) (Allen 2010): The path forward states that NIOSH will revise the model using 

new exposure scenarios [see Issue 4, above.] 

Board Action: 

Status (7/23/11): Open

Issue 10: Errors in Calculating Dose Rates from Uranium 

SC&A Finding: We have found errors in calculations that lead to a significant overstatement of the dose 

rates from uranium presented in Appendix BB. The Appendix lists a dose of 21.7 mrem during the first 30 

min following irradiation. Our model yields a dose of 1.4 mrem, using the same assumptions regarding 

the duration of the radiographic exposure, the duration of the worker’s exposure, and his distances from 

the metal. Since the dose rates in the Appendix are not scientifically correct, they should not be used as 

the basis of dose reconstructions of exposed workers. 

NIOSH Response (6/19/08): To the extent modeled doses are used, any errors in this calculation will be 

corrected. However NIOSH has obtained film badge results for betatron operators. We are in the 

process of comparing this data to the modeled estimates provided by both the appendix and SC&A. 

Path Forward (10/08/10) (Allen 2010): 

Uranium activation and fission products

 Assume four one hour shots per uranium ingot or slice 

 Determine dose rates from activation and fission products and add to natural activity of uranium 

metal

Board Action: 

Status (7/23/11): Open

Draft Appendix BB Issues Matrix 12 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 
Issue Resolution Matrix for SC&A Findings on Appendix BB to TBD-6000 (continued)

Draft Appendix BB Issues Matrix 13 SC&A –Updated July 25, 2011 

This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review. 

NOTICE: 

Issue 11: Underestimate of Doses to Other Workers 

SC&A Finding: Appendix BB states that workers who did not work in the betatron building and did not 

routinely handle steel or uranium within 2 h following the x-ray exposure should be assigned a “dose” rate 

of 0.72 mR/h. As discussed under Finding 4, there were many situations in which these other workers 

could have been exposed to much higher radiation levels. 

NIOSH Response (6/19/08): This finding appears to be a included in finding #4. As noted, NIOSH is in 

the process of evaluating the affect of film badge data on the exposure models presented by both the 

appendix and SC&A. 

Path Forward (10/08/10) (Allen 2010): The path forward addresses developing new exposure scenarios 

based on all the information that has come to NIOSH since the appendix was approved.

Board Action

Status (7/23/11): Open

Issue 12: Incorrect Calculation of Residual Surface Contamination and Resuspension 

SC&A Finding: The Appendix uses the same methods of calculating surface contamination and 

resuspension as were used in the main report (Scherpelz 2006). In SC&A’s review of that report, we 

pointed out that calculating surface contamination on the basis of a settling velocity of 5 μm AMAD 

aerosol particles ignores the sloughing off of much larger flakes of uranium oxide that fall directly onto the 

floor. We also showed that a resuspension factor of 10-6 m-1 might understate the airborne concentrations 

by one or more orders of magnitude. 

NIOSH Response (6/19/08): This finding indicates it is a reiteration of a comment from the Battelle-TBD6000 review. Therefore the finding should be addressed in that review rather than here. 

Board Action: 

Status (7/23/11): Transferred to TBD-6000

Issue 13: Use of Incorrect Units 

SC&A Finding: The Appendix switches erratically between units of mrem and mR. The results of the 

skyshine calculations are stated as 0.72 mrem/h in Section BB.4.2, then as 0.72 mR/h in later sections. 

Dose rates are incorrectly stated in units of mR/h, which is an exposure rate. Uranium dose rates are 

stated in mrem, whereas our review of the output files from the Appendix BB analysis shows that the 

calculations were of air kerma, which is expressed in mrads. A notable misuse of units appears in the 

table in Section BB.4.5, where the dose to the skin from beta radiation is expressed as “R/yr.” Beta 

radiation should not be expressed in roentgens, which only apply to photons.

NIOSH Response (6/19/08): We accept the comment and will correct the units in any future revisions to 

the appendix. 

Board Action: 

Status (7/23/11): In progress, pending completion of revised Appendix BB. 
References 

Advisory Board on Radiation and Worker Health, TBD-6000 Work Group (ABRWH). 2010. 

“Summary of Action Items and Issues from December 12 [sic], 2009 Meeting” [Note: Meeting 

was held on December 16, 2009] (MS Word metadata: Author Paul L. Ziemer, created 4/24/10.) 

Allen, D. (NIOSH/DCAS). 2010. “Path Forward for GSI Appendix and ER Review” (October 

08, 2010). 

Allen, D., and S. Glover. 2007. “Site Profiles for Atomic Weapons Employers that Worked 

Uranium and Thorium Metals - Appendix BB: General Steel Industries,” Battelle-TBD-6000, 

Appendix BB, Rev. 0. http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r0.pdf

Allis-Chalmers Manufacturing Company (Allis-Chalmers). 1951. “Betatron Instruction Manual.” 

Milwaukee, Wisconsin: Author. 

Anigstein, R. (SC&A). 2010a. “Review of NIOSH White Paper on Portable Radiography 

Sources at GSI” (September 23, 2010). 

Anigstein, R. (SC&A). 2010b. “Reports of Interviews with Three Former GSI Employees” 

(November 29, 2010). 

International Commission on Radiological Protection (ICRP). 1997. “Conversion Coefficients 

for use in Radiological Protection against External Radiation,” ICRP Publication 74. Annals of 

the ICRP, 26 (3/4). Tarrytown, New York: Elsevier Science, Inc. 

Murray, M. E., and K. S. Brown. 1994. “Results of the Independent Verification Survey at the 

Old Betatron Building, Granite City, Illinois (GSG001),” ORNL/RASA-94/2. Oak Ridge, 

Tennessee: Oak Ridge National Laboratory. 

Murray, M. E., and M. S. Uziel. 1992. “Results of the Radiological Survey at the New Betatron 

Building, Granite City Steel Facility, Granite City, Illinois (GSG002),” ORNL/RASA-91/8. Oak 

Ridge, Tennessee: Oak Ridge National Laboratory. 

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

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

Industries,’ Battelle-TBD-6000, Appendix BB, Rev. 0” (March 17, 2008). 

S. Cohen and Associates (SC&A). 2010. “Response to Action Items Related to GSI SEC Issues 

Matrix” (May 9, 2010). 

Scherpelz, R. 2006. “Site Profile for Atomic Worker Employers that Worked Uranium and 

Thorium Metals,” Battelle-TBD-6000 Rev. F0. http://www.cdc.gov/niosh/ocas/pdfs/tbd/bat6000-r0.pdf

Schuetz, J. G. 2007. Letter report to Samuel Glover, NIOSH/OCAS, May 1, 2007. 

Draft Appendix BB Issues Matrix 14 SC&A –Updated July 25, 2011 

NOTICE: This July 25, 2011, version of the Issue Resolution Matrix has been reviewed for Privacy Act-protected 

information and redacted for public release. Future revisions will require an additional PA review.