ORAU Lead Technical Evaluator: Mike Domal ORAU Review Completed By: Dan Stempfley 

SEC Petition Evaluation Report
 

Petition SEC-00105 

Report Rev #:_ 0_ Report Submittal Date: October 3, 2008 

Petitioner Class Definition 

All individuals who worked in any location at the General Steel Industries site, located on 1417 State Street, 

Granite City, Illinois, from January 1, 1953 through December 31, 1966, and/or during the residual period from 

January 1, 1967 through December 31, 1992. 

Class Evaluated by NIOSH 

All individuals who worked in any location at the General Steel Industries site, located on 1417 State Street, 

Granite City, Illinois, from January 1, 1953 through June 30, 1966, and/or during the residual radiation period 

from July 1, 1966 through December 31, 1992. 

Subject Expert(s): Louise Buker, Ray Clark, Mike Domal, and Joe Guido 

Site Expert(s): NA 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Qualification Date 

DOE/AWE Facility Name 

SEC-00105 83.13 May 15, 2008 General Steel Industries 

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 

NA NA NA NA 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

NA NA 

Peer Review Completed By: [Signature on file] 

Dave Allen 

10/03/2008 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

10/03/2008 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry Elliott 

10/03/2008 

Date 
SEC-00105 10-03-08 Final General Steel Industries 

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SEC-00105 10-03-08 Final General Steel Industries 

Evaluation Report Summary: SEC-00105, General Steel Industries 

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-00105, qualified on May 15, 2008, requested that NIOSH consider the following class: 

All individuals who worked in any location at the General Steel Industries site, located on 1417 State 

Street, Granite City, Illinois, from January 1, 1953 through December 31, 1966, and/or during the 

residual period from January 1, 1967 through December 31, 1992. 

Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH modified the petitioner-requested class. NIOSH evaluated 

the following class: All individuals who worked in any location at the General Steel Industries site, 

located on 1417 State Street, Granite City, Illinois, from January 1, 1953 through June 30, 1966, 

and/or during the residual period from July 1, 1966 through December 31, 1992. 

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

Based on its complete research of the class under evaluation, NIOSH has assessed Battelle-TBD6000, Battelle-TBD-6000 Appendix BB, the most recently discovered personnel external monitoring 

data, monitoring data bounding operations from other similar sites, and modeling data associated with 

evaluation of the source term at General Steel Industries. 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. Information available from the site profile and additional resources is sufficient to 

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

proposed 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 proposed class. 

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Table of Contents 

Evaluation Report Summary: SEC-00105, General Steel Industries ...................................................... 3
 

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

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

3.0 SEC-00105 General Steel Industries 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 ........................................................... 10 

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

4.2 Technical Information Bulletins (TIBs) .............................................................................. 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 General Steel Industries Plant and Process Descriptions .................................................... 13 

5.2 Radiological Exposure Sources from General Steel Industries Operations ........................ 15 

5.2.1 Internal Radiological Exposure Sources from General Steel Operations ............... 15 

5.2.1.1 Uranium.................................................................................................... 16 

5.2.1.2 Recycled Uranium .................................................................................... 16 

5.2.1.3 Fission Products........................................................................................ 16 

5.2.1.4 Activation Products .................................................................................. 16 

5.2.2 External Radiological Exposure Sources from General Steel Operations .............. 16 

5.2.2.1 Photon....................................................................................................... 18 

5.2.2.2 Beta........................................................................................................... 18 

5.2.2.3 Neutron ..................................................................................................... 18 

5.2.3 Incidents .................................................................................................................. 18 

5.2.4 Residual Radioactivity Period at the General Steel Industries Site......................... 19
 

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 19 

6.1 Available General Steel Industries Internal Monitoring Data ............................................. 19 

6.2 Available General Steel Industries External Monitoring Data ............................................ 20
 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 20 

7.1 Pedigree of General Steel Industries Data........................................................................... 21 

7.1.1 Internal Monitoring Data Pedigree Review............................................................. 21 

7.1.2 External Monitoring Data Pedigree Review............................................................ 21 

7.2 Evaluation of Bounding Internal Radiation Doses at General Steel Industries................... 22 

7.2.1 Evaluation of Bounding Process-Related Internal Doses........................................ 22 

7.2.2 Evaluation of Bounding Residual Period Internal Doses ........................................ 23 

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7.2.3 Methods for Bounding Internal Dose at General Steel ........................................... 23 

7.2.3.1 Methods for Bounding Operational Period Internal Dose........................ 23 

7.2.3.2 Methods for Bounding Residual Period Internal Dose............................. 24 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 24 

7.3 Evaluation of Bounding External Radiation Doses at General Steel Industries ................. 25 

7.3.1 Evaluation of Bounding Process-Related External Doses....................................... 25 

7.3.1.1 Personnel Dosimetry Data ........................................................................ 25 

7.3.2 Evaluation of Bounding Residual Period External Doses ....................................... 28 

7.3.3 General Steel Occupational X-Ray Examinations .................................................. 29 

7.3.4 Methods for Bounding External Dose at General Steel .......................................... 29 

7.3.4.1 Methods for Bounding Operational Period External Dose....................... 29 

7.3.4.2 Methods for Bounding Residual Period External Doses.......................... 30 

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 31 

7.4 Evaluation of Petition Basis for SEC-00105 ....................................................................... 31 

7.4.1 Lack of Monitoring Data ......................................................................................... 31 

7.4.2 Underestimated External Dose Modeling ............................................................... 31 

7.4.3 Residual Contamination Dose ................................................................................. 32 

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation ...... 32 

7.6 Summary of Feasibility Findings for Petition SEC-00105.................................................. 32
 

8.0 Evaluation of Health Endangerment for Petition SEC-00105...................................................... 33
 

9.0 Class Conclusion for Petition SEC-00105 ................................................................................... 33
 

10.0 References .................................................................................................................................... 36 

Tables 

Table 4-1: No. of General Steel Claims Submitted Under the Dose Reconstruction Rule ................... 11 

Table 7-1: Summary of Feasibility Findings for SEC-00105 ............................................................... 32 

Figures 

Figure 5-1: General Steel Industries Plant Layout ................................................................................ 14 

Figure 5-2: Aerial Site Map of General Steel Industries ....................................................................... 15 

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SEC Petition Evaluation Report for SEC-00105
 

1.0 Purpose and Scope 

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

location at the General Steel Industries site, located on 1417 State Street, Granite City, Illinois, from 

January 1, 1953 through June 30, 1966, and/or during the residual period from July 1, 1966 through 

December 31, 1992. 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 Office of Compensation Analysis and Support’s (OCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

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.1 

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 

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 

1

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

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

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

(excluding aggregate work day requirements). 

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 to 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.2 

3.0 SEC-00105 General Steel Industries Class Definitions 

The following subsections address the evolution of the class definition for SEC-00105, General Steel 

Industries. When a petition is submitted by a claimant, the requested class definition is evaluated as 

submitted. If the available site information and data justify a change in the petitioner’s class 

definition, NIOSH will specify a modified class to be fully evaluated. After a complete analysis, 

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-00105, qualified on May 15, 2008, requested that NIOSH consider the following class 

for addition to the SEC: All individuals who worked in any location at the General Steel Industries 

site, located on 1417 State Street, Granite City, Illinois, from January 1, 1953 through December 31, 

1966, and/or during the residual period from January 1, 1967 through December 31, 1992. 

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

accurate dose reconstruction over time is impossible for the General Steel Industries workers in 

question. NIOSH deemed the following information and affidavit statements sufficient to qualify 

SEC-00105 for evaluation: 

The petition indicates that radiation exposures and radiation doses potentially incurred by 

members of the petitioner-requested class were not monitored either through personal 

monitoring or through area monitoring. Certain identified individuals did not wear, nor 

were they offered, radiation monitoring of any kind. The petition further states that no 

radiation monitoring of any kind was performed at the site. 

Some of the affidavit statements made in the petition include the following: 

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

available at http://www.cdc.gov/niosh/ocas. 

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•	 We were never given any type of badge or monitoring device to measure our exposure to 

radiation. 

•	 We were not monitored but were asked to leave certain areas prior to X-ray operations. 

•	 Not many precautions were taken in regard to protecting the workers at General Steel 

industries.
 

Concerns were also expressed about unmonitored employees working in and/or around the 

#10 Building, which was near the New Betatron building. 

Based on its research and data capture efforts related to General Steel Industries, NIOSH determined 

that it has access to film badge data for radiographers who worked at General Steel Industries during 

the time period under evaluation. However, NIOSH also determined that personnel internal and 

external monitoring records are not complete for all time periods or for all radiation energies. NIOSH 

concluded that there is sufficient documentation to support, for at least part of the proposed time 

period, the petition basis that internal and external radiation exposures were not monitored at General 

Steel Industries, 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 modified the petitioner-proposed class. The date for the 

end of the Atomic Energy Commission (AEC) work was based on the last Mallinckrodt purchase 

order requisition dated July 7, 1965 (Purchase Order, 1965), and is also relayed in the Formerly 

Utilized Sites Remedial Action Program (FUSRAP) Authority Determination from the Department of 

Energy (GSI, 1991). The associated purchase order covers services for the period from July 1, 1965 

through June 30, 1966, for the end of the operational period, for performing X-rays on uranium ingots. 

This end date is supported by the end of AEC-related operations in the St. Louis area (including the 

Mallinckrodt and Weldon Spring sites). The AEC Completion Report for the St. Louis area indicates 

that the AEC announced its plans to terminate St. Louis-area uranium production activities in April 

1966, with the subsequent shutdown of Uranium Division operations and placing the Weldon Spring 

site in a standby condition, which was followed by the termination of the AEC contract in early June 

1967 (Mallinckrodt, 1967). Therefore, NIOSH defined the following class for further evaluation: all 

individuals who worked in any location at the General Steel Industries site, located on 1417 State 

Street, Granite City, Illinois, from January 1, 1953 through June 30, 1966, and/or during the residual 

period from July 1, 1966 through December 31, 1992. 

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

Based on its research, NIOSH has obtained sufficient data to determine the facility layout, available 

source terms, site operations, and likely exposure scenarios. NIOSH also obtained film badge data for 

radiographers who worked at General Steel Industries from 1963 through 1974. Airborne monitoring 

data analyses compiled from other uranium metal handling facilities were also available (BattelleTBD-6000). 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. 

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4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

NIOSH identified and reviewed 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 personnel 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 provides process history information, information on 

personnel and area monitoring, radiation source descriptions, and references to primary documents 

relevant to the radiological operations at the site. As part of NIOSH’s evaluation detailed herein, it 

examined the following Site Profiles for insights into General Steel Industries operations or related 

topics/operations at other sites: 

•	 Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium Metals, BattelleTBD-6000 PNWD-3738; Rev. FO; December 13, 2006; SRDB Ref ID: 30671 (Battelle-TBD6000) 

•	 Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium Metals - 

Appendix BB General Steel Industries, Battelle-TBD-6000 Appendix BB; Rev. 0; June 25, 2007; 

SRDB Ref ID: 47713 (Battelle-TBD-6000 Appendix BB) 

4.2 Technical Information Bulletins (TIBs) 

A Technical Information Bulletin (TIB) is a general working document that provides guidance for 

preparing dose reconstructions at particular sites or categories of sites. NIOSH reviewed the 

following TIBs as part of its evaluation: 

•	 Battelle-TIB-5000: Default Assumptions and Methods for Atomic Weapons Employer Dose 

Reconstructions, Battelle-TIB-5000 PNWD-3741, Rev. 00; April 2, 2007; SRDB Ref ID: 32016 

(Battelle-TIB-5000) 

•	 OTIB: Estimating the Maximum Plausible Dose to Workers at Atomic Weapons Employer 

Facilities, Rev. 03 PC-2, ORAUT-OTIB-0004; December 6, 2006; SRDB Ref ID: 36191 

(ORAUT-OTIB-0004) 

•	 OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, Rev. 03 

PC-1, ORAUT-OTIB-0006; December 21, 2005; SRDB Ref ID: 20220 (ORAUT-OTIB-0006) 

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4.3 Facility Employees and Experts 

To obtain additional information, Sanford Cohen & Associates (SC&A) interviewed former 

employees of General Steel Industries on October 9, 2007. The meeting was arranged by SC&A and 

a spokesperson for former workers from General Steel Industries. The purpose of the meeting was to 

gather information for use in reviewing Battelle-TBD-6000 Appendix BB. In addition to the October 

9th meeting, one worker outreach meeting and two affidavit testimony meetings have been conducted 

with former employees of General Steel Industries: 

•	 August 21-22, 2006, General Steel Industries meeting in Collinsville, Illinois (Transcript, August 

21, 2006; Transcript, August 22, 2006; McKeel, 2006) 

•	 August 11, 2006, General Steel Industries affidavit testimony meeting held in East Alton, Illinois 

(Transcript, August 11, 2006) 

•	 July 7, 2006, General Steel Industries affidavit testimony meeting held in East Alton, Illinois 

(Transcript, July 7, 2006) 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (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 July 17, 2008) 

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

Description Totals 

Total number of claims submitted for dose reconstruction 238 

Total number of claims submitted for energy employees who meet the definition criteria for the class 

under evaluation (January 1, 1953 through June 30, 1966, and/or during the residual period from July 

1, 1966 through December 31, 1992) 

238 

Number of dose reconstructions completed for energy employees who meet the definition criteria for 

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

Department of Labor for final approval). 208 

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 11 

Note: 

* OCAS identified 11 claimants with dosimetry records. A review of the records indicated Battelle-TBD-6000 Appendix 

BB was favorable in each case. 

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

records could be obtained for the employee. Most dose reconstructions performed to date were 

completed prior to the availability of personnel monitoring records. Bounding external doses were 

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estimated based on modeled external exposure pathways derived from interview data, site operations, 

estimated exposure rates, and calculated exposure rates. Bounding internal doses were estimated 

based on airborne radioactivity data compiled from other uranium metal handling facilities (BattelleTBD-6000). External monitoring records are now available for some of the claimants, the results of 

which are much lower than the bounding estimates listed in Battelle-TBD-6000 Appendix BB 

(discussed further in Section 7.3). 

4.5 NIOSH Site Research Database 

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

evaluation of the proposed class. Seventy-eight documents in this database were identified as 

pertaining to General Steel Industries. These documents were evaluated for their relevance to this 

petition. The documents include historical background on purchase orders, levels of operation, film 

badge monitoring, survey reports, and equipment manuals. 

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 – 83.13, [Name One Redacted]; June 19, 2008; OSA Ref ID: 105333 (Name One, 2008) 

•	 Affidavit from [Name Two Redacted]; (no date); OSA Ref ID: 105333, p. 15 (Name Two, 

unknown date) 

•	 Affidavit from [Name Three Redacted]; February 9, 2008; OSA Ref ID: 105333, pp. 10-12 (Name 

Three, 2008) 

•	 Letter from [Name Three Redacted]; (no date); OSA Ref ID: 105333, pp. 13-14 (Name Three, 

unknown date) 

•	 Cleanup Criteria Information page; March 3, 2005; DOE; OSA Ref ID: 105333, p. 16 (DOE, 

2005) 

•	 Article: GSI’s Castings Division; (no author identified); (no date); OSA Ref ID: 105333, p. 17 

(Unknown author, unknown date-a) 

•	 Drawing: GSI map; (no author identified); (no date); OSA Ref ID: 105333, p. 18 (Unknown 

author, unknown date-b) 

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize both radiological operations at General Steel Industries from 

January 1, 1953 through June 30, 1966, as well as the potential radioactive material exposures during 

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the residual period from July 1, 1966 through December 31, 1992, 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 General Steel Industries Plant and Process Descriptions 

ATTRIBUTION: Section 5.1 was completed by Ray Clark, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

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

The General Steel Castings Corporation was incorporated in Delaware in December 1928, and was 

originally owned by the Baldwin Locomotive Works and American Steel Foundries. A bond issue 

was floated on June 21, 1929 to enable the company to acquire the Commonwealth Steel Corporation 

in Granite City, Illinois. Commonwealth Steel Corporation was consolidated with General Steel 

Castings in November 1929, becoming the Commonwealth Division of General Steel Castings. The 

company went through various acquisitions and expansions until 1961, when General Steel Castings 

formally changed its name to General Steel Industries, Inc. The General Steel Industries facility is 

located at 1417 State Street in southwest Granite City, Illinois, northeast of St. Louis, Missouri, and 

east of the Mississippi River. All of General Steel Industries’ operations were consolidated in Granite 

City in 1963, and operations continued there until the plant closed in 1973. For the purpose of this 

evaluation report, the name “General Steel Industries” (abbreviated as General Steel) is used to 

represent the Granite City, Illinois site (located at 1417 State Street) over the entire EEOICPA covered 

period for the purpose of evaluating radiological exposures and the ability to reconstruct radiological 

dose under this program (DOE, 2007). 

General Steel Industries, in Granite City, Illinois, performed quality control work for the AEC during 

the 1950s and 1960s. Based on available information, the site primarily supported AEC-related 

activities at the Mallinckrodt Chemical Company site from 1958 through 1966, but may have 

supported the AEC as early as 1953 (Unknown author, 1991, p. 5; Battelle-TBD-6000 Appendix BB; 

GSI, 1991). Utilizing two betatron machines, it performed X-rays on uranium ingots to detect 

metallurgical flaws in support of AEC-related activities at the Mallinckrodt Chemical Company 

(DOE, September 1992, p. 5). This work was performed in areas of the facility which were part of 

what was later known as the South Plant. The uranium ingots that were X-rayed at the site were 

cylindrical, 18 to 20 inches in diameter, approximately 18 inches long, and weighed up to 3,000 

pounds. At least some of the work was performed on Betatron slices, each of which was an 

approximately four-inch-thick slice taken from an ingot. Wherever this document refers to ingots, it is 

intended to mean ingots or betatron slices. In addition to AEC operations, the betatrons were also 

used commercially to detect flaws in metal castings (Battelle-TBD-6000 Appendix BB) during the 

same period of time (1953-1966). 

The X-ray quality control work on uranium ingots was performed on an as-needed basis, as indicated 

by Mallinckrodt Chemical Company purchase orders and associated cost limits, with no indication of 

the frequency or duration (DOE, September 1992, p. 5; Unknown author, 1991). Reasonable 

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estimates regarding the time that the betatrons were in service for both AEC and commercial 

operations each year can be made based on purchase orders and the associated securing of St. Louisarea activities by the AEC, information/documentation available to NIOSH (in its Site Research 

Database) regarding the use of the betatrons at the site, and information obtained from interviews with 

former General Steel Industries operators who worked at the site during the time period evaluated in 

this report (DOE, September 1992, p. 5; Unknown author, 1991; Mallinckrodt, 1967). 

Figure 5-1 depicts the overall General Steel Industries layout. The betatrons were located at the south 

end of the plant (identified as location numbers 35 and 36 in Figure 5-1). 

Figure 5-1: General Steel Industries Plant Layout 

1-General Office 

2-Plant Office 

3-Guard Office 

4-Personnel Office 

5-Safety Office 

6-Dispensary 

7-Locker Room 

8-Test Laboratory 

9-Storeroom 

10-Cafeteria 

11-Storeroom 

12-Blacksmith

13-Power House 

14-Open Hearth 27-No. 8 Building 

15-No. 1 Foundry 28-No. 9 Building 

16-No. 1 Building 29-No. 10 Building 

17-No. 2 Building 30-Heat Treat 

18-No. 3 Building 31-Core Room 

19-No. 4 Building 32-Mechanical Repair 

20-No. 5 Building 33-Patt. Storage 

21-No. 6 Building 34-Patt. Shop 

22-No. 7 Building 35-Gov. Betatron 

23-Seed System 36-Betatron 

24-No. 2 Foundry 37-Research Laboratory 

 25-Carpenter Shop 

26-No. 12 Building 

Source: Reformatted from McKeel, 2006, p. 42 

Figure 5-2 provides an aerial site map of General Steel Industries. 

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Figure 5-2: Aerial Site Map of General Steel Industries 

Source: Murray, 1992, p. 21 

5.2 Radiological Exposure Sources from General Steel Industries Operations 

ATTRIBUTION: Section 5.2 and its related subsections were completed by Mike Domal, MJW 

Corporation. These conclusions were peer-reviewed by the individuals listed on the cover page. The 

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

The following subsections provide an overview of the internal and external exposure sources for the 

General Steel Industries class under evaluation. 

5.2.1 Internal Radiological Exposure Sources from General Steel Operations 

General Steel Industries performed quality-control work on uranium ingots for the Mallinckrodt 

Chemical Company, which involved X-raying uranium ingots to determine if metallurgical flaws 

existed. The quality-control work did not include any cutting, machining, or abrading of the uranium 

ingots; therefore, there was a low probability of producing elevated air concentrations of uranium. 

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The primary source of airborne contamination was from oxidation and dust particles on the surface of 

the ingots that became airborne by forces such as air currents and handling activities. Internal 

radiological exposure could occur by means of inhalation and/or ingestion of radioactive materials. 

5.2.1.1 Uranium 

The AEC quality-control X-ray activities performed by General Steel Industries only involved 

uranium ingots. Therefore the primary radionuclide of concern for internal radiological exposure is 

uranium. Uranium oxides form in a variety of ways in metal working plants, including scale 

formation on hot surfaces and oxidation enhanced by the presence of water (Battelle-TBD-6000). 

Uranium particles could have been removed from the surface and become airborne during handling 

operations and subsequently inhaled or ingested. Until 1953, most uranium handled in AWE metalworking sites was natural uranium (Battelle-TBD-6000). Details regarding the relative concentrations 

of uranium isotopes in the ingots supplied by Mallinckrodt Chemical Company were not available; 

however, it is reasonable to assume that the ingots consisted of natural uranium given the source of 

the uranium metal ingots (or dingots) (ORAUT-TKBS-0005; Mallinckrodt, 1967). 

5.2.1.2 Recycled Uranium 

It is possible that uranium processed in refineries after 1953 was recycled or contained recycled 

uranium. Therefore, for the timeframe evaluated in this report and in the absence of definitive 

information about the origin of the processed uranium, it is assumed that the uranium contained the 

following contaminants: plutonium-239, neptunium-237, technetium-99, thorium-232, and thorium228 (Battelle-TBD-6000). The relative fractions of recycled uranium products are assumed to be 

those stated in Table 3.2 of Battelle-TBD-6000. 

5.2.1.3 Fission Products 

Internal exposure to fission products is considered in this evaluation because it was possible for 

fission products created on the surface of the uranium ingot during betatron operations to be removed 

from the surface and become airborne (Battelle-TBD-6000). 

5.2.1.4 Activation Products 

Internal exposure to activation products from the surface of the uranium ingots was considered in this 

evaluation because it was possible for some uranium to become dislodged during handling operations. 

Internal exposure from steel activation products was considered because during non-AEC work, 

metals were X-rayed and the flaws ground out. The grinding activities of activated steel presented a 

pathway for internal exposure (Battelle-TBD-6000 Appendix BB). 

Additionally, according to SC&A, 2008, the inhalation of dust from activated steel did not constitute a 

significant exposure pathway. 

5.2.2 External Radiological Exposure Sources from General Steel Operations 

External radiological exposures from AEC operations at General Steel Industries resulted from the 

processes involved in taking X-rays of uranium ingots. External radiological exposures from non16 of 39 
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AEC operations resulted from activities associated with taking X-rays of steel castings and then 

handling or grinding the castings to remove any flaws afterwards. External exposure source scenarios 

are divided into three scenarios: X-ray set-up, X-ray operations, and post-X-ray activities. Each 

scenario has specific sources to consider. 

During X-ray set-up activities for uranium ingots, the primary external exposure source was the 

uranium ingot itself. Employees involved in positioning the uranium ingots for X-ray exposures 

received deep and shallow external doses from the external surface of the uranium ingot. Time and 

distance from the surface of the ingot determined the amount of exposure employees received. During 

X-ray set-up activities for steel castings, there was no radiological exposure because the steel was not 

activated. 

During X-ray operations involving uranium ingots and steel castings, employees were potentially 

exposed to two sources of radiation: penetration of the shield wall and skyshine. The betatrons were 

operated from a control room outside of the primary shield wall for protection against being exposed 

to the primary X-ray beam. The betatrons were housed inside of a building with a ten-foot-thick 

shield wall to protect employees from the X-ray beam (Murray, 1992). Additionally, there was a loud 

speaker system and lights along with an interlock system that would prevent the betatron from 

operating if the door was opened (Unknown author, unknown date-c). Discussions with former 

operators indicated that X-rays lasted about one hour , during which time employees who were in 

rooms near the betatron had the potential for external radiological exposure (Meeting Minutes, 

October 9, 2007). A small fraction of the radiation penetrated the shield wall; thus, the closer an 

individual was to the external surface of the shield wall, the higher the exposure rate. External 

exposure was also indirectly possible from skyshine, which consisted of photons that were scattered 

upward out of the building, then downward to ground level, thus bypassing the shield wall. Skyshine 

can be a significant exposure source at facilities which have particle accelerators (depending on the 

energy and flux of resultant radiations). For the General Steel facility, scattered photons were 

determined by calculation to contribute to the external dose of employees. The areas outside of the 

betatron buildings that had the highest calculated dose rates from skyshine were considered in dose 

estimates. 

The post-X-ray operations included two external radiation sources: ingots and activation of the 

betatron components. The ingot itself included short-lived activation products from photon-neutron 

reactions that occurred during X-ray operations. Fission products were also present in the uranium 

ingot due to the photo-fission reaction that occurred during betatron operations (Battelle-TBD-6000 

Appendix BB). Exposure to activation products and fission products from the uranium ingots was in 

addition to radiation normally emitted from un-irradiated uranium ingots. The exposure rates from the 

irradiated ingots were highest immediately after the betatron was shut down; exposure rates dropped 

exponentially with time (Battelle-TBD-6000 Appendix BB). 

The second external radiation source during post-X-ray operations was from activation of the betatron 

apparatus itself (Battelle-TBD-6000 Appendix BB). The external exposure hazard from activation of 

the betatron became minimal after about 30 minutes. 

Additional sources of external radiation include sealed radiography sources and a portable X-ray unit. 

The radiography source and portable X-ray units were used for X-raying components at the facility. 

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5.2.2.1 Photon 

There were a number of photon radiation sources that contributed to the overall external exposures 

associated with performing quality-control X-rays on uranium ingots. The external photon radiation 

exposure sources included photons from the uranium (ingots), X-rays from the betatron operations 

(through the shielding and from skyshine), and activation of the uranium and betatron components 

(post-uranium X-ray operations). 

Photons resulting from the operation of the betatron also contributed to external radiation exposure. 

These photons resulted in personnel exposure through penetration of the primary shield wall or 

through scattering as a result of skyshine. Photons from skyshine were scattered out of the betatron 

building and then back down to ground level, bypassing the primary shield wall. The areas outside of 

the betatron buildings that had the highest calculated dose rates from skyshine were considered in 

dose estimates. 

The activation of uranium and betatron components also resulted in post-X-ray photon sources. In 

uranium, photons resulted from short-lived neutron activation products that were produced from 

photo-neutron reactions while the betatron was in operation; photons also resulted from fission 

products which were produced from photo-fission reactions. Activation of the betatron apparatus also 

resulted in short-term, post-operation photon exposures. The exposure rates from activation of the 

betatron apparatus dropped quickly (Name Four, 2007). 

5.2.2.2 Beta 

The dominant beta radiation source was from the surface of the uranium ingots. In the uranium-238 

decay scheme, there is a short-lived isotope, protactinium-234m. This isotope decays by emitting an 

energetic 2.28 MeV beta particle. It is this beta particle that accounts for shallow-dose hazard 

associated with handling the uranium metal. Beta radiation from the uranium ingot surface is 

considered during X-ray set-up activities and post-X-ray operations since both activities required 

handling the uranium ingot. Beta radiation was also present after X-ray operations from fission and 

activation products present in uranium ingots, and in activation products present in steel following 

non-AEC X-ray operations. 

5.2.2.3 Neutron 

As discussed in ORAUT-OTIB-0004, neutron doses from exposure to natural uranium, including 

uranium metals, are considered negligible (ORAUT-OTIB-0004). During X-ray operations, potential 

neutron exposures were possible from photo-neutron interactions and delayed neutrons from photofission interactions; however, this did not result in a significant exposure source because neutrons 

resulted from secondary radiations from the X-ray interactions with matter in the X-ray area. This 

issue is further assessed in Section 7.3 of this report. 

5.2.3 Incidents 

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A review of General Steel Industries’ records did not uncover any radiological incidents that were 

associated with AEC operations, or that could not be accounted for using the information and 

documentation available to NIOSH. 

5.2.4 Residual Radioactivity Period at the General Steel Industries Site 

Based on the purchase orders for Mallinckrodt to X-ray uranium, the AEC-related radiological 

operations at General Steel Industries were completed in 1966. For the purposes of this evaluation 

report, NIOSH has defined the end-date of radiological operations as June 30, 1966. Therefore, the 

start date of the residual period is considered to be July 1, 1966. The residual period ends in 1992. 

Again, for the purposes of this evaluation report, NIOSH has defined the date as December 31, 1992 

(based on the start of the DOE site remediation under FUSRAP, which occurred in 1993). During the 

period of residual contamination, as designated by NIOSH and as noted in the dates above, employees 

of subsequent owners and operators of this facility are also covered under EEOICPA. 

During the residual contamination period (i.e., after AEC operations ended), internal exposure could 

have resulted from resuspension of settled uranium dust or particles. The potential airborne 

concentrations from resuspended contamination are considered to be significantly less than the 

airborne concentrations that could have occurred during AEC operations. 

In 1989, DOE conducted a radiological survey to establish the current radiological conditions in and 

around the building in which the X-ray equipment was housed. Survey results showed that small 

amounts of residual radioactivity from former operations remained in several discrete areas in the Xray building at the Granite City facility. Uranium-238 was found in elevated concentrations in debris 

from an industrial vacuum cleaner, and in dust and debris in several small locations throughout the 

building. This information, coupled with the radiological exposure sources discussed above for the 

operational period at the site, can be used to evaluate the radiological exposure sources during the 

residual radioactivity period at the General Steel Industries site. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

ATTRIBUTION: Section 6.0 and its related subsections were completed by Louise Buker, Oak Ridge 

Associated Universities (ORAU). These conclusions were peer-reviewed by the individuals listed on 

the cover page. The rationales for all conclusions in this document are explained in the associated 

text. 

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

monitoring data for the General Steel Industries class under evaluation. 

6.1 Available General Steel Industries Internal Monitoring Data 

As of the date of this evaluation, NIOSH has been unable to find any records of internal monitoring 

data for General Steel Industry employees; this includes its search for bioassay data and air 

monitoring data. Therefore, NIOSH developed a bounding internal dose estimation method based on 

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air monitoring data from other AEC uranium-handling facilities. The estimated employee intakes 

were reasonably bounded because the assumed airborne activities were derived from AEC uraniumhandling facilities that used a “slug production” process. The air monitoring data from the slug 

production process provides a basis to bound internal dose estimates since this process includes 

uranium machining activities, which resulted in airborne uranium dust production. General Steel 

operations did not include uranium machining; therefore, the assumed airborne activity levels would 

be considered conservatively bounding for the proposed worker class being evaluated in this report. 

This methodology is discussed in Section 7.2. 

6.2 Available General Steel Industries External Monitoring Data 

As of the date of this evaluation, NIOSH has been unable to find any records of external monitoring 

data prior to 1964 for General Steel employees. However, personnel monitoring data (film badges 

from the film badge vendor Landauer) for the years 1964 through 1973 are available to NIOSH and 

are used in the evaluation of bounding external doses (as discussed in Section 7.2 of this report) 

(Landauer, 1964; Landauer, 1965; Landauer, 1966; Landauer, 1967; Landauer, 1968; Landauer, 1969; 

Landauer, 1970; Landauer, 1971; Landauer, 1972; Landauer, 1973). Although 1966 was the end of 

the operational period, monitoring data are available during the residual period up to 1973. The 

available monitoring data provided in the Landauer reports include only photon dose data. Based on a 

review of the information available to NIOSH, including the available purchase order requisitions and 

personnel interviews, NIOSH determined that the potential for exposure during 1964 was higher than 

in any previous year during the operational period at General Steel Industries. This determination was 

based on the estimated betatron operational times for both AEC and non-AEC uses. Therefore, the 

dosimetry data are considered sufficiently representative for all other years during the operational 

period. In addition, based on the evaluation and assessment of the dose reconstruction approach 

presented in Battelle-TBD-6000 and Battelle-TBD-6000 Appendix BB as performed in this report, the 

dosimetry data also support the conclusion that Battelle-TBD-6000 provides a bounding estimate of 

external doses for the proposed class of workers evaluated in this report. 

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 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

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which together or individually might ensure 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. This approach is discussed in 

OCAS’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-00105 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of General Steel Industries Data 

ATTRIBUTION: Section 7.1 and its related subsections were completed by Louise Buker, Oak Ridge 

Associated Universities (ORAU). These conclusions were peer-reviewed by the individuals listed on 

the cover page. The rationales for all conclusions in this document are explained in the associated 

text. 

This subsection considers questions that need to be addressed 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 

basis 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 

NIOSH has been unable to find records of uranium internal monitoring for uranium for General Steel 

Industries employees. General Steel Industries’ data, such as bioassay results and air sampling results, 

are not available. However, Battelle-TBD-6000 includes air sampling data collected from other AWE 

facilities that handled uranium. The data identified in Battelle-TBD-6000 are considered 

representative measurements for most of the processes that took place at metal-working AWE sites, as 

the results are typical for the state of technology in the late 1950s. The air sample data were 

categorized and presented in Battelle-TBD-6000 based on common uranium metal working processes. 

The air sample results from the uranium metal-working process, known as slug production, were used 

to reasonably bound the airborne radioactivity concentrations that could have existed at the General 

Steel Industries site. The slug production process involved handling uranium slugs as well as abrasive 

activities such as brushing and filing (Battelle-TBD-6000). The activities at General Steel Industries 

also involved handling uranium metal, but did not include abrasive activities. It is therefore 

reasonable to assume that the air sample data used were credible and reasonable for estimating 

internal doses to General Steel employees. 

7.1.2 External Monitoring Data Pedigree Review 

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NIOSH was able to find external dosimetry monitoring records for General Steel employees for the 

years 1964 through 1973, which includes results for the last two years of site operations (Landauer, 

1964; Landauer, 1965; Landauer, 1966; Landauer, 1967; Landauer, 1968; Landauer, 1969; Landauer, 

1970; Landauer, 1971; Landauer, 1972; Landauer, 1973). The data were in the form of film badge 

results and came directly from the paper records provided by Landauer, the external dosimetry vendor. 

The names of several radiographers at General Steel Industries were confirmed to be included in the 

data. The Landauer data appear to include all radiographers at General Steel Industries and some 

support personnel. These data are significant because radiographers were considered to be the highest 

exposed workers at the site. Therefore, these data provide a clear indication of the actual external 

doses of the highest exposed workers at General Steel Industries. However, to form the basis for 

bounding external doses for the site, the methodology in Battelle-TBD-6000 Appendix BB was used. 

This methodology incorporates exposure scenarios based on input from former operators and source 

term modeling and calculations using Monte Carlo N-Particle transport code. 

7.2 Evaluation of Bounding Internal Radiation Doses at General Steel 

Industries 

ATTRIBUTION: Section 7.2 and its related subsections were completed by Louise Buker, Oak Ridge 

Associated Universities (ORAU). These conclusions were peer-reviewed by the individuals listed on 

the cover page. The rationales for all conclusions in this document are explained in the associated 

text. 

The principal sources of internal radiation doses for members of the proposed class include inhalation 

and ingestion of uranium dust from handling uranium metal, fission and activation products from 

handling and examining the uranium following X-ray operations, and activation products from steel 

castings handled and examined following X-ray operations. The following subsections address the 

ability to bound internal doses, methods for bounding doses, and the feasibility of internal dose 

reconstruction at General Steel Industries, located on 1417 State Street, Granite City, Illinois, during 

the operational period from January 1, 1953 through June 30, 1966, and during the residual period 

from July 1, 1966 through December 31, 1992. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses 

As of the date of this evaluation, NIOSH has not found any internal dosimetry data for General Steel 

employees or any air monitoring data associated with General Steel operations. However, since no 

cutting, machining, or abrading of uranium was done, there was a low potential for producing elevated 

air concentrations of uranium at the General Steel site. As reviewed and evaluated in Battelle-TBD6000 and Battelle-TBD-6000 Appendix BB, General Steel’s uranium work process is reasonably 

similar to the “Slug Production” process. They are similar in that the work at General Steel and the 

slug production process both involve the handling of solid uranium metals. They are dissimilar in that 

the slug production process also included abrasive uranium metal-work activities, whereas no uranium 

metal-working took place at General Steel. Therefore, representative air sampling data associated 

with uranium slug production at AEC facilities form a basis to reasonably bound internal exposures 

for members of the proposed worker class evaluated in this report. A specific assessment of this 

methodology is included in Section 7.2.3 of this report. 

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General Steel also X-rayed steel castings to detect internal flaws in the castings; these were non-AEC 

operations that occurred at the same time AEC operations took place. The steel castings could 

potentially be ground out soon after the X-rays were performed, while the steel was still activated, 

thus resulting in radioactive dust being inhaled by the employee grinding the casting. As reviewed 

and evaluated in Battelle-TBD-6000 and Battelle-TBD-6000 Appendix BB, an internal exposure 

scenario based on centerless grinding provides a bounding estimate of the airborne exposure involving 

inhalation of steel activation products. For the purpose of evaluating the exposure scenario, since the 

grinding could not occur until after the film was processed, it is assumed that grinding did not start 

until 30 minutes after the X-ray exposure ended. As assessed in Battelle-TBD-6000, the bounding 

exposure scenario assumes that grinding would start on a freshly X-rayed piece of steel every 2 hours 

(with grinding performed on each piece until the activity was completely decayed away). Employees 

were assumed to inhale iron-53 (steel activation product) every two hours for 2,400 hours per year. 

This intake was calculated to yield an annual dose of less than 1 mrem for all organs. Based on this 

assessment, further evaluation of this internal dose pathway is not included in Section 7.2.3 of this 

report. 

7.2.2 Evaluation of Bounding Residual Period Internal Doses 

Internal dose from the residual contamination period is limited to contamination left behind following 

the operational period. An internal dose pathway is possible if the settled contamination is resuspended into the air. Dose estimates from inhalation and ingestion of re-suspended contamination 

were calculated using a resuspension model. The methodology used in the calculation is described in 

Section 7.2.3.2. 

7.2.3 Methods for Bounding Internal Dose at General Steel 

NIOSH evaluated the potential exposures from possible intakes of radioactive material at General 

Steel Industries based on air monitoring data from other facilities for the operational period. Internal 

exposures from the residual period were estimated by modeling the resuspension of surface 

contamination levels to determine airborne levels that would bound intakes for General Steel 

employees. 

7.2.3.1 Methods for Bounding Operational Period Internal Dose 

General Steel Industries’ internal dose is bounded by using air sampling measurement data from other 

AEC facilities that conducted uranium slug production operations. Since slug production included 

machining uranium and General Steel did not machine uranium, these values are considered 

bounding. The only airborne potential for General Steel Industries uranium work was from handling 

and moving uranium metal. Slug production inherently includes handling and moving the uranium 

metal, as well as uranium machining. 

Uranium may have also contained fission and activation products produced from photonuclear 

reactions from the high-energy X-rays of the betatron. The physics associated with producing these 

products is well-known and can be modeled. Several scenarios have been modeled and have shown 

that internal dose from activation products is negligible (SC&A, 2008). However, to account for 

potential doses from fission products, as noted below, the claimant-favorable assumption was made to 

increase the estimated uranium intake by 1%. 

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In order to bound the internal dose due to fission products, the overestimating methodology of 

increasing the uranium intake by 1% to account for the differences in biokinetic models between 

uranium and the fission products was applied. This was based on assuming a worst-case 2:1 decay 

energy ratio of uranium-to-fission products, meaning the energy associated with the decay of uranium 

was assumed to be twice as high as the energy associated with the decay of fission products. Given 

this ratio, the dose delivered by fission products over the first year after inhalation is approximately 

0.005% that of the dose delivered by uranium. Therefore, it is bounding, for several reasons, to 

estimate the internal dose from fission products by assuming the uranium intake is 1% higher than that 

listed in Tables 7.8 and 7.9 of Battelle-TBD-6000 Appendix BB. First, the energy ratio is actually a 

conservative assumption. Second, uranium will continue to deliver dose long after the first year 

following intake due to its retention in the body while fission products will continue to decrease due to 

elimination from the body and radioactive decay. Finally, the radiation-weighting factor for alpha 

radiation resulting from uranium is 20 times higher than that of beta- and gamma-emitting fission 

products (Battelle-TBD-6000 Appendix BB, Section 5.1). 

According to Battelle-TBD-6000 Appendix BB, internal dose estimates from iron-53 (steel activation 

product from photo-neutron reactions) were considered and found to be negligible. 

7.2.3.2 Methods for Bounding Residual Period Internal Dose 

Internal dose estimates for the residual period were based on resuspension of settled contamination. 

The air sample values collected during operations inherently include airborne uranium caused by 

resuspension (as well as directly from the operation itself). This implies that the intakes from the 

residual period can be bounded if the intakes during the operational period are bounded. For General 

Steel Industries, the internal dose received during the residual contamination period was bounded by 

estimating a surface contamination value created during the operational period, and in turn estimating 

a resuspended air concentration of uranium (Battelle-TBD-6000 Appendix BB). 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

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

operations period at the General Steel Industries site is feasible based on using a bounding estimate of 

uranium intakes from air sampling data at other AWE uranium handling facilities. The estimate is 

bounding due to the fact that air sampling data from facilities involved in uranium slug production 

were used. Activities at uranium slug production facilities included brushing and filing uranium; 

therefore, the slug production facilities produced higher airborne uranium concentrations than what 

was possible at General Steel Industries, which did not brush and file uranium. Internal doses from 

non-AEC operations that occurred during the AEC operational period were conservatively evaluated 

and found to be negligible (SC&A, 2008; Battelle-TBD-6000 Appendix BB). In addition, this 

evaluation supports the ability to bound residual period doses based on a calculated maximum surface 

contamination and an associated airborne radioactivity exposure scenario. Based on the assessment of 

these doses, NIOSH concludes that the methods described in Battelle-TBD-6000 and Battelle-TBD6000 Appendix BB provide reasonable approaches to conservatively bound internal doses for all 

members of the class under evaluation. 

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7.3 Evaluation of Bounding External Radiation Doses at General Steel 

Industries 

ATTRIBUTION: Section 7.3 and its related subsections were completed by Louise Buker, Oak Ridge 

Associated Universities (ORAU). These conclusions were peer-reviewed by the individuals listed on 

the cover page. The rationale for all conclusions in this document are explained in the associated 

text. 

The principal source of external radiation doses for members of the proposed class was from activities 

associated with the betatron machines. During set-up activities in preparation for X-raying uranium 

ingots, there was the potential for exposure directly from the uranium ingots. While in operation, 

there was the potential for exposure from radiation escaping the shielded area (such as skyshine or by 

directly penetrating the shield wall). Following X-ray operations, there was the potential for exposure 

to irradiated steel alloys that were activated by photo-neutron interactions caused by the high-energy 

X-rays, and to the uranium metal (which also included fission and activation products caused by 

photo-neutron interactions). 

Additional sources of external radiation include sealed radiography sources and a portable X-ray unit. 

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 

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

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

7.3.1.1 Personnel Dosimetry Data 

NIOSH has obtained film badge data from Landauer that appear to include records for all workers 

employed as radiographers at General Steel Industries between 1964 and 1973. The radiographers are 

considered to be the maximally-exposed group of workers based on the potential sources for external 

radiation. These included skyshine during operations, exposure to uranium ingots before and/or after 

X-ray operations, and exposure to activated steel after X-ray operations. The time period from 1964 

to 1966 (monitored time period) is considered to be the time period that had the highest potential 

annual site exposures, because a new higher-energy betatron was received in 1963 from the Eddystone 

plant. When the new betatron was upgraded and put into operation, the site then had two operational 

betatrons. The two betatrons were not in close enough proximity to have overlapping exposure 

potentials. Nonetheless, with the ability to use two betatrons came the potential for higher site 

exposures. As expected, X-ray operations increased during this timeframe (Transcript, August 21, 

2006, p. 41). Although there are only two years of dosimetry data for the operational timeframe 

(1964-1966), the data are representative of the highest doses the radiographers may have received. 

Photon 

Radiographers 

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The available radiographer film badge data from 1964 through 1966 can be used to provide a 

bounding estimate of the radiation doses received by radiographers over any period of time at the site. 

One reason for this is that the period of available monitoring includes a period where two betatrons 

were operational at General Steel Industries. Therefore, X-ray operations increased concurrent with 

the potential for higher radiographer and site-employee doses. 

General Steel operators indicated that the new betatron had an output of 250 R/minute, while the old 

betatron had an output of 100 R/minute (Transcript, August 21, 2006, p. 45). This appears credible 

based on an interview with a former Allis Chalmers employee (Name Four, 2007) who indicated that 

there were lower outputs in the early 1950s. The new betatron was reportedly upgraded in 1963 when 

it was moved from the Eddystone Plant to Granite City (SC&A, 2008). Operators also discussed the 

difference in the amount of betatron work before and after 1963. Operators indicated that the 

betatrons were operated almost continuously starting in 1963, when the Eddystone Plant was closed. 

Prior to that, the betatron work occurred at a slower pace (Transcript, August 21, 2006, p. 41; Meeting 

Minutes, October 9, 2007). Thus, NIOSH assumes that the dose received by operators after 1963 

would bound any dose received prior to 1963, and the available film badge data can be used to 

estimate pre-1964 dose. 

There were also sealed sources used for radiography at General Steel Industries, as well as a portable 

X-ray unit. These sources were used infrequently in the plant. When they were used, they were 

operated by the radiographers which is the same group that operated the betatrons. The external dose 

to the radiographers is conservatively bounded by assuming they received the same dose as betatron 

operators, the maximally-exposed work group. 

Other employees (non-radiographers) 

While radiographers wore film badges starting in 1963, most other General Steel employees did not. 

Some of these unmonitored employees worked in, or with, materials recently X-rayed in the Betatron 

building. Two models (SC&A, 2008; Battelle-TBD-6000 Appendix BB) determined that the dose to 

the unmonitored employees would be bounded by assuming that they received the same dose as the 

betatron operators. 

For other unmonitored employees, potential exposure to external photon radiation can be broken 

down into three categories. 

•	 Radiation received from the Betatron building by employees working in elevated locations above 

the height of the Betatron building shield wall; 

•	 Radiation received from the Betatron building by employees working in close proximity to the 

Betatron building but at ground level; or 

•	 Radiation received while in close proximity to a sealed-source radiography unit used in other 

portions of the facility. 

For the first category, two scenarios have been developed (SC&A, 2008). The first is based on 

statements by a former General Steel employee indicating that he performed maintenance on the roof 

fans of the Betatron building twice per year for approximately 20 minutes per fan (Meeting Minutes, 

October 9, 2007). Dose rates at the fans directly above the shooting area of the betatron have been 

modeled to be as high as 208.5 mrem/hour during an X-ray exposure. There are three fans above the 

shooting room in the New Betatron building. The total maintenance time for three fans is estimated to 

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be one hour (20 minutes/fan). If fan maintenance was performed twice per year, the total annual 

maintenance time is estimated to be two hours, and the annual dose equal to 417 mrem/year. A usage 

factor (fraction of time the machine is emitting radiation) has been estimated as 0.414 (SC&A, 2008) 

and 0.5 (Battelle-TBD-6000 Appendix BB). However, if no usage factor is applied, the annual dose is 

estimated to be 417 mrem/year. Therefore this dose estimate can be considered bounding for 

employees included in this scenario, and the bounding dose is not implausibly high. 

The second scenario pertains only to the new betatron since it was in close proximity to Building #10; 

it applies to the period from 1963 through 1966 and to individuals working on the roof of Building 

#10. Based on pictures of the facility combined with scale drawings of the New Betatron building, 

NIOSH estimated approximate distances and heights of these buildings. Using simple geometry, it is 

apparent that for an X-ray taken with the betatron in the center of the shooting area, the unshielded 

beam would be at least 10 feet above the roof line of Building #10. At head height, the beam passes 

through at least one foot of concrete. At the edge of the roof, the beam would pass through the entire 

10 feet of shielding. Based on an unshielded dose rate calculated for the roof of 208.5 mrem/hour 

(SC&A, 2008), the increased distance alone would reduce this to approximately 11.2 mrem/hour. 

However, the 10 feet of shielding will further reduce this to a level that is well below the dose rates 

received in the control room. Therefore, NIOSH estimates that the radiographers in the control room 

would receive a higher dose; thus, radiographer dose estimates would bound this dose scenario. 

It is also possible that employees not associated with radiography could have been exposed while 

outside the Betatron buildings at ground level. Both models (SC&A, 2008; Battelle-TBD-6000 

Appendix BB) used claimant-favorable assumptions when calculating the dose rates at various 

locations outside the Betatron buildings. Dose rates in one model were calculated both assuming the 

betatron was located in the center of the shooting area and again assuming it was located near the 

entrance of the building pointed at the railroad tracks. This last position could only occur if the 

betatron head is “flipped” (SC&A, 2008, Meeting Minutes, October 9, 2007). However, operators 

indicated this was not done until after a particular supervisor left the company (Meeting Minutes, 

October 9, 2007) after the AEC contract period ended. This indicates that this scenario only occurred 

in the residual contamination period. Since only the radiation from residual contamination of AECrelated material can be accounted for during that period (OCAS-IG-003), it is not applicable to dose 

reconstructions under the EEOICPA. Dose rates determined for the center shot include 0.3 

mrem/hour in the control room, 1.5 mrem/hour in a restroom, and 2.4 mrem/hour outside the building. 

The last two areas are not normal work areas and thus would not represent an area where someone 

would be exposed 100% of the workday. Occupancy factors for restrooms and other low-occupancy 

areas vary from 1/8 to 1/40 (Cossairt, 2008; NCRP, 2003; Liu, 2007). If the highest occupancy factor 

(1/8) is used, the highest dose rate outside the shield (2.4 mrem/hour) would be effectively reduced to 

0.3 mrem/hour, which is the same as the control room dose rate. This implies that employees outside 

the Betatron building at ground level would be exposed to the same level of radiation as the betatron 

operators during the X-ray examination. Betatron operators would of course receive additional 

radiation dose while the machine is off, and they are exposed to the irradiated material in the shooting 

area. Therefore, the dose to employees outside of the betatron (at ground level) can be bounded by the 

radiographers’ estimated dose. This indicates that General Steel employee dose from this scenario can 

be plausibly bounded. 

The last source of external radiation exposure at General Steel Industries was exposure caused by the 

use of sealed sources or a portable X-ray unit. Operators indicated that these sources were not used 

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often, and the large cobalt-60 source (80 Ci) was always used in the New Betatron building. There 

was also a smaller cobalt-60 source used in a cinderblock room within Building #6. Indications are 

that all sources and the portable X-ray machine were used by radiographers and that all radiographers 

wore film badges (from 1964 to 1973). The radiographers themselves would likely be the most 

exposed individuals from these sources, since they would always be near the source during an 

exposure while other employees would only infrequently be exposed as they walked by the area. 

Thus, the radiographer film badges can be used as a bounding estimate that is not implausible. There 

is one additional scenario related to this third category. The cinderblock room had no ceiling. 

Therefore, someone working on the 40-foot-high roof of Building #6 (above this cinderblock room) 

could be exposed to radiation without the benefit of the minimal shielding afforded by the 

cinderblock. Since the source is a point source, the dose rate decreases simply with the inverse of the 

square of the distance from the source. The dose rate outside of the room was modeled as 18 

mrem/hour, one meter from the wall (SC&A, 2008). A distance of approximately 27 feet is necessary 

to reduce the unshielded dose rate to18 mrem/hour. Therefore, the dose to employees working above 

the room more than 27 feet from the source can still be bounded with the radiographer film badge 

readings. 

Beta 

Beta dose can be reasonably bounded by using the dose methodology described in Battelle-TBD-6000 

Appendix BB. This methodology assumes the operators received beta dose exposures from handling 

the uranium ingots both before and after X-ray operations. The beta dose estimate was bounded by 

overestimating the exposure time after X-ray operations to be 30 minutes. The operators were 

assumed to spend 15 minutes within one foot of the ingot and 15 minutes within one meter of the 

ingot (Battelle-TBD-6000 Appendix BB). The total exposure included radiation from uranium as well 

as the fission and activation products. The time period and exposure rates were conservative enough 

to bound any beta dose from steel-handling operations as well. 

Neutron 

Neutron dose was considerably smaller than photon doses but still contributed to the overall external 

exposures. As with other facilities, neutron doses can be determined using the photon-to-neutron 

ratio. 

7.3.2 Evaluation of Bounding Residual Period External Doses 

External dose during the residual contamination period at General Steel Industries is limited to the 

radiation emitted from residual uranium contamination (OCAS-IG-003). With no mechanical 

manipulation of the uranium (i.e., cutting, grinding, or machining) and no high-temperature 

applications, no significant large potential for producing large “flakes” of uranium existed. Therefore, 

surface contamination can be modeled from airborne concentration values. As indicated in Section 

7.2, the airborne uranium is bounded by operations with uranium metal that involve mechanically 

disturbing the metal. In addition, the 1989 pre-remediation survey provides information associated 

with an industrial vacuum cleaner which had a dose rate higher than that calculated from the assumed 

contamination level caused by the residual surface contamination. Therefore, the contact dose rate 

from the vacuum cleaner can be used as a basis to calculate external dose from residual contamination 

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(Battelle-TBD-6000 Appendix BB). Based on this information, a bounding external dose estimate can 

be established for the proposed worker class for the residual period evaluated in this report. 

7.3.3 General Steel Occupational X-Ray Examinations 

Dose from occupationally-required medical X-rays has also been considered and assumed to have 

occurred, although exposure data were unavailable. Since occupational X-ray examinations were 

commonly required during the time period covered by this evaluation, potential dose from such 

practices are taken into account for General Steel employees. 

NIOSH considers it feasible to bound the medical dose for General Steel workers by using claimantfavorable assumptions as well as the applicable protocols in the complex-wide Technical Information 

Bulletin Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procures (ORAUTOTIB-0006). 

7.3.4 Methods for Bounding External Dose at General Steel 

By July 17, 2008, 238 EEOICPA claims meeting the class definition being evaluated in this report had 

been submitted to NIOSH. Of those 238 claims, NIOSH has completed dose reconstructions for 208 

claims. 

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 

• Neutron Dose 

• Medical X-ray Dose 

7.3.4.1 Methods for Bounding Operational Period External Dose 

Photon Dose 

As previously indicated, NIOSH has obtained Landauer film badge reports from 1964 through 1973. 

The film badge data include weekly readings with a recording limit of 10 mrem. Through the week of 

June 27, 1966, which would cover the operational period, there were 6,999 individual readings. Of 

these readings, only 22 indicated 10 mrem or greater. Therefore, approximately 99.7% of the readings 

indicated exposure below 10 mrem. Also, no individual had more than one reading above the 10 

mrem recording limit during this timeframe. 

The values resulting in exposure of less than 10 mrem were recorded as “M” (monitored). Since 

99.7% of the readings were below this value, the 95th percentile is clearly less than 10 mrem per week 

or 500 mrem per year for a 50-week work year. This technically accounts for the 22 readings that 

were greater than the recording limit, since those readings are included in the set and they are all 

above the 95th percentile. However, the readings can represent unusual occurrences, and with the 

limited number of recorded readings, an attempt was made to account more favorably for such 

occurrences. There were 89 individuals monitored for varying periods of time during this timeframe. 

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If 10 mrem is substituted for each “M” and added to any recorded values, a weekly average can be 

determined for each individual that accounts for the recorded values as well as those recorded as less 

than 10 mrem. This results in 89 individual weekly averages. This dataset has an average of 10.35 

mrem with a standard deviation of 2.75 mrem for a resulting 95th percentile of 14.87 mrem. If a 50­

week work year is assumed, this results in an annual exposure of 743.6 mrem. This is clearly 

bounding since it represents the 95th percentile of the data, in which 10 mr was substituted for the 

99.7% of the values recorded as less than 10 mrem. 

As discussed in Section 7.3.1, these data confirm that the Battelle-TBD-6000 Appendix BB method 

for assigning external dose can be considered bounding for all employees. 

Beta Dose 

The two sources of external beta dose at General Steel Industries are beta dose from the uranium Xrayed in the Betatron buildings and beta dose from activation of X-rayed steel castings. Beta dose can 

be reasonably bounded by using the dose methodology described in Battelle-TBD-6000 Appendix 

BB. This methodology assumes the operators received beta dose exposures from handling the 

uranium ingots both before and after X-ray operations. The beta dose estimate was bounded by 

overestimating the exposure time after X-ray operations to be 30 minutes. The operators were 

assumed to spend 15 minutes within one foot of the ingot and 15 minutes within one meter of the 

ingot (Battelle-TBD-6000 Appendix BB). The total exposure included radiation from uranium as well 

as the fission and activation products. The time period and exposure rates were sufficiently 

conservative enough to bound any beta dose from steel handling operations as well. 

Neutron Dose 

Neutrons can be produced while material is being X-rayed, as can delayed neutrons from fission 

products produced in uranium. Both effects have been modeled (SC&A, 2008) and always found to 

be less than the photon dose. Neutron dose was considerably smaller than photon doses but still 

contributed to the overall external exposures. A study is in place to determine the photon-to-neutron 

ratio. 

Medical X-ray Dose 

Dose from occupationally-required medical X-rays has also been considered and assumed to have 

occurred. NIOSH considers the adequate reconstruction of medical dose for General Steel employees 

to be feasible by using claimant-favorable assumptions as well as the applicable protocols in ORAUTOTIB-0006. 

7.3.4.2 Methods for Bounding Residual Period External Doses 

External dose during the residual contamination period at General Steel Industries is limited to the 

radiation emitted from residual uranium contamination (OCAS-IG-003). In a survey conducted in 

1989 of the General Steel Industries facility, the highest surface contamination level was determined 

to be 540 dpm/100 cm2

 (Battelle-TBD-6000 Appendix BB). Radiation level surveys indicated nearbackground levels throughout the facility. The only exception to the very low readings was on the 

surface of an industrial vacuum cleaner; where the reading was 90 μR/hour (Battelle-TBD-6000 

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Appendix BB). Rather than use the highest surface contamination level and apply an external dose 

conversion factor, external doses for the residual period were overestimated by assuming an external 

exposure rate of 90 μR/hour throughout the residual period. This methodology reasonably bounds 

potential external exposures during the residual period. 

As discussed in Section 7.3.1, these data confirm that the Battelle-TBD-6000 Appendix BB method 

for assigning external dose can be considered bounding for all employees. 

7.3.5 External Dose Reconstruction Feasibility Conclusion 

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

operations period at the General Steel Industries site is feasible. By modeling external dose from 

radiographer film badge data, dose estimates are plausible and bounding. In addition, this evaluation 

supports the ability to bound residual period doses based on a maximum surface contamination and an 

associated pre-remediation survey exposure scenario. This scenario applies the highest potential 

surface contamination levels (those associated with the operations period). Based on its assessment of 

these doses, NIOSH concludes that the methods described in Battelle-TBD-6000 and Battelle-TBD6000 Appendix BB provides reasonable approaches to conservatively bound external doses for all 

members of the class under evaluation. 

7.4 Evaluation of Petition Basis for SEC-00105 

ATTRIBUTION: Section 7.4 and all related subsections were completed by Louise Buker, Oak Ridge 

Associated Universities (ORAU). These conclusions were peer-reviewed by the individuals listed on 

the cover page. The rationales for all conclusions in this document are explained in the associated 

text. 

The following subsections evaluate the assertions made on behalf of petition SEC-00105 for General 

Steel Industries. 

7.4.1 Lack of Monitoring Data 

SEC-00105: It was asserted that there was no personnel or area monitoring performed at the General 

Steel site. 

Response: Personnel monitoring data from Landauer have been obtained by NIOSH for the years 

1964 through 1973. NIOSH has compared is in the process of comparing the dosimetry data to the 

modeled estimates provided by both Battelle-TBD-6000 Appendix BB and the SC&A analysis. 

Based on a this preliminary assessment of the comparison, the dosimetry data support the finding that 

the dose reconstruction approach in Battelle-TBD-6000 presents a bounding approach for the workers 

at the General Steel Industries site, which includes the proposed worker class dose that is evaluated in 

this report. 

7.4.2 Underestimated External Dose Modeling 

SEC-00105: It was asserted that external dose modeling may have been underestimated if only one 

betatron was assumed to be in use. 

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Response: Although not extensively documented, the presence of a second betatron was accounted for 

in the preparation of Battelle-TBD-6000 Appendix BB. The presence of a second betatron likely 

would not change the modeled exposure because of the large distance between both betatrons and any 

one worker (i.e., a worker could only be in proximity to only one betatron at a time, from a significant 

external dose perspective). However, NIOSH has obtained film badge results for the betatron 

operators and has compared is in the process of comparing these data to the modeled doses. As 

discussed previously, this comparisonbased on a preliminary assessment of the comparison, indicates 

the dosimetry data support that the dose reconstruction approach in Battelle-TBD-6000 presents a 

bounding approach for the workers at the General Steel Industries site, which includes the proposed 

worker class dose that is evaluated in this report. 

7.4.3 Residual Contamination Dose 

SEC-00105: It was asserted that dose from residual contamination might not be included in dose 

estimates. 

Response: Residual contamination was addressed in Battelle-TBD-6000 Appendix BB, and is 

assigned (as applicable to those individuals who may have worked during the residual radioactivity 

period at General Steel Industries) during dose reconstruction. The information, reviews, and 

evaluations in the preceding sections of this report support the ability to bound the residual 

radioactivity period dose for the SEC-00105 proposed worker class. 

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the 

Evaluation 

Other issues have been raised in the review of Battelle-TBD-6000 Appendix BB. These issues have 

either been addressed in the body of this report or relate to the magnitude of the reconstructed dose. 

As such, those do not represent SEC issues. 

7.6 Summary of Feasibility Findings for Petition SEC-00105 

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

Steel Industries from January 1953 through December 1992. 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 7-1 summarizes the results of the feasibility findings at General Steel Industries for each 

exposure source during the time period January 1953 through December 1992. 

Table 7-1: Summary of Feasibility Findings for SEC-00105 

January 1, 1953 - June 30, 1966 and/or residual period from July 1, 1966 - December 31, 1992 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal X 

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Table 7-1: Summary of Feasibility Findings for SEC-00105 

January 1, 1953 - June 30, 1966 and/or residual period from July 1, 1966 - December 31, 1992 

 - U-238 and associated progeny X

 - U-235 and associated progeny X

 - Fission products X 

- Activation products from steel X 

External X

 - Gamma X 

 - Beta X 

 - Neutron X 

 - Occupational Medical X-ray X 

As of July 17, 2008, a total of 238 claims have been submitted to NIOSH for individuals who worked 

at General Steel Industries and are covered by the class definition evaluated in this report. Dose 

reconstructions have been completed for 208 individuals (~87%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00105 

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 

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 assessed Battelle-TBD-6000, Battelle-TBD-6000 Appendix BB, the most recently 

discovered personnel external monitoring data, monitoring data that are similar but bounding for 

operations from other sites, and modeling data associated with the evaluation of the source term at 

General Steel Industries. NIOSH has 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. Modification of the class definition regarding health 

endangerment and minimum required employment periods, therefore, is not required. 

9.0 Class Conclusion for Petition SEC-00105 

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

which it cannot estimate radiation doses with sufficient accuracy. This class includes all individuals 

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who worked in any location at the General Steel Industries site, located on 1417 State Street, Granite 

City, Illinois, from January 1, 1953 through June 30, 1966, and/or during the residual period from July 

1, 1966 through December 31, 1992. 

NIOSH has carefully reviewed all material submitted 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 other sources, including the Site Research Database (SRDB), for 

information relevant to SEC-00105. 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 

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

Metals, Battelle-TBD-6000 PNWD-3738; Rev. FO; December 13, 2006; SRDB Ref ID: 30671 

Battelle-TBD-6000 Appendix BB, Site Profiles for Atomic Weapons Employers that Worked Uranium 

and Thorium Metals - Appendix BB General Steel Industries; Rev. 0; June 25, 2007; SRDB Ref ID: 

47713 

Battelle-TIB-5000, Default Assumptions and Methods for Atomic Weapons Employer Dose 

Reconstructions, Battelle-TIB-5000 PNWD-3741, Rev. 00; April 2, 2007; SRDB Ref ID: 32016 

OCAS-IG-003, Radiation Exposures Covered for Dose Reconstructions under Part B of the Energy 

Employees Occupational Illness Compensation Program Act, Rev. 0; Office of Compensation 

Analysis and Support (OCAS); Cincinnati, Ohio; November 5, 2007; SRDB Ref ID: 35987 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0; 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; SRDB Ref ID: 32022 

ORAUT-OTIB-0004, Estimating the Maximum Plausible Dose to Workers at Atomic Weapons 

Employer Facilities, Rev. 03 PC-2; December 6, 2006; SRDB Ref ID: 36191 

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

Procedures, Rev. 03 PC-1; December 21, 2005; SRDB Ref ID: 20220 

ORAUT-TKBS-0005, Basis for Development of an Exposure Matrix for the Mallinckrodt Chemical 

Company St. Louis Downtown Site and the St. Louis Airport Site, St. Louis, Missouri, Rev. 02; June 

14, 2007; SRDB Ref ID: 32277 

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Cossairt, 2008, Topics in Accelerator Health Physics; J. D. Cossairt, G. Coutrakon, J. C. Liu, J. C. 

McDonald, L. Moritz, and S. H. Rokni; Radiation Protection Dosimetry published online on August 

21, 2008; available at http://www.rpd.oxfordjournals.org/cgi/content/extract/ncn223 

DOE, September 1992, Designation for Remedial Action at the Granite City Steel Site in Madison, 

Illinois, memorandum from James W. Wagoner to L. Price and designation summary; United States 

Department of Energy: September 25, 1992; SRDB Ref ID: 10441 

DOE, 2005, Complete Cleanup Criteria Information, web printout regarding Granite City Steel; 

http://c2d2.eml.doe.gov/complete.cfm?site=GRCS, last accessed March 3, 2005; OSA Ref ID: 

105333, p. 16 

DOE, 2007, Granite City, Illinois Fact Sheet; Department of Energy (DOE); December 20, 2007; 

SRDB Ref ID: 45148 

GSI, 1991, Memorandum: Authority Determination—Granite City Steel Site, Granite City, Illinois, 

memo with attachment; General Steel Industries (GSI); March 11, 1991; SRDB Ref ID: 16356 

Landauer, 1964, 1964 Film Badge Dosimetry Reports; Landauer; 1964; SRDB Ref ID: 41708 

Landauer, 1965, 1965 Film Badge Dosimetry Reports; Landauer; 1965; SRDB Ref ID: 41662 

Landauer, 1966, 1966 Film Badge Dosimetry Reports; Landauer; 1966; SRDB Ref ID: 41663 

Landauer, 1967, 1967 Film Badge Dosimetry Reports; Landauer; 1967; SRDB Ref ID: 41664 

Landauer, 1968, 1968 Film Badge Dosimetry Reports; Landauer; 1968; SRDB Ref ID: 41665 

Landauer, 1969, 1969 Film Badge Dosimetry Reports; Landauer; 1969; SRDB Ref ID: 41666 

Landauer, 1970, 1970 Film Badge Dosimetry Reports; Landauer; 1970; SRDB Ref ID: 41667 

Landauer, 1971, 1971 Film Badge Dosimetry Reports; Landauer; 1971; SRDB Ref ID: 41668 

Landauer, 1972, 1972 Film Badge Dosimetry Reports; Landauer; 1972; SRDB Ref ID: 41669 

Landauer, 1973, 1973 Film Badge Dosimetry Reports; Landauer; 1973; SRDB Ref ID: 41670 

Liu, 2007, Engineered and Administrative Safety Systems for the Control Prompt Radiation Hazards 

at Accelerator Facilities, SLAC-PUB-13048; James C. Liu, Vashek Vylet, and Lawrence S. Walker; 

December 2007; SRDB Ref ID: 48079 

Mallinckrodt, 1967, Fuel for the Atomic Age-Completion Report on St. Louis Area Uranium 

Processing Operations, 1942-1967; Mallinckrodt Chemical Works; September 30, 1967; SRDB Ref 

ID: 6538 

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McKeel, 2006, General Steel Industries, Inc. Radiation Source Terms, NIOSH/OCAS Outreach 

presentation and general information gathered during the meeting; Daniel W. McKeel; August 21-22, 

2006; SRDB Ref ID: 26806 

Meeting Minutes, October 9, 2007, SC&A Interviewing Former Employees of General Steel 

Industries, meeting minutes; October 9, 2007 meeting in Collinsville, Illinois; SRDB Ref ID: 47970 

Murray, 1992, Results of the Radiological Survey at the New Betatron building, Granite City Steel 

Facility, Granite City, Illinois (GSG002), ORNL/RASA-91/8; M. E. Murray and M. S. Uziel; January 

1992; SRDB Ref ID: 10422 

Murray, 1994, Results of the Independent Verification Survey at the Old Betatron Building, Granite 

City, Illinois (GSG001), ORNL/RASA-94/2; M. E. Murray and K. S. Brown; July 1994; SRDB Ref 

ID: 10427 

Name One, 2008, Form B-83.13, misc doc info; Name One; June 19, 2008; OSA Ref ID: 105333 

Name Two, unknown date, Affidavit from [Name Two Redacted]; Name Two; unknown date; OSA 

Ref ID: 105333, p. 15 

Name Three, unknown date, Reason for Reconsidering Decision, correspondence; Name Three; 

unknown date; OSA Ref ID: 105333, pp. 13-14 

Name Three, 2008, Affidavit from [Name Three Redacted]; Name Three; February 9, 2008; OSA Ref 

ID: 105333, pp. 10-12 

Name Four, 2007, Information about General Steel Betatrons, correspondence; Name Four; May 1, 

2007; SRDB Ref ID: 34933 

NCRP, 2003, Radiation Protection for Particle Accelerator Facilities, Report No. 144; National 

Council on Radiation Protection and Measurements (NCRP); December 2003; SRDB Ref ID: publicly 

available 

Purchase Order, 1965, Purchase Order from the AEC and Mallinckrodt Chemical Works for Services 

for the Period of July 1, 1965 through June 30, 1966; Mallinckrodt Purchase Order; Order date of July 

7, 1965; SRDB Ref ID: 10443 

SC&A, 2008, Draft Review of “Site Profiles for Atomic Weapons Employers that Worked Uranium 

and Thorium Metals-Appendix BB: General Steel Industries,” Battelle-TBD-6000, Appendix BB, Rev. 

0, SCA-TR-TASK1-0024, Revision 1; S. Cohen & Associates (SC&A); April 2008; SRDB Ref ID: 

47974 

Transcript, July 7, 2006, GSI Affidavit Testimony, transcript; July 7, 2006; SRDB Ref ID: 47972 

Transcript, August 11, 2006, GSI Affidavit Testimony, transcript; August 11, 2006; SRDB Ref ID: 

47973 

38 of 39 
SEC-00105 10-03-08 Final General Steel Industries 

Transcript, August 21, 2006, Worker Outreach Meeting; August 21, 2006; SRDB Ref ID: 47927 

Transcript, August 22, 2006, Worker Outreach Meeting; August 22, 2006; SRDB Ref ID: 47971 

Unknown author, unknown date-a, Castings Division, article; Unknown author; unknown date; OSA 

Ref ID: 105333, p. 17 

Unknown author, unknown date-b, GSI Map, drawing; Unknown author; unknown date; OSA Ref ID: 

105333, p. 18 

Unknown author, unknown date-c, Betatron Equipment Now in Operation at Both Plants, newspaper 

article; Author not specified, unknown date; SRDB Ref ID: 23389 p. 17 

Unknown author, 1991, Authority Review for Granite City Steel Site in Granite City, Illinois; 

unknown author; February 25, 1991; SRDB Ref ID: 45103 

39 of 39