Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Review of the Linde Ceramics Plant 

Special Exposure Cohort (SEC) Petition 00154 

and the NIOSH SEC Petition Evaluation Report 

Contract No. 200-2009-28555 

SCA-TR-SEC2011-0006 

Prepared by 

Stephen L. Ostrow, PhD 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

July 2011 

Disclaimer

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

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

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

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

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

information only and that premature interpretations regarding its conclusions are unwarranted. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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Document No. 

SCA-SEC2011-0006 

Effective Date: 

 Draft – July 11, 2011 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of NIOSH 

Dose Reconstruction Program Revision No: 

 0 – Draft 

Review of the Linde Ceramics Plant Special 

Exposure Cohort (SEC) Petition 00154 and the 

NIOSH SEC Petition Evaluation Report 

Page 2 of 23 

Task Manager: 

_____________________ Date: ____________ 

Stephen L. Ostrow, PhD 

Supersedes: 

N/A 

Project Manager: 

_____________________ Date: ____________ 

John Mauro, PhD, CHP 

Reviewer: 

 John Mauro 
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NOTICE:

TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4 

Executive Summary.........................................................................................................................5 

1.0 Introduction..........................................................................................................................7 

1.1 Scope and Purpose of the SEC Review ...................................................................7 

1.2 Technical Approach and Review Criteria................................................................7 

1.3 Background Information..........................................................................................8 

1.4 Organization of the Report.....................................................................................10 

2.0 Overview of SEC Petition 00154 and the NIOSH SEC Petition Evaluation Report.........11 

3.0 Assessment of NIOSH’s Ability to Reconstruct Exposures during the SEC-00154 

Period .................................................................................................................................14 

3.1 Introduction............................................................................................................14 

3.2 Internal Exposure...................................................................................................14 

3.2.1 Radon Exposures .......................................................................................14 

3.2.2 Bounding Internal Doses............................................................................17 

3.3 External Exposure..................................................................................................19 

3.3.1 Tunnel Exposures.......................................................................................20 

3.3.2 Bounding External Exposures....................................................................20 

4.0 References..........................................................................................................................22 

LIST OF TABLES 

Table 1. Summary of Findings...................................................................................................... 5 

Table 2. Linde Ceramics Timeline for the Period Under Evaluation............................................ 9 

Table 3.

................................................................................................. 12 

Linde SEC 00154 Petition Issues, NIOSH Petition Evaluation Report Responses, 

and SC&A Assessment

Table 4. Ceramics Plant Worker Radon Exposure Rates, 1947 to 1954..................................... 16 

Table 5. Number of Available Linde Bioassay Records per Year.............................................. 18 

Table 6. Number of Available Air Monitoring Records Per Year.............................................. 18 

Table 7. Air Concentrations Measured During 1948–1949 Clean-up of Building 30 ................ 19 
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

or the Board 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

CFR Code of Federal Regulations 

Ci Curie (unit of activity) 

DOE Department of Energy 

dpm Disintegration per Minute 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ER (SEC Petition) Evaluation Report 

FUSRAP Formerly Utilized Sites Remedial Action Program 

L Liter 

MAC Maximum Allowable Concentration (equivalent to 70 dpm alpha activity) 

MED Manhattan Engineering District 

NIOSH National Institute for Occupational Safety and Health 

ORAUT Oak Ridge Associated Universities Team 

ORNL Oak Ridge National Laboratory 

pCi pico-Curie 

SC&A S. Cohen & Associates 

SEC Special Exposure Cohort 

SRDB Site Research Database 

TBD Technical Basis Document 

TIB Technical Information Bulletin 

WG Work Group 

WLM Working Level Month (measure of radon exposure)
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EXECUTIVE SUMMARY 

The Advisory Board on Radiation and Worker Health (the Board) directed SC&A to perform a 

review of the Linde Special Exposure Cohort (SEC) Petition 00154 (SEC-00154 2009) and 

National Institute for Occupational Safety and Health’s (NIOSH) response to it in its SEC 

Petition Evaluation Report (NIOSH 2010). The petition calls for adding the worker class to the 

SEC, defined as, “All employees who worked in any area at Linde Ceramics in Tonawanda, New 

York, from November 1, 1947 through December 31, 1953.” NIOSH received the petition on 

November 5, 2009, qualified it on January 19, 2010, and produced its evaluation report on 

November 2, 2010, in which it asserts the following: 

Based on its full research of the class under evaluation, NIOSH has obtained 

uranium urinalysis results, film badge reports, air monitoring data, and radiation 

contamination survey data for the time period evaluated. Based on its analysis of 

these available resources, NIOSH found no part of the class under evaluation for 

which it cannot estimate radiation doses with sufficient accuracy. 

SC&A examined the petition, the NIOSH petition evaluation report, and a number of supporting 

documents, to assist the Board in assessing the degree to which NIOSH can “estimate radiation 

doses with sufficient accuracy,” using the criteria of 42 CFR 83. Important, related 

considerations are the adequacy and completeness of the data relied upon by NIOSH. This 

report presents the results of SC&A’s investigations. Findings are summarized in Table 1. The 

table gives only a short description of each finding, and the main body of this report should be 

consulted for a full explanation. All findings relate to the reconstruction of internal or external 

exposure; there are no findings related to occupational medical or environmental exposures. The 

first three findings, which SC&A identified from the SEC-00154 Petition, are discussed further 

in Table 3; the last three findings result from SC&A’s review of the petition, NIOSH’s response, 

and other documents. 

Table 1. Summary of Findings 

No. Internal/ 

External Section Description 

SEC-00154 Petition Issues 

1 

Worker Class: “NIOSH cannot with any certainty define whether employees 

were limited to work in specific buildings at the Linde Ceramics site” (p. 1). 

Hence, the class should consist of “all workers.” Several included worker 

statements are cited in support of this assertion. 

2 

Records/Data (SEC Category F3): The petition refers to Issues 2 (Air 

Concentration Data) and 7 (Radon Exposure and Concentration) of SC&A 2009 in 

support of its claim that limitations of available DOE and/or AWE radiation 

exposure records “might prevent the completion of dose reconstructions for 

members of the class” (SEC-00154 2009). 

The petition goes on to assert: “Furthermore, there is insufficient bioassay data 

from 1947 through 1953 that can provide an accurate depiction of the resuspension 

of the inhalation particles that workers were subjected to during this time period. 
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Table 1. Summary of Findings 

No. Internal/ 

External Section Description 

NIOSH cannot estimate with sufficient accuracy how much of that resuspension of 

inhalation particles was process emission versus resuspension.” 

3 Monitoring Workers (SEC Category F1): The petition claims that workers who 

should have been monitored were not, and refers to attached worker statements in 

support. 

Issues Identified by SC&A 

4 I/E 3.2.1.2 

Utility Tunnel Timeline: Although there has been a considerable amount of 

discussion between NIOSH, SC&A, and the petitioners about the timeline for 

tunnel construction, SC&A still does not believe that the timing is clear, and 

SC&A would like NIOSH to provide a consolidated, illustrated (with plot plans 

showing the tunnel locations), well-documented report supporting its assumptions. 

5 I 3.2.1.2 

Utility Tunnel Radon Exposure: The NIOSH SEC-00154 Petition Evaluation 

Report assumption of a 10 pCi/L radon level present in the utility tunnels should be 

replaced by the 99.31 pCi/L plausible upper-bound estimate of the NIOSH SEC00107 Petition Evaluation Report (Rev. 1), whose methodology was developed 

subsequent to the release of the NIOSH SEC-00154 report. 

6 E 3.3.2 

Job Categories: Based on worker written and oral statements in the SEC-00154 

Petition and in other places (e.g., SC&A 2010), it may have been common for 

workers formally assigned to a particular task in a particular area to be informally 

reassigned to other tasks in other areas in a fluid fashion to accommodate changing 

task requirements. Hence, given these uncertainties, a claimant-favorable approach 

would be to assign unmonitored or partially monitored workers with the highest 

external exposures experienced during a given time period. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

1.0 INTRODUCTION 

1.1 SCOPE AND PURPOSE OF THE SEC REVIEW 

The Advisory Board on Radiation and Worker Health (the Board) directed S. Cohen and 

Associates (SC&A) to perform a review of the Linde Special Exposure Cohort (SEC) Petition00154 (SEC-00154 2009) and the National Institute for Occupational Safety and Health 

(NIOSH) SEC Petition Evaluation Report (ER) (NIOSH 2010), which responds to that petition. 

This report presents the results of SC&A’s review of the Linde SEC Petition and the NIOSH ER. 

The scope of this review addresses specific issues of concern raised in the petition and NIOSH’s 

response to those concerns, as given in the ER. In addition, SC&A identified issues that it 

believed need to be addressed, but were not explicitly identified by the petitioners. 

In the course of its assessment, SC&A reviewed selected documents that were considered 

relevant to the petition, including the following: 

 Documents referenced in the petition 

 Documents referenced/cited in the ER and site profile [NIOSH 2009, also known as the 

Technical Basis Document (TBD)] 

 Documents contained in the NIOSH Site Research Database (SRDB) 

 Other relevant documents 

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

concerns that may impact the feasibility of dose reconstruction during the SEC period and 

NIOSH’s response and proposed methods for addressing them. Following a formal, multi-step 

issues resolution process, any unresolved findings may then be used by the Board to determine 

whether radiation doses can be estimated with sufficient accuracy, as defined in 42 CFR 

§83.13(c)(1); adequacy and completeness of the data are important factors to consider. 

1.2 TECHNICAL APPROACH AND REVIEW CRITERIA 

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

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

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

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

of draft guidelines prepared by a Board-designated work group (WG) for evaluation of SEC 

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

by SC&A and approved by the Board for use by SC&A on an interim basis (ABRWH 2006, 

pg. 132). The procedures are designed to help ensure compliance with Title 42, Part 83, of the 

Code of Federal Regulations (42 CFR 83) and implement the guidelines provided in the report of 

the WG. 
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Key review criteria identified in the report of the WG include the following; the individual 

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

petition and ER: 

 Timeliness (It should be noted that SC&A does not evaluate timeliness in its SEC 

reviews, but leaves it for consideration by the Advisory Board) 

 Fairness 

 Understandability 

 Consistency 

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

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

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

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

data 

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

(1) Conduct a critical review of the petition and relevant reports, documents, and data that 

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

(2) Interview petitioners, claimants, workers, etc. Note that this was done as part of the site 

profile review process and in conjunction with reviewing Linde SEC Petition 00107 

(SEC-00107 2008) and NIOSH’s petition ER (NIOSH 2008) for that petition (SC&A 

2010). SC&A reviewed worker statements provided in SEC Petition 00154, but did not 

find it necessary to perform additional interviews in support of this report. 

(3) Identify additional issues/concerns that emerged from SC&A’s document review, which 

are independent of those stated in the petition. 

(4) As part of the SEC review, develop technical positions for issues identified in the 

petition, and present SC&A’s independent findings. 

SC&A’s report with its findings will subsequently undergo a multi-step issues resolution 

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

of the Board’s WG, petitioners, claimants, and interested members of the public. This resolution 

process is intended to ensure that each finding is evaluated on its technical basis in a fair and 

impartial manner. 

1.3 BACKGROUND INFORMATION 

The site profile (NIOSH 2009), as well as the NIOSH SEC-00154 Petition ER (NIOSH 2010), 

present extensive background information on the history and operations of the Linde plant; a 

brief summary is presented here for the purpose of orientation. 

In October 1942, the Linde Ceramics Plant, located in Tonawanda, New York, was contracted by 

the U.S. government to develop appropriate facilities and methods to perform large-scale 
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processing of domestic and African uranium ores for the Manhattan Engineer District (MED) as 

part of its mission to develop nuclear weapons. Linde was selected for the MED contract 

because of its experience in the ceramics business, part of which involved processing uranium to 

produce salts used to color ceramic glazes. The operational period continued until contract 

termination in 1949. 

Linde processed seven different types of ore—four African ores and three domestic ores; the 

former entered the site unprocessed and contained all members of the uranium decay chain, 

while the latter included tailings from vanadium processing that had most of the radium removed 

before being sent to Linde. Table 5-2 of the SEC-00154 Petition ER (NIOSH 2010) details the 

properties of the uranium feed material. However, NIOSH does not use this information in its 

dose reconstructions, relying instead on internal and external exposure data, as well as models 

using those data. 

Processing consisted of three steps: Step I – separation of uranium oxide (U3O8) from the 

incoming ore by acid digestion, precipitation, and filtration (terminated July 31, 1946); Step II – 

conversion of the uranium oxide to uranium dioxide (UO2; terminated March 8, 1944); and Step 

III – conversion of the uranium dioxide to uranium tetrafluoride (UF4; terminated June 30, 1949 

after earlier standby and restart). Hence, Steps I and II operations terminated before the start 

date (November 1, 1947) of the SEC 00154 period, but Step III continued into the SEC 00154 

period (end date December 31, 1953). As noted in the site profile (NIOSH 2009), Linde 

received ores in various steps from other sites for processing and shipped ores in various steps to 

other sites for further processing. Beginning in 1949, shortly before the end of Step III 

production, the Linde site underwent decontamination and cleanup, and in 1954, the site was 

released for private use. This period is referred to as the “decontamination period.” Section 2.6 

of the site profile provides details on the decontamination and cleanup activities. 

The post-1954 era at the Linde site is known as the “residual period,” and it was during this time 

that the various buildings at the site began to undergo renovation and remediation. In 1976, Oak 

Ridge National Laboratory (ORNL) performed a radiological survey, and in 1980, Linde was 

designated as a FUSRAP (Formerly Utilized Sites Remedial Action Program) site. Linde then 

underwent two periods of FUSRAP remediation, from 1988–1992 and in 1996. All of the 

uranium processing buildings except Building 31 were demolished during this remediation 

period. Table 2-1 of the Linde Site Profile (NIOSH 2009) provides a convenient table of key 

dates in the life of the Linde plant, while Table 5-3 of the SEC-00154 Petition ER (NIOSH 2010) 

provides a timeline specifically for the SEC-00154 period; the latter is reproduced below in 

Table 2 for convenient reference: 

Table 2. Linde Ceramics Timeline for the Period Under Evaluation 

Year Event(s) 

1947 Step III production resumes. 

1948 Steps I and II process equipment dismantling begins. 

1949 Step III production ends. Decontamination of Building 30 continues. 

1950 Decontamination of Building 30 complete. 

1952 Step III dismantlement begins. 

1954 AEC contractual work comes to an end with completion of clean-up activities. Building 38 released to Linde. 

Reproduced from NIOSH 2010, Table 5-3 
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NOTICE:

It should be noted that the SEC petition in question, SEC-00154, covers the time period from 

November 1, 1947, through December 31, 1953. A previously approved SEC petition covers the 

operations time period from October 1, 1942, through October 31, 1947, and SEC Petition 00107 

covers the residual time period from January 1, 1954, through July 31, 2006. The Advisory 

Board recommended granting the latter petition for the time period from January 1, 1954, 

through December 31, 1969 (renovation period) and denying it for the time period from January 

1, 1970, through July 21, 2006 (post-renovation period). 

1.4 ORGANIZATION OF THE REPORT 

Following this introductory section, Section 2 presents an overview of SEC Petition 00154 and 

identifies the issues that it raises, and also presents a summary of NIOSH’s ER responding to the 

petition. Section 3 constitutes SC&A’s assessment of the petition and NIOSH’s response, and 

Section 4 contains a list of documents referenced in this report.
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2.0 OVERVIEW OF SEC PETITION 00154 AND THE NIOSH SEC 

PETITION EVALUATION REPORT 

NIOSH received SEC Petition 00154 on November 5, 2009, and qualified it on January 22, 

2010, with the following petitioner class definition, as expressed in its SEC petition ER of 

November 2, 2010: 

All employees who worked at the Linde Ceramics Plant in Tonawanda, New York, 

from November 1, 1947 through December 31, 1953 (NIOSH 2010, p. 3). 

NIOSH claims that there are sufficient data to estimate the radiation doses to workers during the 

SEC period. NIOSH 2010 states: 

Based on its full research of the class under evaluation, NIOSH has obtained 

uranium urinalysis results, film badge reports, air monitoring data, and radiation 

contamination survey data for the time period evaluated. Based on its analysis of 

these available resources, NIOSH found no part of the class under evaluation 

for which it cannot estimate radiation doses with sufficient accuracy. 

[Emphasis added.] 

The first step in SC&A’s analysis of the petition and NIOSH’s response is to identify the 

petitioners’ concerns as precisely as possible. Following a few forms, the petition consists of a 

short discussion of the proposed SEC class and an argument for granting the petition, followed 

by several supporting documents, including worker interviews, statements, and other material, as 

well as an SC&A report concerned with resolution of Linde site profile issues, appended in its 

entirety (SC&A 2009). The SC&A report, which was prepared at the request of the Board’s 

Linde WG to help inform its deliberations related to the status of issues raised about the Linde 

site profile, stated the expressed issues and traced, in some detail, the disposition of each one 

through SC&A and NIOSH technical papers, and Linde WG meetings. SC&A found that all 

issues were resolved “in concept.”1

SC&A determined that the petition raises three distinct issues. Table 3 summarizes these issues, 

along with NIOSH’s response to them in its ER (see Section 7.4 of NIOSH 2010) and SC&A’s 

assessment of whether NIOSH addressed the petition concerns in a satisfactory fashion.

1

 Some issues were effectively put in “abeyance” pending further agreed-upon actions by NIOSH. 
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Table 3. Linde SEC 00154 Petition Issues, NIOSH Petition Evaluation Report Responses, and SC

Linde SEC 00154 Petition Issue NIOSH SEC Petition Evaluation Report SC&

1. Worker Class: “NIOSH cannot with any certainty 

define whether employees were limited to work in specific buildings at the Linde Ceramics site” (pg. 1). Hence, the class should consist of “all workers.” 

 Several included worker statements are cited in 

support of this assertion. 

NIOSH accepted the proposed class as applicable to: “All employees who worked in any area at the Linde Ceramics Plant in Tonawanda, New York, from November 1, 1947 through December 31, 1953.” 

NIOSH accepted thdefinition, so there consider. 

2. Records/Data (SEC Category F3): The petition 

refers to Issues 2 (Air Concentration Data) and 7 (Radon Exposure and Concentration) of SC&A 2009 in support of its claim that limitations of available DOE and/or AWE radiation exposure records “might prevent the completion of dose reconstructions for members of the class” (SEC00154 2009). The petition goes on to assert: “Furthermore, there is insufficient bioassay data from 1947 through 1953 that can provide an accurate depiction of the resuspension of the inhalation particles that workers were subjected to during this time period. NIOSH cannot estimate with sufficient accuracy how much of that resuspension of inhalation particles was process emission versus resuspension.” 

NIOSH concluded that the petition does not present adequate support for its assertion relative to the adequacy of exposure records; however, NIOSH believes that it has sufficient data on hand to reconstruct doses in an acceptable fashion. This is discussed in Section 7.4.2 of NIOSH 2010. 

Site Profile Issues which form the baswere closed by the noted by NIOSH in 2010. NIOSH invin its SEC 00154 Pand concluded that information to estisufficient accuracyThis report discussconcentration and concerns) in Sectio(aboveground radobelieves that NIOSestimations in accecases. 

3. Monitoring Workers (SEC Category F1): The 

petition claims that workers who should have been monitored were not, and refers to attached worker statements in support of the assertion. 

NIOSH concluded that the petition does not present adequate support for its assertion relative to the adequacy of exposure records; however, further investigation by NIOSH determined that “...monitoring did not adequately assess all potential exposures or exposure periods. Based on this information, NIOSH concluded that the F.1 basis is sufficiently supported” (NIOSH 2010, p. 9). 

NIOSH accepted, wpetition’s assertionon evidence not prreach that conclusifor NIOSH’s qualipetition. SC&A believes thamodel for unmonit

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Table 3. Linde SEC 00154 Petition Issues, NIOSH Petition Evaluation Report Responses, and SC

Linde SEC 00154 Petition Issue NIOSH SEC Petition Evaluation Report SC&

NOTICE

wever, th

Section 7.4.1 of NIOSH 2010 enumerates what monitoring data are available and notes that “Linde Ceramics Plant workers employed after the cessation of Step III operations [in 1949] were not radiation workers” and, therefore, were not monitored. 

monitored workers concerns; this is di
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3.0 ASSESSMENT OF NIOSH’S ABILITY TO RECONSTRUCT 

EXPOSURES DURING THE SEC-00154 PERIOD 

3.1 INTRODUCTION 

The SEC petition raises a number of issues (summarized here in Table 1) related to 

reconstructing internal and external exposures to workers during the SEC-00154 period 

(November 1, 1947–December 31, 1953). No issues were raised with respect to occupational 

medical or environmental exposures. Selected elements of the internal and external exposure 

information and estimation procedures are examined in the following two subsections. 

3.2 INTERNAL EXPOSURE 

There is clearly a measure of subjectivity involved in deciding whether sufficient information is 

available for NIOSH to do bounding calculations, per EEOICPA and 42 CFR §83.13(c)(1), to 

“(1) estimate the maximum radiation dose, for every type of cancer for which radiation doses are 

reconstructed, that could have been incurred in plausible circumstances by any member of the 

class.” In the case of SEC-00154 for the Linde Ceramics Plant, NIOSH has stated that bounding 

exposures can be estimated: 

Information available from the site profile and additional resources is sufficient 

to document or estimate the maximum internal and external potential exposure to 

members of the evaluated class under plausible circumstances during the 

specified period (NIOSH 2010, pg. 3). 

The ensuing discussion on bounding internal exposures at Linde during the subject period 

considers two intertwined issues: 

 Whether or not adequate information exists to perform plausible bounding calculations 

 Whether or not the approach taken by NIOSH in the SEC-00154 Petition ER (and, by 

reference, the site profile) is indeed bounding and scientifically justifiable 

Internal exposures could have arisen from two different pathways; breathing in radon and 

breathing in or ingesting particles containing radioactive uranium and its progeny. These 

pathways will be discussed in turn. 

3.2.1 Radon Exposures 

Radon is a gaseous, radioactive daughter product of radium on the U-238 decay chain (it is also a 

product on other decay chains, which is not important here). There were several sources of 

radon at Linde during the period of concern. The uranium feed ores contained radium; the 

African ores contained a much higher amount than the domestic ores, since the latter generally 

were preprocessed to remove radium. Hence, the African ores were much more prolific 

generators of radon than the domestic ores, and workers may have been exposed to radon during 

ore processing operations. In addition, workers may have been exposed to radon from 

radioactive wastes that were disposed of onsite until the end of 1954 (after the December 31, 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

1953, end of the SEC period), when the initial cleanup was completed (NIOSH 2009), including 

in the form of liquid waste containing radioactive material that was placed into injection wells 

around the site (those wells overflowed on occasion). Finally, although not a consequence of 

Linde operations, soil naturally contains radium from uranium decay and evolves radon gas; this 

may be an issue for workers in any underground tunnels that were constructed at the Linde site. 

3.2.1.1 Aboveground 

The NIOSH SEC-00154 Petition ER acknowledges that, “...NIOSH did not locate any radon 

monitoring data for the period under evaluation; therefore, a data sufficiency and pedigree 

evaluation is not possible for radon monitoring data during the 1947–1953 time period” (NIOSH 

2010, Section 7.1.1). Consequently, NIOSH devised a method for bounding internal radon 

doses: 

During Ceramics Plant production, the only source of radon was African ore 

processing. No direct radon measurements during the period of Step III 

operations are available. An estimate was made based on the lowest measured 

indoor concentrations at the Linde site during African ore processing. 

Approximately 20% of the measurements in the Linde ore-processing building 

yielded results of 10 pCi/L or less, with most of these results at or near 10 pCi/L. 

Therefore, 10 pCi/L was assumed to be the outdoor air concentration. After the 

end of African ore processing, radon concentration in the main ore-processing 

building (Building 30) and all other Linde Ceramics Plant buildings was assumed 

to remain at the 10-pCi/L level due to the removal of uranium ores and their 

raffinates. Concentrations in other Linde buildings were also assumed to be 

10 pCi/L until the end of clean-up in those buildings. 

Because the locations of many workers are likely to be unknown, it was assumed 

that all workers were exposed to 10 pCi/L of radon from November 1, 1947, 

through December 31, 1953. As mentioned in Section 5.2, exposure to radon and 

other uranium progeny are not believed to be a significant source of internal 

exposure due to the age of the source and product materials, and the fact that the 

processing residues were shipped offsite for storage. Because there is a lack of 

source material to increase the radon concentration during the evaluated period, 

the assumption of a 10 pCi/L radon concentration represents a sufficiently 

accurate estimate for the purposes of bounding internal exposures for the class 

under evaluation (NIOSH 2010, Section 7.2.3.2).

NIOSH’s approach, stated above, is consistent with what it presents in the Linde Site Profile 

(NIOSH 2009, Section 3.5.1). Table 3-5, reproduced here as Table 4, summarizes the radon 

exposure during the time period of SEC Petition 00154: 
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Table 4. Ceramics Plant Worker Radon Exposure Rates, 1947 to 1954 

Period/Work Location Time-weighted Concentration 

(pCi/L) Exposure Rate (WLM/yr) 

11/1/1947 – 7/7/1954 

All workers 10.0 0.480 

Source: NIOSH 2009, Table 3-5 

As NIOSH notes, radon measurements associated with Step III processing are not available. 

However, through the course of several exchanges of technical information with NIOSH in 

writing and during Linde WG meetings, SC&A examined and accepted the above-quoted 

method of bounding internal radon exposures and the assumption of a 10 pCi/L radon 

concentration for all workers (since their locations cannot be established with certainty), as 

reported in SC&A’s assessment (SC&A 2009, Issue 7) of the disposition of the Linde Site 

Profile issues. Therefore, SC&A considers this method acceptable with regard to reconstructing 

radon exposures to workers above ground during the SEC-00154 time period. 

3.2.1.2 Tunnels 

The Linde Site had a system of utility tunnels underground from building to building, several 

branches of which still exist today; individual tunnel sections were built at different times over 

the years. Tunnel segment sizes varied, with a maximum of about 8–10 ft high and 15 ft wide. 

Several exhaust fans (approximately 6 ft in diameter) provided ventilation, with an estimated 

average air exchange rate of approximately once every 10 hours. The tunnels were never 

continuously occupied and were never used to carry or store radioactive material, although some 

workers spent extended periods working in them on utility-related projects, and other workers 

passed through them from one building to another without having to go aboveground and be 

exposed to the weather (this was not an authorized practice, but worker interviews and 

statements indicated that the tunnels represented a customary “short cut” and even a “resting 

place”). The issue of dose to workers in the tunnels was considered during evaluation of Linde 

SEC Petition 00107, the residual time period, which follows the time period under consideration 

in SEC Petition 00154. Part of the issue relevant to the latter petition concerns when individual 

tunnel segments were constructed. 

The NIOSH SEC-00154 Petition ER (NIOSH 2010) discusses the utility tunnels and, after 

referring to various documents, including tunnel drawings, asserts that “the utility tunnel sections 

near the Ceramics Plant (Buildings, 30, 31, 37 and 38) were constructed in 1957 and 1961, which 

is after the December 31, 1953 end date of the covered period... There was also a utility tunnel 

section running between Building 14 (the “Tonawanda Laboratory”) and Building 8 (the “Power 

House”) that was assumed to be in existence during the SEC period” (Section 5.1). 

Issue 4: Utility Tunnel Timeline. Although there has been a considerable amount of 

discussion among NIOSH, SC&A, and the petitioners about the timeline for tunnel construction, 

SC&A still does not believe that the timing is clear, and SC&A would like NIOSH to provide a 

consolidated, illustrated (with plot plans showing the tunnel locations), well-documented report 

supporting its assumptions. 
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After some discussion, the NIOSH SEC-00154 Petition ER (NIOSH 2010) concludes that: 

...there is no evidence of an increased radium source-term for soils near the 

utility tunnel section running between Building 14 (the “Tonawanda 

Laboratory”) and Building 8 (the “Power House”), which was assumed to be in 

existence during the SEC period. Therefore, NIOSH believes that a 10 pCi/L 

radon level that has been established for surface buildings in the Ceramics Plant 

will be bounding for these worker exposures during the SEC-00154 petition 

period (Section 7.2.3.2). 

However, subsequent to the release of NIOSH 2010, long, detailed exchanges of technical 

information in writing and at Linde WG meetings resulted in NIOSH adopting a different 

methodology for estimating radon exposures in the tunnels. The final methodology (based on 

measured radon concentrations in basements in the vicinity of the Linde plant) is presented in 

Attachment 3 of Rev. 1 of the NIOSH SEC-00107 Petition ER (NIOSH 2011), which concludes: 

NIOSH proposes that the 95th percentile value of 99.31 pCi/L provides a 

plausible upper bound estimate for radon exposure in the Linde utility tunnels for 

all years at the Linde site beginning from the first MED production through the 

present time. (Emphasis added.) 

The final, settled value is approximately a factor of 10 higher than that proposed in the NIOSH 

SEC-00154 Petition ER and should be applied to the SEC-00154 period in accordance with the 

above statement. In addition, since it cannot be established where particular employees were 

actually located (compelling worker testimony and statements indicate that worker assignments 

were quite flexible, with workers filling in wherever they were needed), the utility tunnel radon 

exposure dose should be applied to all workers on the site during the subject period. A related 

issue, which is actually a dose reconstruction rather than an SEC issue, is the tunnel occupancy 

factor to assign to workers. NIOSH has proposed adopting a 20% factor. However, based on 

worker testimony and statements to the effect that workers often casually walked through the 

tunnels and may have even rested there, this factor may be too low. Whichever value is chosen, 

however, does not affect the feasibility of assigning tunnel radon doses. 

Issue 5: Utility Tunnel Radon Exposure. The NIOSH SEC-00154 Petition ER assumption of 

a 10 pCi/L radon level present in the utility tunnels should be replaced by the 99.31 pCi/L 

plausible upper-bound estimate of the NIOSH SEC-00107 Petition ER (Rev. 1), whose 

methodology was developed subsequent to the release of the NIOSH SEC-00154 report. 

3.2.2 Bounding Internal Doses 

The special cases of radon exposure above ground and in the utility tunnels were discussed in the 

previous sections. The main pathway for internal exposure to operating plant personnel, 

however, was inhalation and/or ingestion of uranium compounds associated with the different 

processing steps, while the main pathway for non-operating personnel was inhalation and/or 

ingestion of resuspended particles from plant activities and from decontamination activities. 
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As reported in Section 6.1 of NIOSH 2010, NIOSH has located uranium urinalysis (bioassay) 

data taken over the time period of interest for SEC Petition 00154, and summarizes what’s 

available in Table 6-1 of the SEC-00154 Petition ER (reproduced here as Table 5). Step III 

operations ceased in 1949; hence, the subsequent large drop in bioassays. 

Table 5. Number of Available Linde Bioassay Records per Year 

Year # of Samples 

1947 75 

1948 372 

1949 183 

1950 11 

 Source: NIOSH 2010, Table 6-1 

The urinalysis data pertain to 41 of the 43 workers identified as Step III process workers, as 

NIOSH determined by examining a number of log sheets, log books, and other sources of 

information. However, NIOSH acknowledges that since it does not have evidence that every 

employee who should have been monitored was, in fact, monitored, it will use the bioassay data 

as input to construct a coworker model in accordance with ORAUT-OTIB-0019 (ORAUT 2005) 

methodology for unmonitored or incompletely monitored workers; the coworker model covers 

the period from November 1947 through January 1950 (Step III shutdown occurred on June 30, 

1949 and D&D operations of Building 30 were completed by March 29, 1950) and is 

documented in Attachment D of the Linde Site Profile (NIOSH 2009); that attachment should be 

consulted for detailed information on how the coworker model was constructed. 

The coworker model approach was developed by NIOSH in response to SC&A comments 

(Issues 2, 3, 4, and 10) and accepted by SC&A and the Linde WG during the site profile review 

process, as documented in SC&A 2009. Furthermore, SC&A evaluated the TIB as part of its 

assignment from the Advisory Board to review NIOSH procedures and resolve issues, and 

determined that all issues have been resolved. Hence, application of this TIB here is appropriate 

and the TIB itself is satisfactory. 

From log sheets, log books, and other sources of information, NIOSH has also located breathing 

zone, general air sampling, and contamination survey data that were taken during the operational 

period (NIOSH 2010). Table 6 reproduces NIOSH’s Table 6-2 summarizing the available data. 

The number of air samples peaked in 1949, the last year of Step III processing operations. 

Table 6. Number of Available Air Monitoring Records Per Year 

# of Samples Year General Air Breathing Zone 

1947 6 0 

1948 57 50 

1949 150 109 

1950 37 19 

 Source: NIOSH 2010, Table 6-2 

Decontamination operations began before the end of Step III processing and continued for a few 

years afterward; the initial cleanup period may have ended in 1954. Dust concentration data 
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were obtained from Table V of Heatherton 1950 for different decontamination methods for the 

concrete and cinderblock surfaces, as well as the building rafters in Building 30 (which housed 

Steps I and II processing equipment), including sandblasting, vacuum cleaning, flame cleaning, 

and pneumatic hammering. NIOSH also has access to the original sample logs containing the 

data and descriptions of the decontamination processes, as well as general area dust sample data. 

Table 7 reproduces decontamination data from Heatherton 1950: 

Table 7. Air Concentrations Measured During 1948–1949 Clean-up of Building 30 

Air Concentration (MAC(a) alpha dust) Process Number of 

Measurements min. max. avg. 

Vacuum cleaning 17 0.1 5.3 1.2 

Removing concrete floor with pneumatic hammer 6 4.2 25 10 

Flame cleaning 6 1.7 13 6.6 

Sandblasting 5 7.0 49 22 

One-half hour after sandblasting 3 1.0 1 1 

(a) – 1 MAC is equivalent to 70 dpm gross alpha activity. 

Source: Heatherton 1950, Table V 

Raffinates, which are waste material from the uranium processing, were removed from the Linde 

site prior to the end of operations, so workers after that period would only have been exposed to 

any remaining residual contamination. Attachment 1 of NIOSH 2009 summarizes available data 

on uranium and uranium progeny concentrations in different materials at Linde, which can be 

used to estimate personnel exposures. 

NIOSH believes that it has sufficient bioassay and air sample data and can use applicable 

methodology (such as ORAUT-OTIB-0019 to estimate doses to unmonitored personnel from 

monitored coworker data) from the Linde Site Profile (NIOSH 2009) to estimate a bounding 

internal dose estimate from exposure to airborne particulates. NIOSH notes that Step III 

operational period urinalysis data are used to estimate maximum exposures for workers in the 

post-operations period through December 31, 1953. As stated before, all site profile issues 

identified by SC&A and the Linde WG, which included data and methodology items, have been 

resolved to the satisfaction of the Linde WG, as summarized in SC&A 2009. 

3.3 EXTERNAL EXPOSURE 

The primary sources of external radiation exposures to Linde workers during the SEC-00154 

time period were uranium and uranium progeny during the operations period (direct and 

resuspended contamination), which ended in 1949, and the decontamination period, which 

continued to the end of the SEC-00154 time period on December 31, 1953 (resuspended 

contamination). Section 6.2 of NIOSH 2010 summarizes available external monitoring data, 

which include film badge data from 1947 to 1949. NIOSH 2010 reports: 

No personnel external dosimetry data have been identified for Linde Ceramics 

workers prior to the start of or after the cessation of Step III operations. 

However, NIOSH does have access to radiological dose rate and contamination 

data documenting site contamination for the period under evaluation in this 

report... (Section 6.2) 
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External exposures to personnel in the utility tunnels will be discussed separately in the next 

section. 

3.3.1 Tunnel Exposures 

Section 3.2.1.2 of this report outlines some of the information available pertaining to the 

existence and use of utility tunnels that ran under the Linde plant. A detailed 2001 FUSRAP 

survey for the U.S. Army Corps of Engineers (Army Corps 2002) looked at beta surface 

contamination levels on the inner surface of the tunnels (many of which may not have been built 

until after the end of the SEC-00154 period), with 6 to 8 circumferential measurements taken 

1 meter apart through the length of the tunnels. In addition, hot spots were located and surveyed 

separately. As stated in NIOSH 2010, “The beta contamination levels were then converted to 

individual isotopic activities based on gamma spectroscopy analysis of soil samples taken during 

site remediation” (Section 6.3). The surface contamination would have accounted for any 

radioactive effluents seeping into the tunnels from the surrounding soil. The isotopic activities 

were then used to determine skin and effective dose rates by radionuclides using the claimantfavorable assumption of applying the 95th percentile surface contamination level (including 

hotspots) to the entire length of the tunnel. SC&A accepted this procedure in its review of the 

SEC-00107 Petition. 

NIOSH 2010 assumes a 2-months per year occupancy factor for workers in the tunnels and, as 

discussed in the SEC-00107 review process, worker documents and statements suggest that 

occupancy, at least for some workers, may have exceeded that amount. As before, however, the 

choice of occupancy factor is a dose reconstruction issue, not an SEC issue, so it is not cited 

here. 

3.3.2 Bounding External Exposures 

NIOSH has available a printout of about 6,000 weekly film badge results of beta and gamma 

exposures for the 1948–1949 period, with many of the records labeled with a job title, allowing 

NIOSH to perform a statistical analysis of the exposure data by job activity and work area. The 

methodology appears in the site profile (NIOSH 2009). NIOSH also has available the results of 

radiation surveys performed at the end of the operational period in 1949, as well as the initial 

FUSRAP survey of 1976, ORNL 1978 (which found Building 30, the location of Steps I and II 

processing, to be the most contaminated), to bound external exposures during standby periods 

and for outdoor areas. NIOSH believes it has sufficient data and applicable methodology 

(appearing in the site profile, NIOSH 2009) to reconstruct external doses for the workers during 

the SEC-00154 Petition period. 

Section 7.3.4 of the SEC-00154 Petition ER states: 

External monitoring data summarized in Section 7.3.1.1 can be used as the basis 

to bound external photon and beta exposure for Linde site workers. Adjustments 

to these data to account for specific job categories and work areas can be made 

based on job description and category information that is also contained within 

the dataset. Adjustments for what are termed “high-“ and “low-“ risk employees 
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NOTICE:

are provided in ORAUT-TKBS-0025 [the site profile]; however, additional 

adjustments can be made using the available dataset, as appropriate, based on 

individual claim dynamics. 

For non-operations periods and following cessation of Step III operations, the site profile 

categorizes workers into three groups; cleanup worker, cleanup support worker, and non-cleanup 

worker. Dose rates for each group by year appears in Table 4-24 of the site profile. 

Issue 6: Job Categories. Based on worker written and oral statements in the SEC-00154 

Petition and in other places (e.g., SC&A 2010), it may have been common for workers formally 

assigned to a particular task in a particular area to be informally reassigned to other tasks in other 

areas in a fluid fashion to accommodate changing task requirements. Given these uncertainties, a 

claimant-favorable approach would be to assign unmonitored or partially monitored workers 

with the highest external exposures experienced during a given time period.
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4.0 REFERENCES 

42 CFR 83. Title 42, Part 83, of the Code of Federal Regulations. 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, Federal Register/ Vol. 69, 

No. 104/Friday, May 28, 2004, p. 30764. 

ABRWH 2006. Transcript of the 38th Meeting of the Advisory Board on Radiation and Worker 

Health, held at the Marriott Metro Center, Washington, DC, on June 16, 2006. U.S. Department 

of Health and Human Services, Centers for Disease Control and Prevention, National Institute 

for Occupational Safety and Health. 

Army Corps 2002. Dose Assessment for the Existing Surface Contamination Within the Linde 

Utility Tunnel Complex, FUSRAP Linde Remedial Action; U.S. Army Corps of Engineers, 

Buffalo District; January 2002. 

Heatherton, R.C. 1950. Decontamination and Survey of Uranium Refinery Plant, NYO-1536; 

December 14, 1950; SRDB Ref ID: 29822. 

NIOSH 2008. SEC Petition Evaluation Report, Petition SEC-00107: Linde Ceramics Plant, 

Rev. 0, November 3, 2008. 

NIOSH 2009. An Exposure Matrix for Linde Ceramics Plant (including Tonawanda 

Laboratory), ORAUT-TKBS-0025, Rev. 01, PC-1, November 10, 2009. 

NIOSH 2010. SEC Petition Evaluation Report, Petition SEC-00154: Linde Ceramics Plant, 

Submittal Date: November 2, 2010. 

NIOSH 2011. SEC Petition Evaluation Report, Petition SEC-00107: Linde Ceramics Plant, 

Rev. 1, January 28, 2011. 

ORAUT 2005. Analysis of Coworker Bioassay Data for Internal Dose Assignment, Rev. 1, 

October 7, 2005. 

ORNL 1978. Formerly Utilized MED/AEC Sites Remedial Action Program—Radiological 

Survey of the Former Linde Uranium Refinery, Tonawanda, New York, W-7405-ENG-26; Oak 

Ridge National Laboratory (ORNL); May 1978. 

SC&A 2006a. Report to the Working Group on Special Exposure Cohort Petition Review, Draft, 

January 16, 2006. 

SC&A 2006b. Board Procedures for Review of Special Exposure Cohort Petitions and Petition 

Evaluation Reports, Revision 1. SCA-TR-TASK5-0002, June 12, 2006. 

SC&A 2009. Assessment of the Disposition of SC&A’s Linde Site Profile Review Issues in 

Response to SEC Petitioner Concerns, draft, August 20, 2009. 
Effective Date: 

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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.

NOTICE:

SC&A 2010. Linde Worker Interview Notes: Niagara Falls, New York, May 19-21, 2010, 

SC&A draft, May 27, 2010. 

SEC-00107 2008. Linde Ceramics SEC Petitions: SEC00106, November 1, 1947 through 

December 31, 1953; SEC00107, January 1, 1954 through July 31, 2006 – Linde Ceramics 

Facility, Tonawanda, New York, March 19, 2008. 

SEC-00154 2009. Linde Ceramics SEC [00154] Petition Application: November 1, 1947 

through December 31, 1953, November 5, 2009.