Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Review of the General Steel Industries 

Special Exposure Cohort (SEC) Petition-00105 

and the NIOSH SEC Petition Evaluation Report 

Contract No. 200-2009-28555 

SCA-SEC-TASK5-0005 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

July 2009 

[Redacted version – October 2, 2009] 

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 pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted.
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S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Revision No. 

0 

Review of the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the 

NIOSH SEC Petition Evaluation Report 

Page 2 of 51 

Task Manager: 

________________________ Date: ___________ 

Robert Anigstein, PhD 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 

Supersedes: 

N/A 
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CONTENTS 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Executive Summary.........................................................................................................................7 

Findings................................................................................................................................7 

References for Executive Summary...................................................................................11 

1.0 Introduction........................................................................................................................12 

1.1 Scope......................................................................................................................12 

1.2 Technical Approach and Review Criteria..............................................................12 

2.0 Background........................................................................................................................14 

3.0 Review of SEC Petition .....................................................................................................17 

4.0 Audits of Dose Reconstructions.........................................................................................21 

4.1 Case [A] .................................................................................................................21 

4.1.1 Occupational External Dose ......................................................................21 

4.1.2 Occupational Medical Dose.......................................................................22 

4.1.3 Occupational Internal Dose........................................................................22 

4.2 Case [B] .................................................................................................................23 

4.2.1 Occupational External Dose ......................................................................24 

4.2.2 Occupational Medical Dose.......................................................................24 

4.2.3 Occupational Internal Dose........................................................................25 

5.0 Review of Evaluation Report (ER)....................................................................................26 

5.1 Section 3.1: Petitioner-Requested Class Definition and Basis .............................26 

5.2 Section 3.2: Class Evaluated by NIOSH...............................................................26 

5.3 Section 4.3: Facility Employees and Experts .......................................................26 

5.4 Section 5.0: Radiological Operations Relevant to the Class Evaluated by 

NIOSH ...................................................................................................................26 

5.5 Section 5.1: General Steel Industries Plant and Process Descriptions..................27 

5.6 Section 5.2.2: External Radiological Exposure Sources from General Steel 

Operations..............................................................................................................27 

5.7 Section 5.2.2.1: Photon .........................................................................................28 

5.8 Section 5.2.2.2: Beta .............................................................................................28 

5.9 Section 5.2.2.3: Neutron .......................................................................................28 

5.10 Section 5.2.3: Incidents.........................................................................................28 

5.11 Section 5.2.4: Residual Radioactivity Period at the General Steel Industries 

Site .........................................................................................................................29 

5.12 Section 6.2: Available General Steel Industries External Monitoring Data .........30 

5.13 Section 7.1.2: External Monitoring Data Pedigree Review..................................31 

5.14 Section 7.2.1: Evaluation of Bounding Process-Related Internal Doses..............31 

5.15 Section 7.2.3: Methods for Bounding Internal Dose at General Steel..................32 

5.16 Section 7.2.3.2: Methods for Bounding Residual Period Internal Dose...............32 

5.17 Section 7.2.4: Internal Dose Reconstruction Feasibility Conclusion ...................32 

5.18 Section 7.3.1: Evaluation of Bounding Process-Related External Doses.............32 

5.19 Section 7.3.3: General Steel Occupational X-Ray Examinations.........................35 

5.20 Section 7.3.4.1: Methods for Bounding Operational Period External Dose.........35 

5.21 Section 7.3.5: External Dose Reconstruction Feasibility Conclusion ..................36 
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CONTENTS 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

5.22 Section 7.4.1: Lack of Monitoring Data ...............................................................36 

5.23 Section 7.4.2: Underestimated External Dose Modeling......................................37 

5.24 Section 7.6: Summary of Feasibility Findings for Petition SEC-00105...............37 

5.25 Section 9.0: Class Conclusion for Petition SEC-00105........................................37 

6.0 Findings..............................................................................................................................39 

References......................................................................................................................................44 

Attachment 1: Report of Interview with [GSI petitioner].............................................................47 

Attachment 2: Interview with [Worker D]....................................................................................48 

Attachment 3: Interview with [Worker B]....................................................................................50 
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ABBREVIATIONS AND ACRONYMS 

AEC Atomic Energy Commission 

AMAD activity median aerodynamic diameter 

AWE Atomic Weapons Employer 

CATI Computer-Assisted Telephone Interview 

CFR Code of Federal Regulations

Ci curie: unit of activity 

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

DR dose reconstruction 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

EML Environmental Measurements Laboratory 

ER (SEC Petition) Evaluation Report 

FOIA Freedom of Information Act 

FR Federal Register 

FUSRAP Formerly Utilized Sites Remedial Action Program 

GSI General Steel Industries 

HY High Yield (steel) 

ICRP International Commission on Radiological Protection 

IMBA Integrated Modules for Modular Bioassay Analysis 

IREP Interactive RadioEpidemiological Program 

MCNP Monte Carlo Nuclear Particle: a family of radiation transport computer codes 

developed by the Los Alamos National Laboratory 

NARA National Archives and Records Administration 
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NIOSH National Institute for Occupation Safety and Health 

NRC U.S. Nuclear Regulatory Commission 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team

ORNL Oak Ridge National Laboratory 

PFG photofluorography 

R roentgen: unit of exposure 

rem roentgen equivalent man: unit of effective dose 

SC&A Sanford Cohen & Associates 

SEC Special Exposure Cohort 

SRDB Site Research Database 

SRQD (NIOSH) Site Research Query Database 

TBD Technical Basis Document
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EXECUTIVE SUMMARY 

During the meeting of the Advisory Board on Radiation and Worker Health held in 

Albuquerque, New Mexico, on February 17–19, 2009, S. Cohen & Associates (SC&A) was 

tasked by the Board to review the NIOSH SEC Petition Evaluation Report of Petition SEC00105—General Steel Industries (GSI) (Buker et al. 2008). This report concludes: 

Based on its full research of the class under evaluation, NIOSH found no part of 

the subject class for which it cannot estimate radiation doses with sufficient 

accuracy. This class includes all individuals who worked in any location at the 

General Steel Industries site, located on 1417 State Street, Granite City, Illinois, 

from January 1, 1953 through June 30, 1966, and/or during the residual period 

from July 1, 1966 through December 31, 1992. 

FINDINGS 

We have a number of findings on this report. 

Finding 1. Lack of Radiation Monitoring Data for 1953–1963 

The lack of radiation monitoring data for the 11-year period 1953–1963 precludes a bounding 

assessment of external exposures to direct penetrating radiation. There were four reported 

incidents during this period: (1) a worker who was not a radiographer mistakenly took home a 

60Co source; (2) [REDACTED] who was not a radiographer, remained inside an Army tank being 

radiographed with the betatron; (3) [Worker A], a betatron operator, reported he was involved in 

an incident with “Betatron II” (presumably the new betatron) just prior to the beginning of the 

Landauer film badge monitoring program; (4) an employee, of St. Louis Testing, a GSI 

contractor, reported finding an unsecured 60Co source that may have exposed GSI employees. 

These incidents, especially the worker’s taking home a 60Co source, indicate a serious 

breakdown of radiation controls. 

Finding 2. Incomplete Monitoring of Workers: 1964–1966 

The film badge dosimetry records for 1964–1966 list the names of 89 workers, who are believed 

to have been members of the betatron teams or radiographers who used sealed sources. Former 

workers have reported that the badges were stored in a rack just outside the New Betatron 

Building, and that they were required to take off their badges whenever they left the betatron 

buildings. Consequently, the monitoring of even these workers was incomplete, since it did not 

cover exposures they might have received outside the betatron building. Areas in 10 Building, 

including the restroom, were potentially exposed while the betatron was in operation. 

Furthermore, some of these workers may have worked as layout men who were in intimate 

contact with castings immediately after betatron radiography. They would not have been 

wearing their badges while performing such duties. 
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The monitored workers represent a small fraction of the total GSI workforce. One incident that 

occurred during this period involved a worker who was inside a casting while it was 

radiographed with a betatron. He was not a radiographer and was therefore not monitored. 

Finding 3. Lack of Documentation 

There are few contemporary records to document operations at GSI during the operational 

period. The available records comprise purchase orders for uranium radiography spanning the 

period 1958–1963, correspondence between General Steel and Mallinckrodt regarding payment 

of a single invoice for radiography prior to February 1958, a December 1953 memo referring to 

betatron radiography at General Steel Castings (as GSI was then known), and Landauer film 

badge dosimetry reports for 1964–1973. There is no information on the extent of uranium 

radiography at GSI prior to March 1, 1958, except for a February 28, 1958, memo requesting 

payment for an earlier invoice (Brownfield 1958). Consequently, it does not appear to be 

possible to determine the exposure of workers to uranium from January 1, 1953, the assumed 

start of uranium handling operations, to March 1, 1958. 

There are no records regarding the radioactive sources used for radiography. For example, the 

“small” 60Co source used in 6 Building was variously described as having an activity of less than 

one curie or 0.25 Ci. The large source was described as 80 Ci; however, we could not determine 

when it was acquired. Given the 5.27 half-life of this nuclide, the date of acquisition would 

affect its activity at various times during the operation of GSI. Given the paucity of 

documentation, it is difficult to establish suitable parameters for dose reconstruction. 

Finding 4. Film Badge Dosimetry Dependence on Photon Energies and Exposure 

Geometry 

The response of a film badge dosimeter is highly dependent on the angle of the incident 

radiation, especially if the radiation source is behind a person wearing a film badge on the front 

of his body. To a smaller extent, the film badge response varies with the energy of the incident 

photons. Consequently, given the complex exposure conditions at GSI, the film badge records 

are at best an approximate measure of the radiation doses received by their wearers. 

Finding 5. Lack of Validation of Models of Radiation Exposure of Betatron Operators 

Even for the period of time for which film badge dosimetry reports are available, there is no 

agreement between the measured and the modeled exposures. In SC&A 2008, we have 

presented a detailed critique of the models of external exposure developed by Allen and Glover 

(2007). We have performed an independent analysis to demonstrate that the exposures to 

betatron radiation and to activated steel could be higher than those predicted by the NIOSH 

model. However, we do not claim that our model is definitive, based as it is on a limited set of 

exposure scenarios and extensive conjectures on exposure durations and geometries. 

The film badge data indicates that the vast majority of weekly reports list doses of less than the 

reporting level of 10 mrem. These results call both the NIOSH and SC&A models into question. 

Conversely, neither model explains how one worker received a dose of 2,470 mrem in one week 
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during the period of covered operations, or how another worker was reported to have received a 

dose of 7,590 mrem in one week after the end of AEC operations at GSI. Although the latter 

dose is, strictly speaking, outside the scope of this review, it does call into question the exposure 

conditions at GSI. Since there is no basis for believing that the operating conditions were 

significantly different in the later years, except for the absence of uranium, such a dose report 

should be considered in evaluating the models of external exposure. 

In short, neither the film badge data nor the modeled exposures can be used to establish an upper 

bound to the external exposures of betatron operators that is claimant favorable and scientifically 

correct. 

Finding 6. Underestimate of External Exposure of Unmonitored Workers 

Allen and Glover (2007) make a seemingly arbitrary distinction between two classes of workers. 

Betatron operators and workers who handle metal within 2 hours of irradiation are assigned a 

higher exposure, ranging from 2.1 to 6.3 R/y, depending on the calendar year, while all other 

workers are assigned a dose of about 1.7 R/y. The latter exposure rate is based on a calculated 

exposure rate of 0.72 mR/h in shielded areas of the plant. SC&A (2008) has calculated exposure 

rates far in excess of this value in locations accessible to workers not involved in radiography, 

including a rate in excess of 1 R/h on the roof while the 80 Ci 60Co was in use. Given the lack of 

any systematic program of radiation protection to bar access to these areas during betatron or 

60Co radiography, and the fact that the exposures of these other workers were not monitored, it 

does not appear to be possible to bound their radiation exposures in a manner that is scientifically 

correct and claimant favorable. Thus, the distinction between the external exposures assigned to 

these two classes of workers is not adequately justified and could result in a significant 

underestimate of the external exposures of some of the workers that are assigned the lower 

exposures. 

Finding 7. Dose Reconstructions Not Based on Best Available Science 

SC&A (2008) has documented a number of scientific errors in Appendix BB. Most notable is a 

20-fold error in calculating the dose rate from irradiated uranium, which we found in the 

computer program files used by NIOSH. Although this error increases the dose rate and is 

therefore claimant favorable, it is not scientifically correct. The calculated values are therefore 

not acceptable for use in dose reconstructions. 

Finding 8. Incomplete Model Used for Exposure Assessments 

It would appear that the model used by NIOSH for the 208 dose reconstructions completed by 

October 3, 2008, the date of the ER, is incomplete. We base this conclusion first on the response 

by NIOSH to some findings in the “Issue Resolution Matrix for SC&A Findings on Appendix 

BB to TBD-600[0],” dated June 19, 2008. In response to Issue 10: “Errors in Calculating Dose 

Rates from Uranium,” NIOSH wrote: 

To the extent modeled doses are used, any errors in this calculation will be 

corrected. However NIOSH has obtained film badge results for betatron 
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operators. We are in the process of comparing this data to the modeled estimates 

provided by both the appendix and SC&A. 

Our review of Case [B] indicates that NIOSH did use doses modeled by Allen and Glover 

(2007). To the best of our knowledge, NIOSH has not revised this model. NIOSH made similar 

comments in response to other SC&A findings regarding the scientific validity of the Appendix 

BB models. 

Other indications that the NIOSH model is incomplete are given by Buker et al. (2008). In 

section 7.3.4.1, under the heading “Neutron Dose,” is the statement, “A study is in place to 

determine the photon-to-neutron ratio.” As we found in our audit of Case [B], NIOSH has 

neglected the neutron dose in performing dose reconstructions. 

Given the undetermined status of the model, we find that the dose reconstructions performed by 

NIOSH to date do not meet the standard of scientific accuracy. 

Finding 9. Underestimate of Beta Dose 

The beta dose assigned to GSI workers may be underestimated. Freshly cast uranium ingots may 

have enhanced concentrations of the short-lived progeny of 238U on the surface, leading to a 

significant increase in the beta dose over aged natural uranium metal. Furthermore, uranium 

ingots were handled not only by the betatron workers but also by chainmen who transferred the 

ingots from the trucks or railway cars on which they arrived at the plant to the plant’s own 

railway system. Such workers would also have been exposed to the beta rays from the uranium, 

but they are not assigned such exposures in the guidance for dose reconstruction of Allen and 

Glover (2007). 

Finding 10. Lack of Consistency in Assigning External Exposures 

Because of an error in calculating the external exposure to irradiated uranium, Allen and Glover 

(2007) assign a disproportionately high exposure rate to workers handling uranium following 

radiography while underestimating (in modeling terms) exposures to the betatron and to 

irradiated steel. This results in exposure rates that vary from year to year. By contrast, SC&A 

(2008) estimated that the bounding external exposures to direct penetrating radiation did not vary 

significantly over the duration of AEC operations. The dose reconstruction approach prescribed 

by NIOSH can inappropriately assign a dose to a betatron operator working in 1961 that would 

be 3 times the dose to one working in 1965. 
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REFERENCES FOR EXECUTIVE SUMMARY 

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

Buker, L., R. Clark, M. Domal, and J. Guido, 2008. “SEC Petition Evaluation Report Petition 

SEC-00105.” http://www.cdc.gov/niosh/ocas/pdfs/sec/gsi/gsier.pdf

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

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

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

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scagsireview.pdf
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1.0 INTRODUCTION 

During the meeting of the Advisory Board on Radiation and Worker Health held in 

Albuquerque, New Mexico, on February 17–19, 2009, S. Cohen & Associates (SC&A) was 

tasked by the Board to review the NIOSH SEC Petition Evaluation Report (ER) of Petition SEC00105—General Steel Industries (GSI) (Buker et al. 2008).1

 

This site has been extensively studied by NIOSH, the Advisory Board, and SC&A over the past 

3 years. A time line of meetings and interviews with former workers, reports that were prepared 

by NIOSH and by SC&A, correspondence with workers and with their advocates, meetings of 

the Advisory Board’s work groups that were assigned responsibility for this site, and other 

significant events, is presented in section 2.0 of this review. 

1.1 SCOPE 

The scope of this review is to address specific issues of concern raised in the petition and 

NIOSH's response to these concerns, as given in the ER. In the course of this assessment, SC&A 

reviewed selected documents that were considered relevant to the petition, including the 

following: 

• Documents that were referenced in the petition 

• Documents referenced or cited in the ER and the site profile (Allen and Glover 2007) 

• Documents contained in the NIOSH Site Research Query Database (SRQD) 

The purpose of this review is to provide the Board with an independent assessment of issues and 

concerns that surround the petition and NIOSH's response and proposed methods for 

accommodating these issues/concerns. Findings identified in SC&A's review are intended to 

provide the Board with an overview of potential issues that may impact the feasibility of dose 

assessment. Following a formal, multistep issues resolution process, any unresolved findings 

may then be used by the Board for determining whether radiation doses can be estimated with 

sufficient accuracy, as defined in 42 CFR §83.13(c)(1); since this final determination lies within 

the purview of the Board and occurs at the end of a formal resolution process, SC&A does not 

draw conclusions from its findings in this report. 

1.2 TECHNICAL APPROACH AND REVIEW CRITERIA 

The approach used by SC&A to perform this review follows the protocols described in the draft 

report prepared by SC&A entitled, “Board Procedures for Review of Special Exposure Cohort 

Petitions and Petition Evaluation Reports, Revision 1" (SC&A 2006b), and the “Report to the 

Working Group on Special Exposure Cohort Petition Review” (SC&A 2006a). The latter is a set 

of draft guidelines prepared by a Board-designated work group for evaluation of SEC petitions 

performed by NIOSH and the Board. The former is a set of draft procedures prepared by SC&A 

and approved for use by SC&A on an interim basis at the 38th Meeting of the Advisory Board on 

1

 This report is sometimes referred to by the acronym ER in this review.
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Radiation and Worker Health on June 16, 2006. The procedures are designed to help ensure 

compliance with Title 42, Part 83, of the Code of Federal Regulations (42 CFR 83) and 

implement the guidelines provided in the report of the working group. 

The key review criteria listed below were identified in the report of the work group; the 

individual criteria have differing degrees of applicability depending on the details of a particular 

SEC petition and evaluation report. 

• Timeliness 

• Fairness 

• Understandability 

• Consistency 

• Credibility and validity of datasets, including pedigree of the data, methods used to 

acquire the data, relationship to other sources of information, and internal consistency 

• Representativeness and completeness of the exposure data with respect to the area of the 

facility, the time period of exposure, the types of workers, and processes covered by the 

data 

The work group guidelines also recommend that NIOSH include in its SEC evaluation a 

demonstration that it is feasible to reconstruct individual doses for the cohort, including sample 

dose reconstructions. 

SC&A's implementation of the SEC review process includes the following steps: 

• Conduct a critical review of the petition and relevant reports, documents, and data that 

are enclosed and/or referenced in the petition/reports. 

• Identify additional issues/concerns that emerged from SC&A's document review, which 

are independent of those stated in the petition. 

• As part of the SEC review, develop a technical position for issues identified in the 

petition, as well as SC&A's independent findings. 

SC&A's report with its findings will subsequently undergo a multistep resolution process. 

Resolution includes a transparent review and discussion of draft findings with members of the 

Board's Work Group on TBD-6000/6001, Appendix BB; petitioners; claimants; and interested 

members of the public. This resolution process is intended to ensure that each finding is 

evaluated on its technical basis in a fair and impartial manner. 
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2.0 BACKGROUND 

The site in question, located in Granite City, Illinois, was originally the Commonwealth Division 

of the General Steel Castings Corporation, later known as the Castings Division of General Steel 

Industries, Inc. (GSI). This facility performed betatron radiography of uranium for the Uranium 

Division of the Mallinckrodt Chemical Works in St. Charles, Missouri, which was under contract 

to the U.S. Atomic Energy Commission (AEC). This activity resulted in potential radiation 

exposures of some workers at this site. However, the facility also performed radiography of steel 

castings, its principal product, during the contract period. The radiological assessments of 

workers exposed to radiation from the weapons-related activities therefore encompass these 

other sources of radiation exposure. 

A series of four meetings were held in July and August 2006 that brought together former GSI 

workers for the purpose of collecting information on the GSI plant, based on the recollections of 

these workers (SimmonsCooper 2006a, 2006b; [Court Reporter] 2006a, 2006b). The meetings 

were organized by advocates for the workers: the GSI copetitioner, [REDACTED], and the late 

Christine Ramspott. NIOSH staff and contractor personnel attended two meetings on August 21 

and 22 ([Court Reporter] 2006a, 2006b). Redacted transcripts of these meetings are posted on 

the NIOSH/OCAS Web site. 

On June 25, 2007, NIOSH issued Appendix BB to “Site Profiles for Atomic Weapons Employers 

that Worked Uranium and Thorium Metals” (Allen and Glover 2007). According to this 

appendix: 

This document serves as an appendix to Battelle-TBD-6000, Site Profiles for 

Atomic Weapons Employers that Worked Uranium and Thorium Metals. This 

appendix describes the results of document research specific to this site. 

During Meeting 48 of the Advisory Board on Radiation and Worker Health, held in Richland, 

Washington, on July 17–19, 2007, the Board directed SC&A to perform a review of “Site 

Profiles for Atomic Weapons Employers that Worked Uranium and Thorium Metals,” BattelleTBD-6000 (Scherpelz 2006), as well as Appendix BB. We reviewed the main report and 

delivered a working draft of our report to the Board on September 14, 2007 (SC&A 2007).2

Following the Board meeting, two sets of public comments on Appendix BB were submitted to 

Larry Elliot, Director of OCAS, by [REDACTED] Christine Ramspott (2007) and by the GSI 

copetitioner (2007). The Board asked SC&A to respond to these comments as part of its review 

of Appendix BB. 

On October 9, 2007, Robert Anigstein of SC&A, the lead author of this review, met with a group 

of former employees of General Steel Industries who had worked at the Castings Division in 

Granite City, Illinois, as well as with other site experts. Two members of the NIOSH/OCAS 

staff attended as observers but did not participate in the discussions. A voice recording was 

 

2

 As of the date of this review, the SC&A report has not been reviewed for compliance with the Privacy Act and is 

therefore not available to members of the public.
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made of the proceedings; NIOSH later prepared a written summary of the recording (Anigstein 

2007). During the course of the meeting, the site experts shared their recollections of activities at 

the site, answered questions, prepared sketches of the layout, and provided written 

documentation. Immediately after this meeting, NIOSH (2007) held a Town Hall meeting for 

former GSI workers at the same location. 

This author held further communications with some of the attendees at the earlier meeting, as 

well as other site experts, by telephone, e-mail, and regular mail. The purpose of these contacts 

was to elicit more details about the layout of the site, the operation of the equipment, and general 

work practices that helped us to perform an independent assessment of the radiation exposures of 

GSI workers and to evaluate Appendix BB. 

[GSI petitioner] (2008) filed an SEC petition on behalf of former GSI employees and their 

survivors that was received by NIOSH on February 25, 2008. In a Federal Register Notice dated 

June 17, 2008, NIOSH (2008a) announced that the petition has met the minimum qualifications 

for review and evaluation. 

On March 17, 2008, we issued a review of Appendix BB (SC&A 2008). Erratum sheets 

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

complies with the Privacy Act was released on April 21. Our review raised a number of issues 

regarding the analyses of radiation exposures performed by NIOSH and their underlying 

assumptions. 

On May 2, 2008, we distributed our “Issue Resolution Matrix for SC&A Findings on Appendix 

BB” that listed 13 issues excerpted from SC&A 2008. We presented these findings at a meeting 

of the Advisory Board’s Work Group on Procedures on May 20, 2008. On May 14, we issued a 

briefing and summary of our review of Appendix BB, which served as the basis of an illustrated 

presentation at the same meeting of the Work Group. 

The next major development took place at the meeting of the Advisory Board that was held in St. 

Louis on June 26, 2008. The Board formed a new work group for the review of Battelle-TBD6000 and -6001, including appendices, with a special focus on Appendix BB. Prior to this time, 

our reviews of these reports were under the aegis of the Work Group on Procedures. However, 

given the significant effort that went into these reviews, which commanded a proportionate effort 

on the part of the Work Group on Procedures, the Board felt that it would be more expeditious to 

turn over this responsibility to a new work group. 

On October 3, 2008, NIOSH issued its evaluation report of the GSI SEC petition (Buker et al. 

2008). On October 31, NIOSH (2008b) issued a white paper that included a review and analysis 

of film badge dosimetry reports on GSI workers for the period of January 1964 through 

December 1973, obtained by NIOSH from Landauer. NIOSH also cited some perceived 

inconsistencies in SC&A 2008. Anigstein (2008) responded to the white paper in a report to the 

Work Group on TBD-6000/6001, Appendix BB on November 8—a Privacy Act-cleared version 

of the report was issued on November 18. The response included an independent analysis of the 

film badge reports during the period of AEC operations, i.e., reports spanning the period of 

January 1964 to July 1966. 
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The first meeting of the Work Group on TBD-6000/6001, Appendix BB was held in Cincinnati 

on November 10, 2008. The meeting included a discussion of the Appendix BB issues matrix 

with NIOSH’s responses to the 13 issues in that matrix. There was further discussion of the 

NIOSH (2008) white paper and of our responses (Anigstein 2008) to that report. The second 

meeting of the Work Group was held in Cincinnati on March 11, 2009. Most of the discussion 

centered on film badge dosimetry data. 

Following the first Work Group meeting, we performed further analyses of the Landauer film 

badge data, including dosimetry reports for the period after AEC operations, namely July 1966–

December 1973. We issued several brief reports and memoranda pertaining to these records and 

to our analyses. 
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3.0 REVIEW OF SEC PETITION 

The cover letter of the SEC petition filed by the GSI petitioner claims that “NIOSH did not have 

a body to conclude this [that the probability of causation was less than 50%] with in my father’s 

case, nor did they have the quantity or quality of the use of the two betatron machines and 

facility conditions to properly conclude their findings.” The author interviewed the GSI 

petitioner to clarify these statements in the petition. She explained that she meant that her father 

was deceased. Since he didn’t have a badge, NIOSH had no concrete proof on which to base his 

dose reconstruction. Her implication was that since NIOSH could not examine his body, and in 

the absence of a dosimeter, they had no evidence for assessing his radiation exposure. She also 

made reference to the two betatrons that were used at GSI, and questioned if NIOSH knew that 

the betatrons were used simultaneously. A summary of the interview appears as attachment 1 to 

the present review. [GSI petitioner] (2009) provided comments on the interview report in an email to this author, with a copy to Paul Ziemer, Chair of the Work Group on TBD-6000/6001, 

Appendix BB, which was received after the summary of the interview was prepared and 

distributed to the Work Group. 

In her petition, the GSI petitioner also states that production and maintenance workers, such as 

her father, [REDACTED], and [REDACTED], all of whom worked at GSI, were not issued any 

radiation monitoring devices. She correctly observes that film badges were available in 1950. 

(In fact, they were already used in the 1940s.) 

A list of references is attached to the petition. These references cite Web sites that were visited 

by the petitioner and summarize relevant information which she found there. They are listed and 

discussed below in the order in which they appear. Only the first citation lists a URL that we 

could identify. 

1. Listed as nuke.worker.com (actually http//:www.nukeworker.com). The petition states: 

(General Steel Cleanup 1993) Go to Illinois - Granite City Steel - states previous 

occupant General Steel Industries 1417 State St. GSI was custodian of (2) 

betatron-government owned machines. 1993 cleanup residual radioactive 

material survey shows amounts in excess of government guidelines. 

This Web page refers to the Granite City Steel site. Granite City Steel was the owner of the 

former GSI site at the time the site was cleaned up under the FUSRAP program. The cited 

information was utilized by Allen and Glover (2007) and by SC&A (2008). Although Allen and 

Glover failed to explicitly note the presence of two betatrons, Buker et al. (2008) do discuss this 

issue. Since the buildings housing the two machines were about 400 feet apart, an individual 

exposed to radiation from one machine could not simultaneously receive any significant 

radiation from the other one. Our review explicitly addressed the two machines, since their 

operating characteristics and exposure conditions were different. 

2. “Betatron and betatron machines dangers . . . . Dr. Laughlin tried to quantify radiation 

exposure through dosimetry. Device or badge was available as of 1950. (Badges were 

available, not used per attached affidavits).” The closest match we found is an obituary of 
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Dr. John S. Laughlin, the former chair of the Department of Medical Physics at the Memorial 

Sloan-Kettering Cancer Center, which appeared in The New York Times on December 25, 

2004. The obituary states, “Dr. Laughlin's later [italics added] research addressed the 

dangers of radiation and tried to quantify exposure for medical workers, scientists and the 

public, in a field known as dosimetry.” We agree that film badges and other dosimeters were 

in use as early as the late 1940s, and that workers other than radiographers and their 

assistants were apparently not issued dosimeters at GSI. This point is not disputed by either 

NIOSH or SC&A. 

3. “Office of Legacy Management Granite City Steel site. . . . States (2) betatron machines 

housed at this site. Doesn't give GSI as previous occupant but cleanup dates are the same. 

Granite City Steel is located on 20th street. No address given in this article. General Steel 

Industries is at 1417 State St. (full address should be mandatory)” 

The information cited is not in dispute. The issue of the two betatrons is discussed under 

citation 1. 

4. “ACS Radiation Exposure and Cancer . . . This site explains the dangers of ionizing 

radiation, how it may not show up for years after exposure and its effects on DNA. This 

website relates beta rays to ionizing radiation and much more.” 

This site, maintained by the American Cancer Society, contains information on the carcinogenic 

effects of ionizing radiation. Such information is explicitly addressed by the Interactive 

RadioEpidemiological Program (IREP) that is used by DOL to estimate probability of cancer 

causation from exposures to radiation. 

5. “DOE listings of nuclear facilities. . . . Gives a list of facilities beryllium metal was provided 

to by beryllium vendors. Granite City Steel listed as one, no address given. AWE/DOE 

(represents ownership change) Granite City Steel used to own General Steel Industries at 

1417 State St.” 

This Web site, maintained by the Federation of American Scientists, displays a DOE Federal 

Register (FR) notice published January 17, 2001, that lists facilities covered by EEOICPA. The 

FR notice first describes the three types of covered facilities: 

• Atomic weapons employer facilities, as defined in section 3621 (4) of the Act; 

• Department of Energy facilities, as defined by section 3621 (12) of the Act; and 

• Beryllium vendors, as defined by section 3621 (6) of the Act. 

This description is followed by a list that combines all three types of facilities, listed 

alphabetically by State. The petitioner seems to have misunderstood the statement, “The 

following list indicates private firms that processed, produced, or provided beryllium metal for 

the Department, as defined by the Act.” She apparently took it to mean that all facilities on the 

list were beryllium vendors, rather than just those identified by the notation BE. When asked 

about this during her interview, the GSI petitioner did not recall the basis of her observation. 
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6. “Energy Employees Occupational Illness Compensation Act of 2000. (States AWE/DOE 

represents ownership change. (Granite Steel was General Steel Industries) [sic].” 

In response to a question during her interview, the GSI petitioner said the issue was that Granite 

City Steel was at 20th Street, while GSI was at 1417 State Street. This issue was resolved by 

DOL in EEOICPA Circular No. 08-02, which specifies the location of the covered facility as 

1417 State Street. During the residual period, it was also known as the South Plant of Granite 

City Steel. 

7. “Residual Radioactive Summary . . . States ... ‘[sic] Documentation reviewed indicates that 

there is potential for SIGNIFICANT RESIDUAL CONTAMINATION in which weaponsrelated production occurred 1958–1994 - Granite City Steel formerly was General Steel 

Industries (no street address given; address should be given in reports)” 

We could not find a Web site with that title. However, residual contamination is explicitly 

addressed by Allen and Glover (2007). 

In section E.5 of the Special Exposure Cohort Petition—Form B, the GSI petitioner answered 

“Yes” to the question, “Is the petition based on one or more unmonitored, unrecorded, or 

inadequately monitored or recorded exposure incidents?” She then cites the affidavits of two 

workers, [Worker B], a welder, and [Worker D], a laborer, that they were never offered nor did 

they receive any radiation monitoring devices, and that they were not warned about the dangers 

of radiation exposure. These statements are reiterated in sections F.1 and F.2 of Form B. 

Two affidavits from former workers are attached to the petition. One is from [Worker D], who is 

identified as [REDACTED], who worked at GSI during the residual period. His affidavit 

suggested that the betatrons were used in various buildings throughout the plant. The author 

interviewed [Worker D] to clarify these statements in his affidavits. During the interview, 

[Worker D] said that he was sure that the betatrons did not leave the betatron buildings, and that 

he had confused the Magnaflux machines with the betatrons. His account is consistent with that 

of other workers and with the NIOSH and SC&A assessments of radiation exposures at the GSI 

facility. A summary of the interview appears as attachment 2 to the present review. 

Other observations in [Worker D’s] affidavit include criticisms of the Energy Employees 

Occupational Illness Compensation Program and an alleged lack of concern of the mills in 

Granite City for the welfare of the workers and of residents in the surrounding community. 

In a separate letter, [Worker D] contrasts the EEOICPA to the Veterans Administration’s 

compensation program for exposure to Agent Orange. Following the mandate of the Agent 

Orange Act of 1991, the VA presumes that any veteran who served in Vietnam (between 1962 

and 1975 [reviewer’s note]) and who contracted one of a number of specified diseases (mostly 

cancers) had been exposed to Agent Orange and that the disease was caused by such exposure. 

This is unlike EEOICPA, under which compensation is awarded only if the probability of 

causation is greater than 50%. [Worker D] makes an interesting observation. However, since 

both the Agent Orange Act and EEOICPA are acts of Congress, it is our understanding that 
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neither NIOSH nor DOL has any discretion in determining how compensation should be 

awarded to energy employees or their survivors. 

A second affidavit is from [Worker B], whom the GSI petitioner identifies as [REDACTED]. His 

affidavit could be interpreted to imply that betatrons were used in the 8, 9, and 10 buildings. 

During my interview with [Worker B], he agreed that the castings were taken on rail cars to the 

betatron building, which was located near the center of the 10 Building. That account is also 

consistent with our understanding of the operation of the betatrons at GSI. A summary of the 

interview appears as attachment 3 to the present review. 

The next enclosure is a printout, dated 3/3/05, of a page from a Web site of the Environmental 

Measurements Laboratory (EML), a government-owned, government-operated facility, then part 

of DOE, now under the U.S. Department of Homeland Security. (That Web site is no longer 

maintained by EML and could not be accessed at the time this review was prepared.) The 

printout summarizes findings of a survey performed by a team from the Oak Ridge National 

Laboratory (ORNL), as reported by Murray and Brown (1994). The referenced document is part 

of the GSI site research database (SRDB) and is cited by SC&A (2008). 

Following the printout is an aerial photograph of the GSI foundry in Granite City. Although 

lacking attribution, the photo appears to be the same as one that was published in the GSI 

magazine for September 1963 (GSI 1963) shown in SC&A 2008, Figure figure 1. Also included 

are photos that we assume to be from inside the plant, and a brief description of the Castings 

Division (i.e., the GSI Granite City facility), most likely from GSI 1963. Although illustrative, 

this page contains no new information that would affect the radiological assessment of GSI 

operations. 

The last enclosure is a hand-drawn plan of a portion of the GSI foundry that indicates the 

location of the (new) betatron and of a restroom used by the workers, as well as several other 

buildings in the facility. These locations are consistent with a plan of the entire facility (GSCC 

1969) that was furnished to this author during the meeting with former GSI workers and other 

site experts (Anigstein 2007). The location of the restroom, not identified on the plant plan, is 

consistent with another drawing that had been provided by a former worker.3

 

3

 [REDACTED], former GSI worker, private communication with Robert Anigstein, SC&A, Inc., January 2008.
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4.0 AUDITS OF DOSE RECONSTRUCTIONS 

As part of Task 4, auditing dose reconstructions performed by NIOSH, we reviewed two dose 

reconstructions of former GSI workers. We found significant issues in both cases. 

4.1 CASE [A] 

Case [A] was a former GSI employee who was diagnosed with chronic myelocytic leukemia. 

NIOSH performed a dose reconstruction based on the default radiation exposures prescribed by 

Allen and Glover (2007). The probability of causation was found to be 43.04%; compensation 

was therefore denied. We have several observations and findings related to this case. 

4.1.1 Occupational External Dose 

The employee was assigned an external exposure rate of 0.72 mR/h during the period of covered 

operations at GSI. Given an assumed annual exposure duration of 2,400 hours, the annual 

exposure was 1.73 R/y. This was in accord with Allen and Glover (2007), who specify this 

exposure rate for workers who did not normally work in the betatron building nor with irradiated 

steel within 2 hours of betatron exposure. However, we question whether this assignment is 

scientifically valid or claimant favorable. 

According to the NIOSH summary of the Computer-assisted Telephone Interviews (CATIs) with 

the employee’s two surviving children, his duties consisted of maintenance, which was described 

as taking “care of all the buildings and the machinery.” He was said to work “all over the plant.” 

His duties apparently took him to the betatron buildings, since the interview report states, “One 

time he was told to get out of the betatron building because ‘it was too high.’ ” 

We have a number of issues regarding the assignment of external exposure in this case. The 

exposure rate of 0.72 R/h was based on calculations of skyshine and/or penetrations of the shield 

walls by the primary betatron beam. However, as shown by SC&A (2008), a number of 

locations outside the betatron buildings could have had exposure rates that were significantly 

higher, due to the incomplete shielding of the New Betatron Building and its proximity to the 

production area. These rates were as high as 208 mR/h on the roof, 25 mR/h in the break area, 

and 24 mR/h in the restroom. As a maintenance worker, he may have at times been on the roof 

of the building, which was unshielded. He certainly may have used the restroom. 

This case exemplifies the arbitrary distinction between the betatron team and steel workers who 

handled or repaired castings following radiography, on the one hand, and all other GSI 

employees. Since this employee was reported to have been in the betatron building, this 

distinction breaks down. Former workers have testified that the betatron building was “like 

Grand Central Station,” with various tradesmen going in and out in the course of their duties. 

There were two reported incidents of workers who were not part of the betatron team being 

exposed in the shooting room while the betatron was operating. Furthermore, Allen and Glover 

(2007) do not indicate to which category workers performing radiography with sealed 

radioactive sources, some of which was performed outside the betatron buildings, should be 

assigned. Given the lack of guidance, such workers could also be assigned the external exposure 
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rate of 0.72 mR/h, which does not account for the significantly higher potential exposures from 

these procedures. 

4.1.2 Occupational Medical Dose 

The employee was assumed to have had an annual chest x-ray as a condition of his employment. 

However, he was assigned a mean organ dose of 18.4 mrem per examination during each year of 

employment during the covered period. This is the dose to the bone marrow of a male from 

conventional radiography of the chest prior to 1970 assigned in ORAUT-OTIB-0006 (Kathren 

and Shockley 2005). It is significantly less than the dose of 276 mrem from photofluorography 

(PFG) prior to January 31, 1962. According to that document, “Dose estimates for PFG 

represent absolute upper limits and must be used to ensure claimant favorability in the absence of 

more specific information.” Consequently, the higher dose should be assigned to the assumed 

chest x-rays for the years 1953–1954 and 1956–1962. This would result in an additional organ 

dose of 2.32 rem, which could be significant, given that the total average calculated dose was 

about 14.2 rem. 

According to Allen and Glover (2007), information to be used in dose reconstruction from 

medical x-rays is provided in ORAUT-OTIB-0006. In this case, however, the guidance in that 

document does not appear to have been correctly applied. 

4.1.3 Occupational Internal Dose 

The occupational internal dose was calculated from the assumed intake of uranium dust, which is 

based on the annual intakes of betatron operators listed by Allen and Glover (2007, section 

BB.5.3). Those intakes have two components. One is the dust generated during the handling of 

the uranium metal prior to and following radiography. The airborne uranium activity 

concentrations are based on the daily weighted average concentrations in the vicinity of an 

operator engaged in uranium slug production and canning. This assumption is plausible and 

claimant favorable. The second component is based on the areal concentrations of uranium on 

the floor. As discussed in SC&A 2008, we believe that the method used by NIOSH to estimate 

surficial contamination is fundamentally flawed and is not claimant favorable. The following is 

excerpted from that report. 

In our review of the main report (Scherpelz 2006), SC&A took issue with the use 

of the settling velocity of 5 μm AMAD aerosols to determine surface 

contamination levels, since that approach neglected the sloughing off of large 

flakes of uranium oxide that fall directly onto the floor and that would make a 

significant contribution to the uranium contamination. The same concerns apply 

to the Appendix [BB]. The observation . . . that the surface contamination level of 

1,170 dpm/100 cm2

 is “. . . reasonably close to the maximum value of 540 

dpm/100 cm2

 measured in a 1989 survey” does not support the calculated value. 

The GSI facility in Granite City continued to operate for another 7 years after the 

cessation of uranium handling activities. It would be expected that normal 

housekeeping activities during this time, as well as additional attrition between 

1973 and 1989, when the site was controlled by the Granite City Steel Division of 
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National Steel Corporation, would have caused more than a 2-fold reduction in 

the surface contamination levels. 

We also dispute the assumption of a resuspension factor (RF) of 1 × 10-6 to calculate the 

concentrations of resuspended dust between uranium handling operations. Such an RF had been 

proposed in NUREG-1720 (Abu-Eid et al. 2002) as a bounding value for decommissioned 

facilities. The authors assumed that the surfaces at these facilities will have been cleaned or 

washed during decommissioning. Such cleaning would remove most of the loosely bound 

contaminants, resulting in a smaller RF for the residual contamination. This low RF value is 

invalid for an active industrial facility where recently deposited contaminants are loosely bound 

to floors and other surfaces. 

We agree that the assignment of the inhalation exposure of a betatron operator to a maintenance 

worker is bounding and claimant favorable. However, we disagree with the calculation of the 

airborne activity between uranium handling operations, which is neither scientifically valid nor 

claimant favorable. This component of the internal exposure becomes increasingly significant 

during the later years of the period of covered operations, when the uranium radiography tapers 

off and the exposure between handling operations has the potential of becoming the dominant 

component of internal exposure. It is the principal source of internal exposure during the 

residual period. 

We also disagree with the assessment of the ingestion of uranium dust, which is discussed 

extensively in section 7.2 of our review of Battelle-TBD-6000 (SC&A 2007). We believe that 

NIOSH’s methodology of estimating intakes by ingestion is neither scientifically valid nor 

claimant favorable. Furthermore, the guidance provided Allen and Glover (2007, section BB.5) 

does not provide suggested ingestion rates, although it does so for inhalation rates. The guidance 

in section BB.6 that “ingestion rate must be included and will be based on this average air intake 

and OCAS-TIB-009” again does not provide guidance on intakes. We were not able to 

reproduce the intakes from uranium ingestion cited in the DR (dose reconstruction)DR Report. 

The DR Report did not include a clear description of the methodology and assumptions used to 

calculate the ingestion intake rates used as input to IMBA. 

That being said, internal exposure to uranium is a very small contributor to the dose to the red 

bone marrow, the target organ in the dose reconstruction of this particular employee. However, 

we address the subject here as a generic issue for all dose reconstructionDRs for this site. 

4.2 CASE [B] 

Case [B] was an employee who worked as a Grinder/Inspector at GSI from [REDACTED], 1941, 

through [REDACTED], 1971, and who was diagnosed with lung cancer on [REDACTED], 1971. 

NIOSH performed a dose reconstruction based on the default radiation exposures prescribed in 

Appendix BB. The probability of causation was found to be 49.23%; compensation was 

therefore denied. SC&A has several observations and findings related to this case. 
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4.2.1 Occupational External Dose 

The employee was assigned external exposures during each year of covered operations at GSI 

that are specified by Allen and Glover (2007, section BB.4.5) for betatron operators. We have a 

number of issues with that assignment. 

The external exposures developed by Allen and Glover are based on the assumption that the 

workers were exposed for 2,400 hours per year, or an average of 46 hours per week. The 

claimant’s widow affirms that he worked 12 h/d, 6 days per week during at least 1 year during 

the covered period. This is consistent with information given by former GSI workers. These 

workers, including betatron operators, estimated that, during peak years, the work week ranged 

from 50 to 80 h. They agreed that 65 hours per week was a reasonable average. (Anigstein 

2007) 

The description of the employee’s duties during most of the covered period is that of an 

[REDACTED]. This position corresponds most closely to the layout man described by SC&A 

(2008). The limiting external exposure of that individual is calculated to be 33.3 mR/shift. 

Assuming 406 shifts per year (65 h/week × 50 weeks/y ÷ 8 h/shift = 406), his limiting annual 

exposure would be 13.5 R/y, slightly less than what we calculated for a betatron operator. The 

exposures listed by Allen and Glover for 1953–1962 range from 5.1 to 6.3 R/y, while those for 

1963–1965 range from 2.1 to 2.8 R/y.4

Because the radiation exposures of this employee were not monitored, he should be assigned the 

most claimant-favorable plausible exposure. 

4.2.2 Occupational Medical Dose 

The employee was assumed to have had an annual chest x-ray as a condition of his employment. 

However, he was assigned a mean organ dose of 84 mrem per examination during each year of 

employment during the covered period. This is the dose to the lung of a male from conventional 

radiography of the chest prior to 1970 assigned in ORAUT-OTIB-0006 (Kathren and Shockley 

2005). It is significantly less than the dose of 1.26 rem from photofluorography (PFG) prior to 

January 31, 1962. As quoted in section 4.1.2 of this review, “Dose estimates for PFG represent 

absolute upper limits and must be used to ensure claimant favorability in the absence of more 

specific information.” Consequently, the higher dose should be assigned to the assumed chest 

x-rays for the years 1953–1962. This would result in an additional organ dose of 11.76 rem, 

which could be significant, given that the total average calculated dose was about 88.6 rem. 

According to Allen and Glover (2007), information to be used in dose reconstruction from 

medical x-rays is provided in ORAUT-OTIB-0006. As in the case discussed in section 4.1.2 of 

this review, the guidance in that document does not appear to have been correctly applied. 

 

4

 The exposure for 1966 is based on 6 months of covered activities and is therefore not strictly comparable.
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4.2.3 Occupational Internal Dose 

The occupational internal dose was calculated from the assumed intake of uranium dust, as 

prescribed by Allen and Glover (2007). Although the job description of this worker does not 

indicate that he handled uranium metal, he was assigned the same intakes of uranium as the 

betatron operators. The decision to assign these intakes to this employee is claimant favorable, 

since we do not know his actual exposure to uranium dust. However, the same comments about 

the adequacy of NIOSH’s assessment of uranium intakes that were made in section 4.1.3 of this 

review apply to this employee. Since the target organ is the lung, the inhalation of uranium plays 

a much more significant role in the dose reconstruction than it does in the previous case. 
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5.0 REVIEW OF EVALUATION REPORT (ER) 

The discussion in this section of the review is keyed to the sections of the ER. 

5.1 SECTION 3.1: PETITIONER-REQUESTED CLASS DEFINITION AND BASIS 

According to Buker et al. (2008), the petitioner class definition encompasses, “all individuals 

who worked in any location at the General Steel Industries site, located on 1417 State Street, 

Granite City, Illinois, from January 1, 1953 through December 31, 1966, and/or during the 

residual period from January 1, 1967 through December 31, 1992.” A similar definition is found 

in the Federal Register Notice announcing that the GSI SEC petition has met the minimum 

qualifications for review and evaluation. However, the SEC petition and attached 

correspondence filed by the GSI petitioner, with a Received stamp dated February 25, 2008, do 

not mention these dates. It would be helpful if NIOSH identified the source of this information. 

5.2 SECTION 3.2: CLASS EVALUATED BY NIOSH 

The “Class Evaluated by NIOSH” is almost identical to the class defined by the petitioners, 

except that the demarcation of the period of AEC activities and the residual period was changed 

from December 31, 1966, to June 30, 1966, which is in accord with the DOL ruling on this site. 

However, the termination of the residual period appears to be in error. According to Bechtel 

National, Inc. (1994), as well as Murray and Brown (1994), the cleanup of the Old Betatron 

Building took place in June 1993. Allen and Glover (2007) state that the residual period extends 

until December 31, 1993, which is consistent with this information. The class definition is thus 

inconsistent with the history of the site and with Appendix BB. 

5.3 SECTION 4.3: FACILITY EMPLOYEES AND EXPERTS 

Section 4.3 of the ER summarizes meetings held with former GSI employees. The meetings held 

on August 21 and 22, 2006 ([Court Reporter] 2006a, 2006b), are listed as a single meeting. 

Since they were held on two different days and a number of people, including congressional staff 

members, attended one meeting but not the other, and since a separate transcript was furnished 

for each meeting, it would be more accurate to refer to them as two separate meetings. 

Furthermore, a Town Hall meeting (NIOSH 2007) is not mentioned. We suggest that this 

section of the ER be revised to indicate the six separate meetings with former GSI employees. 

5.4 SECTION 5.0: RADIOLOGICAL OPERATIONS RELEVANT TO THE CLASS 

EVALUATED BY NIOSH 

Section 5.0 reiterates earlier statements in the ER that the residual period ends December 31, 

1992, which is contrary to the December 31, 1993, date cited by Allen and Glover (2007). 
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5.5 SECTION 5.1: GENERAL STEEL INDUSTRIES PLANT AND PROCESS 

DESCRIPTIONS 

Section 5.1 begins with a history of the General Steel Castings Corporation, the predecessor 

company to GSI, and lists the original owners as the Baldwin Locomotive Works and American 

Steel Foundries. A third owner, the American Locomotive Company, should be included for the 

sake of historical accuracy. More important, the ER fails to mention that the bond issue floated 

on June 21, 1929 enabled the company to build a plant in Eddystone, Pennsylvania as well as 

acquiring the Commonwealth Steel Corporation in Granite City, Illinois. The Eddystone plant 

was the source of the second (“new”) betatron installed at the GSI Granite City foundry in late 

1963. 

The second paragraph of this section cites three references to support the period of AEC-related 

activities at GSI, including “GSI, 1991.” This reference is actually a memorandum signed by W. 

Alexander Williams of the Department of Energy (Williams 1991), and should be cited as such. 

The same paragraph further states, “This work was performed in areas of the facility which were 

part of what was later known as the South Plant.” This statement is confusing to a reader not 

already familiar with the history of operations at GSI. It would be better to state that the work 

was performed at the GSI facility in Granite City. After cessation of operations, the property 

was purchased by the Granite City Steel Division of National Steel Corporation, which referred 

to it as the South Plant to distinguish it from its original plant, which was located north of the 

GSI facility. This clarification is important since DOL had earlier received, and NIOSH had 

evaluated, claims from former employees of Granite City Steel who were not involved with the 

operations at GSI. 

5.6 SECTION 5.2.2: EXTERNAL RADIOLOGICAL EXPOSURE SOURCES FROM 

GENERAL STEEL OPERATIONS 

Section 5.2.2 describes the external exposures of GSI workers during the betatron radiography of 

steel and uranium. The author distinguishes the exposures during setup and during post-x-ray 

activities and states that there was no exposure during the setup for steel radiography because the 

steel was not activated. He reiterates a statement to this effect by Allen and Glover (2007) but 

ignores information presented by SC&A (2008, section 2.2.4) that steel castings were subjected 

to multiple, repeated radiographic exposures. Therefore, in setting up for a new shot, workers 

would be exposed to steel activated during previous irradiations. This is documented by several 

communications from former GSI betatron operators to SC&A, which were transmitted by email to members of the Advisory Board Work Group on Procedures on May 28, 2008, with 

copies to key NIOSH staff members. These communications are the primary sources of 

information on radiographic procedures at GSI and should have been utilized in the preparation 

of the ER. 

In the third paragraph of this section, the author discusses the potential exposures of employees 

during betatron operations. He cites Murray and Uziel (1992) in saying the betatrons were 

housed inside a building with “ten-foot-thick shield wall[s].” Actually, Murray and Uziel 

reported a survey of the New Betatron Building only. Figure 3 of that report shows that the 

shield walls did not, in fact, completely surround the shooting room, nor, according to the scale 
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in the figure, were they 10-ft-thick, varying from 8 to 9 feet. The failure of Allen and Glover 

(2007) to account for the gap in the shield wall led to a significant underestimate of the potential 

exposures outside the building. Skyshine and penetration of the shield are by no means the 

limiting exposure pathways at locations outside the shooting room. 

The fourth paragraph lists sources of radiation exposure following betatron radiography, but 

limits the discussion to ingots and to the betatron apparatus. The term “ingot” is properly 

applied to uranium but not to the activated steel castings, which the author may or may not have 

meant to include. The term photo-neutron reaction does not encompass other reactions, such as 

proton emission, which are also possible. The author failed to note the comment regarding this 

usage by SC&A (2008). 

5.7 SECTION 5.2.2.1: PHOTON 

Section 5.2.2.1 reiterates the sources of external photon exposure discussed in section 5.2.2. It 

omits any mention of radiation from the photoactivation products of irradiated steel castings. 

5.8 SECTION 5.2.2.2: BETA 

Section 5.2.2.2 describes sources of beta radiation. Its description of the beta decay of 234mPa is 

inaccurate for the purpose of dosimetric calculations. Although this nuclide does emit a beta 

particle with an endpoint energy of 2.27 (not 2.28) MeV, the mean energy of the beta radiation is 

819 keV. The author also mentions beta radiation from fission and activation products in 

irradiated uranium. This gives the misleading impression that such radiation was considered by 

Allen and Glover (2007) in estimating doses from nonpenetrating radiation to GSI workers, 

while, in fact, it was not. SC&A (2008) has addressed such radiation and concluded that it 

makes a minor contribution to doses to superficial organs; however, this fact should be explicitly 

addressed in the ER. 

5.9 SECTION 5.2.2.3: NEUTRON 

Section 5.2.2.3 discusses the sources of neutron radiation. This section contains the statement, 

During X-ray operations, potential neutron exposures were possible from photoneutron interactions and delayed neutrons from photofission interactions; 

however, this did not result in a significant exposure source because neutrons 

resulted from secondary radiations from the X-ray interactions with matter in the 

X-ray area. 

This statement neglects the exposure of betatron operators to neutron radiation from the betatron 

target while the betatron is operating. 

5.10 SECTION 5.2.3: INCIDENTS 

Section 5.2.3 states in its entirety, “A review of General Steel Industries’ records did not uncover 

any radiological incidents that were associated with AEC operations, or that could not be 
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accounted for using the information and documentation available to NIOSH.” This statement is 

incorrect and misleading. Since all records of GSI operations at Granite City were destroyed 

when the plant ceased to operate, no review was possible. 

A number of incidents were reported by former workers during the various outreach meetings 

and affidavit testimony. One incident involved a 60Co radiography source that was taken home 

by a worker who mistook it for a plumb bob (Anigstein 2007). The source was strong enough to 

be detected from an airplane carrying a Geiger counter ([Court Reporter] 2006a). A former 

employee of St. Louis Testing reported an incident in which a 250 mCi 60Co source had not been 

properly secured by the worker on the previous shift (Anigstein 2007). The foreman on the next 

shift called the St. Louis Testing employee because the survey meter was pegged, and he thought 

the problem was with the meter. This foreman or one of his workers would have been exposed 

to the unshielded source until the source was secured. 

There were two cases of workers who were not betatron operators or radiographers who were 

inside a casting while it was being radiographed with the betatron beam (SimmonsCooper 2006b, 

[Court Reporter] 2006a, Anigstein 2007). Since the radiation exposures of such workers were 

not monitored, there is no record of their doses. These incidents occurred during the tenure of 

[Supevisor A] as supervisor of the betatron operations. In a follow-up interview on July 8, 2009, 

[Supervisor A] believed that the first incident, involving a worker named [REDACTED], now 

deceased, occurred about 1953. The second incident, involving a man whose first name was 

[REDACTED], occurred about 1964, after the GSI Eddystone plant shut down. 

Another incident was reported in an affidavit of [Worker A] (2006), who stated, “In 1963, the 

day before President Kennedy was shot, I was involved in a nuclear accident at the plant and 

exposed to radiation from Betatron II.” He reported that he was hospitalized following the 

accident. No further details are available. The date would have been November 21, 1963, which 

is 4 days before the starting date of the Landauer film badge dosimetry program, according to the 

Landauer records obtained by NIOSH. 

5.11 SECTION 5.2.4: RESIDUAL RADIOACTIVITY PERIOD AT THE GENERAL 

STEEL INDUSTRIES SITE 

Section 5.2.4 of the ER reiterates the statement in Section 3.2, which states that NIOSH defined 

the date of the end of the residual period as December 31, 1992, and adds that this is based on the 

start of DOE site remediation under FUSRAP, which occurred in 1963. No explanation is given 

for why the residual period did not extend until the end of site remediation, which occurred in 

June 1963, nor why the end of the residual period is different from the date cited by Allen and 

Glover (2007), which is December 31, 1993. 

In summarizing DOE-sponsored activities at the site, the ER refers to residual radioactive 

contamination “in the X-ray building.” The building in question is referred to as the “Old 

Betatron Building” in the FUSRAP reports. Since there were two betatron buildings on the site, 

the reference in the ER is unclear. 
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5.12 SECTION 6.2: AVAILABLE GENERAL STEEL INDUSTRIES EXTERNAL 

MONITORING DATA 

Section 6.2 states: 

Based on a review of the information available to NIOSH, including the available 

purchase order requisitions and personnel interviews, NIOSH determined that the 

potential for exposure during 1964 was higher than in any previous year during 

the operational period at General Steel Industries. 

We have several issues with that statement. First, according the Allen and Glover (2007), the 

greatest period of uranium radiography was July 1, 1961–June 30, 1962, during which time 

437.5 hours may have been devoted to this work. By contract, in 1964 such activity occupied 

only 28 hours per year. In fact, Allen and Glover (2007, section BB.4.5) list a photon exposure 

of 6.321 R/y in 1961 but only 2.220 R/y in 1964. Furthermore, although 1964 saw the initial 

operation of the second betatron at GSI, this would have a minor effect on the radiation 

exposures of the operators, since they could only be in one building at a time, during which time 

they would receive no significant exposure from the operations in the other betatron building. 

Finally, no mention is made of the potential exposures to other radiation sources during the pre1964 period, such as a 250-kVp x-ray machine, and 60Co and perhaps 192Ir sources.5

 Some of the 

incidents discussed in section 5.10 of this review occurred in this earlier period. 

We agree that most of the film badge monitoring data indicates that the doses were lower than 

the doses from external exposure to direct penetrating radiation calculated by Allen and Glover 

(2007). However, there are exceptions. One worker was reported to have received a dose of 

2,470 mrem in one week in 1965, while the exposure for the entire year prescribed in Appendix 

BB is 2,135 mR. Other workers had 1-week doses that were significantly higher than expected, 

if based on the weekly averages of the annual exposures listed by Allen and Glover. 

There are several other issues with the film badge data. One is the dependence of the film badge 

response on the angle of the incident radiation, which could affect the response of the film badge 

to residual radiation from the activated betatron apparatus. While setting up the metal to be 

radiographed, the operator would typically have his back to the betatron instrument. Since his 

badge was worn on the front of his body, the radiation would be shielded by his body. 

According to ICRP (1994, table A.22) the angular dependence factors for radiation incident at 

180o—i.e., the ratio H’(10,180o) ÷ H’(10,0o)—range from < 0.01 for Eγ ≤ 30 keV to 0.62 for Eγ = 

10 MeV. This ratio can be used to estimate the shielding factor for the body, and indicates that 

for 10-MeV photons incident on the back of the worker, a film badge worn in front of his body 

would register only 62% of the incident radiation, while for 30-keV photons, less than 1% of the 

radiation would be recorded. These ratios, calculated for a sphere of tissue-equivalent material, 

may not exactly represent the exposure geometry and radiation field experienced by the worker, 

but provide a rough approximation of the directional dependence of the film badge dosimeters. 

A more exact determination could be performed by modeling the response of the film badge 

5

 It is not clear if GSI owned any 192Ir sources, of if they were only brought on site and handled by personnel of St. Louis 

Testing, a GSI contractor.
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using the MCNP computer codes, or by actual measurements with a precise anthropomorphic 

phantom. 

Since there is no information on the quality of this radiation—SC&A was not able to model the 

activation, although it has been widely reported—it would be difficult if not impossible to derive 

a correction factor for this shielding.6 This may explain why the exposure to the activated 

betatron apparatus, which, according to the SC&A (2008) analysis, would have been the 

dominant source of exposure of betatron operators radiographing steel castings, was not reflected 

in the film badge dosimetry reports. 

Another issue is the energy dependence of the film badge dosimetry. The exposure conditions at 

GSI were different from those in most other facilities. Before relying on the film badges to 

validate its model of worker exposures, NIOSH should characterize the spectrum of the photons 

incident on the film badge, including angular corrections, and compare it to the spectrum of the 

radiation source used to calibrate the badges. Only by means of such a comparison can the film 

badge readings be meaningfully translated into radiation doses. Even then, the dose registered 

by the film badge would be meaningful only if the radiation field were consistent with the 

anteroposterior (AP) exposure geometry. 

5.13 SECTION 7.1.2: EXTERNAL MONITORING DATA PEDIGREE REVIEW 

In discussing the film badge dosimetry reports that NIOSH obtained from Landauer, the ER 

states: 

These data are significant because radiographers were considered to be the 

highest exposed workers at the site. Therefore, these data provide a clear 

indication of the actual external doses of the highest exposed workers at General 

Steel Industries. 

We agree that, on average, radiographers, including the so-called isotope operators (workers 

who performed radiography using sealed radioactive sources, primarily 60Co) had the potential 

for receiving the highest doses. However, this observation does not account for the incidents 

discussed in section 5.10 of this review, which involved workers who were not monitored or for 

whom film badge records were not obtained for the period of time when the incident occurred. 

5.14 SECTION 7.2.1: EVALUATION OF BOUNDING PROCESS-RELATED 

INTERNAL DOSES 

Section 7.2.1 refers to the method prescribed by Allen and Glover (2007) to calculate the intake 

of uranium dust during uranium handling operations (i.e., setting up and removing the uranium 

6

 We do not agree with the assertion by Allen and Glover (2007) that the radiation is from activation products in the 

aluminum cone. First, the Allis-Chalmers betatron manual specifically refers to the betatron tube being radioactive, not 

the cone (Allis-Chalmers 1951). Second, Jack Schuetz, the former Allis-Chalmers maintenance engineer and more 

recently a NIOSH contractor, firmly denied that the radiation came from the cone. Finally, our MCNPX simulation 

showed very little activation of the aluminum after irradiation with the betatron beam—orders of magnitude less than 

would be required to produce the radiation field measured by Mr. Schuetz.
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ingots before and after betatron radiography). No mention is made of the prescribed methods for 

estimating uranium intakes between uranium handling operations, which is most of the time that 

the workers spent in the plant. These methods, which are based on Battelle-TBD-6000, are 

discussed in section 4.1.3 of this review. We do not agree that these methods are scientifically 

correct or claimant favorable. 

We have an editorial comment on the statement in the second paragraph of Section 7.2.1, “As 

assessed in Battelle-TBD-6000, the bounding exposure scenario assumes that grinding would 

start on a freshly X-rayed piece of steel every 2 hours.” Such an assessment was made in 

Appendix BB, not in the main document, as the quotation implies. Another issue is that the 

radiological assessment of internal exposure to the inhalation of steel dust is limited to the intake 

of 53Fe, an activation product that is assumed to be in the dust. From a purely scientific 

standpoint, we disagree with this assumption: SC&A (2008, Table 10) lists 42 radionuclides that 

might be present in HY-80 steel—a common alloy cast at GSI—following betatron irradiation. 

Iron-53 accounts for less than 0.1% of the total internal dose from this scenario. However, we 

agree that exposure to steel dust resulted in no significant doses of radiation. 

5.15 SECTION 7.2.3: METHODS FOR BOUNDING INTERNAL DOSE AT 

GENERAL STEEL 

Section 7.2.3 states that intakes of uranium dust were based on air monitoring data from other 

facilities, while those during the residual period were based on resuspension from contaminated 

surfaces. In fact, as stated in section 5.14 of this review, intakes during the operational period 

also included contributions from resuspended dust in between uranium handling operations. 

5.16 SECTION 7.2.3.2: METHODS FOR BOUNDING RESIDUAL PERIOD 

INTERNAL DOSE 

Section 7.2.3.2 describes the assessment of internal doses during the residual period based on 

assumptions about contamination levels and a resuspension factor, as discussed by Allen and 

Glover (2007). We disagree with these methods, which are also used to estimate uranium 

intakes in between uranium handling operations during the operational period. This issue is 

discussed in section 4.1.3 of this review. 

5.17 SECTION 7.2.4: INTERNAL DOSE RECONSTRUCTION FEASIBILITY 

CONCLUSION 

Section 7.2.4 states, “NIOSH concludes that the methods described in Battelle-TBD-6000 and 

Battelle-TBD-6000 Appendix BB provide reasonable approaches to conservatively bound 

internal doses for all members of the class under evaluation.” We disagree with this conclusion 

for reasons discussed in sections 4.1.3 and 5.16. 

5.18 SECTION 7.3.1: EVALUATION OF BOUNDING PROCESS-RELATED 

EXTERNAL DOSES 

Section 7.3.1 of the ER contains several subsections, which are discussed together in this section 

of the present review. Section 7.3.1.1 states, “The radiographers are considered to be the 
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maximally-exposed group of workers based on the potential sources for external radiation.” This 

assertion overlooks the potential exposures of other workers who were not monitored, as 

discussed in section 5.13 of the present review. Furthermore, section 7.3.1.1 repeats the 

assertion made earlier in the ER that 1964 represents the year of maximum potential exposures. 

We disagree with this statement, as discussed in section 5.12 of the present review. One of our 

objections is that the simultaneous operation of two betatrons did not pose the potential for 

higher exposures to individuals, since each betatron required a separate team, consisting of an 

operator, an assistant, and a film reader. An operator would have had a full schedule, resulting in 

the same period of exposure per shift. It is true that the increased work may have led to more 

overtime work, leading to greater periods of exposure per week. 

Other employees (non-radiographers)

Under the heading “Other employees (non-radiographers),” this section of the ER discusses and 

then dismisses one of the exposure scenarios developed by SC&A (2008). That scenario was 

used to calculate exposure rates outside the shooting room in the New Betatron Building while 

the betatron was used to radiograph a casting that was left on the railroad track at the edge of the 

shooting room. Using the betatron in that orientation required overriding limit switches, which 

could be accomplished by flipping the head of the instrument (i.e., rotating it through 180o). The 

ER dismisses this scenario, saying, “However, operators indicated this was not done until after a 

particular supervisor left the company (Meeting Minutes, October 9, 2007 [Anigstein 2007]) 

after the AEC contract period ended.” 

Although [Supervisor A], the supervisor in question, did remain at GSI until after the AEC 

contract period ended, he had been promoted and moved to another division not involved with 

betatron operations at an earlier time.7 [Supervisor B], the supervisor who took over after 

[Supervisor A], ordered the betatron operator to override the limit switches (Anigstein 2007). 

The Landauer film badge dosimetry reports for 1964 list the name “[Surname of Supervisor A]” 

on weekly reports through the week of November [REDACTED]; this name is not found on any 

later report. Thus, it appears most likely that [Supervisor A] was transferred to his new position 

by the end of that week, if not sooner. Having been issued a film badge, it is highly unlikely that 

he would continue being involved with betatron operation but not be monitored. Furthermore, 

the name “[Surname of Supervisor B]” is first found on the report for the week of January 

[REDACTED], 1965. However, that report indicates that there were nine previous reports for this 

individual, which would have begun in November 1964. Thus, it would appear [Supervisor B] 

started work in the betatron at about the same time [Supervisor A] left that facility.8 

Further evidence is furnished by the headings of the Landauer film badge dosimetry reports. The 

reports for the weeks starting January 25, 1965 and later are addressed as follows: 

 

7

 [Supervisor A], private communication with Robert Anigstein, SC&A, Inc., November 5, 2008. 

8

 According to [Supervisor A], another employee, [Worker C], took over his supervisory duties when he was 

transferred and before [Supervisor B] took charge. The surname of [Worker C] is listed in the film badge reports 

during the entire covered period. 
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GENERAL STEEL IND IN 

ATTN [SUPERVISOR B] 

MGR NON DESTRUCTIVE 

TESTING 

GRANITE CITY ILLINOIS 

This information clearly shows that [Supervisor B] was in charge of the betatron operation, 

starting at least in early 1965. Therefore, the practice modeled in our scenario may have taken 

place during at least part of the covered period (i.e., January 1965–June 30, 1966). 

Since the scenarios modeled by SC&A (2008) most likely did occur during the covered period, 

they need to be addressed in the ER. We calculated exposure rates of 24 and 25 mR/h in the 

restroom and the break area, respectively, while the betatron was used to radiograph castings on 

the railroad track. We must point out that the exposure geometry in this scenario was selected as 

an example, based on information from former betatron operators. It is possible that other 

plausible orientations of the betatron and the castings could have resulted in higher exposure 

rates in these locations. A similar observation applies to exposure rates on the roof, which were 

calculated with the beam aimed horizontally. In reality, the beam could be angled upwards to 

radiograph the lower portion of a round hollow casting, such as the one illustrated in SC&A 

2008, figures 19 and 20. Our purpose in performing these exposure calculations was to point out 

that the exposure rates could be significantly higher than those calculated by Allen and Glover 

(2007). We do not represent them as yielding the maximum exposure rates of workers outside 

the shooting room. 

Beta

Under the heading “Beta,” this section refers to exposures to beta rays from handling uranium 

ingots, and ascribes the discussion of exposure times to Allen and Glover (2007). These authors, 

in turn, state that the beta dose was calculated according to Scherpelz (2006, section 6.3). Our 

calculations of the beta dose from uranium (SC&A 2008, section 2.6.2) yielded higher results 

because of our bounding assumption that the radial surface of the slice (corresponding to the 

surface of the uncut uranium ingot) would have an enhanced concentration of the short-lived 

progeny of 238U, namely 234Th and 234mPa. The latter nuclide is a powerful beta emitter; hence, 

the beta dose would be higher to skin exposed to this surface. 

According to the ER, “The time period and exposure rates were conservative enough to bound 

any beta dose from steel-handling operations as well.” We disagree with this conclusion. 

During the later years of the covered period, the uranium radiography declined steadily, so the 

beta dose from exposure to steel following radiography became relatively more significant. For 

instance, in 1965, the last full year of covered operations, we estimated the annual dose to the 

skin of the hands and forearms to be 3.3 rads, of which 1.4 rads was from uranium and 1.9 rads 

from steel. Allen and Glover (2007, section BB.4.5) stipulate a dose of 1.179 rads during this 

time, or about one third as much. 

Neutron

In the “Neutron” section, the ER states, “As with other facilities, neutron doses can be 

determined using the photon-to-neutron ratio.” Our detailed calculations (summarized in SC&A 
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2008, table 2) show that the neutron:photon ratio can range from 2% to 99% for the exposure 

geometries that we modeled. For exposures to activated steel and to radiographic sources other 

than the betatron, the ratio is zero. Thus, establishing a comprehensive ratio would require 

additional analyses. 

5.19 SECTION 7.3.3: GENERAL STEEL OCCUPATIONAL X-RAY 

EXAMINATIONS 

We agree that doses from occupational radiographic examinations can be estimated using 

ORAUT-OTIB-0006 (Kathren and Shockley 2005). However, in the two cases from GSI that we 

have examined, the methodology prescribed in this guide was not applied in a claimant-favorable 

manner. As discussed in sections 4.1.2 and 4.2.2 of the present review, the dose reconstructions 

did not assume that the examinations utilized photofluorography (PFG) prior to January 31, 

1962, as prescribed in ORAUT-OTIB-0006. 

5.20 SECTION 7.3.4.1: METHODS FOR BOUNDING OPERATIONAL PERIOD 

EXTERNAL DOSE 

Photon Dose

Under the heading “Photon Dose” in section 7.3.4.1 of the ER, the author summarizes the 

Landauer film badge reports for the weeks beginning January 6, 1964 through June 27, 1966. 

We have independently reviewed these reports and found two minor discrepancies. We found 23 

reported values of 10 mrem or greater, not 22 as cited in the ER. Furthermore, the ER states, “no 

individual had more than one reading above the 10 mrem recording limit during this time frame.” 

In fact, one worker had doses of 10 mrem and 290 mrem during two separate weeks in 1964. 

More important, we disagree with the calculation of the 95th percentile weekly dose, based on 

these data. The author calculated a mean weekly dose to the 89 workers of 10.35 mrem with a 

standard deviation of 2.75 mrem. She then uses these values to estimate a 95th percentile weekly 

dose of 14.87 mrem. We have reproduced the calculated values of the mean; however, we 

obtained a value of 2.68 mrem for the standard deviation of the weekly dose of the 89 workers, 

considering the actual number of badge reports during the covered period, as reported by 

Landauer. Another issue with this method is that it gives equal weight to the dosimetry reports 

for each of the 89 workers. The total number of badge reports for each of the 11 workers who 

had reported weekly readings > 10 mrem ranges from 8 to 134. The weekly averages should be 

weighted by the number of badge reports. 

These issues aside, we note that the calculation of the 95th percentile dose, based on the mean 

and the standard deviation, is valid only for data that has a normal distribution. Our analysis of 

these data, reported by Anigstein (2008), shows that the distribution of the average weekly 

dosimetry reports for the 89 workers is neither normal nor lognormal. Consequently, the method 

used to derive a bounding weekly dose is not scientifically correct nor is it claimant favorable. 

The ER next states, “these data confirm that the Battelle-TBD-6000 Appendix BB method for 

assigning external dose can be considered bounding for all employees.” We disagree with this 

statement. In one case, an employee named [REDACTED] had a recorded dose of 2,470 mrem for 
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the week of 06/[REDACTED]/1965. This would represent a 1-week exposure far in excess of the 

average weekly exposure based on the annual exposure of 2,135 mR assigned by Allen and 

Glover (2007). Another instance of high dose was reported for the week of 

11/[REDACTED]/1972, when a worker named [REDACTED] received a recorded dose of 

7,590 mrem. Although this reported exposure occurred after the covered period, there is no 

reason to believe that the operations at GSI had changed between 1966 and 1972. This indicates 

a potential for incidents leading to higher exposures than predicted by the model developed by 

Allen and Glover. 

Beta Dose

Under the heading “Beta Dose,” the ER describes the methodology of calculating the doses from 

external exposure to beta rays adopted by Allen and Glover (2007). We found several issues 

with this methodology, which are discussed under the heading “Beta” in section 5.18 of this 

review. 

Neutron Dose

Under the heading “Neutron Dose” is the statement, “A study is in place to determine the 

photon-to-neutron ratio.” We have to reserve further comments on the neutron dose assessment 

until we have had a chance to review the aforementioned study. 

5.21 SECTION 7.3.5: EXTERNAL DOSE RECONSTRUCTION FEASIBILITY 

CONCLUSION 

Section 7.3.5 of the ER states, “By modeling external dose from radiographer film badge data, 

dose estimates are plausible and bounding.” We interpret this statement to refer to the 

methodology of deriving 95th percentile doses from the Landauer film badge reports for 1964–

1966, which we discuss in section 5.20 of this review. We disagree with this statement, as 

discussed in the previous section. We agree that the methodology for estimating external doses 

during the residual period is bounding and claimant favorable. 

5.22 SECTION 7.4.1: LACK OF MONITORING DATA 

Section 7.4.1 of the ER states: 

NIOSH has compared is in the process of comparing the dosimetry data to the 

modeled estimates provided by both Battelle-TBD-6000 Appendix BB and the 

SC&A analysis. Based on a this [sic] preliminary assessment of the comparison, 

the dosimetry data support the finding that the dose reconstruction approach in 

Battelle-TBD-6000 presents a bounding approach for the workers at the General 

Steel Industries site, which includes the proposed worker class dose that is 

evaluated in this report. [Emphasis added.] 

The emphasized text in the first line seems to indicate that the ER is an unfinished draft—we 

cannot conclude if the comparison has been completed or is in progress. Likewise, the term 

“preliminary assessment” indicates a work in progress. Furthermore, it is not clear if the 

reference in the third line to “Battelle-TBD-6000" is to the main document (Scherpelz 2006) or 
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to the appendix (Allen and Glover 2007). Although Scherpelz (2006) does present methods for 

dose reconstruction, we presume that in this instance, the author meant to refer to Allen and 

Glover 2007. 

5.23 SECTION 7.4.2: UNDERESTIMATED EXTERNAL DOSE MODELING 

Section 7.4.2 of the ER states: 

NIOSH has obtained film badge results for the betatron operators and has 

compared is in the process of comparing these data to the modeled doses. As 

discussed previously, this comparisonbased [sic] on a preliminary assessment of 

the comparison, indicates the dosimetry data support that the dose reconstruction 

approach in Battelle-TBD-6000 presents a bounding approach for the workers at 

the General Steel Industries site, which includes the proposed worker class dose 

that is evaluated in this report. [Emphasis added.] 

The emphasizeditalicized text again indicates that the analysis, if not the ER itself, is a work in 

progress. We again do not know if the comparison has been completed or is in progress. 

5.24 SECTION 7.6: SUMMARY OF FEASIBILITY FINDINGS FOR PETITION SEC00105 

In section 7.6, the author concludes that it is feasible to complete dose reconstructions for GSI 

employees during the covered period, citing as evidence the fact that dose reconstructions have 

been completed for 208 out of 238 claimants. At the direction of the Board, we have reviewed 

two claims for which dose reconstructions were completed and which were denied 

compensation. As discussed in section 4.0 of this review, we found serious deficiencies in both 

cases. 

We agree that, with a few exceptions, Allen and Glover (2007) do provide guidance to enable 

health physicists to perform dose reconstructions. The exceptions are vague instructions for 

assessing intakes of uranium dust via the ingestion pathway, and ambiguity on assigning workers 

who may have performed radiography using sealed sources outside the betatron buildings the 

radiation exposures prescribed for betatron operators or those prescribed for the general worker 

population. These issues aside, we find that the guidance provided by Allen and Glover is 

neither claimant favorable nor scientifically valid. 

5.25 SECTION 9.0: CLASS CONCLUSION FOR PETITION SEC-00105 

In section 9.0, the final section, the author concludes: 

NIOSH’s guiding principle in conducting these dose reconstructions is to ensure 

that the assumptions used are fair, consistent, and well-grounded in the best 

available science. Simultaneously, uncertainties in the science and data must be 

handled to the advantage, rather than to the detriment, of the petitioners. When 

adequate personal dose monitoring information is not available, or is very 
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limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the 

feasibility of reconstructing the dose of an SEC petition class. NIOSH contends 

that it has complied with these standards of performance in determining the 

feasibility or infeasibility of reconstructing dose for the class under evaluation. 

We find that these guiding principles have not been observed in the case of former GSI 

employees. The basis of this conclusion is discussed in section 6 of this review. 
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6.0 FINDINGS 

We do not agree that the methods of dose reconstruction cited by Buker et al. (2008) are 

bounding, claimant favorable, or scientifically correct. We base this conclusion on a number of 

issues with the NIOSH analyses which are summarized below. Most of these issues are 

discussed in greater detail in the preceding sections of this review. 

Issue 1. Lack of Radiation Monitoring Data for 1953–1963 

The lack of radiation monitoring data for the 11-year period 1953–1963 precludes a bounding 

assessment of external exposures to direct penetrating radiation. There were four reported 

incidents during this period: (1) a worker who was not a radiographer mistakenly took home a 

60Co source; (2) [REDACTED], who was not a radiographer, remained inside an Army tank being 

radiographed with the betatron; (3) [Worker A], a betatron operator, reported he was involved in 

an incident with “Betatron II” (presumably the new betatron) just prior to the beginning of the 

Landauer film badge monitoring program; (4) an employee of St. Louis Testing, a GSI 

contractor, reported finding an unsecured 60Co source which may have exposed GSI employees. 

These are based on contemporary accounts of GSI employees ([Worker A] passed away after 

submitting an affidavit on November 25, 2006) and of the former employee of St. Louis Testing. 

There may have been other incidents unknown to the small number of former employees who 

shared their recollections of GSI operations. A more complete discussion is presented in section 

5.10 of this review. 

These incidents, especially the worker’s taking home a 60Co source, indicate a serious 

breakdown of radiation controls. It is not possible to assign bounding exposures under such 

conditions. Given these conditions, we do not believe that extrapolating the film badge 

dosimetry reports back to 1953 provides a valid basis for dose reconstruction during this period. 

Issue 2. Incomplete Monitoring of Workers: 1964–1966 

The film badge dosimetry records for 1964–1966 list the names of 89 workers, who are believed 

to have been members of the betatron teams or radiographers who used sealed sources. Former 

workers have reported that the badges were stored in a rack just outside the New Betatron 

Building, and that they were required to take off the badge whenever they left the betatron 

buildings. Consequently, the monitoring of even these workers was incomplete, since it did not 

cover exposures they might have received outside the betatron building. Areas in 10 Building, 

including the restroom, were potentially exposed while the betatron was in operation. 

Furthermore, some of these workers may have worked as layout men who were in intimate 

contact with castings immediately after betatron radiography. They would not have been 

wearing their badges while performing such duties. 

The monitored workers represent a small fraction of the total GSI workforce. One incident that 

occurred during this period involved a worker identified only by the first name “[REDACTED],” 

who was inside a casting while it was radiographed with a betatron (see section 5.10 of this 

review). He was not a radiographer and was therefore not monitored. 
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Issue 3. Lack of Documentation 

There are few contemporary records to document operations at GSI during the operational 

period. The available records comprise purchase orders for uranium radiography spanning the 

period 1958–1963, correspondence between General Steel and Mallinckrodt regarding payment 

of a single invoice for radiography prior to February 1958, a December 1953 memo referring to 

betatron radiography at General Steel Castings (as GSI was then known), and Landauer film 

badge dosimetry reports for 1964–1973. There is no information on the extent of uranium 

radiography at GSI prior to March 1, 1958, except for a February 28, 1958, memo requesting 

payment for an earlier invoice (Brownfield 1958). Consequently, it is impossible to determine 

the exposure of workers to uranium from January 1, 1953, the assumed start of uranium handling 

operations, to March 1, 1958. 

There are no records regarding the radioactive sources used for radiography. We queried the 

Illinois Emergency Management Agency, Division of Nuclear Safety regarding these sources, 

and were told that the State has no records pertaining to the period when GSI was in operation, 

since that was prior to Illinois’ becoming an NRC Agreement State in 1987. The Agency 

referred us to NRC Region III, which includes Illinois. The Region III office in turn referred us 

to NRC Headquarters in Rockville, Maryland. Our inquiry was referred to the NRC Public 

Document Room. A researcher informed us that the facility had earlier received a FOIA request 

regarding GSI, and that a search of the archives showed that there were no records available. We 

were informed that it was the policy of NRC to turn over records of old radioactive materials 

licenses to the National Archives and Records Administration (NARA). NARA normally 

destroys such records that are more than 30 years old. Consequently, the only information 

regarding the radiography sources is based on the recollections of former GSI employees of 

events that took place 40–50 years ago. For example, the “small” 60Co source used in 6 Building 

was variously described as having an activity of less than one curie or 0.25 Ci. The large source 

was described as 80 Ci; however, we could not determine when it was acquired. Given the 5.27-

y half-life of this nuclide, the date of acquisition would affect its activity at various times during 

the operation of GSI. 

The existence of the two Allis-Chalmers betatrons is documented in a report of a FUSRAP 

survey, which found the machines still on the former GSI site (Cottrell and Carrier 1990). The 

only written documentation specific to the operating characteristics of these units is a data sheet 

on betatron tubes furnished to GSI after the period of AEC operations and a report based on the 

personal recollections of a former Allis-Chalmers employee (Schuetz 2007). However, copious 

information is available about the operating characteristics of Allis-Chalmers betatrons in 

general. 

Given the paucity of documentation, it is difficult to establish suitable parameters for dose 

reconstruction. 

Issue 4. Film Badge Dosimetry Dependence on Photon Energies and Exposure Geometry 

As discussed in section 5.12 of this review, the response of a film badge dosimeter is highly 

dependent on the angle of the incident radiation, especially if the radiation source is behind a 
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person wearing a film badge on the front of his body. To a smaller extent, the film badge 

response varies with the energy of the incident photons. Consequently, given the complex 

exposure conditions at GSI, the film badge records are at best an approximate measure of the 

radiation doses received by their wearers. 

Issue 5. Lack of Validation of Models of Radiation Exposure of Betatron Operators 

Even for the period of time for which film badge dosimetry reports are available, there is no 

agreement between the measured and the modeled exposures. In SC&A 2008, we have 

presented a detailed critique of the models of external exposure developed by Allen and Glover 

(2007). We have performed an independent analysis to demonstrate that the exposures to 

betatron radiation and to activated steel could be higher than those predicted by the NIOSH 

model. However, we do not claim that our model is definitive, based as it is on a limited set of 

exposure scenarios and extensive conjectures on exposure durations and geometries. 

The film badge data, which indicates that the vast majority of weekly reports list doses of less 

than the reporting level of 10 mrem, calls both the NIOSH and SC&A models into question. 

Conversely, neither model explains how one worker received a dose of 2,470 mrem in one week 

during the period of covered operations, or how another worker was reported to have received a 

dose of 7,590 mrem in one week after the end of AEC operations at GSI. Although the latter 

dose is, strictly speaking, outside the scope of this review, it does call into question the exposure 

conditions at GSI. Since there is no basis for believing that the operating conditions were 

significantly different in the later years, except for the absence of uranium, such a dose report 

should be considered in evaluating the models of external exposure. 

In short, neither the film badge data nor the modeled exposures can be used to establish an upper 

bound to the external exposures of betatron operators that is claimant favorable and scientifically 

correct. 

Issue 6. Underestimate of External Exposure of Unmonitored Workers 

Allen and Glover (2007) make a seemingly arbitrary distinction between two classes of workers. 

Betatron operators and workers who handle metal within 2 hours of irradiation are assigned a 

higher exposure, ranging from 2.1 to 6.3 R/y, depending on the calendar year, while all other 

workers are assigned an exposure of about 1.7 R/y. The latter exposure rate is based on a 

calculated exposure rate of 0.72 mR/h in shielded areas of the plant. We have calculated 

exposure rates far in excess of this value in locations accessible to workers not involved in 

radiography, including a rate in excess of 1 R/h on the roof while the 80 Ci 60Co was in use. 

Given the lack of any systematic program of radiation protection to bar access to these areas 

during betatron or 60Co radiography, and the fact that the exposures of these other workers were 

not monitored, it does not appear to be possible to bound their radiation exposures in a manner 

that is scientifically correct and claimant favorable. Thus, the distinction between the external 

exposures assigned to these two classes of workers is not adequately justified and could result in 

a significant underestimate of the external exposures of some of the workers that are assigned the 

lower exposures. 
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Issue 7. Dose Reconstructions Not Based on Best Available Science 

SC&A (2008) has documented a number of scientific errors in Appendix BB. Most notable is a 

20-fold error in calculating the dose rate from irradiated uranium, which we found in the 

computer program files used by NIOSH. Although this error increases the dose rate and is 

therefore claimant favorable, it is not scientifically correct. The calculated values are therefore 

not acceptable for use in dose reconstructions which, according to the guiding principle cited by 

Buker et al. (2008, section 9.0) are to be “well-grounded in the best available science.” 

Issue 8. Incomplete Model Used for Exposure Assessments 

It would appear that the model used by NIOSH for the 208 dose reconstructions completed by 

October 3, 2008, the date of the ER, is incomplete. We base this conclusion first on the response 

by NIOSH to some findings in the “Issue Resolution Matrix for SC&A Findings on Appendix 

BB to TBD-600[0],” dated June 19, 2008. In response to Issue 10: “Errors in Calculating Dose 

Rates from Uranium,” NIOSH wrote: 

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. 

Our review of Case [B] (see section 4.2.1 of this review) indicates that NIOSH did use doses 

modeled by Allen and Glover (2007). To the best of our knowledge, NIOSH has not revised this 

model. NIOSH made similar comments in response to other SC&A findings regarding the 

scientific validity of the Appendix BB models. 

Other indications that the NIOSH model is incomplete are given by Buker et al. (2008). In 

section 7.3.4.1, under the heading “Neutron Dose” is the statement, “A study is in place to 

determine the photon-to-neutron ratio.” As we found in our audit of Case [B], NIOSH has 

neglected the neutron dose in performing dose reconstructions. Furthermore, section 7.4.2 states, 

“NIOSH has obtained film badge results for the betatron operators and has compared is in the 

process of comparing these data to the modeled doses [emphasis added].” This sentence 

obviously requires editing: we cannot judge if the comparison has been completed or is in 

process. In either case, to the best of our knowledge, the results of any such comparison have 

not been communicated to the Board or to SC&A. 

Given the undetermined status of the model, we find that the dose reconstructions performed by 

NIOSH to date do not meet the standard of scientific accuracy. 

Issue 9. Underestimate of Beta Dose 

The beta dose assigned to GSI workers may be underestimated. As discussed under the heading 

“Beta” in section 5.18 of this review, freshly cast uranium ingots may have enhanced 

concentrations of the short-lived progeny of 238U on the surface, leading to a significant increase 

in the beta dose over aged natural uranium metal. Furthermore, uranium ingots were handled not 
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only by the betatron workers but also by chainmen who transferred the ingots from the trucks or 

railway cars on which they arrived at the plant to the plant’s own railway system. Such workers 

would also have been exposed to the beta rays from the uranium, but they are not assigned such 

exposures in the guidance for dose reconstruction of Allen and Glover (2007). 

Issue 10. Lack of Consistency in Assigning External Exposures 

Because of an error in calculating the external exposure to irradiated uranium, Allen and Glover 

(2007) assign a disproportionately high exposure rate to workers handling uranium following 

radiography while underestimating (in modeling terms) exposures to the betatron and to 

irradiated steel. This results in exposure rates that vary from year to year. By contrast, SC&A 

(2008) estimated that the bounding external exposures to direct penetrating radiation did not vary 

significantly over the duration of AEC operations. The dose reconstruction approach prescribed 

by NIOSH can inappropriately assign a dose to a betatron operator working in 1961 that would 

be 3 times the dose to one working in 1965. 
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Ramspott, C., and [REDACTED] 2007. “[REDACTED] Comment and Reply Re: Appendix BB to 

Battelle TBD-6000 for the General Steel Industries Site: Submitted to OCAS and its Director, 

Larry Elliott as a Public Comment to the July 17-19, 2007 ABRWH Meeting and as a Public 

Docket Comment to the Appendix BB for posting on the OCAS Website.” 

http://www.cdc.gov/niosh/ocas/pdfs/d20/020pp2.pdf

[Court Reporter] 2006a. “General Steel Industries Worker Outreach Meeting, August 21, 2006, 

Collinsville Holiday Inn.” http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi082106.pdf

[Court Reporter] 2006b. “General Steel Industries Worker Outreach Meeting, August 22, 2006, 

Collinsville Holiday Inn.” http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi082206.pdf

S. Cohen & Associates (SC&A) 2006a. “Report to the Working Group on Special Exposure 

Cohort Petition Review, Draft.” 

S. Cohen & Associates (SC&A) 2006b. “Board Procedures for Review of Special Exposure 

Cohort Petitions and Petition Evaluation Reports,” Revision 1. SCA-TR-TASK5-0002. 

S. Cohen & Associates (SC&A) 2007. “Draft Review of Battelle-TBD-6000, Site Profiles for 

Atomic Weapons Employers That Worked Uranium and Thorium Metals: Working Draft.” 

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

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

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

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

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. 

SimmonsCooper, LLC. 2006a. “GSI Affidavit Testimony,” July 7, 2006. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi070706.pdf. 

SimmonsCooper, LLC. 2006b. “GSI Affidavit Testimony," August 11, 2006. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/outreach/gsi081106.pdf

Williams, W. A. 1991. “Authority Determination--Granite City Steel Site, Granite City, Illinois.” 

U.S. Department of Energy Memorandum. 

[Worker A] 2006. “Declaration of [Worker A].” Attachment to < [REDACTED] > “GSI source 

terms/incident affidavit” February 19, 2009, personal e-mail to Paul Ziemer, Chair, ABRWH, 

Ted Katz, DFO, Larry Elliott, OCAS-NIOSH, Jim Neton, OCAS-NIOSH, John Mauro, SC&A.
Effective Date: 

July 24, 2009 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 1: REPORT OF INTERVIEW WITH [GSI PETITIONER] 

From: Robert Anigstein, SC&A June 24, 2009 

To: Distribution 

On June 24, 2009, at approximately 3:30 P.M., EDT, I spoke with the GSI petitioner, whom I 

contacted at [REDACTED]. The petitioner had submitted an SEC petition for General Steel 

Industries (GSI). 

 

I asked her to clarify the statement in the cover letter of her petition: NIOSH did not have a body 

to conclude this [that the probability of causation was less than 50%] with in my father's case. 

She explained that the statement meant that her father had died in the 1970s. Since he didn’t 

have a badge, NIOSH had no concrete proof on which to base his dose reconstruction. I then 

asked her to clarify the second part of her statement: nor did they have the quantity or quality of 

the use of the two betatron machines and facility conditions to properly conclude their findings. 

She said she meant that the evaluation report did not mention two betatrons at any given time, 

and wondered if they [NIOSH] knew the betatrons were used simultaneously. 

I then asked her about some of the references in the list that is part of the petition. She said that 

the issue raised via reference 6 was that Granite City Steel was at 20th Street while GSI was at 

1417 State Street. I explained that we are aware that Granite City Steel had purchased the GSI 

site, and she confirmed that that was what that was about. I next asked about the statement in 

conjunction with reference 5 (“DOE listings of nuclear facilities”) that beryllium metal was 

provided to Granite City Steel. She did not recall the basis for that statement. I next said that I 

could not find a Web site corresponding to reference 7, “Residual Radioactive Summary,” 

however, I said the residual contamination, cited under that reference, was taken into account. 

She said her reason for mentioning it was to include the class up to the 1992 (sic) cleanup, 

including the cleanup crew. 

Comment: The GSI petitioner referred to the ER when she apparently meant Appendix BB. 

Since the ER was written after the petition, she is correct in stating that NIOSH had not explicitly 

addressed the issue of the two betatrons which, in fact, were in use simultaneously, albeit in 

different buildings that were about 400 feet apart. 

On June 24, following the interview, I sent the GSI petitioner an e-mail containing the above text 

of my report of this interview and asked her to let me know if she had any corrections, additions 

or other comments, or if she agreed with my report. She has not responded as of this date. 
Effective Date: 

July 24, 2009 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 2: INTERVIEW WITH [WORKER D] 

From: Robert Anigstein, SC&A June 19, 2009 

To: Distribution 

Record of Telephone Conversation

On June 16, 2009, at approximately 9:30 P.M., EDT, I spoke with [Worker D], whom I 

contacted at [REDACTED]. [Worker D] had prepared an affidavit that was submitted by the GSI 

petitioner as part of the SEC petition for General Steel Industries (GSI). 

 

I asked him to clarify the statement in his affidavit: Primarily they would use the betatron 

machines to x-ray castings in buildings 8, 9, and 10. I asked if he meant that they took the 

castings from 8, 9, and 10 and then x-rayed them with the betatron. He replied that his memory 

of all this is “pretty faint.” He recalled a building where they took the castings. He mentioned 

that his [REDACTED] ([Worker B]) worked there for years after him and years before him and 

implied that he might have a better memory of the operations. I told him that I had talked to 

[Worker B] that afternoon, and that he agreed with me that the castings were brought to the 

betatron building which was next to building 10. [Worker D] said he couldn’t remember exactly, 

but that it was in that area, and added that [my account] seemed about right. 

In his affidavit, [Worker D] had also stated, “The betatron machines themselves were portable so 

they too were moved place to place.” I observed that it was my understanding and that of [the 

former GSI betatron operators] that I talked to, that the betatron was mounted on a crane inside 

the betatron building and that it could not leave the building. [Worker D] said they had little 

portable units that were taken out, but he didn’t know if they were actually called betatrons but 

were called Magnaflux machines. I described my understanding of the Magnaflux machines as 

magnetic devices that did not emit [ionizing] radiation. 

Later in his affidavit, [Worker D] stated, “The betatron machines were also used in 6 and 7 

buildings to x-ray tank hulls and turrets.” I asked if I was correct in saying that he didn’t believe 

that the betatron machines were actually taken to buildings 6 or 7. He replied, “No, if they had a 

casting, I remember they had a railroad car that would go across buildings on a track and they 

could put the castings on a railroad car and run it to the betatron building and pluck it off with a 

crane and put into the betatron building.” He was sure that the betatron did not leave the 

building. He guessed that there was some confusion in his mind about the betatron versus the 

Magnaflux. I mentioned that there was a portable x-ray machine, but [Worker D] said a portable 

would have been only for light castings. 

Followup E-mail Communication

On June 17, I prepared a draft summary of our telephone conversation and inserted it into an email message to [Worker D] ([REDACTED]). In my message, I asked [Worker D] to review the 

report and let me know if it correctly summarizes our discussion. In an e-mail that I received on 

June 17 at 11:50:45 PM EDT, [Worker D] replied, “I have read your transcript of our telephone 

conversation and I would attest that it accurately reflects that conversation.” 
Effective Date: 

July 24, 2009 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Comment: [Worker D’s] account is entirely consistent with our understanding of the operation 

of the betatrons at GSI.
Effective Date: 

July 24, 2009 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 3: INTERVIEW WITH [WORKER B] 

From: Robert Anigstein, SC&A July 13, 2009 

To: Distribution 

On June 16, 2009, at approximately 12:30 P.M., EDT, I spoke with [Worker B], whom I 

contacted at [REDACTED]. [Worker B] had prepared an affidavit that was submitted by the GSI 

petitioner as part of the SEC petition for General Steel Industries (GSI). 

 

I asked him to clarify the statement in his affidavit that he “worked primarily in buildings #8, #9, 

and #10 where the betatron machine was in operation.” I explained that it was my understanding 

that the betatron machine operated in the betatron building, which was adjacent to these 

buildings. He described the 10 building, and recollected that the betatron was right in the middle 

of it. I said that the betatron building connected to the center of the 10 building—[Worker B] 

agreed. I said that the rail cars went straight through the 10 building to the betatron building—

[Worker B] again agreed. I then asked if it was his recollection that the castings were taken to 

the betatron building. He said “Yes,” that he assumed they used the railroad tracks to push them 

in and out of the building. 

Comment: [Worker B’s] account is entirely consistent with our understanding of the operation 

of the new betatron at GSI. 

On June 18 I sent [Worker B] the above text of my report of this interview via the U.S. Postal 

Service, along with a letter asking him to let me know if he had any corrections, additions or 

other comments, or if he agreed with my report. He has not responded as of this date.