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SEC Petition Evaluation Report 

Petition SEC-00190

Report Rev #:0 Report Submittal Date: 02/13/2012 

Subject Expert(s): Joseph Guido, Michael Kubiak

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition

Receipt Date

Qualification Date DOE/AWE Facility Name

SEC-00190 83.13 July 28, 2011 November 17, 2011 Titanium Alloys Manufacturing 

Petitioner-Requested Class Definition 

All employees performing their duties who worked at Titanium Alloy Manufacturing Company in Niagara Falls, 

NY from 1950 to 1956.

Class Evaluated by NIOSH

All employees who worked in any area or building at Titanium Alloys Manufacturing from January 1, 1955 

through December 31, 1956.

NIOSH-Proposed Class(es) to be Added to the SEC

None.

Related Petition Summary Information 

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

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

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name

N/A N/A

ORAU Lead Technical Evaluator: Joseph Guido ORAU Peer Review Completed By: Michael Kubiak

Peer Review Completed By: [Signature on File] 2/13/2012

Tom Tomes Date

[Signature on File] 2/14/2012 SEC Petition Evaluation Reviewed By:

J. W. Neton Date

[Signature on File] 2/14/2012 SEC Evaluation Approved By:

Stuart L. Hinnefeld Date
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Evaluation Report Summary: SEC-00190, Titanium Alloys 

Manufacturing 

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

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

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

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

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000.

Petitioner-Requested Class Definition 

Petition SEC-00190 was received on July 28, 2011, and qualified on November 17, 2011. The 

petitioner requested that NIOSH consider the following class: All employees performing their duties 

who worked at Titanium Alloy Manufacturing Company in Niagara Falls, NY from 1950 to 1956. 

Class Evaluated by NIOSH 

Based on its preliminary research, and changes to the EEOICPA-covered period for the facility, 

NIOSH reduced the petitioner-requested class. NIOSH evaluated the following class: All employees 

who worked in any area or building at Titanium Alloys Manufacturing from January 1, 1955 through 

December 31, 1956.

NIOSH-Proposed Class(es) to be Added to the SEC 

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

the types of materials, quantities of materials, and processing methods at Titanium Alloys 

Manufacturing to allow dose reconstruction to be performed with sufficient accuracy. 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. 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient 

information 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; or (2) estimate radiation doses of members of the class more precisely than an estimate of 

maximum dose. The available information 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.

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is not required 

because NIOSH has determined that it has sufficient information to estimate dose for the members of 

the evaluated class. 
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Table of Contents 

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

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

3.0 SEC-00190 Titanium Alloys Manufacturing Class Definitions ..................................................... 8

3.1 Petitioner-Requested Class Definition and Basis .................................................................. 8

3.2 Class Evaluated by NIOSH ................................................................................................... 9

3.3 NIOSH-Proposed Class(es) to be Added to the SEC ............................................................ 9

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ............................................................. 9

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 10

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 10

4.3 Facility Employees and Experts .......................................................................................... 11

4.4 Previous Dose Reconstructions ........................................................................................... 11

4.5 NIOSH Site Research Database .......................................................................................... 12

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 12

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 12

5.1 Titanium Alloys Manufacturing Plant and Process Descriptions ........................................ 12

5.2 Radiological Exposure Sources from TAM Operations ...................................................... 14

5.2.1 Internal Radiological Exposure Sources from TAM Operations ............................ 14

5.2.1.1 Uranium .................................................................................................... 15

5.2.1.2 Recycled Uranium Contaminants (Np-237, Pu-239) ............................... 15

5.2.2 External Radiological Exposure Sources from TAM Operations ........................... 15

5.2.2.1 Photon ....................................................................................................... 16

5.2.2.2 Beta ........................................................................................................... 16

5.2.2.3 Neutron ..................................................................................................... 17

5.2.3 Incidents .................................................................................................................. 17

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 17

6.1 Available TAM Internal Monitoring Data .......................................................................... 17

6.2 Available TAM External Monitoring Data ......................................................................... 17

6.3 Other Available Data ........................................................................................................... 17

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 19

7.1 Pedigree of Titanium Alloys Manufacturing Data .............................................................. 20

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 20

7.1.2 External Monitoring Data Pedigree Review ............................................................ 20

7.2 Evaluation of Bounding Internal Radiation Doses at TAM ................................................ 20

7.2.1 Evaluation of Bounding Process-Related Internal Doses ........................................ 21

7.2.1.1 Airborne Levels ........................................................................................ 21

7.2.1.2 Alternative Data Sources for Bounding Internal Dose ............................. 21

7.2.2 Evaluation of Bounding Residual Period Internal Doses ........................................ 21
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7.2.3 Methods for Bounding Internal Dose at TAM ........................................................ 21

7.2.3.1 Methods for Bounding Operational Period Internal Dose ........................ 21

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 22

7.3 Evaluation of Bounding External Radiation Doses at TAM ............................................... 23

7.3.1 Evaluation of Bounding Process-Related External Doses ....................................... 23

7.3.2 Evaluation of Bounding Residual Period External Doses ....................................... 23

7.3.3 TAM Occupational X-Ray Examinations ............................................................... 23

7.3.4 Methods for Bounding Operational Period External Dose at TAM ........................ 24

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 25

7.4 Evaluation of Petition Basis for SEC-00190 ....................................................................... 25

7.4.1 Decontamination of the Research Area ................................................................... 25

7.4.2 Absence of Monitoring Data ................................................................................... 26

7.5 Summary of Feasibility Findings for Petition SEC-00190 .................................................. 26

8.0 Evaluation of Health Endangerment for Petition SEC-00190 ...................................................... 26

9.0 Class Conclusion for Petition SEC-00190 ................................................................................... 27

10.0 References .................................................................................................................................... 28

Attachment 1: Data Capture Synopsis ................................................................................................... 32

Figure 

5-1: Titanium Alloys Manufacturing Complex at Niagara Falls, NY ................................................... 13

Tables 

4-1: No. of TAM Claims Submitted Under the Dose Reconstruction Rule .......................................... 11

5-1: Estimated Contaminant Activity Fractions in Recycled, Depleted U Source Term ...................... 15

5-2: Principal Radiation Emissions from Natural U and Its Short-Lived Decay Products ................... 16

6-1: TAM Air Monitoring Data ............................................................................................................. 18

6-2: TAM Surface Contamination Data ................................................................................................ 19

6-3: Surface Contamination Present on Materials Designated for Scrap Melting ................................ 19

7-1: Estimated Annual Inhalation Intake Quantity for TAM ................................................................ 22

7-2: Estimated Annual Ingestion Intake Quantity for TAM ................................................................. 22

7-3: Summary of Feasibility Findings for SEC-00190 .......................................................................... 26
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SEC Petition Evaluation Report for SEC-00190

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

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: 

Joseph Guido, MJW Corporation. The rationales for all conclusions in this document are explained 

in the associated text.

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for all employees who worked in any area 

or building at Titanium Alloys Manufacturing from January 1, 1955 through December 31, 1956. It 

provides information and analyses germane to considering a petition for adding a class of employees 

to the congressionally-created SEC.

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

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

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83,

and the guidance contained in the Division of Compensation Analysis and Support’s (DCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, DCAS-PR-004.1

2.0 Introduction 

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

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

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

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2

 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to 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, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

radiation doses may have endangered the health of members of the class. The regulation requires 

 

1

 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS). 

2

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

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 
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NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

members of a class when it has been established that the class may have been exposed to radiation 

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

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

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

classes. 

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

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

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

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

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

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

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

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

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

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

seek a review of certain types of final decisions issued by the Secretary of HHS.3

3.0 SEC-00190 Titanium Alloys Manufacturing Class Definitions 

The following subsections address the evolution of the class definition for SEC-00190, Titanium 

Alloys Manufacturing. When a petition is submitted, the requested class definition is reviewed as 

submitted. Based on its review of the available site information and data, NIOSH will make a 

determination whether to qualify for full evaluation all, some, or no part of the petitioner-requested

class. If some portion of the petitioner-requested class is qualified, NIOSH will specify that class 

along with a justification for any modification of the petitioner’s class. After a full evaluation of the 

qualified class, NIOSH will determine whether to propose a class for addition to the SEC and will 

specify that proposed class definition. 

3.1 Petitioner-Requested Class Definition and Basis 

Petition SEC-00190 was received on July 28, 2011, and qualified on November 17, 2011. The 

petitioner requested that NIOSH consider the following class: All employees performing their duties 

who worked at Titanium Alloy Manufacturing Company in Niagara Falls, NY from 1950 to 1956. 

The petitioner provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the Titanium Alloys Manufacturing workers 

in question. The petitioner’s requested time period was based on the EEOICPA Atomic Weapons 

Employer (AWE) covered period designated for the facility at the time (1950-1956). NIOSH deemed 

the following information and affidavit statements sufficient to qualify SEC-00190 for evaluation: 

 

3

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

available at http://www.cdc.gov/niosh/ocas. 
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In support of his claim, the SEC-00190 petitioner claimed that radiation exposures and radiation 

doses potentially incurred by members of the proposed class were not monitored, either through 

personal monitoring or through area monitoring. In the original petition, the petitioner provided 

the following statements: 

I personally worked on the lab arc furnace and later vacuumed the building, which was 

checked with a geiger counter. We had no dosage monitoring, no special breathing 

masks, no laundering or personal washing instruction. Only after reading my dose 

reconstruction, I realized we were melting uranium ores and compounds. We were told 

it was a secret project and were only told on a need only basis. 

Lack of monitoring the entire area over several days. 

Based on its Titanium Alloys Manufacturing research and data capture efforts, NIOSH determined 

that it has access to information on the specific activities performed and to surface contamination and 

air monitoring data. However, NIOSH also determined that internal and external exposure monitoring 

records are not complete for all time periods or for all radionuclides. NIOSH concluded that there is 

sufficient documentation to support the petition basis that internal and external radiation exposures 

and radiation doses were not adequately monitored at Titanium Alloys Manufacturing, either through 

personal monitoring or area monitoring. The information and statements provided by the petitioner 

qualified the petition for further consideration by NIOSH, the Board, and HHS. The details of the 

petition basis are addressed in Section 7.4.

3.2 Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH reduced the petitioner-requested class because the 

Department of Labor changed the start of the covered period at Titanium Alloys Manufacturing from 

January 1950 to January 1955 (Leiton, 2011). Therefore, NIOSH defined the following class for 

further evaluation: All employees who worked in any area or building at Titanium Alloys 

Manufacturing from January 1, 1955 through December 31, 1956. 

3.3 NIOSH-Proposed Class(es) to be Added to the SEC 

Based on its research, NIOSH has obtained information on the types and quantities of material and 

processing methods that allow dose reconstruction to be performed with sufficient accuracy. 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. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

As is standard practice, NIOSH completed an extensive database and Internet search for information 

regarding Titanium Alloys Manufacturing. The database search included the DOE Legacy 

Management Considered Sites database, the DOE Office of Scientific and Technical Information 

(OSTI) database, the Energy Citations database, and the Hanford Declassified Document Retrieval 

System. In addition to general Internet searches, the NIOSH Internet search included OSTI OpenNet 

Advanced searches, OSTI Information Bridge Fielded searches, Nuclear Regulatory Commission 
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(NRC) Agency-wide Documents Access and Management (ADAMS) web searches, the DOE Office 

of Human Radiation Experiments website, and the DOE-National Nuclear Security AdministrationNevada Site Office-search. Attachment 1 contains a summary of Titanium Alloys Manufacturing 

documents. The summary specifically identifies data capture details and general descriptions of the 

documents retrieved. 

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH.

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into 

Titanium Alloys Manufacturing operations or related topics/operations at other sites: 

Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium Metals, BattelleTBD-6000; Rev. 1; June 17, 2011; SRDB Ref ID: 30671 

Technical Basis for Atomic Energy Operations at Blockson Chemical Company, Joliet, Illinois, 

NIOSH Division of Compensation Analysis and Support; DCAS-TKBS-0002, Rev. 03; December 

20, 2010; SRDB Ref ID: 91205 

4.2 Technical Information Bulletins and Procedures 

A Technical Information Bulletin is a general working document that provides guidance for preparing 

dose reconstructions at particular sites or categories of sites. A procedure provides specific 

requirements and guidance regarding EEOICPA project-level activities, including preparation of dose 

reconstructions at particular sites or categories of sites. NIOSH reviewed the following Technical 

Information Bulletins as part of its evaluation: 

Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, ORAUT-OTIB0006, Rev. 4; Oak Ridge Associated Universities; June 20, 2011; SRDB Ref ID: 98147

Estimation of Ingestion Intakes, OCAS-TIB-009, Rev. 0, NIOSH Office of Compensation 

Analysis and Support; April 13, 2004; SRDB Ref ID: 22397 
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Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays Administered Off 

Site, ORAUT-OTIB-0079, Rev. 00; Oak Ridge Associated Universities; January 3, 2011; SRDB 

Ref ID: 89563

4.3 Facility Employees and Experts 

In an attempt to obtain additional information, NIOSH pursued interviews with former Titanium 

Alloys Manufacturing employees. NIOSH attempts to identify interviewees with process knowledge 

of the period under evaluation were complicated by the short duration of interest (1955-1956), time 

elapsed, and a small dose reconstruction claim pool. NIOSH has reviewed the computer-assisted 

telephone interviews conducted for claims filed with NIOSH for energy employees who worked at 

Titanium Alloys Manufacturing during the period from 1955 through 1956. These interviews 

confirmed the use of radioactive materials at the site and indicated that monitoring was not provided. 

At least one individual indicated that knowledge of the type of material in use was often withheld 

from the workers. Neither the available interviews nor the petitioner identified any potential sources 

for additional monitoring or process data. To date, NIOSH attempts to contact labor union 

organizations associated with the period under evaluation have not provided any potential sources for 

additional information or data. 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH DCAS Claims Tracking System (referred to as NOCTS) to locate 

EEOICPA-related dose reconstructions that might provide information relevant to the petition 

evaluation. Table 4-1 summarizes the results of this review. (NOCTS data available as of January 14, 

2012) 

Table 4-1: No. of TAM Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 14

Total number of claims submitted for energy employees who worked during the period under 

evaluation (January 1, 1955 through December 31, 1956). 12

Number of dose reconstructions completed for energy employees who worked during the period

under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 12

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 0

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 0

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. As noted in Table 4-1, NIOSH has not received external 

or internal monitoring data from Titanium Alloys Manufacturing for any claimants. 
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4.5 NIOSH Site Research Database 

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. Seventy-two (72) documents in this database were identified as 

pertaining to Titanium Alloys Manufacturing. These documents were evaluated for their relevance to 

this petition. The documents include historical background on facility operations and the results of air 

and surface contamination sampling. 

4.6 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioners: 

Form B for SEC-00190; DSA Ref ID: 104385 (Form B-SEC00190) 

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize both radiological operations at Titanium Alloys Manufacturing 

from January 1, 1955 through December 31, 1956 and the information available to NIOSH to 

characterize particular processes and radioactive source materials. From available sources NIOSH has 

gathered process and source descriptions, information regarding the identity and quantities of each 

radionuclide of concern, and information describing processes through which radiation exposures may 

have occurred and the physical environment in which they may have occurred. The information 

included within this evaluation report is intended only to be a summary of the available information. 

5.1 Titanium Alloys Manufacturing Plant and Process Descriptions 

Titanium Alloys Manufacturing (TAM) was located in Niagara Falls, NY on an approximately 35-

acre site (see Figure 5-1). The company was founded in 1906 and initially produced ferro carbon 

titanate, an alloy developed for use in steelmaking. The company went on to develop a process to 

separate titanium oxide leading to its use in the pigmentation of paint (Survey, Date Unknown).

TAM was issued a contract to supply zirconium for the AEC complex starting in 1950. Zirconium 

materials were provided to Electromet, Y-12, and Fernald, to name a few. Waste materials from 

zirconium operations were sent to the Lake Ontario Ordinance Works (LOOW); however, none of the 

operations involving these materials involved the use of radioactive materials (Collins, 1993; Epp, 

1950; Fry, 1951; LOOW, 1982).

Current knowledge of the AEC-related uranium work at TAM is based on two work operations. The 

first operation is documented by air samples and surface contamination survey reports for uranium 

compound reduction activities performed July 10-11, 1956. The survey records indicate that uranium 

samples in several different chemical forms were processed at TAM. NIOSH currently has no 

information on the source of the samples or for whom this work was conducted (Health and Safety 
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Division, 1956). Based on the description of the activity, the operation appeared to be only a 

laboratory test. This work took place in the Building 103 Furnace Room and the Uranium Chemistry 

Laboratory. 

The second operation is documented in a correspondence that indicates that in January 1955, the AEC 

Health and Safety Laboratory (HASL) requested that Mallinckrodt Chemical Works ship uraniumcontaminated scrap to TAM for what is described as “AEC melt requirements.” HASL requested 40 

pounds of uranium-contaminated scrap stainless steel and 30 pounds of uranium-contaminated scrap 

aluminum, all cut into 3-inch by 3-inch squares (the stainless steel was approximately 1/4-inch thick; 

the aluminum was between 1/16-inch and 1/4-inch thick) (Klevin, 1955). An April 1956 journal 

article describes a pilot study by Klevin and Harris of the HASL in which decontamination of small 

quantities of uranium-contaminated nickel, stainless steel, copper, and aluminum scrap was performed 

by melting the material in a high-frequency furnace (Klevin, 1956). A citation in the article indicates 

that Titanium Alloys Manufacturing and American Smelting and Refining (Central Research 

Laboratory) “cooperated in processing the metal.” Based on the 1955 request for steel and aluminum, 

it can be deduced that the decontamination by melting of these two materials was performed at 

Titanium Alloys Manufacturing. 

Interest in the decontamination of scrap metals by melting occurred after a study conducted by the 

New York Operations Office (Blatz, 1951) reported that uranium contamination was reduced in 

contaminated scrap metal. This observation allowed for the shipment of 2400 tons of contaminated 

scrap metal to Diamond Magnesium between 1952 and 1953 (Diamond, 1990). 

The pilot study at TAM was performed by the HASL to demonstrate this process and determine the 

health and safety implications. Full-scale operation of the melting process demonstrated at TAM was 

performed by National Lead of Ohio at Knoxville Iron between 1957 and 1958 (Knoxville, 1958) and 

by Y-12 at Oak Ridge Processing Company in 1958 (Oak Ridge, 1974). The quantity of material 

processed was 6000 tons of scrap metal at Knoxville Iron and 27,000 tons at the Oak Ridge 

Processing Company. 

Source: Leigh, 1979 

Figure 5-1: Titanium Alloys Manufacturing Complex at Niagara Falls, NY 
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5.2 Radiological Exposure Sources from TAM Operations 

Uranium work at TAM is documented by air samples and surface contamination survey reports for 

activities performed between July 10 and 11, 1955. These documents describe the activity performed 

as reduction of uranium ore and uranium compounds. The “uranium ore” description is indicated on a 

removable contamination report; the accompanying air monitoring report contains a description of the 

processed compound and indicates it to be UO2. For this reason, the processing of uranium ore is not 

believed to have occurred at TAM. Additional compounds listed on the sheets were U02, UF4 and 

UF6. No information was located on the source of these materials or the reason for the sampling; 

however, based on the quantity of material mentioned (in the case of UF4, three grams), the activities 

appear to be bench-scale testing (Health and Safety Division, 1956). 

Additional work with uranium was indicated in a 1955 correspondence from the Atomic Energy 

Commission (AEC) Health and Safety Laboratory directing Mallinckrodt Chemical Works to ship 

uranium-contaminated scrap metal (40 pounds of steel and 30 pounds of aluminum) to TAM. The 

documentation lists the purpose to be for “AEC melt requirements.” Specific direction was provided 

on the size and shape of the material (3-inch by 3-inch squares; the stainless steel was approximately 

1/4-inch thick; the aluminum was between 1/16-inch and 1/4-inch thick) (Klevin, 1955). 

Correspondence between TAM and the AEC indicated an interest by TAM in processing scrap 

thorium. An AEC license for possession of 10 pounds of thorium was issued in 1955 to process scrap 

thorium materials. However, additional correspondence indicates that the AEC did not agree to 

furnish thorium as requested, but agreed to sell ten pounds of thorium to TAM if TAM submitted an 

application for it to be used for other purposes. The AEC indicated it had no interest in purchasing 

refined thorium from TAM. NIOSH has no reference indicating TAM ever received the 10 pounds of 

thorium. (Dowling, 1955; Roth, 1955; Urban, 1955). 

A general description of the activities at the TAM site is contained in a 1982 Nuclear Regulatory 

Commission (NRC) report (Leigh, 1979). The report states that the site was “authorized by License 

No. SMB-00211 to possess and use uranium and thorium as reagents in general chemical, physical, 

ceramic and metallurgical research and to store thorium fluoride and monazite ore.” One FUSRAP 

document (FUSRAP, 2001) states that License SMB-00211 is to have expired on June 1962; another 

NRC document indicates the license may have been extended beyond 1962. A 1979 radiological 

survey report stated that the manufacturing process “used beach sands containing naturally occurring 

radioactive materials for the production of rare earth chemicals.” The results of this survey indicate 

that the site met the NRC criteria for unrestricted release. There is no evidence that these activities 

occurred during the 1955-1956 period. The referenced license (SMB-00211) was issued on June 28, 

1961 (NRC License Tracking, 1999). 

5.2.1 Internal Radiological Exposure Sources from TAM Operations 

The primary source of internal radiological exposure resulting from TAM operations was inhalation 

and/or ingestion of uranium contained in uranium compounds and scrap materials. 
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5.2.1.1 Uranium 

The radiological hazard presented by uranium metal or compounds results primarily from alpha 

particles emitted by U-238 (4.15 MeV and 4.20 MeV) and its isotopes U-235 (4.37 MeV, 4.40 MeV, 

and 4.58 MeV) and U-234 (4.72 MeV and 4.77 MeV). Naturally-occurring uranium is 0.71% (w/w) 

U-235 and 0.0055% (w/w) U-234. It was reported (Klevin, 1956) that the material melted at Titanium 

Alloys Manufacturing was ‘natural uranium.’ 

It is also known that some AEC facilities were involved in processing uranium recovered from spent 

nuclear fuel. This material contained trace amounts of transuranic radionuclides which could have 

been concentrated during the refining process, thereby presenting an internal dose hazard. Since the 

dates of operation (1955-1956) are after the introduction of recycled uranium into the AEC complex, 

recycled uranium is assumed to be present in the material processed at the TAM site. 

Other alpha-emitting radionuclides occur naturally as part of the U-238 decay process; however, these 

would have been removed during the processing of uranium feed materials to generate the uranium 

compounds present at TAM. Sufficient time would not have elapsed to allow in-growth of these 

progeny to appreciable activities such that an additional hazard would have been posed to site 

personnel. 

5.2.1.2 Recycled Uranium Contaminants (Np-237, Pu-239) 

Based on the timeframe, the uranium source term processed at TAM during the period under 

evaluation might have contained recycled uranium. Recycled uranium might have been processed at 

TAM during the period under evaluation. Based on a review of recycled uranium contaminants at 

Hanford and Fernald, estimates of contaminants that might have contributed the most to internal doses 

are shown in Table 5-1. The activity fractions shown in Table 5-1 are based on the specific activity of 

depleted uranium, which increases the proportion of the contaminants by activity. The contaminant 

level for depleted uranium overestimates the contaminants in uranium of normal enrichment by about 

40%. 

Table 5-1: Estimated Contaminant Activity Fractions in Recycled, Depleted U Source Term

(pCi contaminant per pCi uranium)

Uranium Plutonium-239 Neptunium-237 Technecium-99 Thorium-232 Thorium-228

1 0.00246 0.00182 0.379 2.73 E -06 2.73 E -06

Source: Battelle-TBD-6000, Table 3.2 

5.2.2 External Radiological Exposure Sources from TAM Operations 

The primary source of external radiological exposure resulting from TAM operations was exposure to 

gamma and beta radiation emitted from uranium and associated short-lived progeny. 
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5.2.2.1 Photon 

The majority of the photons from natural uranium metals are in the 30-250 keV energy range. Solid 

uranium objects provide considerable shielding of the lower-energy photons and harden the spectrum, 

causing the majority of the photons emitted from a solid uranium object (such as a billet or rod) to 

have energies greater than 250 keV. While it is recognized that solid uranium sources will have a 

hardened photon spectrum, exposure to a thin layer of uranium on a surface will result in a larger 

fraction of exposure to lower-energy photons (Battelle-TBD-6000). 

Table 5-2 shows the primary isotopes and photon energies associated with the recovery and clean-up 

of uranium. Exposure to these photons was possible during the period under evaluation from direct 

radiation during metal-handling and to submersion in metal-contaminated air. 

Table 5-2: Principal Radiation Emissions from Natural U and Its Short-Lived Decay Products

Radionuclide Half-life Beta Energy (MeV Max) Photon (x or γ) Energy (MeV)

U-238 4.468 x 109years None x: 0.013 (8.8%)

Th-234 24.1 days 0.096 (25%) x: 0.013 (9.6%)

0.189 (73%) γ: 0.063 (3.8%)

γ: 0.093 (5.4%)

Pa-234m 1.17 minutes 2.28 (98.6%) γ: 0.765 (0.2%)

~1.4 (1.4%) γ: 01.001 (0.6%)

U-235 7.038 x 108years None x: 0.013 (31%)

x: 0.090-0.105 (9.3%)

γ: 0.144 (10.5%)

γ: 0.163 (4.7%)

γ: 0.186 (54%)

γ: 0.205 (4.7%)

Th-231 25.5 hours 0.206 (15%) x: 0.013 (71%)

0.288 (49%) γ: 0.026 (14.7%)

0.305 (35%) γ: 0.084 (6.4%)

U-234 244,500 years None x: 0.013 (10.5%)

γ: 0.053 (0.2%)

Source: Battelle-TBD-6000, pdf p. 20. The table shows the principal radiation emissions from natural uranium and its 

short-lived decay products that were of concern for external radiation (not including bremsstrahlung). 

5.2.2.2 Beta 

Table 5-2 shows the principal beta emitters and their energies for the uranium present at TAM. As 

indicated in this table, there are a significant number of high-energy beta radiations that represent a 

shallow dose exposure concern to site workers. Workers who handled the uranium would have 

received shallow dose exposures. The primary exposure areas would have been the hands and 

forearms, the neck and face, and other areas of the body that might not have been covered. 
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5.2.2.3 Neutron 

Based on the type and quantity of material present at TAM, neutrons could have arisen from the α-n 

reaction with light elements, interactions with the oxides, and through spontaneous fission. Data 

provided in Battelle-TBD-6000 show that any neutron dose rate would be negligible compared to 

beta/gamma dose rates in dose calculations. 

5.2.3 Incidents 

The information available to NIOSH gives no indication of incidents occurring at the site during the 

period under evaluation. The petitioner describes a time when the facility was vacuumed and there 

were individuals monitoring with a Geiger counter. The description of this event is consistent with 

monitoring which may occur during routine decontamination activities and, as such, is not considered 

by NIOSH to be indicative of an off-normal incident. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the Titanium Alloys Manufacturing class under evaluation. 

6.1 Available TAM Internal Monitoring Data 

No internal monitoring data are available to NIOSH for the period under evaluation. 

6.2 Available TAM External Monitoring Data 

No external monitoring data are available to NIOSH for the period under evaluation. 

6.3 Other Available Data 

Air Sample Data 

A limited number of air samples were located for the period under evaluation, as shown in Table 6-1. 

These samples were taken in both the Uranium Chemistry Laboratory and the Building 103 Furnace 

Room. 
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Table 6-1: TAM Air Monitoring Data

Location Sample 

Date

Sample 

Number

Sample Description Result

(dpm/m3)

Uranium Chemistry Lab 7/10/1956 7376 GA in front of reactor section of lab hood 

during apparatus warm-up period. Approx. 3 

grams of UF4 in furnace.

4

7377 GA In front of condenser & scrubber section 

of hood during same period as above.

ND

7378 GA Same location as 7376 sample during 

fluorination of UF4 sample (20 min).

ND

7379 GA Same location as 7377 during fluorination 

of UF4 sample.

1

7380 GA In front of reactor section of lab hood 

during heating of condenser.

ND

7381 GA In front of condenser section of lab hood 

during above period.

ND

7382 GA Same location as 7380 during blowing 

and precipitating of UF6 with NAOH.

ND

7383 GA Simultaneous with 7382, sample location 

as 7381.

ND

Building 103 Furnace Room 7/11/1956 7392 GA induction furnace area during period 

while furnace was charged with UO2.

2

7393 GA continuation of 7392. 3

7394 GA continuation of 7393. 6

Source: Health and Safety Division, 1956 

In addition to the aforementioned air sample datasheets, a description of airborne radioactivity levels 

during the processing of scrap metal was provided by Klevin in the report on the melting operation 

(Klevin, 1956). This report indicates that airborne radioactivity levels were less than 10 dpm/m3

in all 

but one sample collected during melting operations. The one high sample showed an air concentration 

of 80 dpm/m3

, For perspective, air dust measurements taken during the full-scale operations described 

Section 5.1 ranged from 9 to 318 dpm/m3

at Knoxville Iron (Knoxville, 1958), and from <1 to 17 

dpm/m3 at the Oak Ridge Processing Company (Oak Ridge, 1974).

Surface Contamination Data 

A limited number of workplace contamination samples were located for the period under evaluation, 

as shown in Table 6-2. These samples were taken in the Building 103 Furnace Room. 
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Table 6-2: TAM Surface Contamination Data

Location Sample 

Date

Sample 

Number

Sample Description Result

(dpm/100 cm2)

Building 103 Furnace Room 7/11/1956 7384 Floor, center aisle near arc furnace. 16

7385 Floor, center aisle between arc furnace 

and induction furnace

23

7386 Floor, near induction furnace. 27

7387 Scale, by induction furnace. 5

7388 Side of induction furnace panel. 520

7389 Large tool box top near south wall 39

7390 Work bench top north end of room 12

7391 Lab bench top in Room 103 office 22

Source: Health and Safety Division, 1956 

Klevin reported the surface contamination present on materials entered into the scrap-metal melting 

activities conducted at TAM (Klevin, 1956), as shown in Table 6-3. 

Table 6-3: Surface Contamination Present on Materials Designated for Scrap Melting

Material Description Surface Contamination, dpm/100 cm2

( Total / Removable)

Minimum Maximum Average

Stainless Steel Top 1,800 / 58 8,750 / 97 375 / 42

Bottom 6,850 / 297 26,800 / 530 500 / 133

Remelt 100 / 10.5 120 / 15.7 75 / 8

Slag from Melt NR / 4.8 NR / 6.3 NR / 3.7

Aluminum Top 8,245 /50.9 18,000 / 94.3 1,530 / 10

Bottom 4,450 / 45.8 7,500 / 61.7 1,625 / 24.6

Remelt 3,870 / 10.4 6,800 / 13.7 2,000 / 3.3

Slag from Melt 5 / 17.1 6,500 / 20.9 3,700 / 13.1

NR = Not Reported 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH 

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 
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evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class as summarized in Section 7.5. 

This approach is discussed in DCAS’s SEC Petition Evaluation Internal Procedures which are 

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine: 

The sufficiency and reliability of the available data. (Section 7.1) 

The feasibility of reconstructing internal radiation doses. (Section 7.2) 

The feasibility of reconstructing external radiation doses. (Section 7.3) 

The bases for petition SEC-00190 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Titanium Alloys Manufacturing Data 

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

7.1.1 Internal Monitoring Data Pedigree Review 

While no internal monitoring data have been located, air monitoring and surface contamination data 

are available in the form of original data sheets and, as such, are primary data sources. Air monitoring 

and surface contamination data for scrap-metal melting was contained in a peer-reviewed journal 

article. Therefore, no additional pedigree review was performed for those data. 

7.1.2 External Monitoring Data Pedigree Review 

NIOSH did not locate any external monitoring data for the operational period under evaluation 

(January 1, 1955 through December 31, 1956). Therefore, a data sufficiency and pedigree evaluation 

is not possible for this data type for this period. 

7.2 Evaluation of Bounding Internal Radiation Doses at TAM 

The principal source of internal radiation doses for members of the class under evaluation was 

inhalation and ingestion of uranium and uranium progeny contained in dusts and fumes associated 

with the furnace operations. 
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The following subsections address the ability to bound internal doses, methods for bounding doses, 

and the feasibility of internal dose reconstruction. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation.

7.2.1.1 Airborne Levels 

Air samples were taken on two occasions: one set of samples in the Chemistry Lab, and another in the 

Building 103 Furnace Room. The maximum measured air concentration reported for uranium 

compound reduction activities was 6 dpm/m3

(see Table 6-1). Based on the reported background 

count rate, the minimum detectable air concentration would have been approximately 15 dpm/m3. 

This value is based on information in the air monitoring reports for background count rate (0.27 cpm), 

count time (15 minutes), counter efficiency (0.41), volume (0.2 m3), and filter collection efficiency 

(0.7) (Health and Safety Division, 1956). The average reported air concentration during the scrapmetal melting operations in the Furnace Room was reported as less than 10 dpm/m3

 with the 

maximum reported air concentration being 80 dpm/m3(Klevin, 1956). 

7.2.1.2 Alternative Data Sources for Bounding Internal Dose 

Available records indicate that the quantity of material processed at TAM was small. Sample data 

sheets for the operation in the Chemistry Laboratory indicate quantities in process of three grams 

(Health and Safety Division, 1956). While exact details are not available, it appears to be a benchscale test operation. The total quantity of uranium scrap received totaled 70 pounds (40 pounds of 

contaminated steel and 30 pounds of contaminated aluminum) (Klevin, 1955). 

7.2.2 Evaluation of Bounding Residual Period Internal Doses 

TAM does not have a designated residual radiation period. Accordingly, evaluation of residual 

radiation period dose is not relevant. 

7.2.3 Methods for Bounding Internal Dose at TAM 

7.2.3.1 Methods for Bounding Operational Period Internal Dose 

NIOSH has determined that uranium internal exposures during the operational period can be bounded 

using measured air concentration data. For the uranium reduction operations conducted between July 

10, 1956 and July 11, 1956, the calculated MDA of 15 dpm/m3

for the associated air samples can be 

used (see Section 7.2.1.1). 

For the scrap-metal melting operations, the highest reported air result value of 80 dpm/m3can be used 

(Klevin, 1956). Klevin provides a description of the melting process and indicates that one melt was 

performed for each material type (Klevin 1956). Accordingly, melting operations are assumed to take 

place over a two day period in 1955, occurring after January 18, 1955 (the date the material was 

requested). Decontamination of the facility is assumed to last one work day. Based on the maximum 
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reported total surface contamination level from Table 6-3 (26,800 dpm/100 cm2), and the appropriate 

re-suspension factor of 1 E-5 m-1 representative of decontamination efforts (ORAUT-OTIB-0070), the 

calculated air concentration during decontamination activities is 26.8 dpm/m3. Based on this 

information and assumptions, a bounding internal inhalation dose estimate for scrap-melting 

operations in 1955 can be based on two days of exposure at 80 dpm/m3and one day at 27 dpm/m3. 

Dose from ingestion during this same period is determined based on these same air concentrations 

using the methodology in OCAS-TIB-009. 

Tables 7.1 and 7.2 provide a summary of the intake quantities associated with the air sample 

information reported above. Doses from scrap-melting operations are assigned in the year 1955, and 

doses from uranium compound reduction operations are assigned in the year 1956. 

Intakes are assigned from scrap-melting operations to workers with covered employment in the period 

January 18, 1955 through December 31, 1955. Intakes are assigned from uranium compound 

reduction operations to workers with covered employment on July 10 and 11, 1956. 

Table 7-1: Estimated Annual Inhalation Intake Quantity for TAM

Activity Period

Total Annual Intake 

(pCi)

Uranium Pu-239 Np-237 Tc-99 Th-232 Th-228

Scrap 

Melting 1955 8.1E+02 2.0E+00 1.5E+00 3.1E+02 2.2E-03 2.2E-03

Uranium 

Compound 

Reduction

1956

(July 10-11) 1.3E+02 3.2E-01 2.4E-01 4.9E+01 3.5E-04 3.5E-04

Table 7-2: Estimated Annual Ingestion Intake Quantity for TAM

Activity Period

Total Annual Intake 

(pCi)

Uranium Pu-239 Np-237 Tc-99 Th-232 Th-228

Scrap

Melting 1955 1.7E+01 4.1E-02 3.1E-02 6.4E+00 4.6E-05 4.6E-05

Uranium 

Compound 

Reduction

1956

(July 10-11) 2.7E+00 6.6E-03 4.9E-03 1.0E+00 7.4E-06 7.4E-06

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

This evaluation concludes that internal dose at Titanium Alloys Manufacturing can be bounded using 

the air sample data reported during operations. 

Based on the assessment provided in this section, NIOSH’s conclusion is that reported air sample data 

provides a reasonable approach to bound internal dose for the operational period for all members of 
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the class under evaluation. NIOSH may choose to employ a more refined approach when 

reconstructing individual doses based on information associated with individual claims. NIOSH will 

use appropriate dose reconstruction methods, including best-estimate approaches that employ new 

details of site operations, if discovered, to complete individual dose reconstructions. 

7.3 Evaluation of Bounding External Radiation Doses at TAM 

The principal source of external radiation doses for members of the evaluated class was exposure to 

beta and gamma radiation emanating from uranium-bearing materials. The following subsections 

address the ability to bound external doses, methods for bounding doses, and the feasibility of external 

dose reconstruction. 

7.3.1 Evaluation of Bounding Process-Related External Doses 

NIOSH has not identified any external monitoring records or personal dosimetry data associated with 

the uranium processing that occurred during the period under evaluation. NIOSH has not been able to 

identify any radiation level surveys or area dose rate monitoring data for this time period. 

Information on the quantity of uranium present within the scrap metal processed at TAM can be used 

to bound the external dose from exposure to this material. The concentration of uranium in input 

scrap material and slag ranged from 0.3 μg/g to 83 μg/g for stainless steel, and 800 μg/g to 6500 μg/g 

for aluminum (Klevin, 1956). Based on the reported quantities of scrap metal shipped to TAM (30 lb. 

of aluminum and 40 lb. of stainless steel), the total amount of uranium contained in these materials 

would be 89 grams of U within the aluminum material and 1.5 grams of U within the stainless steel. 

7.3.2 Evaluation of Bounding Residual Period External Doses 

TAM does not have a designated residual radiation period. Accordingly, evaluation of residual 

radiation period dose is not relevant. 

7.3.3 TAM Occupational X-Ray Examinations 

Although no specific information regarding occupational medical dose has been identified for TAM, 

the dose associated with medical X-ray exams, if required as a condition of employment, can be 

bounded by using the assumptions in the complex-wide Technical Information Bulletin, Dose 

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

NIOSH believes this methodology supports its ability to bound the occupational medical X-ray doses 

for the TAM class under evaluation. 
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7.3.4 Methods for Bounding Operational Period External Dose at TAM 

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

Photon Dose 

Beta Dose 

Medical X-ray Dose (as applicable per Section 7.3.3) 

Photon Dose 

Although no external monitoring data are available to NIOSH for the TAM site, Table 6-1 of BattelleTBD-6000 can be used to bound the operational period photon dose. This table provides dose rates at 

the surface, one foot, and one meter from various uranium shapes. While not cited in the Battelle 

document, the corresponding material dimensions are presented in the research paper upon which the 

table was based (Anderson, 2005). The total quantity of uranium present within all of the TAM scrap 

material is indicated to be 90 grams. The smallest object modeled in Battelle-TBD-6000 (uranium 

slug) would contain a much higher mass of uranium (2000 gram). Based on this fact, the external 

dose to scrap-metal workers at TAM can be bounded using the dose rates at one foot from the slug 

listed in Table 6-1 of Battelle-TBD-6000. This value is 0.0524 mrem/hr. 

Combining the information above with the exposure scenarios described in Section 7.2.3.1, the dose 

rate at one foot can be applied during: 

the two days of melting operations in 1955; 

the one day of decontamination in 1955; and

the two days of uranium compound reduction operations in July 1956. 

The total doses would be 1.3 mrem in 1955 associated with the three-day exposure period for 

scrap-melting operations; and 1 mrem in 1956 associated with the two-day uranium compound 

reduction operations. 

Doses are assigned from scrap-melting operations to workers with covered employment in the period 

January 18, 1955 through December 31, 1955. Doses are assigned from uranium compound reduction 

operations to workers with covered employment on July 10 and 11, 1956. 

Beta Dose 

Although no external monitoring data are available to NIOSH for the TAM site, the methodology 

indicated above for photon exposure can be used to reconstruct the beta dose. Section 6.3 in BattelleTBD-6000 provides justification for the use of a factor of 10 multiplier to calculate beta exposure 

based on the photon dose at one foot. Using this relationship, the beta dose rate for TAM workers at 

one foot would be 0.524 mrad/hr. This beta dose rate results in 12.6 mrad in 1955 associated with the 

three-day exposure period for scrap-melting operations; and 8.4 mrad in 1956 associated with the twoday uranium compound reduction operations 
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Beta doses are assigned from scrap-melting operations to workers with covered employment in the 

period January 18, 1955 through December 31, 1955. Beta doses are assigned from uranium 

compound reduction operations to workers with covered employment on July 10 and 11, 1956. 

Medical X-ray Dose 

Although NIOSH has not located specific parameters associated with occupational medical X-rays 

(i.e., specific information on the X-ray devices), default values of entrance KERMA developed for the 

three most commonly-used occupational medical diagnostic procedures are available in ORAUTOTIB-0006. The ORAUT-OTIB-0006 values can be used to support bounding the medical X-ray 

dose for the time period under evaluation. These default values are upper-limit values developed from 

review of patient doses as reported in the literature, machine characteristics, and knowledge of X-ray 

procedures used during different time periods. These default values can be used in lieu of actual 

measurement data or entrance KERMA derived from technique factors to bound the occupational 

X-ray exposures for the TAM site. NIOSH believes this methodology supports its ability to bound 

occupational medical X-ray doses (reconstruct the medical X-ray dose with sufficient accuracy) for 

the operational period for the class under evaluation. 

7.3.5 External Dose Reconstruction Feasibility Conclusion 

This evaluation concludes that external dose reconstruction for personnel working during the 

operational period at Titanium Alloys Manufacturing is feasible. Using source term quantities and 

exposure rate modeling from Battelle-TBD-6000, external dose estimates are plausible and bounding 

for the TAM operational period. Based on its assessment of these doses, NIOSH concludes that these 

methods provide reasonable approaches to conservatively bound external doses for all members of the 

class under evaluation. NIOSH may choose to employ a more refined approach when reconstructing 

individual doses based on information obtained during the evaluation of individual claims. 

7.4 Evaluation of Petition Basis for SEC-00190 

The following subsections evaluate the assertions made on behalf of petition SEC-00190 for Titanium 

Alloys Manufacturing. 

7.4.1 Decontamination of the Research Area 

SEC-00190: The petitioner states that at one point the entire research area was vacuumed and 

afterwards was checked with a Geiger counter.

As discussed in Section 5.2.3, the description given is consistent with decontamination and survey 

efforts that were not uncommon in facilities like Titanium Alloys Manufacturing. The evaluated 

internal and external doses described in sections 7.2.3.1 and 7.3.4 of this evaluation report include the 

contribution from decontamination of the facility at the conclusion of activities. 
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7.4.2 Absence of Monitoring Data 

SEC-00190: The petitioner states that monitoring for external and internal radiation was not 

performed nor were workers at the facility informed of the presence of radioactive materials. 

NIOSH has identified sufficient TAM-specific air monitoring data to bound exposures at TAM. 

7.5 Summary of Feasibility Findings for Petition SEC-00190

This report evaluates the feasibility for completing dose reconstructions for employees at Titanium 

Alloys Manufacturing from January 1, 1955 through December 31, 1956. NIOSH found that the 

available monitoring records, process descriptions and source term data available are sufficient to 

complete dose reconstructions for the evaluated class of employees. 

Table 7-3 summarizes the results of the feasibility findings at Titanium Alloys Manufacturing for each 

exposure source during the time period January 1955 through December 1956.

Table 7-3: Summary of Feasibility Findings for SEC-00190

January 1, 1955 through December 31, 1956

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible

Internal X

 - U X

 - Recycled U Contaminants X

External X

 - Gamma X

 - Beta X

 - Neutron N/A N/A

 - Occupational Medical X-ray X

As of January 14, 2012, a total of 12 claims have been submitted to NIOSH for individuals who 

worked at Titanium Alloys Manufacturing during the period under evaluation in this report. Dose 

reconstructions have been completed for 12 individuals (100%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00190

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

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

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

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

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

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

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 
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the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

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

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

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

employees in the SEC. 

NIOSH has sufficient information on the types and quantities of material processed at Titanium 

Alloys Manufacturing as well as sufficient air monitoring data to bound internal and external 

exposures. NIOSH’s evaluation determined that it is feasible to estimate radiation dose for members 

of the NIOSH-evaluated class with sufficient accuracy based on the sum of information available from 

available resources. Therefore, a health endangerment determination is not required. 

9.0 Class Conclusion for Petition SEC-00190 

Based on its full research of the class under evaluation, NIOSH found no part of said class for which it 

cannot estimate radiation doses with sufficient accuracy. This class includes all employees who 

worked in any area or building at Titanium Alloys Manufacturing from January 1, 1955 through 

December 31, 1956. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00190. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation. 
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10.0 References 

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

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

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

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

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

19392

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

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

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

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

Program Act of 2000, as amended 

Anderson, 2005, Bremsstrahlung Doses from Natural Uranium Ingots, J. L. Anderson and N. E. 

Hertel; Radiation Protection Dosimetry (2005) Vol. 115, No. 1-4, pp. 298-301; 2005; SRDB Ref ID: 

29254 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Rev. 1; Battelle; June 17, 2011; SRDB Ref ID: 30671 

Blatz, 1951, Investigation of the Potential Hazard in Releasing Scrap Steel Contaminated with 

Uranium to Commercial Channels, H. Blatz, J. H. Harley, and M. Eisenbud; NYO-1558; U.S. Atomic 

Energy Commission, New York Operations Office; June 15, 1951; SRDB Ref ID: 107133 

Collins, 1993, Development and Testing of Ion Exchangers for Treatment of Liquid Wastes at Oak 

Ridge National Laboratory, J. L. Collins; March 1993; SRDB Ref ID: 101802 

DCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 1, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; April 15, 2011; 

SRDB Ref ID: 94768 

DCAS-TKBS-0002, Technical Basis for Atomic Energy Operations at Blockson Chemical Company, 

Joliet, Illinois, Rev. 03; NIOSH Division of Compensation Analysis and Support; December 20, 2010; 

SRDB Ref ID: 91205 

Diamond, 1990, Scrap Steel to Diamond Magnesium, OTS Note from E. Mitchelle to A. Williams; 

U.S. Department of Labor; November 19, 1990; SRDB Ref ID: 60945 

Dowling, 1955, Reply to Thorium Processing at Titanium Alloy Manufacturing, F. R. Dowling; Feed 

Materials Division; November 25, 1955; SRDB Ref ID: 10488, pdf pp. 59-60
SEC-00190 02-13-12 Titanium Alloys Manufacturing 

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Epp, 1950, Shipping Schedule, F. J. Epp; Tonawanda Sub-Office; May 23, 1950: SRDB Ref ID: 

10488, pdf p. 83 

Fry, 1951, Procurement of Zirconium Tetrachloride, H. B. Fry; New York Operations Office; June 

13, 1951; SRDB Ref ID: 10488, pdf p. 73

FUSRAP, 2001, FUSRAP Sites Review, Author Unknown; April 18, 2001; SRDB Ref ID: 42536 

Health and Safety Division, 1956, Analytical Data Sheet, Analytical Dept. – Health and Safety 

Division, 1956; SRDB Ref ID: 10488, pdf pp. 53-56

Klevin, 1955, Uranium Contaminated Stainless Steel and Aluminum Scrap, P. B. Klevin; Industrial 

Hygiene Branch; January 18, 1955; SRDB Ref ID: 9236, pdf p. 42

Klevin 1956, Remelting May Permit Reclaiming Uranium Contaminated Metals, Nucleonics, April 

1956; SRDB Ref ID: 106926, pdf pp. 93-96 

Knoxville, 1958, Trip Report to Knoxville Iron Company, Knoxville, Tennessee on March 6, 1958, J. 

A. Quigley, National Lead Company; March 11, 1958; SRDB Ref ID: 43060, pdf pp. 21-22 

Leigh, 1979, Summary of Radiological Survey of NL Industries Niagara Falls Plant, D. W. Leigh; 

Spring 1979; SRDB Ref ID: 101488, pdf p. 10 

Leiton, 2011, DOL Determination on TAM Covered Years to be Revised and Limited to 1955 through 

1956, R. P. Leiton, U.S. Dept. of Labor, Division of Energy Employees Occupational Illness 

Compensation; October 4, 2011; SRDB Ref ID: 106600 

LOOW, 1982, Background and Resurvey Recommendations for the Atomic Energy Commission 

Portion of the Lake Ontario Ordnance Works, ATR-82 (7963-04)-1; The Aerospace Corporation; 

August 1982; SRDB Ref ID: 61031, pdf p. 44 

NRC License Tracking, 1999, Information Regarding Terminated License Number SMB-00211, 

Nuclear Regulatory Commission (NRC) Terminated License Tracking System, August 10, 1999; 

SRDB Ref ID: 106614 

Oak Ridge, 1974, Health Physics Studies of Smelting Uranium-Contaminated Ferrous Metal Scrap, 

letter and survey from L. R. Phillips (Union Carbide) to W. E. Shaw (National Lead); June 21, 1974; 

SRDB Ref ID: 85458 

OCAS-TIB-009, Estimation of Ingestion Intakes, Rev. 0, Technical Information Bulletin, NIOSH 

Office of Compensation Analysis and Support; April 13, 2004; SRDB Ref ID: 22397 

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

Procedures, Rev. 04; ORAU Team Dose Reconstruction Project for NIOSH; June 20, 2011; SRDB 

Ref ID: 98147 
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ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities, Rev. 00, ORAU Team Dose Reconstruction Project for NIOSH; March 

10, 2008; SRDB Ref ID: 41603 

ORAUT-OTIB-0079, Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays 

Administered Off Site, Rev. 00; ORAU Team Dose Reconstruction Project for NIOSH; January 3, 

2011; SRDB Ref ID: 89563

Roth, 1955, Request for Thorium Metal, H. M. Roth; Research and Development Division; December 

5, 1955; SRDB Ref ID: 8649, pdf pp. 21-22 

S. Cohen & Associates, 1997, Technical Support Document: Evaluation of the Potential for Recycling 

of Scrap Metals from Nuclear Facilities, Volume 1 of 3; July 15, 1997; SRDB Ref. ID: 88799 

Survey, Date Unknown, Intensive Level Survey Historic Resources – Downtown Neighborhood City 

of Niagara Falls: Phase I, CBCA PN 02-036, Author Unknown, Date Unknown; SRDB Ref ID: 

101809, pdf pp. 36 and 37 

Urban, 1955, Production and Sale of Zirconium and Titanium at the National Lead Division of 

Titanium Alloy Manufacturing, S. F. Urban, Titanium Alloy Mfg, Division; October 26, 1955; SRDB 

Ref ID: 10488, pdf pp. 61-62 
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SEC-00190 02-13-12 Titanium Alloys Manufacturing 

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Attachment 1: Data Capture Synopsis 

Table A1-1: Data Capture Synopsis for Titanium Alloys Manufacturing

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Primary Site/Company Name: Titanium Alloys 

Manufacturing; AWE 1955-1956

[Name and title redacted], National Lead Industries; [Phone 

no. redacted]

Alternate Site Names: 

Humphreys Gold Co. 

Titanium Alloys Mfg Co, Div. Of National Lead 

Titanium Alloy Metals

Titanium Pigment Co.

Physical Size of the Site: 35 Acres

Site Population: Undetermined

No relevant documents identified. 01/18/2012 0

State Contacted: [Name and title redacted], Bureau of 

Environmental Radiation Protection [Phone No. redacted]

No relevant documents identified. 01/03/2012 0

Department of Labor / Paragon Background and resurvey recommendations for the AEC portion of the 

Lake Ontario Ordnance Works, weekly and monthly reports.

12/30/2008 6

DOE Germantown Thorium information and site history. 09/11/2002 1

DOE Legacy Management - Grand Junction Office Commercial facilities used by National Lead Company of Ohio, final 

voucher for Titanium Alloys Manufacturing, FUSRAP elimination 

recommendation, monazite dredging operations, NRC Region 1 

inspection report with release survey, raw material feed for FMPC 

Thorium Plant, request for thorium scrap, shipment documents, trip 

reports, source material license C-3413 for thorium metal, and a 

Titanium Alloy Manufacturing Division progress report.

08/22/2011 27

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

Proposed work for New Brunswick Laboratory and a summary 

technical report.

05/21/2008 3

DOE Office of Scientific and Technical Information 

(OSTI)

A process development report. 02/11/2011 1

Florida Archives No relevant documents identified. 01/17/2012 0

Internet Report on Residual Radioactive and Beryllium Contamination at 

Atomic Weapons Employer Facilities and Beryllium Vendor Facilities 

(December 2006).

01/25/2007 1
SEC-00190 02-13-12 Titanium Alloys Manufacturing 

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Table A1-1: Data Capture Synopsis for Titanium Alloys Manufacturing

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - Defense Technical Information Center (DTIC) No relevant documents identified. 09/30/2011 0

Internet - DOE Comprehensive Epidemiologic Data 

Resource (CEDR)

No relevant documents identified. 11/29/2011 0

Internet - DOE Hanford Declassified Document Retrieval 

System (DDRS)

No relevant documents identified. 09/14/2011 0

Internet - DOE Legacy Management Considered Sites DOE response for information concerning subcontractors at Fernald. 

NOTE: 2 documents were added by Site Association Review. 

09/14/2011 2

Internet - DOE National Nuclear Security Administration 

(NNSA) - Nevada Site Office

No relevant documents identified. 09/14/2011 0

Internet - DOE OpenNet Monthly status reports. NOTE: 2 documents were added by Site 

Association Review. 

09/14/2011 2

Internet - DOE OSTI Energy Citations No relevant documents identified. 09/14/2011 0

Internet - DOE OSTI Information Bridge Quarterly reports, contamination of molten thorium and ion exchanger 

development and testing. NOTE: 2 documents were added by Site 

Association Review. 

09/14/2011 3

Internet - Google The Bomb that fell on Niagara, potentially contaminated sites list, 

radiation exposure report details, and an Adirondack chronology.

09/14/2011 11

Internet - Health Physics Journal No relevant documents identified. 11/29/2011 0

Internet - Journal of Occupational and Environmental 

Hygiene

No relevant documents identified. 11/29/2011 0

Internet - National Academies Press (NAP) No relevant documents identified. 09/14/2011 0

Internet - NRC Agencywide Document Access and 

Management (ADAMS) 

A FUSRAP sites review. NOTE: 3 documents were added by Site 

Association Review. 

09/14/2011 3

Internet - USACE/FUSRAP No relevant documents identified. 09/14/2011 0

Internet - US Transuranium and Uranium Registries No relevant documents identified. 09/14/2011 0

National Archives and Records Administration (NARA) -

Atlanta

Purchase Order WCX-A-16 Covering Zirconium Tetrachloride 

Anhydrous for Y-12 Plant.

08/16/2011 1

National Archives and Records Administration (NARA) -

Kansas City

Love Canal and Niagara Frontier Region history. 08/14/2008 1

Unknown Correspondence files, New York Operations Office monthly and 

weekly reports, production processes at Titanium Alloys 

Manufacturing, radiological surveys, receipts and shipment 

documentation, and Westinghouse Nuclear Fuels Division and 

Westinghouse Atomic Power Development Plant information.

09/11/2002 10

TOTAL 72
SEC-00190 02-13-12 Titanium Alloys Manufacturing 

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Table A1-2: Databases Searched for Titanium Alloys Manufacturing

Database/Source Keywords / Phrases Hits Selected

NOTE: Database search terms employed for each of the databases listed below are available

in the Excel file called “Titanium Alloys Manufacturing Rev 00, (83.13) 01-20-12

Defense Technical Information Center (DTIC)

https://www.dtic.mil/

COMPLETED 09/30/2011

See Note above 0 0

DOE CEDR

http://cedr.lbl.gov/

COMPLETED 11/29/2011

See Note above 0 0

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 09/14/2011

See Note above 0 0

DOE Legacy Management Considered Sites

http://csd.lm.doe.gov/

COMPLETED 09/14/2011

See Note above 130 0

DOE NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 09/14/2011

See Note above 0 0

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 09/14/2011

See Note above 2 0

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 09/14/2011

See Note above 50 0

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 09/14/2011

See Note above 28 1

Google

http://www.google.com

COMPLETED 09/14/2011

See Note above 281,402 11

HP Journal

http://journals.lww.com/health-physics/pages/default.aspx

COMPLETED 11/29/2011

See Note above 2 0
SEC-00190 02-13-12 Titanium Alloys Manufacturing 

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Table A1-2: Databases Searched for Titanium Alloys Manufacturing

Database/Source Keywords / Phrases Hits Selected

Journal of Occupational and Environmental Health 

http://www.ijoeh.com/index.php/ijoeh

COMPLETED 11/29/2011

See Note above 0 0

National Academies Press

http://www.nap.edu/

COMPLETED 09/14/2011

See Note above 21 0

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/web-based.html

COMPLETED 09/14/2011

See Note above 4 0

USACE/FUSRAP

http://www.lrb.usace.army.mil/fusrap/

COMPLETED 09/14/2011

See Note above 0 0

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 09/14/2011

See Note above 0 0

Table A1-3 OSTI Documents Requested for Titanium Alloys Manufacturing

Document Number Document Title Requested

Date

Received

Date

No documents requested.