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

FROM: Robert Anigstein and John Mauro, SC&A 

SUBJECT: Review of Appendix BB, Revision 1 

DATE: December 10, 2014 

Review of “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals 

Appendix BB – General Steel Industries,” Revision 1
 

On June 23, 2014, David Allen (NIOSH/DCAS) issued a revision of Appendix BB to TBD-6000 

(Allen 2014). In an e-mail message on June 30, 2014, Ted Katz, Designated Federal Official to 

the Advisory Board, asked SC&A to review this report. In our review, we confine the discussion 

to observations and issues in areas in which we and NIOSH are not in agreement. We also 

address, when appropriate, comments by the GSI copetitioner on the revised Appendix BB that 

were submitted jointly to James Melius, Chair of the Advisory Board on Radiation and Worker 

Health, Paul Ziemer, Chair of the Work Group on TBD 6000, and Ted Katz on July 21, 2014. 

Our comments address issues that affect the dose reconstruction methods prescribed in the revised 

appendix, and include observations on statements in the appendix that, while they do not affect 

dose reconstructions, fail to accurately describe the GSI facility in Granite City, Illinois, and its 

operations. 

1 Review Comments 

This review follows the sequence of topics presented by Allen (2014). Unless otherwise 

specified, the section, table, and figure numbers are from Allen 2014. 

1.1 Section BB.2.1: Site Activities 

In Section BB.2.1, Allen (2014) states “During the late 1950s and early 1960s, General Steel 

Industries used a betatron to x-ray uranium metal for the AEC under purchase orders issued by 

Mallinckrodt Chemical Works.” (Italics added) We observe that this statement is not strictly 

correct, in that the period of covered operations at GSI is October 1, 1952–June 30, 1966. 

Although the starting date on the Mallinckrodt purchase orders that were furnished by DOE is 

March 1, 1958, it must be assumed that there were purchase orders prior to that date. Later in the 

site profile, Allen correctly credits the radiation exposures of GSI workers during this earlier 

period; however, the statements in this section may mislead or confuse the reader and should be 

corrected. The sentence quoted above should be further edited by replacing “a betatron” with 

“betatrons” to explicitly recognize the presence of two betatrons in 1963–1966. 

1.2 Section BB.2.2: Frequency of Uranium X-Rays 

In Section BB.2.2, Allen (2014) describes the Mallinckrodt purchase orders covering the period 

March 1, 1958–June 30, 1961, as stipulating limits on monthly expenditures for the radiography 

of uranium metal shapes. We observe that, in fact, these purchase orders only list estimates of 

monthly expenditures, not limits. Allen is correct in citing annual limits on expenditures in the 

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purchase orders spanning the period July 1, 1961–June 30, 1966. We agree with NIOSH on the 

use of Mallinckrodt’s estimated expenditures to derive the hours of uranium exposure during the 

March 1, 1958–June 30, 1961, period. However, presenting the estimates of monthly 

expenditures as limits overstates the degree of conservatism in the exposure assessments during 

the earlier period. These statements and the heading “Monthly limit” in the fourth column of 

Table 1 (Allen 2014) should be revised. 

1.3 Section BB.4: Occupational External Dose 

As pointed out by the copetitioner, the sources of external radiation exposure included two 

250-kVp x-ray machines. This has no effect on worker exposures, since the two machines would 

not have been used simultaneously in the same location; however, the first sentence of 

Section BB.4 should be revised in the interest of accuracy. The second sentence of that section 

reads as follows: “Except for the uranium, all these sources were used to x-ray metal.” This 

sentence needs to be edited. A suggested revision is: “Except for the betatron, all these sources 

were used to x-ray steel castings.” (Italics added to identify changes) 

1.4 Section BB.4.1: Betatrons 

Expanding on a comment by the copetitioner, we suggest that references to the “old betatron” and 

the “new betatron” in the second paragraph of Section BB.4.1 be changed to “Old Betatron 

Building” and “New Betatron Building.” The construction dates refer to when the two buildings 

were erected. The text could be misinterpreted as referring to when the machines were 

manufactured.1

 Similar references to the construction of the New Betatron Building should 

include the word “building” to distinguish it from the betatron apparatus itself. 

To resolve a comment by the copetitioner regarding the source of the information on the betatron 

beam intensity, we suggest rewording the beginning of the third paragraph of Section BB.4.1 as 

follows (added text underlined and displayed in red, deleted text shown in blue with strikeout): 

Schuetz (2007) reported the intensity of the x-rays from the new betatron to be 250 R/min at 

3 feet from the platinum target with the aluminum compensator removed. He reported that 

the compensator reportedly reduced the intensity by a third. 

As suggested by the copetitioner, the sources of Figures 1–5 and Figure 8 should be cited. More 

legible versions of Figures 2–5 should be extracted from the original source documents. We 

suggest that the caption to Figure 1, “Drawing of the Old Betatron Building,” be clarified to 

indicate that it is the floor plan of the second floor (Bechtel 1994). 

1

 The “new” betatron went into operation at the General Steel foundry in Eddystone, Pennsylvania, in November 1951 

and was later moved to the Granite City facility, while the “old” betatron became operational at the Granite City foundry in 

January 1952. 

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1.5 Section BB.4.2: Betatron Building Model 

In Section BB.4.2, Allen (2014) describes the MCNP model of the New Betatron Building. In 

order to validate this model, NIOSH performed MCNP simulations of a radiation survey of this 

building described in NRC (2009a, pp. 34 et seq. of PDF file). Allen (2014, Table 3) lists the 

results of MCNPX simulations of the exposure rates at locations corresponding to those listed in 

the survey report. As observed by Anigstein and Olsher (2012), 

One significant difference between Allen's (2012) MCNPX simulation and information 

in the GSI AEC files is that Allen assumed a source strength of 80 Ci. Although it was 

referred to as an “80-Ci” source, the source had been procured 3 years prior to the 

survey. Assuming it had a nominal activity of 80 Ci at that time (there is no record of 

the actual assay of the source), the decayed activity at the time of the survey would 

have been approximately 54 Ci. . . . The results of Allen's (2012) MCNPX simulation, 

after adjustment for the lower source strength, are in reasonable agreement with the 

1971 survey data. 

The “modeled radiation levels” listed by Allen (2014, Table 3) should be adjusted to reflect the 

decayed activity of the 60Co source used for the radiation survey. Although such a change does 

not affect the dose reconstructions of former GSI workers, the MCNPX results presented in 

Table 3 overstate the conservatism of the model. Furthermore, as suggested by the copetitioner, 

the source of the survey data should be explicitly cited. 

1.6 Section BB.4.3: Betatron Operations External Dose Estimate 

In the section with the subheading “Neutron and Gamma Dose from Freshly Exposed Material,” 

Allen (2014, Section BB.4.3) discusses the neutron doses to the betatron operator. Although he 

does not identify the dosimetric quantities, these values are consistent with the neutron effective 

doses from this scenario calculated by SC&A (Anigstein and Mauro 2014). However, such doses 

cannot be used for dose reconstructions according to the guidelines in OCAS-IG-001 

(OCAS 2007). This document does not list dose conversion factors for neutron effective dose to 

organ dose equivalent, the choices being fluence to organ dose equivalent; ambient dose 

equivalent, H*(10), to organ dose equivalent; and deep dose equivalent, Hp,slab(10, 0o) (also known 

as personal dose equivalent), to organ dose equivalent. The neutron-fluence-to-dose conversion 

coefficients for H*(10) and Hp,slab(10, 0o) listed by ICRP (1997, Table A.42) are significantly 

higher than those for effective dose (ICRP 1997, Table A.41); therefore, using neutron effective 

doses with either the ambient dose equivalent or deep dose equivalent conversion factors from 

OCAS-IG-001 would be neither scientifically correct nor claimant favorable. 

As part of the present review, we have calculated neutron ambient dose equivalents to the 

betatron operator and the layout man using MCNPX, employing the same model we described 

previously (Anigstein and Mauro 2014), but substituting the neutron-fluence-to-ambient-dose 

conversion coefficients, H*(10) (ICRP 1997, Table A.42), for the fluence-to-effective-dose 

coefficients (ICRP 1997, Table A.41) used previously. The results are listed in Table 1 of this 

memo. As shown in this table, the dose from delayed neutrons emitted from uranium is 

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0.79 mrem ambient dose equivalent per shift. This numerical value is significantly higher than 

the 0.555 mrem (effective) dose cited by Allen (2014). 

Table 1 

Neutron Ambient Dose Equivalent, H*(10) to Betatron Operator and Layout Man (mrem/shift) 

Source of radiation Betatron 

operator 

Layout 

man 

Uranium handling 0.79 — 

Uranium radiography 1.47 — 

Steel radiography 0.86 1.84 

Pursuant to an observation by the copetitioner, we note that neutrons emitted by the new betatron 

constituted a second source of exposure to an operator in the Old Betatron Building. To perform 

a bounding calculation, we calculated the ratio of the neutron fluxes from the old and new 

betatrons in the control room of the Old Betatron Building, based on the inverse square law. 

Figure 1 of this memo shows the location of the two betatron buildings, copied from the GSI 

layout drawing. The New Betatron Building is shown in the upper left-hand corner of the figure, 

while the Old Betatron Building, labeled “Gov. Betatron Bldg.,” is in the lower right-hand corner. 

The red asterisk #1 in Figure 1 marks the position of the betatron operator in the control room of 

the Old Betatron Building, while asterisk #2 indicates the position of the head of the new betatron 

in the center of the shooting room of the New Betatron Building. According to the scale 

superimposed on this section of the plant plan, the distance between the two locations is 450 feet. 

In our MCNPX simulation of the neutron dose rate in the control room of the Old Betatron 

Building, the operator was 1,257 cm (41.25 ft) from the platinum target of the betatron. Applying 

the inverse square law, we find that the neutron flux from the new betatron would be 0.84% of the 

flux from the old betatron, taking no credit for the additional shielding of intervening strictures. 

This is well within the statistical uncertainty of the MCNPX simulations; therefore, this trivial 

contribution need not be considered further. 

This conclusion is further bolstered by the fact that the limiting scenario for external exposure 

during 1963–1966, the years during which both betatrons were operating, is the layout man. In 

this scenario, the worker is assumed to be located just outside the New Betatron Building, in the 

area shown in the upper-left-hand corner of Figure 1. Any neutrons from the old betatron 

reaching this location would be attenuated by passing through the southwest shield wall of the 

New Betatron Building, in addition to being greatly reduced by the distance. We nevertheless 

recommend that the revised Appendix BB should take note of this potential contribution to 

resolve any questions regarding this issue. 

1.6.1 Beta Skin Dose 

Allen (2014, Table 5) lists ß doses to the skin of betatron operators. We compare these doses to 

the current SC&A estimates, which have several components. We have previously listed the ß 

dose rates from irradiated steel (Anigstein and Mauro 2013a, Table 2)—we reproduce the relevant 

portion in Table 2 of this memo. We have also previously listed the annual doses to the skin of 

betatron operators from exposures to uranium and to irradiated steel (Anigstein and Mauro 2013a, 

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Table 5). Our analysis incorporated Allen’s (2014) assumption that the betatron operator was 

“1 foot from the [metal] object for half of the time he was exposed and 1 meter from the object for 

the remainder of the time.” However, we had neglected to include the dose rate from irradiated 

steel at a distance of 1 m, shown in Table 2 of this memo, in the annual doses from irradiated 

steel. A corrected version of our earlier tabulation is shown as Table 3 of this memo. 

Figure 1. Detail from Plant Layout, Showing Betatron Buildings (GSCC 1969) 

Table 2. Dose Rates to Skin from Beta Radiation from HY-80 Steel 

Distance 

Contact 

Shield 

 None 

Dose (mrad/shift) 

Betatron operator 

Shorta

 Longa Composite Shorta

9.20 5.02 7.71 3.15 

Layout man 

Longa

 Composite 

7.09 4.55 

1 ft Cloth 5.68 3.09 4.75 1.87 4.22 2.71 

1 m Cloth 2.09 1.14 1.75 0.08 0.17 0.11 

a Short and long shots 

The total ß doses to the skin of the hands and forearms listed by Allen (2014, Table 5) are lower 

than those shown in Table 3 of this memo for the years 1963–1966. The doses to the skin, other 

than that on the hands and forearms, listed by Allen are lower than those shown in Table 3 for 

every year of the covered period. We recommend that NIOSH and SC&A reconcile these 

differences. 

Allen (2014, Table 6) lists annual ß doses to the skin of the layout man: 807 mrads to the hands 

and forearms and 463 mrads to the skin of the whole body. As part of the present review, we 

recalculated the ß skin dose to the layout man, using the revised MCNPX analyses and the 

methodology we described previously (Anigstein and Mauro 2013a). We retained the exposure 

scenario described by SC&A (2008, p. 42): “To calculate the exposure of the layout man, we 

simplified the scenario described in Section 2.2.4 and made the claimant-favorable assumption 

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that he would be exposed to the steel 15 min after the last irradiation and would be in contact 

with the casting 90% of the time for 75 min.” As in our analysis of the ß dose to the skin of the 

betatron operator, we assumed that the skin of the layout man, other than that on the hands and 

forearms, was 1 ft from the casting while he was in close contact with the steel (90% of the time, 

vs. 50% for the betatron operator), and that he was at a distance of 1 m the remaining 10% of the 

time. The components of the ß skin dose per work shift derived from this analysis are listed in 

Table 2 of this memo. Using these results, we obtain annual doses of 1.89 and 1.14 rads to the 

skin of the hands and forearms and to the skin on the rest of the body, respectively, as shown in 

Table 4 of this memo—more than a 2-fold difference from the NIOSH results. We again 

recommend that NIOSH and SC&A reconcile these differences. 

Table 3. Annual Doses to Skin of Betatron Operators from Beta Radiation (rads) 

Annual number of shifts Hands and forearms Other skin 

Year 

Uranium Steel Uranium Steel Total Uranium Steel Total 

1952-1957 54.7 351.6 31.96 3.33 35.29 2.03 2.29 4.32 

1958 45.8 360.4 26.79 3.41 30.20 1.70 2.35 4.05 

1959-1960 42.2 364.1 24.66 3.44 28.10 1.57 2.37 3.94 

1961 48.4 357.8 28.31 3.39 31.69 1.80 2.33 4.13 

1962 35.2 371.1 20.55 3.51 24.06 1.31 2.41 3.72 

1963 9.6 396.7 5.59 3.75 9.35 0.36 2.58 2.94 

1964 3.5 402.7 2.05 3.81 5.87 0.13 2.62 2.75 

1965 2.6 403.7 1.50 3.82 5.32 0.10 2.63 2.72 

1966a 0.8 202.3 0.47 1.91 2.38 0.03 1.32 1.35 

a During contract period January 1–June 30 

Source: Anigstein and Mauro (2013a, Table 5) 

Table 4. Annual Exposures of Layout Man to External Radiation (1963–1966) 

External exposure Beta dose to skin (rads/y) Neutron H*(10) 

(R/y) Hands and forearms Other skin (rem/y) 

9.00 1.89 1.14 0.746 

As observed by the copetitioner, the second sentence of the last paragraph of p. 17 (Allen 2014) 

reads “MCNP was then used to calculation . . .” (Italics added) The word, of course, should be 

“calculate.” 

1.7 Section BB.4.4: External Dose Estimate for Isotope Source Operations 

In the subsection entitled “Radium-226 Radiography,” Allen (2014, Section BB.4.4), in 

describing the radiographic facility in No. 6 Building, refers to armor steel plates used for 

shielding. However, the drawing of this facility included in the report of the radiological survey 

of this facility, which shows the steel plates, includes the notation “shows additional shielding 

added June–July 1962” (NRC 2009b, p. 31). Furthermore, Anigstein (2011) reported an interview 

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with a former radiographer who worked at GSI during part of the Radium Era, which spanned the 

years 1952–1962. This worker recounted that steel plates were added to the facility when GSI 

started using radiographic sources other than radium. Although the plates were not included in 

the MCNPX model of the facility, and therefore do not affect the dose calculations, the reference 

to the steel plates should nevertheless be corrected. 

Allen (2014, Section BB.4.4) describes a triangular distribution that was adopted by the work 

group, NIOSH, and SC&A to characterize photon exposures of GSI plant personnel during the 

Radium Era. The distribution has a minimum of 6.279 R/y, a mode (the most likely value) of 

9.69 R/y, and a maximum of 12 or 15 R/y, depending on the year. The mode has two 

components: the exposure of 9.40 R/y a radiographer received while placing and retrieving a 

226Ra source, and the exposure of 0.295 R/y he received in the office inside the radiographic 

facility during the radiographic exposure. This exposure scenario is valid for the years 1956– 

1962. This time span includes the period 1957–1962 during which the former employee who 

furnished information on the use of 226Ra sources performed radiography at GSI, and reported 

being in the office during the exposures.2 However, it appears that this facility did not exist until 

1955. During the April 26, 2013, teleconference meeting of the Work Group on TBD 6000, the 

copetitioner cited accounts of two former GSI workers who reported that the radiographic facility 

was built in 1955. (Although the two workers were on the conference call, neither of them 

volunteered this information.) This account is further substantiated by an e-mail to the 

copetitioner from a former GSI betatron operator from a later era, who had spoken with one of 

these two workers on the telephone. The latter worker said he was directly involved in 

constructing the radiographic facility. In the absence of contradictory information, the site profile 

should assume that the building was not in existence until sometime in 1955. Absent such a 

facility, it should be assumed that the 226Ra sources were used in an unshielded area of the plant 

during the years 1952–1955. 

This changed assumption requires a change in the external photon exposures assigned to 

radiographers and other plant personnel during 1952–1955. NIOSH should assume that the 

radiographer waited at the 2-mR/h isoexposure boundary for the exposure to be completed. This 

is a reasonable assumption, given the need to have someone present to prevent intrusion into this 

restricted area. In such a case, the exposure in the radiographer’s office is replaced by an 

exposure at the boundary of 1.54 R/y. This is calculated by first noting that radiography using 

226Ra sources took place 30% of the time. Thus, assuming 3,250 work hours per year, 975 hours 

were devoted to this activity. The estimate of 9.4 R/y from handling the sources assumed that it 

took 15 s to position the source and an equal time to retrieve it, for a total handling time of 

~34 h/y (15 s × 2 × 10 exposures/shift × 406.25 shifts/y ÷ 3600 s/h ≈ 34 h/y). Thus, the 

radiographer can be assumed to have spent ~941 h/y (975 - 34 = 941) at the 2-mR/h boundary, 

incurring an additional exposure of 1.88 R/y (941 h × 0.002 R/h ≈ 1.88 R/y), for a total of 

9.4 + 1.88 = 11.28 R/y. This value should be used as the mode of the triangular distribution 

during 1952–1955. 

2

 According to this employee's "Occupational External Radiation Exposure History" (Form AEC-4), he most likely 

began working with radioactive sources in 1957. 

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Allen (2014) refers to the small enclosed area inside the radiographic facility as a “control room.” 

This implies that there were some mechanisms in this room that could be used to control the 

exposure, which was not the case. Allen’s Figure 8 shows a drawing of the radiography room, in 

which the small inner enclosure is marked “operation room,” while the radiographer who worked 

in that facility referred to it as the radiographer’s office (Anigstein 2011). This term should be 

corrected to avoid confusion. 

The third sentence of the second paragraph on p. 23 (Allen 2014) reads “An interview with the 

radiographer indicated he only performed radiography on a part time basis and estimated he did 

this between 40 to 90 shifts per year.” The radiographer did not, in fact, provide an estimate of 

his annual shifts. He only recalled that he worked 80%–90% of the weekends, one or two shifts 

per weekend. Anigstein (2011) used this information to estimate the annual shifts. Given the 

importance of this information in determining external exposures to radium sources, this 

statement should be clarified so as not to incorrectly attribute our conclusion to the worker. 

The copetitioner had several comments on the third full paragraph on p. 23 (Allen 2014). In 

response to one of these comments, the second sentence of this paragraph should be changed to 

“The most likely value will be . . . .” (Added text underlined and displayed in red) To resolve 

another comment, NIOSH should cite the references for the upper limits of the triangular 

distribution. NIOSH may choose to cite our previous report (Anigstein and Mauro 2013b), which 

discusses the sources of these exposure limits and provides the required documentation. In 

response to a third comment, a citation should be included to document the statement that 

applicable AEC limits were never exceeded. A suggested reference is NRC (2009c, p. 26). 

1.8 Section BB.4.5: External Dose Estimate for Portable X-Ray Machines 

As noted by the copetitioner, the last sentence in the first paragraph of Section BB.4.5 should be 

corrected as follows: “ Nor would they have been used near others sources of radiation.” 

(Extraneous text crossed out and marked in blue) 

1.9 Section BB.4.7: External Dose Estimate Summary 

We note an error in the maxima of the triangular distributions used to characterize photon 

exposures to plant personnel listed in Table 8 (Allen 2014). The values of the maxima, which are 

based on the AEC exposure limits in effect during each year of the Radium Era, are listed as 

15 R/y for 1952–1961, and 12 R/y for 1962. However, the AEC lowered the exposure limit to a 

maximum of 3 R per quarter, or 12 R/y, effective January 1, 1961 (Anigstein and Mauro 2013b). 

The maximum of the distribution for 1961 should therefore be 12 R/y. 

We disagree with the prescription for dose reconstruction presented by Allen (2014, 

Section BB.4.7). During the Radium Era, radiography using radium sources is assumed to have 

taken place during 30% of a given shift. The same radiographer could have been in the Old 

Betatron Building radiographing uranium during the time he was not working with radium. In 

fact, in recounting an interview with a former GSI radiographer who worked during the Radium 

Era, Anigstein (2011) reported: “During his weekend shifts as a radiographer, he did both radium 

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and betatron radiography—perhaps 50%–60% of the time using the betatron, the remainder using 

radium.” As listed in Table 3 of this memo, a maximum of 54.7 shifts/y were devoted to the 

radiography of uranium, which represent ~13% of the assumed 406.25 shifts in a work year, 

leaving ample time for both functions to be performed by the same worker. 

To be claimant favorable, NIOSH should assume that a radiographer spent 70% of each shift in 

the Old Betatron Building during 1952–1962, during which time he participated in all the uranium 

radiography performed at GSI during any given year, and spent the remainder of his time in that 

building radiographing steel. He should be assigned all of the ß skin dose from uranium handling 

and a portion of the ß skin dose from handling irradiated steel, based on the hours available for 

the latter task. The average annual shifts spent on betatron radiography of steel can be calculated 

by taking 70% of 406.25 shifts/y and subtracting the shifts spent on uranium radiography—the 

results are shown in Table 5 of this memo. 

Table 5. Annual Doses to Skin of Radiographers from Beta Radiation During 1952–1962 (rads) 

Year Annual number of shifts 

Uranium Steela

Hands and forearms 

Uranium Steel Total 

Other skin 

Uranium Steel Total 

1952-1957 54.7 229.7 31.96 2.17 34.13 2.03 1.49 3.53 

1958 45.8 238.5 26.79 2.26 29.04 1.70 1.55 3.25 

1959-1960 42.2 242.2 24.66 2.29 26.95 1.57 1.58 3.14 

1961 48.4 235.9 28.31 2.23 30.54 1.80 1.54 3.33 

1962 35.2 249.2 20.55 2.36 22.90 1.31 1.62 2.93 

a Adjusted for 70% of work hours devoted to betatron radiography 

A similar approach should be used to calculate neutron ambient dose equivalents, shown in 

Table 6 of this memo, where we derived annual neutron doses by multiplying the neutron doses to 

the betatron operator from uranium and steel, listed in Table 1 of this memo, by the number of 

shifts devoted to the betatron radiography of uranium and steel, respectively. 

Table 6. Annual Neutron Ambient Dose Equivalents, H*(10), to Radiographers (rem/y) 

Year 

Annual number of shifts 

Uranium Steela 

H*(10) 

Uranium 

Handling Radiography 

Steel 

radiography Total 

1952-1957 54.7 229.7 0.043 0.080 0.197 0.320 

1958 45.8 238.5 0.036 0.067 0.204 0.308 

1959-1960 42.2 242.2 0.033 0.062 0.208 0.303 

1961 48.4 235.9 0.038 0.071 0.202 0.311 

1962 35.2 249.2 0.028 0.052 0.214 0.293 

1963 9.6 396.7 0.008 0.014 0.340 0.361 

a Adjusted for 70% of work hours devoted to betatron radiography during 1952–1962 

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For the years 1963–1966, the limiting external exposure scenario is the layout man, as stated by 

Allen (2014). However, the skin and neutron doses need to be reconciled with the values in 

Table 4 of this memo. As stated earlier in this memo, the neutron doses should be expressed in 

terms of the ambient dose equivalent. These doses, calculated by SC&A, are shown in Table 6 of 

this memo. 

1.10 Section BB.5.1: Intakes from Handling Uranium Metal 

The first sentence of the third paragraph of Section BB.5.1 should be corrected as follows: 

“Twenty-five samples from three different sites were found to be represent the airborne activity . . . 

1.11 Section BB.5.4: Summary of Intakes of Radioactive Material 

The value of 1.47 dpm/cal. day for intake of uranium by inhalation during uranium-handling 

operations for the period 1/1/1966–6/30/1966, listed in Table 10 (Allen 2014), is in error. The 

author apparently multiplied the uranium work hours during the first 6 months of 1966 by the 

airborne activity of 68.7 dpm/m3 (the consensus value accepted by the TBD-6000 work group) 

and the breathing rate of 1.2 m3

/h, and then divided by 365 d/y. The correct divisor is 181 days— 

the number of calendar days in the first 6 months. The corrected value is 2.96 dpm/cal. day. 

We also question the method for calculating the ingestion rate. According to OCAS-TIB-009 

(OCAS 2004), the ingestion rate—in units of dpm—during an 8-h day is numerically equal to 

20% of the average air concentration in dpm/m3

. Allen (2014) apparently calculated the ingestion 

per 8-h day as 20% of the assumed concentration of uranium dust during uranium handling 

operations. then assigned this intake during each year of operations, regardless of the uranium 

work hours during a given year. This ignores the long periods in between uranium handling 

operations, when the only airborne uranium was from resuspension. 

While this method is claimant favorable, it does not appear to be consistent with the methodology 

of OCAS-TIB-009. We believe that the ingestion rate should be based on the average air 

concentration over the course of the work year. Since the daily inhaled intake is 9.6 times the 

average air concentration (1.2 m3

/h [assumed breathing rate] × 8 h/d = 9.6 m3/d), the ingested 

intake should be 2.08% of the inhaled intake (0.2 ÷9.6 ≈ 0.0208) during any 8-h work shift. The 

ingestion rates during the operational period would thus range from 0.06 to 2.38 dpm/calendar 

day, rather than having the fixed value of 15.45 dpm/calendar day listed by Allen (2014, 

Table 10). Finally, we suggest revising the title of Table 10 to indicate that the intakes are of 

uranium, for the benefit of the casual reader. 

1.12 Section BB.6: Residual Contamination 

We found two problems with the ingestion rates presented by Allen (2014, Table 11), who lists 

uranium intakes during the residual period. First, if we were to accept Allen’s method of 

calculating the rates based on the airborne uranium concentration during metal handling, the 

value for 7/1/1966–12/31/1967 would be 15.45 dpm/cal. day rather than 15.88. The latter value 

was apparently copied from the total daily inhalation rate for 1966 in Table 10, rather than the 

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ingestion rate for that year. However, as we stated in Section 1.11, we believe that the ingestion 

rate should be calculated as 2.08% of the average inhalation rate in a given year. 

The remaining data in Table 11 (Allen 2014) are consistent with the agreed-upon methodology of 

calculating inhalation rates and external exposure rates. Repeating our comment on the title of 

Table 10, we suggest that the title specifies that the intakes in question are of uranium. 

1.13 Section BB.7: References 

It would be helpful to include live links to web pages, when available, in all references. 

1.13.1 Reference “AEC 1962” 

The citation for Reference “AEC 1962” should be changed to the title listed by NRC (2009d, 

Appendix A): “General Steel Industries Byproduct Materials License for Cobalt-60 Sealed Source 

not to exceed 1 curie.” The correct date is 04/30/1963. The title and date cited by Allen (2014, 

Section BB.7) refer to a document inside this parent document; however, the page number cited 

by Allen is from the parent document, so the reference should be to the parent document. 

1.13.2 Reference “AEC 1962a” 

The citation for Reference “AEC 1962a” should be changed to the title listed by NRC (2009d, 

Appendix A): “Compliance Inspection Report from General Steel Industries for License Number 

12-8271-1.” The correct date is 11/6/1962. 

1.13.3 Reference “Kleber 1962” 

The citation for Reference “Kleber 1962” should be changed to the title listed by NRC (2009d, 

Appendix A): “Letter to James Mason from L. A. Kleber enclosing an application for two 

Cobalt-60 radiographic sources.” 

1.13.4 Reference “NCC 1962” 

The citation for Reference NCC 1962 should be changed to the title listed by NRC (2009d, 

Appendix A): “Letter to James Mason from L. A. Kleber regarding an area radiation survey that 

was made of the Radiographic Exposure Facility in Granite City, Illinois.” The correct date is 

9/7/1962. The title and date cited by Allen (2014, Section BB.7) refer to an attachment to this 

parent document. The author of the parent document should be listed as L. A. Kleber, VicePresident-Manufacturing, General Steel Industries. 

1.13.5 Reference “ORAU Collection” 

The citation for Reference “ORAU Collection” should be revised to read: “Oak Ridge Associated 

Universities (ORAU) 2011, Radium Industrial Radiography Source (ca. 1940s),” 

http://www.orau.org/ptp/collection/Sources/radiumradiog.htm. (We retain the punctuation style 

used by Allen, 2014). 

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1.13.6 Reference “SC&A 2014” 

The full title of Reference “SC&A 2014” is “Update of Doses from External Exposure at General 

Steel Industries” (not “GSI”). The three SC&A references (2008, 2011, and 2014) should be 

listed in chronological order, earliest first. 

1.13.7 Reference “MCNP” 

Reference MCNP is not listed in alphabetical order. A more suitable form of this reference is 

“Los Alamos National Laboratory (LANL). 2011. MCNP5/MCNPX: Monte Carlo N–Particle 

Transport Code System Including MCNP5-1.60 and MCNPX 2.7.0 and Data Libraries, RSICC 

Code Package CCC-740 [Computer software and manual]. Oak Ridge, TN: Oak Ridge National 

Laboratory.” 

1.14 Attachment A 

Attachment A (Allen 2014) shows a drawing of the radiographic boundary. This boundary is 

intended to be circular, all points lying at an equal distance from the center. Instead, it appears to 

be oval, most probably the result of the width and height of the original figure not being kept in a 

fixed ratio. 

2 Conclusions 

The revised Appendix BB (Allen 2014) represents a major advance over the original version 

(Allen and Glover 2007) and is the culmination of nearly 7 years’ work on the part of the Work 

Group on TBD-6000 and its predecessor, the Work Group on Procedures; DCAS; and SC&A. 

However, our review of the appendix produced a number of findings that still need to be resolved. 

2.1 Summary of Findings 

Finding 1: Neutron Dose Rates 

Allen (2014) cites values of neutron dose rates without specifying which dosimetric quantities 

were calculated. Based on the similarity of his numerical values to neutron effective doses 

calculated by SC&A for the same scenarios, we conclude that these are effective dose rates, 

which are incompatible with the dose conversion factors listed in OCAS-IG-001 (OCAS 2007). 

All the neutron doses need to be recalculated—we suggest that DCAS uses neutron ambient dose 

equivalent, H*(10), rates. 

Finding 2: Beta Skin Dose 

Allen (2014, Table 5) lists annual ß doses to the skin of the betatron operator, other than the skin 

on his hands and forearms, that are 12%–33% lower than our values. The ß doses to the skin on 

his hands and forearms are 3%–14% lower than our values for the years 1963–1966. These 

differences need to be resolved. 

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Finding 3: No Dedicated Radiographic Facility in No. 6 Building Prior to 1955 

The copetitioner has presented persuasive evidence that the dedicated radiographic facility in 

No. 6 Building was constructed in 1955. The mode of the triangular distribution of photon 

exposure rates during 1952–1962 is based on the use of that facility. Assuming that the 

radiographer remained at the 2 mR/h boundary of the controlled area during the radiographic 

exposures rather than in the not-yet-constructed radiographer’s office increases the mode from 

9.69 to 11.28 R/y during 1952–1955. 

Finding 4: Maximum of Triangular Distribution of Photon Exposures for 1961 Should Be 

12 R/y 

Because AEC lowered the exposure limit to a maximum of 3 R per quarter, or 12 R/y, effective 

January 1, 1961, the maximum of the triangular distribution of photon exposures for 1961 should 

be 12 instead of 15 R/y. 

Finding 5: Combined Exposures to 226Ra and Betatron Operations during 1952–1962 

Since radiography using 226Ra sources occurred during only 30% of a given shift, it is plausible 

that the same radiographer would have worked in the betatron building, performing radiography 

on uranium and steel, during the remainder of his shift. It is plausible and claimant-favorable to 

assume that the radiographer participated in all the uranium work during a given year and spent 

the balance of his time on the betatron radiography of steel. He should thus be assigned a ß dose 

to the skin as well as a neutron dose in addition to a triangular distribution of photon exposures 

during 1952–1962. 

Finding 6: Beta Skin Dose to Layout Man 

The ß doses to the skin of the hands and forearms as well as to the skin on the rest of the body 

listed by Allen (2014, Table 6) are significantly lower than those calculated by SC&A. These 

differences need to be resolved. 

Finding 7: Uranium Inhalation from Metal Handling in 1966 

Due to an apparent calculational error, the inhalation of uranium dust during the handling of the 

metal during the first 6 months of 1966 is understated by a factor of 2. 

Finding 8: Ingestion Intakes Not Consistent with OCAS-TIB-009 

The intakes of uranium particulates via ingestion listed by Allen (2014, Table 10) are significantly 

higher than the rates derived by applying OCAS-TIB-009 (OCAS 2004) to the airborne uranium 

dust concentrations, averaged over the work year. Although Allen’s rates are claimant favorable, 

they should be corrected for the sake of consistency with other site profiles, or an explanation 

given why these rates are valid. 

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Finding 9: Ingestion Intakes during Residual Period 

The intakes of uranium particulates via ingestion during the residual period listed by Allen (2014, 

Table 11) are inconsistent with OCAS-TIB-009 (OCAS 2004), as discussed in Finding 8. 

Furthermore, they are inconsistent with Allen’s methodology for the operational period, since the 

rate for the first year is equal to the inhalation, rather than ingestion, rate during the last year of 

AEC operations. 

2.2 Observations 

. 

We have made a number of comments throughout the present memo intended to correct or clarify 

statements in the text which, although they do not affect the prescribed methods of dose 

reconstruction, do not accurately represent the GSI site or its activities. Furthermore, there are 

some errors in wording that should be corrected, and some references that should be cited more 

precisely to aid the reader in understanding the background of the report. The report could benefit 

from further editorial improvements, such as consistent use of initial caps in section headings. 

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References 

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

Betatron Operations.” 

Allen, D. 2014. “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals: 

Appendix BB – General Steel Industries,” Battelle-TBD-6000, Appendix BB, Revision No. 1. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r1.pdf 

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. 

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

Industries.” http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiradsrc.pdf 

Anigstein, R., and J. Mauro. 2013a. “Review of Skin Dose Calculations for General Steel 

Industries.” Memo to Advisory Board on Radiation and Worker Health Work Group on 

TBD-6000. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiskindose-120513.pdf 

Anigstein, R., and J. Mauro. 2013b. “Review of NIOSH Estimates of External Exposures at 

GSI.” Memo to Advisory Board on Radiation and Worker Health Work Group on TBD-6000. 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiextexp-042313.pdf 

Anigstein, R., and J. Mauro. 2014. “Update of Doses from External Exposure at General Steel 

Industries.” Memo to Advisory Board on Radiation and Worker Health Work Group on 

TBD-6000.” http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiexdose-011214.pdf 

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

Steel Industries: Dose Estimates for Betatron Operations’.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsibeta-r0.pdf 

Bechtel National, Inc. 1994. “Certification Docket for the Remedial Action Performed at the 

Granite City Site In Granite City, Illinois, June 1993." 

General Steel Castings Corp., Plant Engineering Department (GSCC). 1969. “Plant Layout,” 

Change F, Drawing 28337. 

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

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

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

Nuclear Regulatory Commission (U.S.) (NRC). 2009a. “Letter to Nathan Bassin from Robert 

Ripley regarding their AEC License for the period through July 1977.” ADAMS acquisition 

number ML093451651. 

Review of Appendix BB, Revision 1 -15- SC&A –December 10, 2014 

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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.
 
 

 

Nuclear Regulatory Commission (U.S.) (NRC). 2009b. “Application for Byproduct Materials 

License Use in the Metallurgy Department from General Steel Industries for metallic source of 

Cobalt-60 in a sealed source, w/handwritten notes.” ADAMS acquisition number ML093480296. 

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

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

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

Nuclear Regulatory Commission (U.S.) (NRC). 2009d. “Response to Freedom of Information 

Act (FOIA) / Privacy Act (PA) Request.” ADAMS acquisition number ML093431290. 

Office of Compensation Analysis and Support (OCAS). 2004. “Technical Information Bulletin: 

Ingestion Intakes,” OCAS-TIB-009, Revision No. 0. 

http://www.cdc.gov/niosh/ocas/pdfs/tibs/oc-t9-ro.pdf 

Office of Compensation Analysis and Support (OCAS). 2007. “External Dose Reconstruction 

Implementation Guideline,” OCAS-IG-001, Revision No. 3. 

www.cdc.gov/niosh/ocas/pdfs/dr/oc-ig-001-r3.pdf 

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