Issue #14
SALT BATH SOAKING TIME REQUIREMENTS & LEAKS
There was a 4-hour loss of time with a salt bath leak.

Accident: September 22, 1952

© 303 billets rolled, 9 billets at a time to charge the sait bath
© 23 minutes average time to soak per charge

© 759 minutes total time for soaking time

e 12.5 house needed for soaking only.

This work cannot be done in a 10-hour working day. It is impossible for this work to
be done in a 10-hour working day based on the time requirements.

Please explain this impossibility. How many other inconsistencies and invalid claims
are in these reports?

Fernald representatives reported in FMPC-17 (April 1952) that the rollers were
running a billet every two (2) minutes when they hit their stride. Soaking time is
not likely to be the limiting factor because billets were removed one at a time and
could be replaced to keep the process moving. NIOSH has developed an
exposure model such that the employees worked 10 hours at each of the rollings.
Even if there was some deviation on one rolling day in the time required, the

profile provides a very claimant favorable estimate for days when 30 billets were
tolled.

Issue #15
MANUAL LABOR
Far exceeds the rolling process at Simond Saw & Steel
o Sledge hammer rods into shape
o Moving rods across salt bath with crowbars
o Removing cobbles
o Hand held Geiger counters
As has been provided in previous correspondence with you, manual processes
were cited by the AEC as being one of the factors that elevated exposures. One of

the largest factors involved the dragging of the rods between various stations and

12


Discussions with workers have also provided evidence that the occupation of this
area was intermittent. Previous estimates as well as the updated exposure model
for Revision 2 provide for a 10 hour exposure during rolling days and for residual
contamination during the remaining periods of time which account for exposures
in all areas of the plant.

Issue #2

NIOSH never met with site workers until 16 months after Bethlehem Steel’s TBD was
approved (July 2004). Why? When at other facilities compensation was withheld until
the site profile was completed.

While NIOSH did not hold a town hall meeting, each claimant was requested to
participate in a Computer Aided Telephone Interview (CATI) and asked to
provide information which would assist in the dose reconstruction process.
Further, NIOSH developed exposure models that were believed to be plausible
bounding upper estimates for exposure when data were unavailable. This is
consistent with the dose reconstruction regulation and the associated
implementation guides. The Bethlehem Steel Corporation site profile was
developed to provide timely and accurate compensation decisions for claimants
from Bethlehem Steel.

Issue #3

Four (4) Bethlehem Steel claimants were compensated prior to the TBD approval on
March 30, 2003. What was their criteria for compensation?

NIOSH has reviewed all completed dose reconstructions from Bethlehem Steel
and cannot find evidence that we approved any dose reconstructions for
Bethlehem Steel claims prior to March 31, 2003, the date the original Bethlehem
Steel Corporation site profile was issued for use.

As with all claims, NIOSH does not determine compensation. The adjudication
of a claim and decision on compensability is the responsibility of the Department
of Labor.

Issue #4

Once Bethlehem Steel’s TBD was approved, NIOSH began denying claimants without
having a completed site profile. Please explain.

As discussed in the response to question 1, the site profile and technical basis document
for Bethlehem Steel are the same document. The original site profile was issued on
March 31, 2003, and we can find no evidence that we approved any dose reconstructions
for Bethlehem Steel claimants prior to the March 31, 2003 issuance date of the site
profile. We did find that in some of the very early dose reconstructions (i.e., those
approved on April 7, 2003), the dose reconstruction report references a draft technical

3


why did they need to talk to Dr. Breslin to substantiate the data? Remember
this was a Technical Document. The air sample data should have been
researched thoroughly prior to the TBD document approval. Explain please.

NIOSH has and will continue to follow-up on sources of information that might
become available to assist in the dose reconstruction process. For example,
NIOSH had previously obtained the input of Dr. Naomi Harley who at the time
was the counting technician at HASL for these samples. NIOSH was not aware
that any member of the original Health and Safety Laboratory (HASL) air
monitoring team was still alive at the time the first site profile for Bethlehem Steel
was released. Through additional professional contacts and considerable
searching for other HASL personnel, NIOSH located Dr. Breslin. NIOSH sought
information from Dr. Breslin, a technical expert in the field, regarding the
interpretation of certain air sample results.

We asked that Dr. Breslin allow NIOSH and SC&A to interview him, and he
declined. The reasons provided by Dr. Breslin at that time were the poor status of
his health and his inability to recall specific facts and/or events that occurred so
long ago. This resulted in NIOSH using a claimant favorable interpretation of the
air sample data which led to an increase in the estimate of exposures used in the
revised site profile. Finally, to address the legibility issue, NIOSH obtained the
original air sample records from the Department of Energy to verify the data for
difficult to read values. SC&A confirmed all but one result was legible.

Issue #9

GAMMA RAYS - NIOSH states no Gamma rollings took place at Bethlehem Steel.
Refer to document HW -22474 Finished Rollings Done at Bethlehem Steel -“ 4 to6 12
foot long gamma extruded rods”.

Issue #9.a

If no gamma rollings were done, then why does the “Elimination Analysis” refer to
“The survey included direct measurement of alpha and beta-gamma radiation levels”?
January 25, 2005 Findings - Item #8 (Beta and Gamma).

I would like to clarify that the terms alpha, beta, and gamma phases are all related
to the structure of the metal (not the radioactivity content) following rolling at
various temperatures (please see the figure below). The gamma extruded rods
were rods extruded at temperatures higher than the temperature used when rods
were rolled. The gamma in this case refers to the lattice structure of the metal
grain; it does not refer to radioactivity. The gamma referred to in (9.a.) above is
gamma radiation which can also be referred to as photon radiation. Dose from
photon (gamma and x-rays) radiation estimates have been included in all revisions
of the BSC TBD for all years. The following figure from HW-34868, Nuclear
Metallurgy Lectures from 1955 shows the various physical structures based on


documentation indicates the rollings ended, not in 1951, but in 1952. NIOSH
presented this evidence to the DOE, and the covered period was expanded from
1949 to 1952.

The dose reconstruction model at Bethlehem Steel has always included an
estimate for exposure during the 1949 and 1950 time period. The contracts
referenced in your question are the contracts for National Lead of Ohio (NLO) to
operate Fernald. Fernald did not have the ability to conduct oversight of off-site
rolling operations until the issuance of amendment 4 to contract AT(30-1)-1156
which was set forth on June 27, 1951. Finally, NIOSH has obtained many
documents regarding the Atomic Energy Commission’s rolling program that was
conducted from 1943 and later during its research activities to improve the
uranium quality for Hanford. No documentation of the rolling of uranium in 1949
or 1950 at Bethlehem Steel has been found. Thus, the NIOSH Bethlehem Steel
Site Profile and dose reconstruction of Bethlehem Steel claims gives substantial
benefit of the doubt to the claimants for the years 1949-1950.

Issue #7 - SURROGATE INFORMATION

Surrogate information used by NIOSH was obtained from Simonds Saw, a facility
approximately one tenth the size of Bethlehem Steel Company.

Issue #7.a

Not one procedure at Simonds Saw was comparable to Bethlehem Steel’s operation not
even remotely close to allow for a comparison. Please explain.

First, it is important to point out that the site profile used Simonds Saw data to
reconstruct exposures for workers in 1949 and 1950, when no air monitoring data
were available for Bethlehem Steel. While NIOSH acknowledges that there are
differences between these two facilities, we are confident that the site profile
adequately accounts for these differences and provides plausible bounding upper
estimates of internal uranium exposure for claimants. While a more detailed
evaluation is provided in the revised site profile, the following discussion
highlights the main reason why NIOSH believes the Simonds Saw data is
appropriate for reconstructing exposures at Bethlehem Steel and why these
exposures adequately bound the exposures experienced by workers in 1949 and
1950.

A detailed review of the air concentrations that result from the mechanical
processing of uranium (e.g., rolling, grinding, shearing, etc.) has been conducted
by NIOSH. In these reviews, it has been observed that the operation with the
potential for generating the highest airborne levels of uranium is that from rolling
operations. This is particularly true for rolling operations that did not use a
protective coating on the uranium or used a protective coating of lead. As the
earliest rolling at Simonds Saw did not use a protective coating on the uranium
and no relevant ventilation was used, this operation produced extremely high

5


basis document, dated December 2002, rather than the March 31, 2003 revision. This
was an administrative oversight on our part, as the dose reconstructions were completed
in accordance with the approach described in the March 31, 2003 revision.

Issue #5

Four (4) government-owned facility claimants were compensated without a Site
Profile, TBD, or Dose Reconstruction prior to Bethlehem Steel’s TBD approval. Why
should Bethlehem Steel claimants be treated differently?

If we have interpreted your comment correctly, classes of workers at the four
facilities to which you are referring were legislatively granted exemption from
dose reconstruction under EEOICPA when certain specified criteria are met. The
decision to legislatively add these classes to the Special Exposure Cohort for these
facilities is not related in any way to NIOSH’s dose reconstruction efforts under
EEOICPA.

Issue #6

1949-1950 No records exist at all. How can NIOSH say that “nothing went on” when
Bethichem Steel had contracts to do experimental work? AT(30-1) -1279 and AT(30-
1)-1156. The technical information resulting from that work was of a classified
nature. And the government admits destroying all documentation for that period.
NIOSH had no knowledge of what went on in 1949 to 1951. Can this be explained in
detail?

The covered period for Bethlehem Steel was based on a letter that indicated
rollings of uranium occurred there between 1949 and 1951°. The reported
purpose of these rollings was to identify the required pass schedules that could be
used in the design of a rolling mill at the Fernald plant. Based on documents
acquired by NIOSH, the first rolling at Bethlehem Steel, for the purpose of
developing the Fernald design, took place on 4/26/1951. This rolling is referred
to as experimental rolling number | in AEC documents. Either the rollings
started in 1949 for a different purpose or the rollings started in 1951. Without the
Range letter, there is no indication of rollings occurring at BSC prior to 1951.
The decision was made by NIOSH, however, that the recollection of monthly
rollings beginning in 1949, as cited in the Range letter, cannot be refuted and to
give the benefit of doubt to the claimant. The site profile was, therefore, written to
assume monthly rollings starting in 1949.

As previously discussed, the rolling dates cited in the Range letter were based on
memories from more that 25 years ago. Historical records acquired by NIOSH
indicate that these memories contain at least one factual error. AEC

© Range, W., 1976, letter to David M. Anderson (Bethlehem Steel Corporation), Energy Research and Development
Administration, June 7.


model adequately bound the upper exposure conditions experienced by workers at
this facility.

Issue #7.d.

Simonds Saw site profile was not completed at the time Bethlehem Steel’s TBD was
approved, but NIOSH was using data from Simonds Saw to calculate Bethlehem
Steel’s Dose Reconstruction and deny claims.

In keeping with the guidance contained in parts 82.16 and 82.17 of 42 CFR Part
82, Methods for Radiation Dose Reconstruction Under the EEOICPA, the site
profile relied on data from Simonds Saw that conducted a similar operation using
a similar source term. Working conditions at Simonds Saw and Steel were the
subject of extensive analysis by HASL and others regarding practices and health
and safety reports over the entire time that uranium was rolling. These data,
which are many times higher than the data obtained from Bethlehem Steel in the
1951 and 1952 time period, were used to support the analysis of claims during the
1949 and 1950 time periods.

Issue #8 - AIR SAMPLE LOCATION & DATA
Issue 8.a

After four years of NIOSH stating the “highest area of contamination was at the
Rollers, we find all the breathing zone samples (approximately 9) were taken at the
Shear Area 500 feet from the Rollers. Please explain.

Documentation that the rollers had the highest exposures is far broader than
simply evaluating the Bethlehem Steel data. Harris and Kingsley provided data
based on the extensive Health and Safety Laboratory (HASL) analyses of
exposure in their 1958 document regarding the Industrial Hygiene of Uranium
Fabrication. This document and other reports have typically noted that the rollers
had the highest exposure. The current site profile for Bethlehem Steel also
discusses that other areas may have higher levels of airborne uranium
contamination during periods in which uranium was preheated in a salt bath.

It is incorrect, however, to state that all the breathing zone (BZ) samples were
obtained at the shear. Breathing zone samples in part include such descriptions as
“BZ transferring bar from bath to 1 stand”, “Runout table BZ”, “Lead furnace
loading rods”, “runout table and shearing composite BZ”, and “BZ salt bath 3
rods”.

Issue #8.

Many of the original documents are undated, illegible or incomplete with no
“sample description”. No dates, messy at best. The person that took these
samples would not testify for NIOSH - Why? If NIOSH had the proper records

7


oun

otttaanyy

& DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service

National Institute for Occupational
Safety and Health

Robert A. Taft Laboratories

4676 Columbia Parkway

Cincinnati, OH 45226-1998

Phone: 513-533-6825

Fax: 513-533-6826

August 22, 2006

Mr. Edwin A. Walker
8614 S. Main Street
Eden, NY 14057

Dear Mr. Walker:

As an active participant in the process, you are aware that the Bethlehem Steel Corporation (BSC) site
profile has undergone extensive review by the Advisory Board on Radiation and Worker Health
(ABRWH). With the assistance of the Board’s contractor, Sanford Cohen & Associates (SG&A), all
technical aspects of the BSC site profile have undergone rigorous scientific scrutiny. The results of this
independent review were discussed at a number of working group meetings that were open to the public.
This review process has resulted in NIOSH making a number of technical revisions to the original site
profile that was issued on March 31, 2003. We believe that this process has not only improved the
scientific basis for our dose reconstructions at Bethlehem Steel, but also highlights NIOSH’s commitment
to conducting our work in an open forum that is as transparent to the public as possible.

At the final meeting of the Board’s BSC working group on November 28, 2005, the remaining six issues to be
resolved between SC&A and NIOSH were discussed in some detail. According to the transcript of that
teleconference, the approach to be taken for all issues was agreed upon between NIOSH and SC&A, with the
exception of finding number 2 that dealt with how NIOSH would address exposures from the cutting of
uranium cobbles. At the end of this meeting, NIOSH committed to further investigate this issue by
interviewing workers who were involved in the cutting of cobbles. With your assistance, a meeting was held
with these workers on June 21, 2006. Although the workers’ recall of events that occurred almost 50 years
ago was not perfectly clear, it was obvious to NIOSH that the torch cutting of cobbled uranium rods could not
be discounted. As such, NIOSH has revised the BSC site profile to include an exposure scenario for this
activity.

NIOSH has recently updated the Bethlehem Steel site profile to address all the scientific issues that were
raised by the ABRWH and SC&A. The significant changes that were made include:

_ 1. Increasing the air concentration values for 1951 and 1952 to account for the possibility that the air
samples taken by Health and Safety Laboratory personnel were not representative of the
breathing zones of workers.

2. In 1952, when air concentrations were no longer bounded by rolling operations, NIOSH selected
the highest recorded air sample, which was taken during a grinding operation, as representative of
the breathing zone concentration for all workers.

3. An exposure scenario for the torch cutting of uranium cobbles was added.


These documents indicate that the experimental work conducted at Bethlehem
Steel was conducted on a very limited basis. The site profile has incorporated
exposure conditions during which all employees are assumed to perform the
highest exposure job for 10 hours per workday. This significantly overestimates
the time required for an operation that involved the small number of billets
processed during the experimental phase. During the 1951 and 1952 rollings, air
sample data, surface contamination data and production records exist for the
uranium rollings at Bethlehem Steel.

Issue #11
PERSONAL PROTECTIVE EQUIPMENT

No personal protective equipment was issued at Bethlehem Steel such as: Glovebox,
Masks, Hoods, Film Badges, etc. How can accurate Dose Reconstruction be modeled
without reliable air data or personal monitoring on workers?

Dose reconstruction at Bethlehem Steel was based on modeling exposure
conditions that used air monitoring results and production data. Each version of
the Bethlehem Steel site profile provided consistent guidance to the dose
reconstructor that no personal protective equipment was used at BSC. The
Advisory Board as well as their contractor reviewed and concurred with the
approach.

Issue #12
LOST URANIUM
Issue #12.a.

Of the approximately 48+ rollings in Bethlehem Steel’s TBD only 27.083 % of those
rollings are actually documented.

NIOSH has obtained detailed documentation from a number of sources which
provide the specific sites that rolled uranium for the Atomic Energy Commission
in the late 1940s. A detailed review of all the information on these early rollings
casts serious doubt on the involvement of Bethlehem Steel in the rolling of
uranium in 1949 and 1950. The time period of 1949-1950 precedes the plans to
centralize the rollings at Fernald where the concept of using a continuous rolling
mill for uranium rolling was proposed. However, as detailed in my earlier
response, NIOSH has chosen to provide a claimant favorable evaluation of
potential exposure during the covered period. The inclusion of additional rollings
in 1949 and 1950 doubles the covered exposure period and significantly increases
the dose calculated for workers at Bethlehem Steel.

10


rolling temperatures. These terms have no relationship with radioactivity in this
context.

AY
1200} Liguia
ANNAN
1100
1000
Game ‘Gamma Phase
Porging or Extrusion
900
Hf
<
»TM 2
ra
8 0 (7) & 1) seve Phase Rolling
TUL
Hy T |] High Alpha Phase Rolling,
f 0 Extrusion or Forging ine
500
Yoo} Alpha
Ee
300 3 [==] Cold Rolling
=
200 4
8
100
Cold Finishing - Drawing, Swaging or Rolling
L
FIGURE 1. Fabrication Temperatures for Uranium
Issue #10

“BBW” - “Best Bar Mill in the World” No other facility in the World was doing
continuous Uranium rolling. We were Guinea Pigs.

When doing experimental work you are working with the unknown. The government
admits (documented) to destroying these records. Please explain.

The description that the government admitted to destroying the records was
provided in a letter from someone not involved in the program. In our data
capture efforts, NIOSH has obtained a significant number of documents from
HASL and Hanford regarding Bethlehem Steel.

9


levels of uranium in the air. The Bethlehem Steel site profile selected the 95"
percentile air concentration value measured at Simonds Saw (~600 times the
maximum allowable concentration) and assumed that all Bethlehem Steel
claimants breathed this concentration at a heavy work inhalation rate for every
minute of a 10 hour work day.

The use of Simonds Saw and Steel data to evaluate exposures at Bethlehem Steel
has been the subject of extensive review by the Advisory Board and its contractor,
Sanford Cohen and Associates. The relevance of the use of Simonds Saw data
has been discussed at length, and the consensus opinion among the Board, SC&A
and NIOSH is that the Simonds Saw data adequately bound exposures for
Bethlehem Steel workers in the 1949 and 1950 time period.

Issue 7.6

In 1948 at Simonds Saw, many safety procedures were implemented while working
with Uranium, but those safety procedures were never introduced to the experimental
process at Bethlehem Steel from 1949-1952. Why? Please explain.

We cannot answer why certain administrative procedures to reduce exposure
potential were not adopted at Bethlehem Steel Corporation (BSC). We can say
that certain aspects of the Simonds Saw and Steel pilot runs (like the lead bath)
were utilized in the rollings at BSC to reduce exposure potential.

The dose reconstruction model being used by NIOSH for Bethlehem Steel is
based on monitoring data taken at Simonds Saw prior to the installation of
ventilation and the floor gratings. These data were selected to specifically avoid
the issues you have raised in previous correspondence. Several documents from
the AEC Health and Safety Laboratory (HASL) describe the incremental addition
of ventilation and gratings at Simonds Saw and the impact that it made on dust
levels. Furthermore, as was discussed during our meetings with SC&A, the air
measurement data were collected during the rolling of uranium without benefit of
protective coating on the uranium bars. Because the lead bath used at BSC
provided improved resistance to oxidation compared to bare metal, the application
of Simonds Saw air concentration data is likely to be an overestimate of the actual
conditions at BSC.

Issue #7.c

Personal monitoring took place at Simonds Saw, but such personal monitoring was
never considered or conducted at Bethlehem Steel. Why?

Again, we cannot say why personal monitoring was not done at BSC. It would be
speculation on the part of NIOSH to offer reasons as to why bioassay samples or
additional breathing zone samples were not collected at Bethlehem Steel. NIOSH
has developed an exposure model for BSC claimants based on existing air
sampling data. We believe that the claimant favorable assumptions built into this

6


uranium rods. As indicated in the report, this survey found no removable
radioactivity on any of the surfaces. The 1980 survey was conducted as part of
the Formerly Utilized Sites Remedial Action Program (FUSRAP). At the time of
this survey, the 10” bar mill equipment had been dismantled, so the investigators
evaluated contamination levels in the area that the bar mill previously occupied,
as well as the dismantled equipment. This investigation found that: Radiological
surveys of the plant area in which the rolling was performed and of the equipment
used indicated the radiation levels were typical natural background for the area.

Because no contamination was detected in the bar mill area or on the bar mill
equipment in either survey, and the rolling equipment was no longer in its original
location, NIOSH did not believe that a site visit to the rolling area would produce
meaningful information.

Issue #1.5

Other buildings were involved, including the Blooming Mill (Reference Wayne Range
Letter of June 7, 1976.). The purpose of the Blooming Mill was to reduce ingots to
billets - (ingots) referred to in Government Reports of Bethlehem Steel Company but
not acknowledged by NIOSH. Why?

The Range letter you reference mentions that the statements related to uranium
activities at the site were the recollections of a contract officer more that 25 years
after the activities occurred. The letter simply states that a suitable blooming mill
and rolling mill were present at Lackawanna; the letter does not indicate or
confirm the use of these facilities for uranium work at Lackawanna. Every
document reviewed by NIOSH describing the rollings indicates that all billets
were rough rolled at a separate facility (e.g. Simonds Saw and Steel or Allegheny-
Ludlum). Finally, the estimates used to determine the air concentration for 1949
and 1950 are based on the Simonds Saw and Steel data and experience. The
Simonds Saw and Steel uranium rolling operation was a precursor for the
operations conducted at Bethlehem Steel.

Issue #1.c

NIOSH overlooked the 28,000 sq. ft. of unmonitored high Uranium concentration area
(sub-basement open under the Cooling Bed). They also overlooked the Cooling Bed
above, A total area of 56,000 sq. ft. unaccounted for, without any air data at all. Can
this be explained?

While this area occupies a large portion of the facility, it does not represent a
component that impacts either the previous or current evaluation of dose at
Bethlehem Steel. This area was evaluated as part of the updates to the technical
basis document, but was found not to be as limiting as the updated exposure
models which were based on plausible worst-case occupational exposure
conditions being assigned to all employees.


resuspending the dust (this includes the example of reintroducing the rods).
Simonds Saw and Steel rolled large quantities of uranium for long periods of time
with no protective coating resulting in significant amounts of uranium on the
floor. This is why grating was later installed at Simonds. The various duties you
have mentioned have been discussed at length during meetings of the Advisory
Board and with SC&A, and a bounding exposure has been established for workers
at Bethlehem Steel. Finally the number of workers does not impact the magnitude
of the 95" percentile air concentration value that NIOSH has chosen to use in the
dose reconstruction for workers at BSC. As you have indicated in your
description of a state-of-the-art facility and is described in documents on the
facility, the 10” mill was designed to minimize manual labor.

Issue #16
GRINDING LOCATION

No grinding was recognized or incorporated in BSC’s TBD until long after claimants
were denied. This is a critical error and needs to be explained.

NIOSH changed its analysis that the highest air concentrations of uranium were
consistently measured at the rollers based on extensive review of the rolling
processes employed at Bethlehem Steel. It became obvious that the salt bath
technology employed during the later years (1951 and 1952) significantly reduced
air concentrations of uranium over the technology employed in the earlier period.
The reduction was so significant that other operations became the bounding
exposure scenario. In keeping with the claimant favorable assumptions used in
the site profile, NIOSH has adopted the highest exposure scenario for assigning
intakes to workers in the later years. Based on an analysis of the measured air
samples, grinding operations provide the highest potential for worker exposure
during the latest time frame at Bethlehem Steel when salt bath heating was used
exclusively for the billets. NIOSH will assume that all workers, regardless of job
category, were exposed to these air concentrations 10 hours per day for each day
of rolling. The final outcome of this will be that the dose determined during this
later time frame based on grinding data will be lower than the dose determined
previously.

Issue #17
SKETCH FOR BETHLEHEM’S ROLLING PROCESS

Submitted into record was a sketch as a description of a 10” rolling mill. This sketch
was of a completely different rolling process. Explain why the wrong sketch was used.
On January 25, 2005 at the California meeting during SC&A’s presentation, no one
challenged the content of the sketch where a sheet metal mill was displayed not a
rolling mill. Also, it is very evident that the 56,000 sq. ft. Cooling Bed area was not
depicted and went unnoticed by all.

13


are no missing pages. To help explain why we believe this to be the case, I've attached the
section of the PDF file which contains the non-sequentially numbered pages.

Based on the imaging software's numbering sequence, pages 16,18,20,22,24,26, and 28 appear
to be missing. One can see, however, that the memo, labeled as page 15 by the imaging
software, states that a copy of the minutes of the May 28, 1951 meeting are attached. Inspection
of the next page (labeled as page 17 by the imaging software) reveals that this is indeed the first
page of the minutes of this meeting. In fact, the upper right hand corner of the meeting

minutes states that the document consists of 6 pages. /f one steps through the following pages, it
can be seen that the original pages were sequentially numbered and that all 6 pages are there.

Again, | can't explain why the imaging software didn't label these pages consecutively, but all the
documents that we intended to send in our September 12th e-mail to Arjun are included in the
PDF file. There are no missing pages in this transmittal.

Issue #19
BETHLEHEM STEEL COMPANY: A STATE-OF -THE-ART FACILITY

During 1949 - 1952 Bethlehem Steel Company was a state-of-the-art facility with no
comparable facilities Worldwide. There are no other facilities comparable for
comparison worldwide. Please explain where NIOSH data was obtained.

This question has been discussed in previous answers. As stated, air monitoring
measurements were taken at Bethlehem Steel during these operations. This data
was supplemented by taking select measurements at other facilities to provide a
claimant favorable analysis of exposure, which when coupled with the many
claimant favorable assumptions regarding time, solubility, particle size, and
location provide a very claimant favorable analysis for determination of the
probability of causation.

15


Attachment 1
Responses to Issues Raised in Mr. Edwin Walker’s June 25, 2006 E-mail

Issue #1

Bethlehem Steel’s Site Profile was not completed before the Technical Based
Document (TBD) was approved on March 30, 2003. Please explain.

The terms site profile and technical basis document are used interchangeably by
NIOSH. Both terms are used to describe a document which provides a standard
set of information for a facility that can be used in the dose reconstruction.
process. The Bethlehem Steel site profile, ORAU-TKBS-0003, that was issued
on March 31, 2003 was the first version of the site profile for Bethlehem Steel.
There have been two subsequent revisions to this document that were issued on
June 29, 2004 and July 27, 2006.

The initial technical basis document for Bethlehem Steel was designed to provide
an exposure estimate that accurately depicted exposure conditions at Bethlehem
Steel, but used claimant favorable estimates where information was unavailable.
The technical basis document for Bethlehem Steel, as a living document, has and
will continue to be evaluated against any additional research findings that are
discovered over the course of this program. OCAS has conducted (and continues
to conduct) an extensive document retrieval and information gathering regarding
the facilities for which it is responsible for conducting dose reconstruction. Ifa
change is warranted, a revision to the TBD would be issued, and previously
completed claims would be re-evaluated. In this manner, a timely decision was
reasonably provided to claimants without sacrificing the ultimate accuracy
necessary to provide a correct decision.

Issue #1.a

NIOSH was unaware of the existence of the 10” (10-inch) Bar Mill building at the time
of the TBD approval. Why?

Actually, NIOSH was aware of the 10” bar mill area at the time the site profile
was developed. Prior to the completion of the site profile, NIOSH reviewed
documentation of two radiological surveys of the 10” bar mill area that were
performed in 1976 and 1980*”. The 1976 survey, conducted the U.S. Energy
Research and Development Administration (ERDA), included direct
measurements and smear samples of the rolling equipment that was used to form

3 LaMastra, A., 1976, “Investigation Report: Uranium Metal Rolling, 10” Bar Mill, Lackawanna Plant,” report to D.
L. Webster, Bethlehem Steel Corporation, June 29.

> DOE (U.S. Department of Energy), 1985, FUSRAP Elimination Report for Bethlehem Steel Corporation,
Lackawanna, New York.


Mr. Edwin A. Walker - Page Two

4, The uranium ingestion model was revised to better reflect the air concentration and contamination
conditions that existed at BSC.

5. The resuspension model was revised to increase the plausible bounding value for exposure from
this pathway.

6. The external exposure model was revised to allow for exposure to contaminated clothing for up to
two weeks between washings. This will increase the shallow dose to the skin to 1.8 rem per year
from potential uranium contamination on clothing.

The revised version of the BSC Site Profile, which includes these changes, was approved for use on July
27, 2006 and is now posted on our web site. For your reference I have enclosed a hard copy version of
this revised document. This version will be used to reconstruct the doses for those claims that have been
on hold during the profile review process. Further, as with any technical change that NIOSH makes, we
have begun to review previously completed dose reconstructions to determine what effect, if any, these
changes might have on the calculated probability of causation. While it is too early to determine the
magnitude of the change across cases, I can say that these changes will not always result in a higher
probability of causation than would have been calculated using the previous version.

Subsequent to the BSC worker meeting on June 21, 2005 that was held in Hamburg, New York, you
provided an e-mail to NIOSH on June 25, 2006 that summarized a number of issues you have related to
the suitability of the Bethlehem Steel Site Profile for reconstructing radiation doses for workers at the
Bethlehem Steel facility. Many of the issues you raise have been the subject of ongoing communications
between yourself and NIOSH for over a year. Through numerous e-mails and in the letters, I have
previously provided written responses to many of the issues raised in your current e-mail. In addition,
other issues have been addressed during meetings of the Advisory Board working groups in which you
participated as a representative of workers at Bethlehem Steel. As such, my responses to each of the 19
issues you raise are largely based on information that we have previously communicated. These are
provided in Attachment 1 of this letter.

I want to personally thank you for the dedicated effort you put forth over the last several years on behalf
of claimants from the Bethlehem Steel facility. Through your persistent efforts, you have helped to

revise the technical basis document to reflect more accurately the exposure conditions of workers at the
Bethlehem Steel facility.

Sincerely,

Absbf-

Larry J. Elliott, MSPH, CIH
Director
Office of Compensation Analysis and Support
Enclosure

Attachment

cc: ABRWH


Issue #12.b

Using NIOSH’s figures to calculate the amount of lost Uranium:

Lost Uranium for 48+ rollings at 8 pounds per billet equals 13 tons of lost Uranium in
4 years of rollings at Bethlehem Steel.

Amount of “Lost Uranium”: 13 tons of radioactive material left on the site according
to NIOSH’s calculations. How did NIOSH account for this?

Because scrap recovery was an important component of the AEC uranium
program, NIOSH does not believe that 13 tons of material were left behind by
AEC at Bethlehem Steel. As a valuable metal, fines and scraps of uranium were
picked up and vacuumed. This has been consistently reported in various
documénts and in interviews with Bethlehem Steel workers. The amount you
speculated that was lost also includes cropping the ends of the billet. These
cropped ends were also recovered as part of the scrap program but did not
contribute to material which could be used by Hanford. Of these 48+ rollings,
only 16 are documented. Without documentation to the contrary, the remaining
rollings were assumed to have occurred, which provides for a claimant favorable
determination of dose. The NIOSH exposure model accounts for the inhalation
and ingestion of residual contamination after rollings. The residual contamination
model, which accounts for the spread of uranium in the plant from rolling
operations, has been the subject of detailed discussion of the Advisory Board’s
working group.

Issue #13
ROUGH ROLLING

NIOSH states only finished rolling took place at Bethiehem Steel. However, the
Government documentation verifies that the government purchased rough rollers as
well as finish rollers for Bethiehem Steel. This error is further evidence of the lack of
proper (valid) research by NIOSH.

The “government documentation” that you reference is a report of a meeting held
on 5/28/1951 where a proposal was made to use BSC for production rolling until
the Fernald mill was operational (estimated mid 1952). It was proposed during
this meeting that new rolls be purchased for the roughing and finishing mills at
BSC. However, all documents prior to and following that meeting continue to
indicate BSC received smaller diameter rods that were rough rolled at other mills.
As previously discussed in question 1.b, this report does not indicate or confirm
the use of these roughing facilities for uranium work at Lackawanna.

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As described in previous correspondence, the issue you raise was from a
presentation by SC&A to the Advisory Board. This information did not impact
our dose reconstruction efforts at that time nor have they changed our current
methods, which have been extensively scrutinized during our discussions with
SC&A. While we have included updated drawings and photographs and
additional background for the site in the revision to the technical basis document,
these again do not change the underlying method or end results of the analysis.
The Board was copied on my previous correspondence regarding this issue.

Issue #18
NO CONTAMINATION WHEN ROLLERS STOP
Finding dated January 25, 2005 - Explain observation #3.

The statement by NIOSH asserts that when the rollers stopped: “The generation of
airborne activity would cease.” That observation #3 is invalid. NIOSH ignored or
refused to address the lack of invalidity of Observation #3. Explain the basis for that
conclusion.

NIOSH originally considered the residual activity following the day of rolling to
be a small route of exposure that was accounted for by other overestimating
assumptions. The latest revision of the TBD now accounts for the resuspension of
uranium that was dispersed throughout the facility. This results in a 1.7%

increase in the amount of inhaled uranium for 1949 and about 0.2% for 1950
(Simonds Saw and Steel data), for 1951, and 1952.

The Bethlehem Steel site profile does not assume that the facility was
decontaminated in one day. In fact, the revised site profile employs a model that
was extensively reviewed during the comment resolution process. This new
model accounts for the fact that the production of uranium was a very small part
of the production activities at Bethlehem Steel. As such, the amount of uranium
available for resuspension would be reduced over time by the dust that was
generated during the normal steel manufacturing process. Although you are
concerned about the accumulation of uranium on the plant rafters, there is no
scientific basis for the selective concentration of uranium dust over the steel dust
at these locations.

NIOSH sent a document of 40 pages, 7 pages were missing. They never resolved this
specific issue,

The following e-mail response was provided to you by Jim Neton on December 22, 2005.

Dear Mr. Walker,

As | indicated in my October 26th response to your original inquiry, a review of the documents in
the PDF file in question revealed that they are complete. While | can't explain the reason for the
non-sequential page numbering in the PDF file, a close review of the document shows that there

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