SEC Petition Evaluation Report 

Petition SEC-00161 

Report Rev #: 0 Report Submittal Date: January 20, 2010

Subject Expert(s): Michael Kubiak 

Site Expert(s): Pete Darnell 

Petitioner Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition A 

Receipt Date DOE/AWE Facility Name 

SEC-00161 83.14 December 28, 2009 General Electric Company (Ohio) 

NIOSH-Proposed Class Definition 

All employees of the Department of Energy, its predecessor agencies, and their contractors and subcontractors 

who worked at General Electric Company in Evendale, Ohio, from January 1, 1961 through June 30, 1970, for 

a number of work days aggregating at least 250 work days, occurring either solely under this employment or in 

combination with work days within the parameters established for one or more other classes of employees 

included in the Special Exposure Cohort.

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

N/A N/A N/A N/A 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

N/A N/A

ORAU Lead Technical Evaluator: Michael Kubiak ORAU Peer Review Completed By: James Mahathy

Peer Review Completed By: [Signature on file] 1/20/2010 

Pete Darnell Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 1/21/2010 

J. W. Neton Date 

SEC Evaluation Approved By: [Signature on file] 1/22/2010 

Stuart L. Hinnefeld Date 
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Evaluation Report Summary: SEC-00161, General Electric Co. (Ohio) 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees 

as Members of the Special Exposure Cohort Under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

NIOSH-Proposed Class Definition

All employees of the Department of Energy, its predecessor agencies, and their contractors and 

subcontractors who worked at General Electric Company in Evendale, Ohio, from January 1, 1961 

through June 30, 1970, for a number of work days aggregating at least 250 work days, occurring 

either solely under this employment or in combination with work days within the parameters 

established for one or more other classes of employees included in the Special Exposure Cohort. 

Feasibility of Dose Reconstruction Findings

NIOSH lacks sufficient information, which includes biological monitoring data, sufficient air 

monitoring information, and sufficient process and radiological source information, to allow it to 

estimate with sufficient accuracy the potential internal and external exposures to uranium, thorium, 

and fission product radionuclides to which the proposed class may have been subjected. 

NIOSH finds that it is likely feasible to reconstruct occupational medical dose for General Electric 

Company (Ohio) workers with sufficient accuracy. 

 Principal sources of internal and external radiation for members of the proposed class included 

exposures to uranium, thorium, and fission product radionuclides during operations such as hightemperature testing of refractory metals and alloys, reactor components, and fuel element 

materials, as well as the treatment of thorium-oxide in high-temperature furnaces. 

 NIOSH has obtained uranium and thorium urinalysis results for both 1965 through 1968 and 1970, 

but has determined that the data are insufficient for development of coworker dose distributions. 

NIOSH has found no fission product bioassay monitoring data for the period from January 1, 1961 

through June 30, 1970. 

 NIOSH has obtained individual external monitoring data for approximately twenty-five percent of 

the claims referred to NIOSH for dose reconstruction. NIOSH has found insufficient external 

monitoring data to allow for estimation of external dose for unmonitored energy employees. 

 A majority of workplace monitoring and source term information obtained by NIOSH pertains to 

periods outside the 1961-1970 Atomic Energy Commission operations period being evaluated. 

NIOSH has obtained source term information for some specific projects or experiments, but lacks 

the specific information from which to identify the operations with the highest exposure potential. 

Such information is required to enable NIOSH to bound potential exposures in the absence of 

personnel monitoring data. 
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 Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available (and that can be interpreted using existing NIOSH dose reconstruction processes or 

procedures) for an individual claim. Therefore, dose reconstructions for individuals employed at 

General Electric Company (Ohio) during the period from January 1, 1961 through June 30, 1970, 

but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 

Health Endangerment Determination

The NIOSH evaluation did not identify any evidence supplied by the petitioners or from other 

resources that would establish that the class was exposed to radiation during a discrete incident likely 

to have involved exceptionally high-level exposures, such as nuclear criticality incidents or other 

events involving similarly high levels of exposures. However, the evidence reviewed in this 

evaluation indicates that some workers in the class may have accumulated chronic radiation exposures 

through intakes of uranium, thorium, and fission products, and from direct exposure to these 

radioactive materials. Therefore, 42 C.F.R. § 83.13(c)(3)(ii) requires NIOSH to specify that health 

may have been endangered for those workers covered by this evaluation who were employed for a 

number of work days aggregating at least 250 work days within the parameters established for this 

class or in combination with work days within the parameters established for one or more other 

classes of employees in the SEC. 
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Table of Contents 

Evaluation Report Summary: SEC-00161, General Electric Co. (Ohio) ................................................ 3 

1.0 Purpose and Scope....................................................................................................................... 7 

2.0 Introduction ................................................................................................................................. 7 

3.0 NIOSH-Proposed Class Definition and Petition Basis................................................................ 8 

4.0 Radiological Operations Relevant to the Proposed Class ........................................................... 8 

4.1 Operations Description....................................................................................................... 8 

4.2 Radiation Exposure Potential from Operations.................................................................. 9 

4.3 Time Period Associated with Radiological Operations...................................................... 9 

4.4 Site Locations Associated with Radiological Operations .................................................. 9 

4.5 Job Descriptions Affected by Radiological Operations ................................................... 10 

5.0 Summary of Available Monitoring Data for the Proposed Class.............................................. 10 

5.1 Data Capture Efforts and Sources Reviewed ................................................................... 10 

5.2 Worker Interviews............................................................................................................ 11 

5.3 Internal Personnel Monitoring Data ................................................................................. 11 

5.4 External Personnel Monitoring Data................................................................................ 11 

5.5 Workplace Monitoring Data............................................................................................. 11 

5.6 Radiological Source Term Data ....................................................................................... 11 

6.0 Feasibility of Dose Reconstruction for the Proposed Class ...................................................... 12 

6.1 Feasibility of Estimating Internal Exposures ................................................................... 12 

6.2 Feasibility of Estimating External Exposures .................................................................. 13 

6.3 Class Parameters Associated with Infeasibility................................................................ 14 

7.0 Summary of Feasibility Findings for Petition SEC-00161........................................................ 14 

8.0 Evaluation of Health Endangerment for Petition SEC-00161................................................... 15 

9.0 NIOSH-Proposed Class for Petition SEC-00161 ...................................................................... 15 

10.0 Evaluation of Second Similar Class .......................................................................................... 15 

11.0 References ................................................................................................................................. 17 

Attachment 1: Data Capture Synopsis................................................................................................... 19 
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SEC Petition Evaluation Report for SEC-00161

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the Oak Ridge Associated Universities (ORAU) 

Team Lead Technical Evaluator: Michael Kubiak, MJW Technical Services, Inc. The rationales for 

all conclusions in this document are explained in the associated text. 

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for employees who worked at the General 

Electric Co. facility in Evendale, Ohio, from January 1, 1961 through June 30, 1970. It provides 

information and analysis germane to considering a petition for adding a class of employees to the 

Congressionally-created Special Exposure Cohort (SEC). 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report. 

This evaluation, in which NIOSH provides its findings both on the feasibility of estimating radiation 

doses of members of this class with sufficient accuracy and on health endangerment, was conducted in 

accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services add a class of employees to the SEC. The evaluation is 

intended to provide a fair, science-based determination of whether it is feasible to estimate, with 

sufficient accuracy, the radiation doses of the proposed class of employees through NIOSH dose 

reconstructions.1

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioners and the 

Advisory Board on Radiation and Worker Health. The Board will consider the NIOSH evaluation 

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, to make recommendations to the Secretary of HHS on whether or not to 

add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

 

1

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this final decision process, the 

petitioner(s) may seek a review of certain types of final decisions issued by the Secretary of HHS.2

3.0 NIOSH-Proposed Class Definition and Petition Basis 

The NIOSH-proposed class includes all employees of the Department of Energy, its predecessor 

agencies, and their contractors and subcontractors who worked at General Electric Company in 

Evendale, Ohio, from January 1, 1961 through June 30, 1970, for a number of work days aggregating 

at least 250 work days, occurring either solely under this employment or in combination with work 

days within the parameters established for one or more other classes of employees included in the 

Special Exposure Cohort. During this period, employees at this facility were involved with hightemperature testing of refractory metals and alloys, reactor components, and fuel element materials, as 

well as the treatment of thorium-oxide in high-temperature furnaces. 

The evaluation responds to Petition SEC-00161 which was submitted by an EEOICPA claimant 

whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient dosimetryrelated information. NIOSH’s determination that it is unable to complete a dose reconstruction for an 

EEOICPA claimant is a qualified basis for submitting an SEC petition pursuant to 42 C.F.R. § 

83.9(b). 

4.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize the radiological operations at the General Electric Company 

facility in Evendale, Ohio (GE-Ohio) from January 1, 1961 through June 30, 1970 and the information 

available to NIOSH to characterize particular processes and radioactive source materials. Using 

available sources, NIOSH has attempted to gather process and source descriptions, information 

regarding the identity and quantities of radionuclides of concern, and information describing processes 

through which the radiation exposures of concern may have occurred and the physical environment in 

which they may have occurred. The information included within this evaluation report is meant only 

to be a summary of the available information. 

4.1 Operations Description 

General Electric’s Aircraft Nuclear Propulsion (ANP) Project began in 1951 at the facility in 

Evendale, Ohio. The ANP work was performed in a facility known as Air Force Plant 36, a 68-acre 

portion of the larger General Electric Aircraft Engine Plant (EPA, 2008). The ANP Project was 

terminated in 1961; however, the use of radioactive materials continued under other Atomic Energy 

Commission (AEC) contracts (Murphy, 1988, p. 9). From 1961 through June 30, 1970, the AEC 

contract work occupied buildings C and D and certain other smaller auxiliary structures, under a use 

2

 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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permit from the Air Force. Custody of the facilities was returned to the Air Force on June 30, 1970 

(General Electric, 1974). 

AEC operations at GE-Ohio during the Department of Energy (DOE) operations period from January 

1, 1961 through June 30, 1970 included: 

 testing fuel element materials and high-temperature reactor materials (Rice, 1966, p. 110); 

 testing the effects of radiation on refractory metals and alloys (Rice, 1966, p. 110); 

 examining radiation effects in beryllium oxide (Rice, 1966, p. 110); 

 examining fission product transport processes in reactor fuels (Rice, 1966, p. 110); 

 testing the effects on clad uranium-oxide fuels in meltdown environments (Rice, 1966, p. 110); 

 developing a process for densification of thoria (Herries, 1966, p. 5); and 

 calcination of thorium-oxide in high-temperature furnaces (Rennich, 1965, p. 53). 

NIOSH has been unable to collect detailed data describing the processes or equipment associated with 

the operations listed above. A majority of the operations and monitoring data obtained by NIOSH are 

relevant only to the ANP Project years at GE-Ohio, prior to the covered period under evaluation in 

this report. NIOSH data capture efforts also failed to produce detailed source term information related 

to DOE/AEC operations at GE-Ohio during the 1961-through-1970 period. Review of the available 

data indicates the onsite existence of thorium and fission product residues (Karl, 1969). The potential 

for uranium and thorium exposures is also evidenced by the inclusion of elemental uranium, enriched 

uranium, and thorium in the GE-Ohio bioassay program through the 1960s (Boback, 1965; General 

Electric, 1964; General Electric, 1967). 

4.2 Radiation Exposure Potential from Operations 

The potential for internal and external radiation dose existed in Buildings C and D and surrounding 

support areas, including a fenced and locked outside radioactive waste storage area north of Building 

D. Based on the site operations outlined in Section 4.1, sources of exposure included uranium and 

fission product radionuclides from fuel and reactor component testing, and thorium from the 

calcination operations with thorium-oxide. 

4.3 Time Period Associated with Radiological Operations 

Per the DOE Office of Health, Safety and Security, the time period associated with DOE operations at 

GE-Ohio is from 1961 through 1970. NIOSH has found no data to identify a specific start date in 

1961, and therefore assumes January 1, 1961 for the start of DOE operations. NIOSH has found 

evidence that DOE/AEC operations ceased on June 30, 1970 when the facilities were returned to the 

Air Force (General Electric, 1974. Therefore, NIOSH assumes that the DOE operations period at GEOhio ended on June 30, 1970. 

4.4 Site Locations Associated with Radiological Operations 

Although Buildings C and D are specifically noted for the use of AEC-related radiological materials, 

documentation available to NIOSH does not indicate any definite boundaries between radiological and 

non-radiological areas for the period being evaluated. Given the lack of information to completely 

describe the source term and operations processes, especially in support areas outside of Building C 
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and D, NIOSH is unable to define individual worker exposure scenarios based on specific work 

locations within the GE-Ohio facility. 

4.5 Job Descriptions Affected by Radiological Operations 

Given the general lack of process knowledge, workplace surveys, or detailed source term information, 

it is not possible to determine that any specific work group was not potentially exposed to radioactive 

material during DOE operations at the GE-Ohio facility. NIOSH has found no documentation 

associating job titles and/or job assignments with specific radiological operations or conditions and is, 

therefore, unable to define potential radiation exposure conditions based on worker job descriptions. 

5.0 Summary of Available Monitoring Data for the Proposed Class 

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring are unavailable, internal 

exposures can sometimes be estimated using more general area monitoring, process information, and 

information characterizing and quantifying the source term. 

This same hierarchy is used for determining the external exposures to the cancer site. Personal 

monitoring data from film badges or thermoluminescent dosimeters (TLDs) are the primary data used 

to determine such external exposures. If there are no personal monitoring data, exposure rate surveys, 

process knowledge, and source term modeling can sometimes be used to reconstruct the potential 

exposure. 

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available at: 

http://www.cdc.gov/niosh/ocas/ocasdose.html. 

5.1 Data Capture Efforts and Sources Reviewed 

In addition to examining its Site Research Database (SRDB) to locate documents supporting the 

evaluation of the proposed class, NIOSH identified and reviewed numerous data sources to locate 

information relevant to determining the feasibility of dose reconstruction for the class of employees 

proposed for this petition. This included determining the availability of information on personnel 

monitoring, workplace monitoring, and radiological source term data. 

NIOSH data capture efforts for GE-Ohio focused on the General Electric Co., the Ohio Department of 

Health, DOE (including OpenNet repository; and Office of Scientific and Technical Information 

[OSTI]), and the National Archives record centers. Attachment One contains a summary of GE-Ohio 

documents. The summary specifically identifies specific data capture details for each document 

retrieved. 
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5.2 Worker Interviews 

To obtain additional information, NIOSH interviewed one former GE-Ohio employee on two different 

occasions. 

 Personal Communication, 2008, Personal Communication with Retired GE Evendale Health & 

Safety Manager; Telephone Interview by ORAU Team; April 1, 2008; SRDB Ref ID: 43509 

 Personal Communication, 2009, Personal Communication with Retired GE Evendale Health & 

Safety Manager; Telephone Interview by ORAU Team; August 18, 2009; SRDB Ref ID: 73138 

5.3 Internal Personnel Monitoring Data 

As of December 10, 2009, one of the 140 GE-Ohio claims referred to NIOSH for dose reconstruction 

has individual internal monitoring data available to NIOSH. NIOSH has found insufficient data to 

allow for the estimation of internal dose for unmonitored GE-Ohio energy employees. NIOSH has 

obtained GE-Ohio documents from DOE Legacy Management that contain uranium and thorium 

urinalysis results for 1965 through 1968 and 1970. The uranium and thorium urinalysis results are 

listed by sample number only (with no work identifiers), and NIOSH has determined that the data are 

insufficient for development of a coworker dose distribution. NIOSH has found no fission product 

bioassay monitoring data for GE-Ohio for the period being evaluated. 

5.4 External Personnel Monitoring Data 

As of December 10, 2009, 32 of the 127 GE-Ohio claims referred to NIOSH for dose reconstruction 

have individual external monitoring data available to NIOSH. Although some claimant files contain 

external monitoring data, NIOSH has found insufficient external data to allow for estimation of 

external dose for unmonitored GE-Ohio energy employees. 

5.5 Workplace Monitoring Data 

NIOSH has found insufficient workplace surface or air monitoring data to allow sufficiently accurate 

dose reconstruction in the absence of personnel internal or external monitoring data. A majority of the 

workplace monitoring data obtained by NIOSH pertains to the pre-1961 ANP project at GE-Ohio. 

NIOSH has also obtained U.S. Nuclear Regulatory Commission Decontamination Reports for the 

release of Buildings C and D in 1984 and 1986, respectively (General Electric, 1984; General Electric, 

1986), but the data are insufficient to bound potential exposures in the diverse fuel production and 

laboratory environments during the 1961-1970 AEC period of operations. 

5.6 Radiological Source Term Data 

NIOSH has found insufficient source term information to allow sufficiently accurate dose 

reconstruction in the absence of personnel internal or external monitoring data. As with the workplace 

monitoring data in Section 5.5 of this report, a majority of source term data obtained by NIOSH 

pertains to periods outside the 1961-1970 AEC operations period being evaluated. NIOSH has 

obtained source term information for some specific projects or experiments during the period from 

January 1, 1961 through June 30, 1962, but lacks the specific information from which to identify the 
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operations with the highest exposure potential. Such information is required to enable NIOSH to 

bound potential exposures in the absence of personnel monitoring data. 

6.0 Feasibility of Dose Reconstruction for the Proposed Class 

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient,

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy. 

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible. 

In accordance with § 83.14(a), NIOSH may establish a second class of coworkers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 

research and analysis is required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and whose only possible remedy under EEOICPA is the addition 

of a class of employees to the SEC. 

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions. 

6.1 Feasibility of Estimating Internal Exposures 

NIOSH has evaluated the available personnel and workplace monitoring data and source term 

information and has determined that there are insufficient data for estimating internal exposures, as 

described below. 

NIOSH has identified insufficient personnel and workplace monitoring data from which to draw 

conclusions regarding the potential magnitude of any internal doses from exposure to uranium, 

thorium, or fission products at GE-Ohio for the entire DOE operations period. The uranium and 

thorium bioassay data available to NIOSH do not represent potential exposures during the entire 

period under evaluation and are insufficient to support development of an internal dose coworker 

distribution. 

NIOSH has not identified sufficient documentation to define and quantify the total source term for 

GE-Ohio during the DOE operations period. Available documentation indicates that GE-Ohio worked 

with uranium, thorium, and fission product radionuclides throughout the entire DOE operations 
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period. Without additional documentation, NIOSH can make no assumptions about the relative 

amounts of these materials that would have been encountered at the site during the period from 

January 1, 1961 through June 30, 1970. Therefore, there is insufficient source term information 

available to NIOSH to bound internal exposures to uranium, thorium, and fission products for the 

period from January 1, 1961 through June 30, 1970. 

NIOSH does not have access to sufficient personnel monitoring, workplace monitoring, or source 

term data to estimate potential internal exposures to uranium, thorium, or fission product 

radionuclides during the period of DOE operations at GE-Ohio from January 1, 1961, through June 

30, 1970. Consequently, NIOSH finds that it is not feasible to estimate, with sufficient accuracy, 

internal exposures and resulting doses for the class of employees covered by this evaluation. 

Although it is not possible to completely reconstruct internal radiation doses for the period from 

January 1, 1961 through June 30, 1970, NIOSH intends to use any internal monitoring data that may 

become available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Dose reconstructions for individuals who do not qualify for 

inclusion in the SEC may be performed using these data as appropriate. 

6.2 Feasibility of Estimating External Exposures 

This evaluation responds to a petition based on NIOSH determining that internal radiation exposures 

to uranium, thorium, and fission product radionuclides could not be reconstructed for a dose 

reconstruction referred to NIOSH by the Department of Labor (DOL). As noted above, HHS will 

consider this determination to be sufficient without further consideration to determine that it is not 

feasible to estimate the levels of radiation doses of individual members of the class with sufficient 

accuracy. Consequently, it is not necessary for NIOSH to fully evaluate the feasibility of 

reconstructing external radiation exposures for the class of workers covered by this report. 

External dosimetry data are scarce for the GE-Ohio energy employees for the period January 1, 1961 

through June 30, 1970. Lacking information on the nature and extent of the radiological source term 

and monitoring practices at GE-Ohio, it is not feasible to fully reconstruct with sufficient accuracy the 

external doses that may have been received from potential external exposures during the operational 

period from January 1, 1961 through June 30, 1970. 

Adequate reconstruction of medical dose for GE-Ohio workers is likely to be feasible by using 

claimant-favorable assumptions in the complex-wide Technical Information Bulletin, Dose 

Reconstruction from Occupationally Related Diagnostic X-Ray Procedures (ORAUT-OTIB-0006). 

Although it is not possible to completely reconstruct external radiation doses for the period from 

January 1, 1961 through June 30, 1970, NIOSH intends to use any external monitoring data that may 

become available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Dose reconstructions for individuals who do not qualify for 

inclusion in the SEC may be performed using these data as appropriate. 
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6.3 Class Parameters Associated with Infeasibility 

As presented in Section 4.3, NIOSH has found no data to identify a specific start date in 1961, and 

therefore assumes January 1, 1961 for the start of DOE operations. NIOSH has found evidence that 

DOE/AEC operations ceased on June 30, 1970, when the facilities were returned to the Air Force 

(General Electric, 1974). NIOSH therefore recommends that the class be defined within the period 

from January 1, 1961 through June 30, 1970. 

As presented in Section 4.4, NIOSH is unable to define individual worker exposure scenarios based 

on specific work locations within the GE-Ohio facility. NIOSH therefore recommends that the class 

definition include all areas of the GE-Ohio facility during the specified time period. 

As presented in Section 4.5, NIOSH has found insufficient documentation associating job titles and/or 

job assignments with specific radiological operations or conditions. Without such information, 

NIOSH is unable to define the proposed SEC class based on worker job descriptions. NIOSH 

therefore recommends that the proposed class definition include all employees of DOE, its 

predecessor agencies, and their contractors and subcontractors who worked at GE-Ohio during the 

specified time period. 

7.0 Summary of Feasibility Findings for Petition SEC-00161 

This report evaluates the feasibility for completing dose reconstructions for employees at GE-Ohio 

from January 1, 1961 through June 30, 1970. NIOSH determined that members of this class may have 

received radiation exposures from uranium, thorium, and fission product radionuclides. NIOSH lacks 

sufficient information, which includes biological monitoring data, sufficient air monitoring 

information, or sufficient process and radiological source information that would allow it to estimate 

the potential internal exposures to which the proposed class may have been exposed. Reconstruction 

of external dose for individuals for whom personal monitoring records are not available is also not 

feasible. NIOSH considers the adequate reconstruction of medical dose for GE-Ohio workers to be 

feasible. 

NIOSH has documented herein that it cannot complete the dose reconstruction related to this petition. 

The basis of this finding demonstrates that NIOSH does not have access to sufficient information to 

estimate either the maximum radiation dose incurred by any member of the class or to estimate such 

radiation doses more precisely than a maximum dose estimate. 

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any available internal and external monitoring data that may 

become available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

GE-Ohio during the period from January 1, 1961 through June 30, 1970, but do not qualify for 

inclusion in the SEC, may be performed using these data as appropriate. 
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8.0 Evaluation of Health Endangerment for Petition SEC-00161 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by EEOICPA and 42 C.F.R. § 83.14(b) and § 83.13(c)(3). Pursuant to these requirements, if 

it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH 

must determine that there is a reasonable likelihood that such radiation doses may have endangered 

the health of members of the class. The regulations require NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has determined that members of the class were not exposed to radiation during a discrete 

incident likely to have involved levels of exposure similarly high to those occurring during nuclear 

criticality incidents. However, the evidence reviewed in this evaluation indicates that some workers in 

the class may have accumulated chronic radiation exposures through intakes of uranium, thorium, and 

fission product radionuclides, as well as from direct exposure to radioactive materials. Consequently, 

NIOSH is specifying that health was endangered for those workers covered by this evaluation who 

were employed for a number of work days aggregating at least 250 work days within the parameters 

established for this class or in combination with work days within the parameters established for one 

or more other classes of employees in the SEC. 

9.0 NIOSH-Proposed Class for Petition SEC-00161 

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all employees of the Department of Energy, its 

predecessor agencies, and their contractors and subcontractors who worked at General Electric 

Company in Evendale, Ohio, from January 1, 1961 through June 30, 1970, for a number of work days 

aggregating at least 250 work days, occurring either solely under this employment or in combination 

with work days within the parameters established for one or more other classes of employees included 

in the Special Exposure Cohort. 

10.0 Evaluation of Second Similar Class 

In accordance with § 83.14(a), NIOSH may establish a second class of coworkers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses are required. Such a class would be 

addressed in a separate SEC evaluation rather than delay consideration of the current claim. At this 

time, NIOSH has not identified a second similar class of employees at GE-Ohio for whom dose 

reconstruction may not be feasible. 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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11.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000; as amended; OCAS website 

Boback, 1965, Bio-Assay Department Monthly Report for November 1965, correspondence to J. A. 

Quigley; M. W. Boback; December 7, 1965; SRDB Ref ID: 44783 

EPA, 2008, Department of Defense Formerly Used Defense Sites (FUDS) Air Force Plant 36, 

website; Ohio Environmental Protection Agency (EPA); 

http://offo2.epa.state.oh.us/DoD/FUDS/SWfuds/Air_Force_Plant_36.htm; last accessed March 27, 

2008; SRDB Ref ID: 42496 

General Electric, 1964, Urinalysis: General Electric Company Invitation to Bid and Fernald’s 

Response; General Electric Co. and R. C. Heatherton, Fernald; September 9 & 18, 1964; SRDB Ref 

ID: 73178 

General Electric, 1967, General Electric Purchase Orders Issued to Fernald for Uranium and 

Thorium Urinalysis Services; General Electric Purchase Orders; May 23 and October 19, 1967; SRDB 

Ref ID: 73198 

General Electric, 1974, Air Force Plant 36, Evendale, Ohio; General Electric Co.; 1974; SRDB Ref 

ID: 7034, p. 8 

General Electric, 1984, Summary Report Decontamination of Building C-West U.S. Air Force Plant 

No. 36, Evendale, Ohio; General Electric; June 1984; SRDB Ref ID: 45568 

General Electric, 1986, Summary Report Decontamination of Laboratory Facilities Building D U.S. 

Air Force Plant No. 36, Evendale, Ohio; General Electric; November 1986; SRDB Ref ID: 45802 

Herries, 1966, Thoria Program, correspondence to T. C. Evans; R. R. Herries; January 10, 1966; 

SRDB Ref ID: 58545 

Karl, 1969, Nuclear Materials Control Survey of General Electric Company, correspondence to M. A. 

Zipkin; C. L. Karl; June 9, 1969; SRDB Ref ID: 44779 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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Murphy, 1988, Confirmatory Radiological Survey of the Building D Laboratory Area General 

Electric Company, Evandale [sic], Ohio, Final Report; G. L. Murphy and A. D. Luck; August 1988; 

SRDB Ref ID: 40240 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 03 PC-1; Oak Ridge Associated Universities (ORAU) Team Dose Reconstruction 

Project for NIOSH; December 21, 2005; SRDB Ref ID: 20220 

Personal Communication, 2008, Personal Communication with Retired GE Evendale Health & Safety 

Manager; Telephone Interview by ORAU Team; April 1, 2008; SRDB Ref ID: 43509 

Personal Communication, 2009, Personal Communication with Retired GE Evendale Health & Safety 

Manager; Telephone Interview by ORAU Team; August 18, 2009; SRDB Ref ID: 73138 

Rennich, 1965, Minutes of September 8, 1965 Thorium Operations Review and Planning Meeting, 

Memorandum to Files; George Rennich; September 21, 1965; SRDB Ref ID: 43017, pp. 48-55 

Rice, 1966, Summaries of Fuels and Materials Development Programs, draft copy; William L. R. 

Rice; March 1966; SRDB Ref ID: 21847 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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Attachment 1: Data Capture Synopsis 

Table A1-1: Summary of Holdings in the SRDB for General Electric Company (Ohio) 

Data Capture Information Data Capture Description Completed 

Uploaded 

into 

SRDB 

Primary Site/Company Name:

General Electric-Evendale 

BE 1951-1970; AWE/DOE 1961-

1970; Residual Radiation 1971-

1994 Company contacts are Troy 

Ochs, IH, and Susanne Herald, 

Environmental Counsel 

Other Site Names:

 GE Evendale 

 GE Cincinnati 

 GE Lockland 

 Air Force Plant 36 

Radiation and contamination surveys, 

decontamination reports, air sample results, 

instrument calibration and performance records, and 

source calibration records. 

07/06/2009 116 

State Contacted: Ohio Department 

of Health, physical data capture 

conducted on 11/19 and 

11/20/2007 

 

State registrations and license, description of ANP 

work, reactor safety determination, and a site 

survey. 

11/20/2007 26 

Comprehensive Epidemiologic 

Data Resource (CEDR) 

No relevant documents identified. 04/10/2008 0 

Department of Energy (DOE) AEC documents regarding the application of the 

AEC indemnity provision to the ANP Program. 

06/19/2008 25 

Department of Labor/Paragon Uranium scrap evaluations, nuclear safety 

inspections, industrial hygiene inspections, process 

descriptions, and FUSRAP documentation and 

review. 

12/30/2008 10 

DOE EM FUSRAP Files FUSRAP elimination recommendation, license 

applications, and a database report. 

07/22/2003 2 

DOE Hanford Declassified 

Document Retrieval System 

(DDRS) 

Hanford monthly reports. 10/15/2008 6 

DOE Headquarters, Germantown, 

MD 

Thorium research and development, beryllium data, 

and safety recommendations. 

07/22/2003 2 

DOE Legacy Management 

Considered Sites 

Tonawanda area progress report. 10/25/2007 1 

DOE Legacy Management - 

MoundView (Fernald Holdings, 

includes Fernald Legal Database) 

Health & Safety Division annual report, thorium 

process information, contamination survey of 

thorium handling equipment, laundering 

contaminated clothing, calcining thorium oxalate to 

thorium oxide for the FMPC Bettis Project, 

FUSRAP report, request for spectrographic analysis 

of thorium oxide, thoria powder progress reports, 

procurement documents, removal of equipment 

from GE, and accountability documents. 

04/03/2008 78 

DOE Office of Scientific and 

Technical Information (OSTI) 

Summary hazards reports, tensile strength of 

irradiated material, parameters of beryllium 

moderated critical assemblies, and proceedings of a 

nuclear propulsion conference. 

09/05/2008 5 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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Table A1-1: Summary of Holdings in the SRDB for General Electric Company (Ohio) 

Data Capture Information Data Capture Description Completed 

Uploaded 

into 

SRDB 

DOE OpenNet Human radiation studies oral history, AEC 

semiannual reports, and NYOO monthly status 

reports. 

04/04/2008 7 

DOE OSTI Energy Citations No relevant documents identified. 04/12/2008 0 

DOE OSTI Information Bridge Fuels, materials, and reactor component reports and 

a radioactive waste evaluation. 

04/12/2008 8 

Federal Records Center, Chicago, 

IL 

Plant air sampling records, film badge reports, 

exposure reports, urinalysis results, contamination 

surveys, nuclear safety records, and stack sampling 

results. 

10/02/2008 67 

Federal Records Center, Lee's 

Summit, MO 

Film badge reports. 11/04/2008 1 

Federal Records Center, San 

Bruno, CA 

Summaries of high temperature reactor research 

programs. 

01/31/2006 1 

Google Physics Division progress report, ORNL ceramics 

information meeting, DOD report on Air Force 

Plant 36, news report of toxic leak, health hazard 

evaluation reports, and reactor component research 

reports. 

05/27/2008 17 

Idaho National Engineering 

Laboratory Library 

Report of heat transfer reactor experiment No. 3. 10/30/2006 1 

Lawrence Berkeley National 

Laboratory 

History of GE contract with LBNL. 02/06/2007 1 

NARA - Atlanta Annual health protection status report, neutron 

source transfer records, material transfer records, 

material transfers to ORNL, and ANP fuel and core 

experiment reports. 

05/21/2008 22 

NARA - Kansas City Site decontamination history. 03/03/2005 1 

National Academies Press (NAP) No relevant documents identified. 04/13/2008 0 

National Nuclear Security 

Administration (NNSA) - Nevada 

Site Office 

No relevant documents identified. 04/10/2008 0 

New York State Department of 

Environmental Conservation 

Report on carbon reduction of uranium oxide. 02/25/2008 1 

NOCTS Organizational chart, job descriptions, process 

information, U-235 process information, shielding 

information, building 700 ventilation grievance, and 

radium chip exposure grievance. 

07/10/2008 20 

NRC Agencywide Document 

Access and Management 

(ADAMS) 

No relevant documents identified. 04/13/2008 1 

ORAU Team Project spreadsheets and process knowledge expert 

documented communications. 

04/01/2008 8 

Robert Kispert, FMPC Process 

Knowledge Expert 

History of FEMP thorium process operations. 03/28/2007 1 

SAIC Annual whole body exposure summaries. 09/02/2004 3 

Savannah River Site Dosimetry visitor cards. 08/26/2008 8 

Southern Illinois University, 

Edwardsville, IL 

GE waste disposed in the St. Louis area and an 

ERDA report citing need for obtaining GE 

dosimetric data. 

10/18/2008 2 
SEC-00161 01-20-2010 Rev.0 FINAL General Electric Co. (Ohio)

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Table A1-1: Summary of Holdings in the SRDB for General Electric Company (Ohio) 

Data Capture Information Data Capture Description Completed 

Uploaded 

into 

SRDB 

Unknown Fernald area and Lockland trip reports, technical 

report on GE ANP Program, exposure information, 

beryllium reports, NYOO air dust survey, and 

material transfers from Fernald. 

08/04/2003 10 

Washington State University (U.S. 

Transuranium and Uranium 

Registries) 

No relevant documents identified. 04/13/2008 0 

Total 451