SEC Petition Evaluation Report

Petition SEC-00056 

Report Rev # 0 Report Submittal Date: 2/20/2007

Subject Expert(s): Robert Coblentz, Roger Gard, Timothy Adler 

Site Expert(s): Not Applicable 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition B 

Qualification Date 

DOE/AWE Facility Name 

SEC-00056 83.13 August 29, 2006 Bethlehem Steel Corporation 

Petitioner Class Definition 

Millwrights, welders, electricians, bricklayers, carpenters, all maintenance, testers, rollers, supervisors, crane 

operators, hookers, clean-up crews, and grinders who worked in the 10-Inch Bar Mill and Blooming Mill from 

the years 1949 through 1952. 

Proposed Class Definition 

All Atomic Weapons Employer personnel at the Bethlehem Steel Corporation who were monitored or should 

have been monitored for exposure to uranium during uranium rolling activities at the Bethlehem Steel, 

Lackawanna, New York facility from January 1, 1949 through December 31, 1952. 

Related Petition Summary Information 

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

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

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

N/A N/A 

ORAU Lead Technical Evaluator: Robert Coblentz ORAU Review Completed By: Daniel Stempfley 

Peer Review Completed By: [Signature on file] 2/20/2007 

Sam Glover Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 2/21/2007 

Jim Neton Date 

SEC Evaluation Approved By: [Signature on file] 2/21/2007 

Larry Elliott Date 
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Evaluation Report Summary: SEC-00056, Bethlehem Steel Corporation 

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-00056, qualified on August 29, 2006, requested that NIOSH consider the following 

class: Millwrights, welders, electricians, bricklayers, carpenters, all maintenance, testers, rollers, 

supervisors, crane operators, hookers, clean-up crews, and grinders who worked in the 10-Inch Bar 

Mill and Blooming Mill from years 1949 to 1952. 

NIOSH-Proposed Class Definition

Based on its research, NIOSH expanded the petitioner-requested class to define a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all Atomic Weapons Employer personnel at the Bethlehem Steel Corporation 

who were monitored or should have been monitored for exposure to uranium during uranium rolling 

activities at the Bethlehem Steel, Lackawanna, New York facility from January 1, 1949 through 

December 31, 1952. The class was expanded because NIOSH determined that the available 

information does not allow NIOSH to definitively link all individuals to their specific work 

title/function or work location for the proposed time period and because NIOSH can estimate close 

with sufficient accuracy for this class. 

 

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 incurred by any member of the class; or (2) 

estimate radiation doses more precisely than a maximum dose estimate. 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, and that NIOSH has sufficient information to reconstruct dose for the 

broader class. 

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-00056, Bethlehem Steel Corporation............................................................. 3

1.0 Purpose and Scope ....................................................................................................................................... 9

2.0 Introduction.................................................................................................................................................. 9

3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis.......................................................... 10

4.0 Data Sources Reviewed by NIOSH ........................................................................................................... 11 

4.1 Site Profile Technical Basis Documents (TBDs) ............................................................................. 11 

4.2 ORAU Technical Information Bulletins (OTIBs)............................................................................ 12 

4.3 Facility Employees and Experts....................................................................................................... 12 

4.3.1 Worker Outreach................................................................................................................. 12 

4.3.2 Advisory Board on Radiation and Worker Health .............................................................. 13 

4.3.3 Telephone Interviews .......................................................................................................... 13 

4.3.4 Bethlehem Steel Corporation Worker Issues ...................................................................... 13 

4.4 Previous Dose Reconstructions........................................................................................................ 14 

4.5 NIOSH Site Research Database ....................................................................................................... 15 

4.6 Documentation and/or Affidavits Provided by Petitioners .............................................................. 15

5.0 Radiological Operations Relevant to the Proposed Class .......................................................................... 15 

5.1 Bethlehem Steel Corporation Plant and Process Descriptions ......................................................... 16 

5.2 Bethlehem Steel Corporation Functional Areas............................................................................... 18 

5.3 Radiological Exposure Sources from Bethlehem Steel Operations ................................................. 19 

5.3.1 Alpha Particle Emissions .................................................................................................... 19 

5.3.2 Beta Radiation Fields .......................................................................................................... 19 

5.3.3 Neutron Exposures .............................................................................................................. 20 

5.3.4 Photon Exposures................................................................................................................ 20

6.0 Summary of Available Monitoring Data for the Proposed Class............................................................... 20 

6.1 Bethlehem Steel Corporation Internal Monitoring Data .................................................................. 21 

6.2 Bethlehem Steel Corporation External Monitoring Data ................................................................. 21 

6.3 Air Sampling Data............................................................................................................................ 21 

6.3.1 Simonds Saw and Steel Air Sampling................................................................................. 21 

6.3.2 Bethlehem Steel Corporation Air Sampling........................................................................ 22

7.0 Feasibility of Dose Reconstruction for the Proposed Class ....................................................................... 22 

7.1 Pedigree of Data............................................................................................................................... 23 

7.1.1 Internal Data Review........................................................................................................... 23 

7.1.2 External Data Review.......................................................................................................... 25 

7.2 Internal Radiation Doses at Bethlehem Steel Corporation............................................................... 25 

7.2.1 Process-Related Internal Doses at Bethlehem Steel............................................................ 25 

7.2.1.1 Evaluation of Inhalation Exposure: January 1949-December 1950 ................... 26 

7.2.1.2 Evaluation of Inhalation Exposures: January 1951-September 1951 ................. 27 

7.2.1.3 Evaluation of the Inhalation Exposure: October 1951-December 1952 ............. 29 

7.2.1.4 Evaluation of Intakes to Cobble Cutters: 1949-1952.......................................... 30 

7.2.1.5 Evaluation of Ingestion Dose.............................................................................. 31 

7.2.1.6 Evaluation of Inhalation and Ingestion Doses due to Residual Contamination.. 34 
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7.2.2 Ambient Environmental Internal Radiation Doses at Bethlehem Steel .............................. 35 

7.2.3 Internal Dose Reconstruction Feasibility Conclusion ......................................................... 36 

7.3 External Radiation Doses at Bethlehem Steel Corporation.............................................................. 36 

7.3.1 Process-Related External Radiation Doses at Bethlehem Steel .......................................... 36 

7.3.1.1 External Dose from Uranium Dust ..................................................................... 37 

7.3.1.2 External Dose from Direct Contact with Uranium Billets .................................. 37 

7.3.1.3 External Dose from Residual Contamination ..................................................... 38 

7.3.1.4 External Dose from Reusing Contaminated Clothing......................................... 39 

7.3.2 Ambient Environmental External Radiation Doses at Bethlehem Steel ............................. 39 

7.3.3 Bethlehem Steel Corporation Occupational X-Ray Examinations ..................................... 39 

7.3.4 External Dose Reconstruction Feasibility Conclusion........................................................ 39 

7.4 Evaluation of Specific Petitioner Statements in SEC-00056 ........................................................... 39 

7.4.1 Comparison between Bethlehem Steel Corporation and Simonds Saw and Steel .............. 39 

7.4.2 Blooming Mill Involvement................................................................................................ 41 

7.4.3 Areas of High Uranium Concentration ............................................................................... 41 

7.4.4 Lack of Records for 1949-1950 .......................................................................................... 41

7.4.5 Accurate Dose Reconstructions for Unprotected Workers ................................................. 42 

7.4.6 Lost Uranium ...................................................................................................................... 42 

7.4.7 Salt Bath Leak on September 22, 1952 ............................................................................... 42 

7.4.8 Manual Labor at Bethlehem Steel....................................................................................... 43 

7.4.9 Destroyed Records .............................................................................................................. 43 

7.4.10 Exposure to Uranium throughout the Facility..................................................................... 43 

7.4.11 Areas of Highest Exposures at the Bethlehem Facility....................................................... 44 

7.4.12 Absence of Grinding in the Technical Basis Document ..................................................... 44 

7.4.13 Ingestion of Uranium from Eating and Drinking ................................................................ 44 

7.4.14 Contaminated Clothing ....................................................................................................... 45 

7.5 Other Issues Relevant to the Petition Identified During the Evaluation........................................... 45 

7.6 Summary of Feasibility Findings for Petition SEC-00056............................................................... 46

8.0 Evaluation of Health Endangerment for Petition SEC-00056 ................................................................... 46

9.0 NIOSH-Proposed Class for Petition SEC-00056....................................................................................... 47

10.0 References.................................................................................................................................................. 49 

Tables 

Table 4-1: Number of Bethlehem Steel Claims Submitted Under the Dose Reconstruction Rule..................... 14

Table 5-1: Bethlehem Steel Company Development Chronology....................................................................... 18

Table 7-1: Simonds Saw and Steel-Air and Surface Contamination Values ....................................................... 32 

Table 7-2: Bethlehem Steel Corporation-Air and Surface Contamination Values .............................................. 32 

Table 7-3: Median General Area Air Sample Concentrations............................................................................. 35 

Table 7-4: Annual External Uranium Dose ......................................................................................................... 37 

Table 7-5: Estimated External Shallow Dose Due to Electron Exposure from Natural Uranium Sources ......... 38 

Table 7-6: Annual Dose from Contaminated Surfaces at Bethlehem Steel, 1949 to 1952.................................. 38 

Table 7-7: Summary of Feasibility Findings for SEC-00056 .............................................................................. 46 
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Figures 

Figure 7-2: Uranium Dust Data from Bethlehem Steel: Jan.–Sept. 1951 (prior to augmentation)...................... 28 

Figure 7-3: Uranium Dust Data from Bethlehem Steel: Jan.-Sept. 1951 (after augmentation)........................... 29 

Figure 7-4: Air Concentration and Surface Contamination Levels at Simonds Saw and Steel and Bethlehem 

Steel ..................................................................................................................................................................... 34 
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SEC Petition Evaluation Report for SEC-00056

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for all Atomic Weapons Employer 

personnel at the Bethlehem Steel Corporation who were monitored or should have been monitored for 

exposure to uranium during uranium rolling activities at the Bethlehem Steel, Lackawanna, New York 

facility from January 1, 1949 through December 31, 1952. 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, NIOSH must also then determine whether or not 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 

 

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

established for the class or in combination with work days within the parameters established for 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 petitioners 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, petitioner(s) 

may seek a review of certain types of final decisions issued by the Secretary of HHS.2

 

3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis 

Petition SEC-00056, qualified on August 29, 2006, requested that NIOSH consider the following class 

for addition to the SEC: Millwrights, welders, electricians, bricklayers, carpenters, all maintenance, 

testers, rollers, supervisors, crane operators, hookers, clean-up crews, and grinders who worked in 

the 10-Inch Bar Mill and Blooming Mill from years 1949 through 1952.

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

accurate dose reconstruction over time is impossible for the Bethlehem Steel Corporation workers in 

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

SEC-00056 for evaluation: 

The original submission and supplemental supporting documents included 25 documents to 

support the petition for including the above stated class of workers into the Special 

Exposure Cohort (SEC). The supporting documentation included various letters, 

production reports, trip reports, articles, and 69 affidavits. The basis of the petition is that: 

1) radiation monitoring records for the proposed class have been lost, falsified, or 

destroyed; 2) there is no information regarding monitoring, source, source term, or process 

for uranium rolling activities at Bethlehem Steel; and 3) one or more unmonitored, 

unrecorded, or inadequately monitored or recorded exposure incidents occurred. 

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. 

Based on its research, NIOSH expanded the petitioner-requested class to define a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSH-

 

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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proposed class includes all Atomic Weapons Employer personnel at the Bethlehem Steel Corporation 

who were monitored or should have been monitored for exposure to uranium during uranium rolling 

activities at the Bethlehem Steel, Lackawanna, New York facility from January 1, 1949 through 

December 31, 1952. The class was expanded because NIOSH determined that the available 

information does not allow NIOSH to definitively link all individuals to their specific work 

title/functions or work locations for the proposed time period; and, that NIOSH has sufficient 

information to reconstruct dose for the broader class. 

4.0 Data Sources Reviewed by NIOSH 

NIOSH identified and reviewed numerous data sources to determine the availability of information 

relevant to determining the feasibility of dose reconstruction for the class of employees proposed for 

this petition. This included determining the availability of information on personal monitoring, area 

monitoring, industrial processes, and radiation source materials. The following subsections 

summarize the data sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

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

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

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

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

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

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

radiological operations at the site. As part of NIOSH’s evaluation of this petition, it examined the 

following TBDs for insights into Bethlehem Steel Corporation operations or related topics/operations 

at other sites: 

• Technical Basis Document: Basis for Development of an Exposure Matrix for Bethlehem Steel 

Corporation, Lackawanna, New York; Period of Operation: 1949-1952; OCAS-TKBS-0003, Rev. 

1; July 27, 2006; SRDB Ref ID: Not available in SRDB 

• Technical Basis Document: Basis for Development of an Exposure Matrix for Bethlehem Steel 

Corporation, Lackawanna, New York; Period of Operation: 1949-1952; ORAUT-TKBS-0001, 

Rev. 1; June 29, 2004 (superseded by OCAS-TKBS-0003 Rev. 0); SRDB Ref ID: Not available in 

SRDB 

• Technical Basis Document: Basis for Development of an Exposure Matrix for Bethlehem Steel 

Corporation, Lackawanna, New York; Period of Operation: 1949-1952; ORAUT-TKBS-0001, 

Rev. 0; June 29, 2004 (superseded by ORAUT-TKBS-0001, Rev. 1); SRDB Ref ID: 19475 

• Technical Basis Document: Site Profile for Simonds Saw and Steel Company, Lockport New York; 

ORAUT-TKBS-0032; Rev. 0; May 31, 2005; SRDB Ref ID: 20181 
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4.2 ORAU Technical Information Bulletins (OTIBs) 

An ORAU Technical Information Bulletin (OTIB) is a general working document that provides 

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

the following OTIBs as part of its evaluation: 

• OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, Revision 

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

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

Facilities, Revision 03, ORAUT-OTIB-004; August 12, 2005; SRDB Ref ID: 19421

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH attended three worker outreach meetings and one Town Hall 

meeting: 1) a May 4, 2004 public meeting; 2) a July, 1, 2004 meeting with the Bethlehem Steel 

Claimants Action Group; 3) a January 12, 2005 Town Hall meeting to discuss modifications and 

updates to the Bethlehem Steel Site Profile and to hear public comment; and 4) a June 21, 2006 

second meeting with the Bethlehem Steel Claimants Action Group. NIOSH also conducted telephone 

interviews with two former site employees. The following subsections describe the worker outreach 

meetings and telephone interviews in more detail. 

4.3.1 Worker Outreach 

Three worker outreach meetings were conducted. A public meeting was held on May 4, 2004 to 

provide information to former Bethlehem Steel employees about the EEOICPA program. In addition, 

two meetings were conducted with the Bethlehem Steel Claimants Action Group: one on July 1, 2004 

and one on June 21, 2006. A Town Hall meeting was also conducted on January 12, 2005. All 

meetings were conducted to solicit questions and/or comments from former Bethlehem Steel 

employees or survivors, and for NIOSH to gather first-hand information about uranium rolling 

activities at Bethlehem Steel. 

In addition to the meetings, members of the public have provided numerous comments and questions 

through written correspondence on behalf of former Bethlehem Steel workers, primarily through the 

representative (also the designated representative for the Bethlehem Steel Special Exposure Cohort 

claim petition) of the Bethlehem Steel Claimants Action Group (Petition Form B, 2006, Submitted 

Comments3

). NIOSH also corresponded with the SEC petition representative, who explained various 

issues related to the Bethlehem Steel dose reconstructions. Specific issues raised during these 

activities are briefly cited in Section 4.3.4 and further evaluated in Section 7.4. 

 

3

 Submitted comments can be located at http://www.cdc.gov/niosh/ocas/bethst.html under the Comments on Bethlehem 

Steel Company Documents heading 
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4.3.2 Advisory Board on Radiation and Worker Health 

The Advisory Board on Radiation and Worker Health held several meetings in various cities across 

the country, for which the Board’s agendas4

 included the Bethlehem Steel Site Profile. These efforts 

focused on addressing concerns from members of the public and discussing proposed updates to the 

site profile. Advisory Board meetings are open to the public and provide an opportunity for members 

of the public to observe the review process and make comments; former Bethlehem Steel workers 

attended several of these ABRWH meetings. Verbatim transcripts of these public meetings can be 

found at www.cdc.gov/NIOSH/OCAS. 

4.3.3 Telephone Interviews 

Due to extensive prior interaction with former Bethlehem Steel workers, NIOSH conducted fewer 

telephone interviews for this evaluation than usual. NIOSH interviewed two former Bethlehem Steel 

employees: the Bethlehem Steel SEC petition designated representative and another individual who 

was present during uranium rolling activities at Bethlehem Steel. Interview questions focused on the 

following issues: cobble cutting activities, conditions in the cooling bed sub-basement, protective 

equipment/practices, and accidents or incidents. Interviewees confirmed that uranium rod cobblecutting was performed by torch-cutting. Interviewees also stated that the cooling bed sub-basement 

was cleaned once or twice a month by using air hoses to blow debris from inaccessible areas, then 

using shovels, brooms, and wheelbarrows to clean the debris off of the sub-basement floor. 

Interviewees also stated that no personal protective equipment was used during uranium rolling 

activities. 

• Personal Communication with Don Lotocki and Ed Walker; Telephone Interview by Jack Beck 

and Libby Gilley; October 26, 2006; SECIS Document ID: 112 and 113 

4.3.4 Bethlehem Steel Corporation Worker Issues 

Former Bethlehem Steel Corporation employees have expressed concerns regarding dose 

reconstructions for Bethlehem Steel workers. The issues were expressed in public meetings, phone 

interviews, and written correspondence. The following is a brief list of those issues. Further details 

can be found in Section 7.4. 

• Information from Simonds Saw and Steel is not a valid comparison to Bethlehem Steel 

Corporation. 

• Other buildings were involved [in uranium work], including the Blooming Mill. 

 

4

 The following meetings included conversations related to the Bethlehem Steel Site Profile: January 2003; ABRWH 

Working Group, March 2004; ABRWH, June 2, 2004; ABRWH, June 3, 2004; ABRWH, December 2004; ABRWH, 

February 7, 2005; ABRWH, February 8, 2005; ABRWH, July 2005; ABRWH, August 2005; ABRWH, October 6, 2005; 

ABRWH, October 17, 2005; ABRWH, October 18, 2005; ABRWH, November 2005; ABRWH, January 2006; ABRWH, 

June 2006; ABRWH, September 2006 
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• NIOSH did not consider [exposures from working in] the sub-basement under the Cooling Bed, 

nor the Cooling Bed above. 

• There are no records for the time period from 1949 through 1950. 

• Workers were not supplied with personal protective equipment. 

• Thirteen ton of radioactive materials were left at the Bethlehem Steel site. 

• The amount of uranium rolling could not have been done in a 10-hour day. 

• The work at Bethlehem Steel involved more manual labor than at Simonds Saw and Steel. 

• The government admits to destroying records. 

• The work areas could not have been cleaned in one day. 

• NIOSH initially stated that the highest dust levels were at the rollers, and then later, NIOSH stated 

the highest exposures were somewhere else. 

• Grinding was not recognized or incorporated in the Bethlehem Steel Technical Basis document. 

• Workers ate and drank in dusty areas and could have ingested uranium. 

• Workers wore contaminated coveralls. 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NOCTS dose reconstruction database to locate EEOICPA-related dose 

reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review for the period of January 1, 1949 through December 31, 1952 

(NOCTS data available as of December 14, 2006). 

Table 4-1: Number of Bethlehem Steel Claims Submitted Under the Dose Reconstruction Rule 

(January 1, 1949 through December 31, 1952) 

Description Totals 

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

criteria 732 

Number of dose reconstructions completed for energy employees who were employed during the 

years identified in the proposed class definition 634 

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

proposed class definition 0 

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

proposed class definition 0 
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NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for each employee. At the time that dose reconstructions were performed, 

NIOSH was not able to obtain personnel dosimetry records for any employee represented in an 

individual claim submitted for dose reconstruction under EEOICPA for the time period of January 1, 

1949 through December 31, 1952. It is apparent to NIOSH that personal radiation monitoring 

information was not collected for Bethlehem Steel workers. As a result, prior dose reconstructions 

have relied on available monitoring data, source term information, production rate records, and air 

sampling data from a site with similar processes. 

As part of the dose reconstruction process, NIOSH conducts Computer Assisted Telephone Interviews 

(CATIs) with claimants to obtain additional information relevant to each dose reconstruction, 

including work locations, hours, job titles, and other information. NIOSH carefully reviewed the 

CATI summary reports to identify information relevant to this evaluation, with particular attention 

given to those interviews with former employees. The interviews provided information regarding the 

number of hours worked and typical working conditions that existed during the covered period. Most 

interviewees reported that no radiological monitoring of any sort was performed. Other individuals 

reported that they did not know if monitoring had been performed. 

4.5 NIOSH Site Research Database 

NIOSH also reviewed its Site Research Database to locate documents supporting the evaluation of the 

proposed class. Currently, there are 141 documents in this database that were identified as pertaining 

to Bethlehem Steel Corporation. These documents were evaluated for their relevance to this petition. 

The documents include historical background on process information for experimental rolling of 

uranium rods, trip reports, and air dust sampling data sheets. There are post-production documents 

that include surveys for residual contamination, Formerly Utilized Site Remedial Action Program 

(FUSRAP) elimination reports, and memos concerning the availability of records. 

4.6 Documentation and/or Affidavits Provided by Petitioners 

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

petitioners (received 03/13/06): 

• Wayne Range Letter, submitted to support the lack of monitoring data, Wayne Range/Bethlehem 

Steel Corporation; June 7, 1976; SECIS Document ID: 9576 

• 69 affidavits, submitted to support the lack of monitoring data, Workers and Survivors/Bethlehem 

Steel Corporation; SECIS Document ID: 9576

5.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize both radiological operations at the Bethlehem Steel Corporation 

from January 1949 to December 1952, and the information available to NIOSH to characterize 
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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 both 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 Bethlehem Steel Corporation Plant and Process Descriptions 

Bethlehem Steel Corporation, one of the largest steel manufacturers in U.S. history, acquired the 

Lackawanna facility in 1922. By the end of World War II, the Lackawanna facility was a large 

complex employing over 20,000 workers with a broad range of production capabilities. In 1947, work 

was completed on a continuous rolling mill known as the 10-Inch Bar Mill. This state of the art mill 

was chosen by the Atomic Energy Commission to assist with experimental uranium rolling work 

(Range, 1976; LaMastra, 1976; Summary 1950-1951). The purpose of this experimental uranium 

rolling work was to assist in the design of the Fernald facility, which was to be based on a continuous 

rolling mill technology such as that used at Bethlehem Steel Corporation. The Atomic Energy 

Commission contracted with Bethlehem Steel Corporation, and records indicate that Bethlehem Steel 

Corporation participated in both experimental and production uranium rolling runs. 

AEC programmatic goals associated with uranium rollings included the following: 

• To evaluate the continuous rolling mill as a source of uranium rods for the plutonium production 

program at Hanford and Savannah River; 

• To gain information during the uranium rollings that would be used for the design of the Fernald 

plant; 

• To evaluate technological improvements leading to reduced oxidation of uranium metal through 

the use of lead bath and salt bath heating (using a combination of lithium and potassium carbonate 

salts) which would reduce losses during rolling; and 

• To evaluate the metallurgical implications of heat treatments for the purpose of improving quality 

during irradiations. 

The specific purpose of the contract with Bethlehem Steel included the following: 

• To finish rolling of bars rough-rolled at Simonds Saw or Aliquippa Forge (Summary 1950-1951); 

• To compare lead bath versus salt bath heating on product and process quality; 

• To heat treat rods and billets (rolled or to be rolled at other facilities), which in some cases also 

included grinding as part of this preparation; and 

• To produce finish-rolled uranium rods from rough-rolled billets. 

The uranium billets were prepared by Mallinckrodt Chemical in St. Louis, Missouri, shipped to the 

rough-rolling mill (Simonds Saw or Aliquippa Forge), and then shipped to Lackawanna in freight cars 
SEC-00056 02-20-2007 Final Bethlehem Steel Corporation

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for finish-rolling. The work only involved the 10-Inch Bar Mill and associated billet preparation and 

handling equipment (LaMastra, 1976; Thornton, 1977; DOE, 1985; Range, 1976; ORNL, 1980), and 

generally took place only on weekends because the mills were in full use five days per week for 

normal steel production. 

According to some accounts, material accountability practices for the project included collection of 

scale, residue, fine debris, and cropped ends. Workers reported the use of vacuum cleaners to assist in 

the cleanup in many areas. These materials were packaged and returned to the AEC, which had a 

documented scrap recovery program (Range, 1976; LaMastra, 1976; ORNL, 1980). Most uranium 

metal accountability records, however, were apparently destroyed (Range, 1976; Fletcher, 1976; 

LaMastra, 1976; ORNL, 1980). A memorandum from the Tonawanda sub-office titled Monthly 

Progress Report for November and dated November 1951, accounts for thirteen bundles of cobbled 

rods and four drums of scrap from the last Bethlehem rolling, occurring in October 1951, that were 

transferred to storage at the Lake Ontario Ordinance Works (LOOW) by personnel from the 

Bethlehem Steel Corporation (Malone, 1951). 

A number of documents provide varied information regarding the time period during which the 

rollings occurred. Some reference memos and reports indicate that all work, which could have 

included rolling work, occurred between 1949 and 1952 (LaMastra, 1976; Summary 1950-1951; 

ORNL 1980; Range, 1976; NLO, 1952). However, NIOSH has only been able to substantiate that 

rollings were performed in 1951 and 1952 (NLO, 1952). Although NIOSH was unable to substantiate 

that uranium rollings were performed in 1949 and 1950, to ensure claimant-favorability in individual 

dose reconstructions, it has been assumed that one rolling occurred per month in the years 1949 and 

1950. NIOSH also obtained a letter from a labor representative in October 1979 asserting that six to 

eight rollings took place in 1955. NIOSH was unable to locate any historical documentation to 

corroborate that rollings were performed on these dates (Kosanovich, 1979) and therefore, did not 

include 1955 in the operational period that was evaluated. The rolling work at Bethlehem Steel 

Corporation was used in the design of a rolling mill at the National Lead Company plant in Fernald, 

Ohio, and by all indications, uranium rolling was transferred to the Fernald Plant around September 

1952 when Fernald began pilot-operations (Range, 1976; NLO,1952; NLO, 1985; LaMastra, 1976). 

Several documents report that AEC personnel were present during all rolling operations, and several 

site-visit reports document these visits. AEC personnel conducted air and surface radioactivity 

monitoring and checked personnel involved in the rolling for contamination during some of the 

uranium rollings (LaMastra, 1976; DOE, 1985; ORNL, 1980). Although some reports indicate that no 

records are available regarding these monitoring activities (Range, 1976; LaMastra, 1976; ORNL, 

1980), a review of AEC historical records has produced several documents containing air sampling 

data from the Health and Safety Laboratory (HASL) and National Lead Company for eight of the 

fourteen rollings from April 1951 through October 1952 at Bethlehem Steel. These documents, 

supplemented with data collected at Simonds Saw and Steel, (which performed similar work), along 

with source-term information gained from AEC uranium rolling production reports (Summary 1950-

1951; OCAS-TKBS-003, Table 1)5

, provide the basis for worker dose estimation methodology. 

 

5

 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source documents: AEC, 

1951-1952 Sample Sheets; AEC, 1952 Sample Sheets; Bowman, 1952; Gardner, 1952; Hershman, 1952; Kattner, 1951; 

Kattner, 1952a; Kattner, 1952b; Kattner, 1952c; NLO, 1952; Reichard, 1951; Riches, 1951; Schneider, No date; Stewart, 

1952 
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Radiological surveys were performed in 1976 and in 1980; the radiological surveys identified no 

residual contamination above natural background levels in the original facility or in the equipment; 

(DOE, 1985; LaMastra, 1976; ORNL, 1980; OCAS-TKBS-0003)6

. 

Table 5-1 summarizes the site development. 

Table 5-1: Bethlehem Steel Company Development Chronology 

Years Buildings Comments Plant Population 

1949-1950 10-Inch Bar 

Mill 

Although no documentation or records have 

been found to substantiate that rolling 

operations were actually performed in this 

period, uranium rolling is assumed to have 

been performed. 

Simonds Saw and Steel is used as a surrogate, 

with no protective coatings or ventilation 

methods applied. 

(This data includes Simonds Saw and 

Steel’s rough-rolling activities.)

All workers are assumed 

affected at the 95th percentile 

value of the maximum dose 

potential data set, with the 

cobble-cutting dose model 

added for suspected cobblecutters. 

January 1951 - 

September 1951 

10-Inch Bar 

Mill 

Lead and salt bath technologies were utilized. 

General area air monitoring was mainly 

performed. 

A breathing zone/general area ratio from 

Simonds Saw & Steel air monitoring data was 

applied to Bethlehem Steel general area air 

monitoring results to derive surrogate 

breathing zone levels at Bethlehem Steel. 

All workers are assumed 

affected at the 95th percentile 

value of the maximum dose 

potential data set, with the 

cobble-cutting dose model 

added for suspected cobblecutters. 

September 1951-

1952 

10-Inch Bar 

Mill 

Salt bath technology was fully employed, 

significantly reducing airborne uranium levels 

at the rollers. Hence, grinding operations 

became the task with maximum dose 

potential. 

All workers are assumed 

affected at the grinding 

airborne level, with the cobblecutting dose model added for 

suspected cobble-cutters. 

5.2 Bethlehem Steel Corporation Functional Areas 

Bethlehem Steel Corporation uranium rolling operations were limited to the 10-Inch Bar Mill, which 

included the following components: 

• Heating furnace and molten lead/salt vats 

• Multi-stage continuous bar rollers 

 

6

 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: 

Kattner, 1952 
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19 of 53 

• Rotary Shear 

• Rod Cooling Bed/Racks (North Side and South Side) 

• North and South Shears 

• North and South Scale Mounted Cradles and Stop-blocks 

• Packaging Area 

Rough-rolled billets were brought to Bethlehem Steel by railcar and were stored during the week for 

finish rolling on the weekends at the 10-Inch Bar Mill. The billets were heated to approximately 

1,200 degrees by submersion into molten lead or salt vats, and then rolled into approximately 1-inch 

diameter rods. Rough ends were cropped, and then the rods were cooled on a two-sided cooling 

bed/rack. Once cooled, the rods were sheared to specified lengths, and bundled for shipment. Handgrinding was sometimes necessary to correct surface imperfections. Occasionally, the rods were 

misfed while passing from one roller stage into the next; the incorrect feeding resulted in the rod 

bending and twisting into what was referred to as a cobble. The cobbles were then, according to 

worker reports, torch-cut into pieces small enough for placement into scrap barrels. These scraps 

were recovered as part of the AEC’s scrap recovery program, which also included other scrap such as 

vacuumed slag and scale. Additional information regarding Bethlehem Steel Corporation uranium 

rolling operations can also be found in OCAS-TKBS-0003. 

5.3 Radiological Exposure Sources from Bethlehem Steel Operations 

The Bethlehem Steel Corporation had only one process involving radioactive material: rolling natural 

uranium metal. This process included receipt of rough-rolled uranium billets, lead or salt bath heating 

of the billets, finish-rolling the billets into approximately one-inch diameter bars, shearing off rough 

ends, air-cooling the bars, grinding off surface imperfections, cutting the rods into four-inch and eightinch slugs, and packaging slugs for shipment. Also included was scrap recovery, in which slag, 

debris, and cobbles (produced when rods did not feed correctly into the successive rollers) were 

collected and cut into pieces and collected in drums. The scrap materials were then packaged for 

shipment. 

5.3.1 Alpha Particle Emissions 

Alpha particle emissions from natural uranium processed at Bethlehem Steel presented the greatest 

potential for internal radiation exposure through internal deposition via inhalation and ingestion (alpha 

particles do not present an external exposure hazard). Processed natural uranium consists of 

approximately equal activities of uranium-238 [4.20 MeV and 4.15 MeV alpha particles] and 

uranium-234 [4.77 MeV and 4.73 MeV alpha particles] (Radiological Health, 1970). There are 

smaller amounts of uranium-235 (approximately 1/20 of the activity levels of uranium-238 or 

uranium-234) with alpha particles of 4.40 MeV and 4.36 MeV. 

5.3.2 Beta Radiation Fields 
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Beta particle radiation was the dominant source of external radiation exposure associated with 

uranium rolling activities at Bethlehem Steel. The dominant beta radiation from natural uranium is 

from the uranium-238 decay products. The most energetic of these beta particles is from 

protactinium-234m [2.29 MeV]. The surface beta dose rate from a uranium slab is approximately 230 

millirad (mrad) per hour. 

5.3.3 Neutron Exposures 

Neutron exposures were not evaluated for Bethlehem Steel because they are negligible for natural 

uranium metal-handling facilities (ORAUT-OTIB-0004). 

5.3.4 Photon Exposures 

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

contrast, solid uranium objects provide considerable shielding of the lower-energy photons and 

“harden” the spectrum, causing the majority of photons emitted from a solid uranium object (e.g., a 

billet or rod) to have energies greater than 250 keV. While it is recognized that solid uranium sources 

have a hardened photon spectrum, exposure to a thin layer of uranium results in a larger fraction of 

exposure to lower-energy photons. Therefore, for the purposes of this evaluation, deep dose estimates 

from the uranium sources at Bethlehem Steel are evenly distributed between photons with E=30-250 

keV and photons with E>250 keV, which is consistent with the Bethlehem Steel Technical Basis 

Document (OCAS-TKBS-0003). 

6.0 Summary of Available Monitoring Data for the Proposed Class 

Dose estimates for workers at Bethlehem Steel are based on a compilation of data sources. The 

available sources of monitoring data are listed below: 

• Simonds Saw and Steel work area and breathing zone air monitoring (surrogate data for 

Bethlehem Steel for years 1949 through 1950) 

• Bethlehem Steel work area air monitoring for years 1951 through 1952 

• Simonds Saw and Steel surface contamination monitoring for 1948 

• Bethlehem Steel surface contamination monitoring for 1952 

• Source term and process information; information from contract language and production reports 

Work area air monitoring was performed at Bethlehem Steel during the years 1951 through 1952, but 

no records of air monitoring for Bethlehem Steel for the years 1949 through 1950 have been located. 

However, work area and breathing zone air monitoring was performed at Simonds Saw and Steel from 

1949 through 1950, and due to the similarities of the work processes for Simonds Saw and Steel and 

Bethlehem Steel Corporation, data from Simonds Saw and Steel were deemed appropriate for 

bounding dose determinations for uranium rolling operations at Bethlehem Steel during the years 

1949 and 1950. Data from work area air monitoring performed at Bethlehem Steel during the years 
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1951 and 1952 and the application of a derived work area/breathing zone ratio from the Simonds Saw 

and Steel data, present a reasonable approach for determining bounding airborne radioactivity levels 

during the years of 1951 through 1952. 

Surface contamination monitoring was performed at Simonds Saw and Steel in 1948, and also at 

Bethlehem Steel Corporation in 1952. These data were utilized in the Bethlehem Steel Technical 

Basis Document to establish a correlation between surface contamination and airborne contamination 

levels. This correlation was then used to develop a dose model relating worker ingestion rates to 

airborne concentrations. 

Production reports for the uranium rolling activities at Bethlehem Steel are available for the years 

1951 and 1952 and provide a means for determining source term data, which are beneficial for 

determining bounding dose estimates for internal and external exposure to residual contamination and 

from direct handling of uranium metal. 

6.1 Bethlehem Steel Corporation Internal Monitoring Data 

NIOSH reviewed AEC historical records and found no evidence of personnel internal monitoring at 

Bethlehem Steel. Therefore, personnel internal dose estimates will be based on air monitoring, 

surface contamination monitoring, and source term data. 

6.2 Bethlehem Steel Corporation External Monitoring Data 

No external dosimetry data are available for Bethlehem Steel. However, dose rates from submersion 

in a cloud of uranium dust, direct exposure to uranium metal, exposure to workers from residual 

contamination, or from re-use of contaminated work clothing can be estimated by application of the 

rolling information, residual contamination estimates, and exposure rate constants for uranium 

materials. 

6.3 Air Sampling Data 

Records show that work area air monitoring was performed at Bethlehem Steel for the years 1951and 

1952; but, no records of air monitoring at Bethlehem Steel for the years 1949 through 1950 have been 

located (this is consistent with the absence of documentation of uranium rolling in 1949 and 1950). 

NIOSH has assumed, for claimant favorability that rollings occurred in 1949 and 1950. Simonds Saw 

and Steel was then considered as a source for surrogate air monitoring data for the years 1949 and 

1950 because extensive air monitoring had been performed at Simonds Saw and Steel and Simonds 

had work processes that were similar to those at Bethlehem Steel. The air monitoring at both 

Bethlehem Steel Corporation and Simonds Saw and Steel was performed by representatives from 

Health and Safety Laboratory (HASL). A detailed discussion of the application of Simonds Saw and 

Steel air monitoring data to work performed at Bethlehem Steel is provided in Section 7.4.1. 

6.3.1 Simonds Saw and Steel Air Sampling 

Simonds Saw and Steel began rolling uranium in February 1948 and continued serving as a principal 

source of rolled uranium for several years. In October 1948, prior to the implementation of any air 

control measures, AEC collected a variety of air and urine samples from Simonds Saw and Steel 
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workers; these included 22 breathing zone samples and 15 general area samples. Several controls and 

a sample from the stack were also collected (OCAS-TKBS-0003). AEC’s next visit, December 1, 

1948, found improvements in the air control measures, including exhaust ventilation over each of the 

operating rolls, the central vacuum cleaner was discharged outside, and a temporary enclosure was 

provided over the de-scaling device (OCAS-TKBS-0003)7. Although improvements in ventilation 

were later made and documented in various reports, the Simonds Saw and Steel data from October 

1948 (before ventilation changes) is the only Simonds Saw and Steel data used to support the internal 

dose estimates for Bethlehem Steel’s Lackawanna facility. It is important to note that the Simonds 

Saw and Steel data exceeds that directly measured at Bethlehem Steel by approximately 100% and 

that a number of factors described in Section 7.4.1 indicate that the Simonds Saw and Steel data 

represent claimant-favorable exposure levels. 

6.3.2 Bethlehem Steel Corporation Air Sampling 

Several documents report that AEC personnel were present during all rolling operations, and several 

site visit reports document these visits. During some of these rollings, AEC personnel conducted air 

and surface radioactivity monitoring and checked personnel involved in the rolling for contamination 

(OCAS-TKBS-0003; ORNL 1980). NIOSH’s review of AEC historical records, however, showed 

several documents containing air sampling data from HASL and National Lead Company for the 

rollings shown in Table 1 of the Bethlehem Steel TBD (OCAS-TKBS-0003). These records 

document 203 legible results for air samples which were taken at various locations during eight of the 

fourteen rollings during 1951 and 1952. Five of these samples were quality control samples and were 

not used in data analyses for dose reconstruction purposes. 

7.0 Feasibility of Dose Reconstruction for the Proposed Class 

The feasibility determination for the proposed class of employees covered by this evaluation 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 was 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 (discussed in Section 9.0). 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, which together or individually might enable NIOSH to estimate either the 

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

the variability of exposures experienced by groups or individual members of the class as summarized 

in Section 7.6. This approach is discussed in OCAS’s SEC Petition Evaluation Internal Procedures 

 

7

 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: AEC, 

1948 
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23 of 53 

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-00056 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Data 

This subsection answers questions that must be asked before a feasibility evaluation is performed. 

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

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

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

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

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

7.1.1 Internal Data Review 

As mentioned previously, the monitoring data available for performing Bethlehem Steel dose 

reconstructions are primarily air sample data collected from Bethlehem Steel Corporation and 

Simonds Saw and Steel. The AEC Health and Safety Laboratory provided a detailed description of 

the methods and background on air monitoring and exposure assessment utilized at these sites (DOE, 

1982). This assessment was provided in a 1973 HASL manual. The detailed description of the 

concept of representative workplace monitoring was written by A. J. Breslin, Director, Health 

Protection Engineering Division, HASL. (Note that Mr. Breslin was one of the sample collection 

scientists for the Bethlehem Steel Corporation’s uranium dust monitoring data.) Breslin’s write-up 

provides a detailed discussion of the type of samples taken, how they were taken, how they were 

analyzed, and how the results should be interpreted. The discussion of sampling locations, 

designation of sampling sites and the job task analysis sheets contained in this document are 

consistent with the sampling strategy employed at both Simonds Saw and Steel and Bethlehem Steel 

Corporation. The following text, as excerpted from (DOE, 1982), provides a summary description of 

the various sample types and methodologies used by HASL to evaluate representative exposure. 

Please also note that from the early days of operation, HASL relied on time-weighted average 

exposure measurements to assess inhalation hazards in the workplace (OCAS-TKBS-0003). 

Breathing Zone Samples - Typically, a worker performs a few operations in which he 

may come into close or direct contact with the hazardous material. Examples of these 

operations are operating a machine tool, charging a furnace, working at a chemical 

hood, changing the glove on a dry box, or any one of a hundred maintenance tasks that 

involve the dismantling of or entrance to equipment. At jobs such as these, dust 

concentrations are apt to be much greater than in the general area. Therefore, these 

activities may influence the average exposure far out of proportion to their duration. 

To measure accurately the concentration to which a worker is exposed while 
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performing such a task, a breathing zone (BZ) sample must be collected. The sampling 

instrument is held in the vicinity of the worker’s breathing area for the duration of the 

task. It should be held as close to his nose as possible short of interfering with his 

freedom of movement, because in situations where dust is escaping from a small 

aperture, concentration gradients around a source can be sharp. In one uranium plant, 

samples collected one foot apart at certain operations have shown concentration 

differences of twenty-fold. On the other hand, a sample collected so close as to 

interfere with the worker’s movements is invalid because the job cannot be performed 

in the normal fashion. A small deviation in work habit may alter the dust concentration 

markedly. 

General Air Samples - Usually, the total time spent by a worker on operations 

requiring BZ samples constitutes a small fraction of the day. There are, of course, 

exceptions... Worker exposure during the balance of the work day may be 

characterized by samples collected of the general air (GA) in the area that he occupies. 

A GA samples is one that is collected at a fixed location during a sustained sampling 

period. To be meaningful, the sample must be collected within an occupied area but 

also it must be away from dust sources except those that may dominate the area. 

Customarily, the sampling instrument is placed at a height from four to six feet from the 

floor although in a heavily trafficked area, the instrument must be placed over the 

heads of the workers to avoid interference with the normal work routine.... 

Process Samples - There is yet another kind of air sample that is often useful, the 

process sample. It is used to identify sources of air contamination or to determine the 

relative strengths of two or more sources. Process samples are distinguished from BZ 

and GA samples by the fact that they are taken in and around process equipment at 

locations where employees normally are not exposed. For this reason they should 

never be used in the evaluation of occupational exposure. 

As an example, a process sample might be collected directly over a furnace to determine 

the amount of radioactivity that is carried by convection from the furnace to the room. 

The concentration at that point is not representative of an employee’s exposure. 

The sampling methods, as listed above, meet the most current recommendations from ICRP 

Publication 75 for collecting representative samples to determine exposure (OCAS-TKBS-0003)8

. 

The breathing zone samples collected by HASL were held in a position to represent the breathing zone 

and are not associated with a fixed sampler. General area samples were taken with the expressed 

purpose of evaluating non-localized releases to which an employee could be exposed during the 

course of the day. Finally, process samples that were obtained during the measurement period were to 

assess source terms and are not indicative of concentrations to which workers may have been exposed. 

While the standards and requirements for radiological counting and sampling equipment have changed 

significantly over the history of health physics and industrial hygiene, it is clear that the variation in 

the instrument calibration data over this time have contributed to a relatively small variation in air 

sample data uncertainty as compared to large changes in air concentration (as a function of time and 

 

8

 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: ICRP, 

1998 
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location). Though OCAS-TKBS-0003 does not use time-weighted averages to determine exposure to 

uranium dust, HASL reported that time-weighted averages of exposure were consistent with results 

obtained from personal lapel-mounted air samplers (after the lapel sample data became available in 

the late 1960s) (OCAS-TKBS-0003)9

. This consistency provides additional support for the reliability 

of the data and the use of time-weighted average air sample results to estimate exposure. 

7.1.2 External Data Review 

No external dosimetry data are available for Bethlehem Steel. External exposures to workers can be 

estimated, however, by using uranium rolling information, residual contamination estimates, and 

exposure rate constants for uranium materials. Uranium rolling reports indicate the amount of uranium 

materials processed and provide a means for determining source-term estimates. Air monitoring and 

surface contamination monitoring data can be used to determine an upper-bound estimate of residual 

contamination levels. External dose rates from uranium metals have been studied and documented, 

and provide a means, when coupled with source-term estimates, of estimating external dose from 

direct contact with uranium metal. External dose is further described in Section 7.3. 

7.2 Internal Radiation Doses at Bethlehem Steel Corporation 

The principal source of internal radiation doses for members of the proposed class includes inhalation 

and ingestion of various uranium oxides that resulted from the production of uranium metal rods. 

Intake of these contaminants could have resulted from either routine or non-routine events. Routine 

operations that could directly cause airborne radioactivity or release contamination to work surfaces 

where it could be re-suspended included heating, rolling, cutting, and grinding (by machine and hand). 

7.2.1 Process-Related Internal Doses at Bethlehem Steel 

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

reconstructing the process-related internal doses of members of the proposed class. 

Because exposure potentials were process-specific and varied over time, and because the availability 

of site-specific air monitoring data also varied with time, evaluation of the feasibility of dose 

reconstruction for the proposed class is divided into specific timeframes and activities and is presented 

accordingly in following subsections. For example, no records of any air sampling are known to exist 

for 1949 or 1950 at Lackawanna. Additionally, NIOSH has not discovered any documentation that 

confirms that uranium rolling occurred in 1949 or 1950. Thus, this time period was evaluated using 

the data collected at Simonds Saw and Steel on October 27, 1948, prior to the implementation of any 

ventilation controls. Data from 1951 and 1952 were divided into two periods to reflect changes that 

occurred in the processing technologies (e.g., the change from lead bath and salt bath heating to only 

using salt bath heating). In summary, evaluation of internal dose from inhalation of contaminants was 

split into three periods: (1) January 1949 through December 1950 (Subsection 7.2.1.1); (2) January 

1951 through September, 1951 (Subsection 7.2.1.2); and (3) October 1951 thru December 1952 

(Subsection 7.2.1.3). A special exposure scenario for workers who participated in the cutting of 

 

9

 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: 

Breslin, 1967 
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cobbles was established and is described in Subsection 7.2.1.4. Evaluation of internal doses due to 

ingestion and residual contamination is presented in Subsections 7.2.1.5 and 7.2.1.6. 

7.2.1.1 Evaluation of Inhalation Exposure: January 1949-December 1950

NIOSH has not located any production, monitoring, or inspection records indicating that Bethlehem 

Steel processed uranium for DOE or its predecessors prior to 1951. However, the Technical Basis 

Document: Basis for Development of an Exposure Matrix for Bethlehem Steel Corporation, 

Lackawanna, New York; Period of Operation: 1949-1952 indicates that a 1976 memo from the 

Energy Research and Development Administration (ERDA), which provides details recalled by 

retirees of the AEC who had knowledge of the company’s operations; a memo by a plant radiological 

control engineer who used the 1976 memo from Range as a source along with discussions with plant 

personnel(Range, 1976); and a 1977 memo from Thornton (Thornton, 1977) as part of the ERDA 

resurvey program who based the time estimates on a discussion with LaMastra, have all been used to 

justify the 1949 to 1950 timeframe (Range, 1976; LaMastra, 1976; Thornton, 1977). Because there 

are no records documenting rollings at Bethlehem Steel for the 1949 through 1950 time period, and 

because the use of Bethlehem Steel data for uranium dust exposure assessment prior to 1951 may be 

inappropriate (lead bath heating may not have been performed), data from Simonds Saw and Steel will 

be used as a surrogate for the determination of dose for the 1949 through 1950 time period at 

Bethlehem Steel Corporation. The appropriateness of using Simonds Saw and Steel as a surrogate 

facility (discussed earlier in this document) is discussed at greater length in the Technical Basis 

Document: Basis for Development of an Exposure Matrix for Bethlehem Steel Corporation, 

Lackawanna, New York; Period of Operation: 1949-1952, and was the subject of significant review 

by the Advisory Board on Radiation and Worker Health (ABRWH or the Board). 

HASL visited Simonds Saw and Steel on October 27, 1948 and collected 37 particulate air samples 

that were used to evaluate the time-weighted average exposure to various job categories at the plant. 

These samples included 22 breathing zone samples and 15 general area samples. Several controls and 

a sample from the stack were also collected. The median length of time of collection for a breathing 

zone sample was 0.71 minutes (range 0.5 to 2.5 minutes) while general area samples typically were 

collected over a much longer time (median 15 minutes, range 3 to 45 minutes). To prevent severe 

dust loading of the filters, the shorter sampling times were used by HASL in areas with high expected 

dust concentrations. To improve statistics associated with sample counting, longer sampling times 

were used in areas of expected low dust concentrations. 

The data include various locations throughout the mill areas. Some of these locations represent higher 

air concentrations than others. Therefore, assigning the distribution could underestimate an 

individual’s intake for someone located in one of the higher air concentration areas for extended 

periods of time. Thus, in order to prevent a dose from being underestimated, the 95th percentile of 

this distribution will be assumed for exposure estimates. This value will be assumed to be present in 

the breathing zone 100% of the time and be assigned as a constant. Figure 7-1 plots the distribution of 

uranium concentrations observed at Simonds Saw and Steel during this period of no ventilation. The 

95th percentile of this distribution, 553 MAC (38,710 dpm m-3 of natural uranium), will be used as the 

basis for evaluation of inhalation exposure during the 1949 through 1950 time period (TKBS-OCAS0003). 
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Figure 7-1 demonstrates the distribution and fit of uranium dust concentration data taken from 

Simonds Saw and Steel on October 27, 1948 (MAC=70 dpm m-3). 

z score

-3 -2 -1 0 1 2 3

uranium dust concentration, dpm m-3

1

10

100

1000

10000

100000

1000000

95th percentile (553 MAC)

0.98

concentration e

2

7.071 2.124(z)

=

= +

R

Figure 7-1: Uranium Dust Data from Simonds Saw and Steel: October 27, 1948 

7.2.1.2 Evaluation of Inhalation Exposures: January 1951-September 1951

As previously discussed, the air sample data from Bethlehem Steel consist of a total of 204 air sample 

results, drawn and analyzed by HASL and National Lead. Personnel from National Lead were 

originally from HASL and used the same approaches and time weighted averages. These samples 

were collected on various days of rolling in 1951 and 1952. Sample types included general area (GA), 

breathing zone (BZ), and process samples. Of the 204 samples, one sample was found to be illegible 

(after reviewing the original records) and five were quality control samples; these six samples were 

not used in this analysis. Evaluation of the 204 samples found that changes in the process methods 

clearly impacted the air concentration data. This was reflected in both the monthly HASL reports and 

reports written by Hanford personnel who participated in those process changes. 

The period from January 1951 to September 1951 was identified by NIOSH as the phase in which 

lead and salt bath technologies were both being evaluated at Bethlehem Steel. It was recognized that 

the number of breathing zone samples was a much lower fraction of the total samples as compared to 

the Simonds Saw and Steel measurements used to evaluate the 1949 to 1950 time period. For this 

reason, a breathing zone sample surrogate (BZ-GA) was developed to evaluate the breathing zone-to-
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general air sample concentrations at Simonds Saw and Steel, and to apply this factor to the general air 

samples gathered during this early 1951 period. 

Both section 7.4.6 of this document and OCAS-TKBS-0003 discus the role that the Bethlehem Steel 

Corporation Lackawanna Rolling Mill played in the development of continuous rolling experiments 

for Hanford. Both documents also discuss the comparison of lead and salt bath heating. Only the first 

four experimental runs conducted in 1951 were known to have used the lead bath heating. Air 

sampling was conducted on three of those experimental runs. While it is known that the salt produced 

a more effective coating for reducing oxidation hence uranium dust, the data have been evaluated 

together to determine the 95% air concentration data. 

Figure 7-2 graphically analyzes data from this time period prior to augmentation. Figure 7-3 shows 

the analysis of the augmented data set (which includes BZ-GA samples). The 225 MAC (15750 dpm 

m-3) air concentration represents the 95% level, which can be used for analysis of uranium air 

concentration during rolling days for this early 1951 period. 

Figure 7-2 displays the distribution and fit of uranium dust concentration data, prior to augmentation 

with BZ-GA samples, obtained at Bethlehem Steel from January 1951 through September 1951 

(MAC=70 dpm m-3). 

z score

-1.0 -0.5 0.0 0.5 1.0 1.5 2.0 2.5 3.0

uranium dust concentration, dpm m-3

1

10

100

1000

10000

100000

1000000

95th percentile prior to augmentation (87 MAC)

0.970 2 R

(3.758 3.013(z)) ) e 3 concentration(dpm/m

=

+ =

Figure 7-2: Uranium Dust Data from Bethlehem Steel: Jan.–Sept. 1951 (prior to augmentation) 
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Figure 7-3 displays the distribution and fit of uranium dust concentration data obtained at Bethlehem 

Steel from January 1951 through September 1951—augmented to include BZ-GA samples (MAC=70 

dpm m-3), with 225 MAC (1575 dpm m-3) as the air concentration level to be used for the assessment 

of rolling day intakes for this period. 

z score

-0.5 0.0 0.5 1.0 1.5 2.0 2.5 3.0

uranium dust concentration, dpm m-3

1

10

100

1000

10000

100000

1000000

10000000

 95th percentile (225 MAC)

0.976 2 R

(4.006 3.440(z)) ) e 3 concentration(dpm/m

=

+ =

Figure 7-3: Uranium Dust Data from Bethlehem Steel: Jan.-Sept. 1951 (after augmentation) 

7.2.1.3 Evaluation of the Inhalation Exposure: October 1951-December 1952

The majority of uranium airborne contamination in the early period at Bethlehem Steel was caused by 

the actual rolling of uranium metal. However, after the salt bath furnace was utilized, airborne 

contamination from the rolling operations greatly decreased. The median value of all the air samples 

collected from the rolling operations areas from late 1951 through 1952 is slightly less than 0.2 MAC. 

This means that other previously minor sources of airborne contamination are now accounted for the 

highest exposure potentials at the plant. Air monitoring data from these other areas, therefore, provide 

the airborne contaminant concentrations necessary for bounding worker exposures. 
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Grinding of the uranium billets to remove surface imperfections for some of the rollings was one such 

documented operation at Bethlehem Steel. A single process air sample was obtained for this 

operation. The air sample (70 MAC) was actually the highest recorded at Bethlehem Steel during the 

1951 through 1952 time frame. This value can be used to estimate the air concentrations for the later 

period at Bethlehem Steel. 

As with previous time periods, NIOSH has assumed that the operators inhaled the 70 MAC 

concentration continuously for a 10-hour work day (on days when uranium rolling occurred). Based 

on measurements taken at the Joslyn Steel plant while grinding on uranium metal (both breathing zone 

and general air samples), air concentration ranged from 0.4 MAC to 17 MAC (OCAS-TKBS-0003). 

These concentrations indicate that the 70 MAC concentration, which was determined from a process 

sample, provides a reasonable and claimant favorable upper bound dose to the operation. 

While there may have been other sources of airborne contamination, it is likely that this estimate, with 

the exception of an exposure category of workers (cobble cutters) discussed below, is a bounding 

estimate. For other sources to be bounding, they would have to produce greater than 700 MAC-hours 

of exposure per day (70 MAC times 10-hours per day). This would require any other operation to not 

only create higher air concentrations, but to do so routinely. The most likely routine source of elevated 

airborne activity that has been postulated at Bethlehem Steel is the cutting of cobbles (OCAS-TKBS0003)10. 

7.2.1.4 Evaluation of Intakes to Cobble Cutters: 1949-1952

In brief, cobbles are bent rods that are formed when a bar of metal is misfed from one stand into the 

next. Workers indicated that cobbles would have been removed from the mill in the most expeditious 

manner possible, utilizing an overhead crane whenever possible (OCAS-TKBS-0003). Worker 

information was confirmed in the documentation NIOSH reviewed on cobbles, which indicates that 

there was a fairly short time-span between a cobble being removed and the next sample passing 

through the stand. The short time-span was a result of workers cutting the cobbles at the stands only 

if it were necessary for their removal from the mill. Analysis of the time required for each rod rolled 

shows that cobbling did not grossly impact the production rate; this is further indication of the 

efficiency of the removal process. After removal, the cobbles were taken elsewhere for any additional 

cutting to return them to scrap (OCAS-TKBS-0003). 

Test and production records indicate that during initial testing, a higher percentage of cobbles 

occurred during the initial testing than later in the production process. However, an evaluation of 

Bethlehem Steel records indicates that this initially higher rate of cobbling was offset by a lower total 

number of billets rolled. That is, despite a general increase in the numbers of billets rolled/day over 

time, the number of cobbles encountered per day remained relatively constant (~3.5 cobbles/day). 

Based on interviews with workers, the time required to cut uranium cobbles varied between five 

minutes and one hour (Summary Notes, 2006; NIOSH, 2006). Potential methods of cutting uranium 

cobbles included using a torch, power saw, and/or shears. Worker accounts from several meetings 

indicate that torch cutting was the method used at Bethlehem Steel Corporation. NIOSH has 

 

10 The Bethlehem Steel Site Profile referenced Transcript November 28, 2005 as the source document. We were unable to 

locate this specific source document. However, related source document include Conference Call Notes, 2005a ; 

Conference Call Notes, 2005b 
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previously expressed reservations that, while torch cutting might have been used to cut steel cobbles, 

it would not necessarily be the best method to cut uranium. This is due to the pyrophorric nature of 

uranium, which would have a tendency to ignite while being cut with a torch. However, NIOSH has 

included an approach to estimate cobble cutters’ exposures from torch cutting of uranium as a 

claimant-favorable assumption (OCAS-TKBS-0003). 

The exposure to the cobble worker can be evaluated based on an average of two-hours per day 

engaging in torch cutting of cobbles. The time is based on an average reported during worker 

interviews and compared to published values for the cutting of stainless steel with acetylene torch. 

The latter values reported cutting time for stainless steel ranging from 2 to 4.2 minutes (3.6 minute 

mean) per cut of a 5-centimeter stainless steel pipe of 0.4 cm wall thickness (OCAS-TKBS-0003)11. 

Air concentrations are based on expected sustainable levels of contamination of 600 MAC, which is 

higher than both the largest air concentration documented at Bethlehem Steel and higher than the air 

concentration used to evaluate exposures at Bethlehem Steel during the 1949 to 1950 time-span. This 

air concentration is based on estimated bounding levels of sustainable airborne contamination 

concentrations over the course of this two-hour period from torch cutting (OCAS-TKBS-0003)12. 

7.2.1.5 Evaluation of Ingestion Dose

Ingestion intakes can be most closely related to surface contamination values. Very few 

measurements exist for surface contamination. However, airborne contamination levels and surface 

contamination levels are generally related. To evaluate the relationship between air contamination 

and surface contamination, NIOSH reviewed the available air and surface contamination 

measurements at Simonds Saw and Steel and Bethlehem Steel. 

Air and surface contamination measurement data for Bethlehem Steel data were available for a rolling 

that took place on September 14, 1952. The Bethlehem Steel surface contamination data were 

obtained by smears wiped over a 100 cm2

 area. As such, the smears represent only the removable 

portion of the contamination. 

At Simonds Saw and Steel, air and surface contamination measurements were taken during a uranium 

rolling campaign that took place on October 27, 1948. The Simonds Saw surface contamination data 

were direct measurements made with a portable instrument called a Zeuto. This type of instrument 

has an active surface measurement area that is three inches by four inches, or approximately 75 cm2

. 

Each rolling stand at both Bethlehem Steel Corporation and Simonds Saw and Steel was evaluated. In 

addition, the shear at Bethlehem Steel Corporation was also evaluated. Stand Number Six at 

Bethlehem Steel was not evaluated because the surface smear indicated no detectable activity. Where 

more than one sample was taken, the results were averaged. Table 7-1 and Table 7-2 show the 

average air and surface contamination measurements for various locations. The surface contamination 

measurements at Simonds Saw were normalized to 100 cm2 (OCAS-TKBS-0003). 

 

11 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: 

Newton, 1987 

12 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source documents: 

Conference Call Notes, 2005a ; Conference Call Notes, 2005b; SC&A, 2005 
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Table 7-1: Simonds Saw and Steel-Air and Surface Contamination Values 

Table 7-1: Simonds Saw and Steel-Air and Surface Contamination Values 

Air sample Air concentration 

(dpm/m3) 

Surface Contamination 

Location 

Surface Contamination Value 

(dpm/100 cm2) 

L709 49,000 - - 

L710 75,000 East Roller 1 50,000 

L711 22,400 West Roller 1 35,000 

Average 48,800 Average 42,500 

 

L718 14800 - - 

L719 23800 - - 

L720 27900 - - 

L721 943 - - 

L722 836 - - 

L723 418 West Roller 2 15,000 

Average 11,449.5 Average 15,000 

Notes: 

Source of data is OCAS-TKBS-0003 

- indicates no data available 

Table 7-2: Bethlehem Steel Corporation-Air and Surface Contamination Values 

Table 7-2: Bethlehem Steel Corporation-Air and Surface Contamination Values 

Air sample Air concentration 

(dpm/m3) 

Surface Contamination 

Location 

Surface Contamination Value 

(dpm/100 cm2) 

Q921 2,076 - -

Q922 2,973 Shear 679 

Q923 1,080 Shear 404 

Average 2,043 Average 541.5 

 

Q903 3 - -

Q905 10 Stand 1 2 

Average 6.5 Average 2 
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Table 7-2: Bethlehem Steel Corporation-Air and Surface Contamination Values 

Air sample Air concentration 

(dpm/m3) 

Surface Contamination 

Location 

Surface Contamination Value 

(dpm/100 cm2) 

 

Q906 10 - -

Q908 12 Stand 2 9 

Average 11 Average 9 

 

Q909 18 - -

Q911 14 Stand 3 6 

Average 16 Average 6 

 

Q912 13 - -

Q913 10 - -

Q920 6 Stand 4 5 

Average 9.7 Average 5 

 

Q914 12 - -

Q915 3 - -

Q919 12 Stand 5 9 

Average 9 Average 9 

Notes: 

Source of data is OCAS-TKBS-0003 

- indicates no data available 

As in Tables 7-1 and 7-2, Figure 7-4 demonstrates the observed air concentration and surface 

contamination levels at Simonds Saw and Steel and Bethlehem Steel Corporation. Plotting the 

average surface and air concentrations shown in the above two tables, Figure 7-4 clearly indicates that 

the surface contamination is proportional to the air contamination. It should also be noted that this 

proportional relationship is internally consistent at the two facilities. That is, high airborne activity is 

predictive of high surface contamination levels, and vice versa. This means that if any large particle 

surface contamination that does not add to the air concentrations exists, the fraction of surface 

contamination represented by this is consistent across locations, sites, and concentrations. Using this 

relationship, NIOSH developed a model that relates the ingestion rate to air concentrations. This 

model can then be used to conservatively estimate internal doses due to ingestion (see OCAS-TKBS0003 for model application details). 
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Air Concentration (dpm per m3)

1 10 100 1000 10000 100000

Surface Contamination (dpm per 100 cm2

)

1

10

100

1000

10000

100000

Figure 7-4: Air Concentration and Surface Contamination Levels at Simonds Saw and Steel and Bethlehem Steel 

7.2.1.6 Evaluation of Inhalation and Ingestion Doses due to Residual Contamination

Following rolling operations, residual contamination would have been present in the form of uranium 

oxide dust on the floor and on other horizontal surfaces. While no surface or airborne contamination 

surveys could be found from Bethlehem Steel during days in which only steel was processed, NIOSH 

noted that because the 10-Inch Bar Mill was being fully utilized for steel production during the week, 

uranium rolling occurred primarily during weekends. 

The principal product of Bethlehem Steel’s Rolling Mill, measured in thousands of tons per year, was 

steel. On days in which Bethlehem Steel was not rolling uranium, steel was being produced. Because 

the production of steel generates large quantities of dust and debris and because as steel is rolled, a 

coating of this dust is likely to settle on top of any uranium contamination, the debris from the steel 

would have acted as a protective layer, making it less likely that the uranium would be re-suspended. 

However, as uranium contamination is re-suspended in the air, it settles back to horizontal surfaces 

and essentially forms a mixture of uranium and steel. This mixture would then allow uranium to 

continue to be re-suspended, but only as part of a mixture. The re-suspension of the material would 

have required some mode of force, such as ventilation, foot or vehicular traffic, etc. It is likely the 

same type of forces exist whether the mill was rolling steel or uranium. It is therefore likely that the 
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same mass of material may be re-suspended at any given time. As the steel debris builds up, this resuspended material is composed of fractionally less uranium and more steel. 

The dose from residual contamination can be determined based on the above operations, which result 

in the re-suspension of contamination. NIOSH has assumed the uranium contamination to be diluted 

by additional rollings of steel occurring between uranium rollings. For the purposes of this model, 

NIOSH has also assumed that an equal mass of steel is added to the uranium each day. This is a 

conservative estimate because the steel production was measured in thousands of tons per year while 

uranium was rolled only on a limited basis (on the order of a few hundred tons). The material 

available for re-suspension one day after uranium rolling would therefore be one part uranium and one 

part steel. On the following day, the material would be one part uranium and two parts steel, and so 

on. 

While rolling operations could result in high localized air concentrations, air concentrations from resuspension of residual contamination would be more consistent throughout the area. Therefore, the 

median general air concentrations are used as the starting point. This value is then assumed to 

decrease in the days following uranium rolling as described above. The average air concentration due 

to re-suspension of residual contamination can be estimated using the following expression: 

*0.117

29

ln( ) *

29

/

* .

30

1

.

30

1

Avg Int. Int CInt

t C

dt t

C = C = =

∫

Where: 

CAvg. = the average air concentration through the 29 days following a rolling operation; 

CInt. = the median general air concentration on the day of rolling; and 

t = the number of days following the day of rolling. 

The median general area air sample concentrations for the three time periods are listed in Table 7-3. 

Table 7-3: Median General Area Air Sample Concentrations 

Site Median General Area Air Samples 

(MAC) 

Simonds Saw and Steel (1949-1950) 4.13 

Bethlehem Steel (early 1951) 0.215 

Bethlehem Steel (1951-1952) 0.081 

The same method can be used for ingestion; however, the initial concentration factor is replaced by 

the daily ingestion rate on rolling days. 

7.2.2 Ambient Environmental Internal Radiation Doses at Bethlehem Steel 

Occupational environmental dose provides a mechanism to account for ambient dose on site that has 

not been either monitored or attributed to occupational exposure. The exposures of all employees of 
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the Bethlehem Steel Corporation will be estimated based on the 95% air concentration at the Rolling 

Mill for a 10-hour day. This estimate precludes the use of environmental dose, which would be much 

lower than the exposures estimated. As such, any potential exposures to ambient environmental dose 

would be accounted for in the assigned occupational exposures at Bethlehem Steel Corporation. 

7.2.3 Internal Dose Reconstruction Feasibility Conclusion 

NIOSH found that available air monitoring records, process descriptions, and source term data are 

sufficient to complete internal dose reconstructions for the proposed class of employees. Though no 

records of any air sampling are known to exist for the 1949 through 1950 time period at Lackawanna, 

exposures during this period can be evaluated by using data collected at Simonds Saw and Steel prior 

to the implementation of any ventilation control measures at that site. The appropriateness of using 

Simonds Saw and Steel data as surrogate data is summarized earlier in this document, detailed in 

OCAS-TKBS-0003, and was subject to significant review by the Board. 

Internal dose reconstructions for later years can be performed utilizing available Bethlehem Steel air 

monitoring data. Though the data contain only limited breathing zone measurements, a breathing 

zone sample surrogate can be calculated from Simonds Saw and Steel data and used to augment the 

Bethlehem Steel breathing zone data. These augmented data can then be used to bound inhalation 

doses associated with uranium metal rolling in early 1951 (prior to the established routine use of the 

salt bath furnace). After use of the salt bath furnace became a standard process procedure, airborne 

uranium contamination associated with the rolling of uranium metal was greatly reduced and was no 

longer the highest inhalation exposure potential activity. Instead, the single highest air sample result 

was obtained at a uranium billet grinding area; this result (70 MAC), can be used to calculate 

exposures from late 1951 through 1952. Doses to cobble cutters can be bounded by modeling an 

estimated air concentration of 600 MAC, which is higher than both the largest air concentration 

documented at Bethlehem Steel and the air concentration used to evaluate exposures during the 1949 

through 1950 time period. Based on available air and surface contamination data, ingestion doses and 

doses from residual contamination can also be calculated. 

7.3 External Radiation Doses at Bethlehem Steel Corporation 

The principal source of external radiation dose for members of the proposed class was natural uranium 

metal. The primary exposure pathways were: 1) submersion in a cloud of uranium dust; 2) direct 

exposure to uranium metal; 3) external dose from residual contamination; and 4) external dose from 

wearing contaminated clothing (OCAS-TKBS-0003). 

No external dosimetry data are available for Bethlehem Steel workers. However, external exposures 

to workers can be estimated by using uranium rolling information, air monitoring information, 

residual contamination estimates, and exposure rate constants for uranium materials. 

7.3.1 Process-Related External Radiation Doses at Bethlehem Steel 

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

reconstructing the process-related external doses of members of the proposed class. 
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7.3.1.1 External Dose from Uranium Dust

Derived air concentrations, combined with rolling times, number of rollings, and the dose conversion 

factors for uranium-238 with the daughter radionuclides thorium-234 and protactinium-234m, can be 

used to determine the external dose due to submersion in a natural uranium dust cloud (OCAS-TKBS0003). However, only the skin should be reported, because all other doses are less than 1 mrem. 

Table 7-4 indicates the annual external uranium skin dose due to submersion in air contaminated with 

natural uranium dust. 

Table 7-4: Annual External Uranium Dose 

Time Frame Annual Skin Dose 

(Rem) 

1949 0.002 

1950 0.002 

1951 0.001 

1952 0.000 

7.3.1.2 External Dose from Direct Contact with Uranium Billets

External doses from exposure to a uranium source were evaluated using extended (semi-infinite plane) 

natural uranium sources. Estimated surface dose rates of 230 mrad/hour at a depth of 7 mg/cm2 and 2 

mrad/hr at a depth of 1000 mg/cm2

 were obtained from a search of the literature (OCAS-TKBS0003)13. Conservative values for the length of time workers were present near the source were based 

on descriptions of processes and different job types (OCAS-TKBS-0003)14. A triangular distribution 

for electron exposure from uranium was determined in the following manner: 

• The minimum was estimated by assuming the worker was one meter from an extended uranium 

source for one hour (per 10-hour shift). The estimated dose rate for this scenario was 90 mrad/hour 

(OCAS-TKBS-0003)15. 

• Survey data of the Simonds facility were used to estimate the mode. The highest value measured 

during those surveys was 15 mrad/hour (OCAS-TKBS-0003)16. To be claimant-favorable, this dose 

rate was assumed for an entire 10-hour shift. 

• A maximum value was estimated by assuming the worker was 0.3 meter (one foot) from an extended 

uranium source for six hours (150 mrad/hour) and one-meter away for four-hours (90 mrad/hour). 

 

13 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source documents: U.S. 

Army, 1989; Coleman, 1983 

14 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: AEC, 

1948 

15 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: U.S. 

Army, 1989 

16 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: AEC, 

1949 
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Table 7-5 summarizes annual values for estimated external shallow dose due to electron exposure 

from uranium. The target organs for this type of exposure are the skin, male genitals, and breast. In 

the case of male genital cancer or female breast cancer, additional evaluation might be needed to 

consider shielding and attenuation provided by clothing. 

Table 7-5: Estimated External Shallow Dose Due to Electron Exposure from Natural Uranium Sources 

Time Frame Annual Organ Dose (Rem)

Minimum Mode Maximum

1949 1.08 1.80 15.12 

1950 1.08 1.80 15.12 

1951 1.17 1.95 16.38 

1952 1.35 2.25 18.90 

7.3.1.3 External Dose from Residual Contamination

An estimate of surface contamination was calculated by using the terminal settling velocity of 0.00075 

m s-1 multiplied by both the rolling day concentrations and the amount of time uranium was rolled in 

one year. The Simonds Saw and Steel concentration data were used for all years to simplify the 

calculations, as they overestimate the later rolling data. This calculation results in a contamination 

estimate of 12,500,000 dpm m-2 (1,250,000 dpm 100cm2), which exceeds all the measured surface 

contamination levels. This calculation was then assumed to be constant for all years that rolling took 

place. The residual contamination value was converted to dose using the dose coefficients in the 

Federal Guidance Report Number 12 (OCAS-TKBS-0003)17 for contaminated ground surfaces for 

uranium-238 and progeny protactinium-234m and thorium-234. The doses from contaminated 

sources are listed for skin, bone surfaces, and all other organs in Table 7-6. The “all other organ 

category” is the highest other organ rounded up to the nearest mrem. 

Table 7-6: Annual Dose from Contaminated Surfaces at Bethlehem Steel, 1949 to 1952 

Timeframe Skin 

(rem) 

Bone Surfaces 

(rem) 

All Other Organs 

(rem) 

1949-1952 1.771 0.010 0.005 

 

17 The summary provided in the Bethlehem Steel Site Profile was based on the following primary source document: 

ORNL, 1993 
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7.3.1.4 External Dose from Reusing Contaminated Clothing

The average dose-rate data from contaminated clothing were documented at Mallinckrodt at an 

indicated level of 1.5 mrem/hour (HASL, 1958). Bethlehem Steel doses were estimated using these 

data as a bounding condition, based on the types and quantities of materials handled at Mallinckrodt. 

The dose was determined by assuming that the clothing was worn at Bethlehem Steel for two-work 

weeks prior to cleaning. Therefore, the annual dose to the skin was determined by assuming 1.5 

mrem/hour multiplied by 50 hours per week, multiplied by two-weeks per month multiplied by 12-

months per year. This results in an estimated annual dose to the skin of 1.8 rem per year. 

7.3.2 Ambient Environmental External Radiation Doses at Bethlehem Steel 

All significant sources of occupational external dose have been addressed in OCAS-TKBS-0003. As 

a result, ambient environmental dose is accounted for in the assessment of process-related dose. 

7.3.3 Bethlehem Steel Corporation Occupational X-Ray Examinations 

There is no information available with reference to whether occupationally-required medical X-ray 

examinations were performed at Bethlehem Steel. However, the AEC typically required both preemployment and periodic medical examinations of workers involved in the larger uranium processing 

programs to include a preliminary and annual chest X-ray. For this analysis, it is assumed that all 

workers received both a pre-employment and annual X-ray examination, with exposure geometry 

assumed to be posterior-anterior. Annual X-ray data from OTIB-0006, Dose Reconstruction from 

Occupationally Related Diagnostic X-ray Procedures, and associated instructions should be used 

when evaluating occupational medical dose at Bethlehem Steel Corporation. 

7.3.4 External Dose Reconstruction Feasibility Conclusion 

Based on NIOSH’s reviews and analyses of the available data, and the approach described in OCASTKBS-0003, there is sufficient information to either: 1) estimate the maximum external 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 2) estimate the external radiation doses 

to members of the class more precisely than a maximum dose estimate. 

7.4 Evaluation of Specific Petitioner Statements in SEC-00056 

Former Bethlehem Steel Corporation employees have expressed concerns regarding dose 

reconstructions for Bethlehem Steel workers. The issues were expressed in various forums/formats, 

including public meetings, phone interviews, and written correspondence. This section presents 

specific affidavit statements made by workers on behalf of petition SEC-00056. The italicized 

statements are from the petition; the comments that follow are from NIOSH. 

7.4.1 Comparison between Bethlehem Steel Corporation and Simonds Saw and Steel 

SEC-00056: Simonds Saw and Steel Company information is not a valid comparison to the work 

done at Bethlehem Steel. Since Simonds was a much smaller facility, Simonds used different rolling 
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equipment and procedures, Simonds implemented safety procedures and equipment which Bethlehem 

Steel did not use, and personal air monitoring was performed at Simonds and not at Bethlehem Steel. 

Simonds Saw and Steel represents a bounding case for Bethlehem Steel exposures to uranium based 

on the following: 

• Data collected at Simonds in 1948 is used for years 1949 and 1950 at Bethlehem Steel, assuming 

that all workers at Bethlehem Steel were exposed to the 95th percentile of all air monitoring data. 

This level corresponds to the airborne level of the maximally exposed workers in these plants. 

While only a small fraction of the 20,000 workers at the Bethlehem Steel-Lackawanna plant were 

rolling mill operators, this claimant-favorable decision was made because of the difficulty of 

assessing the extent of other workers’ involvement in and exposure to the rolling mill processes. 

• Comparison of the exposure levels at Simonds Saw and Steel to those actually measured at 

Bethlehem Steel further show that these are bounding measurements. Assuming the 95th percentile 

level as a constant intake rate for 10 hours during rolling, the intake based on Simonds Saw and 

Steel data is over 26 times higher than that based on the Bethlehem Steel data. This is a claimant 

favorable decision to avoid underestimating the intake periods prior to 1951 when the use of 

protective coatings on the uranium cannot be confirmed. 

• Simonds was a smaller facility and the processes were close to one another. Air concentration 

data for general area samples would tend to be higher because of the cross-talk between locations. 

Also, contamination would have remained more localized and thus more available for resuspension. Thus, air concentration data from the much larger rollings quantity would have been 

greater. 

• Simonds Saw and Steel processed bare metal uranium rods for the October 27, 1948 rollings and 

preceding rollings as well. Bare metal uranium is more susceptible to oxidation than lead bathheated or salt bath-heated uranium and increases the uranium oxide dust production. All rollings 

which are known to have occurred at the Lackawanna plant were lead- or salt bath-heated. 

• The dose reconstruction model being used by NIOSH for Bethlehem Steel is based on monitoring 

data taken at Simonds Saw and Steel prior to the installation of ventilation and floor gratings. 

NIOSH’s calculations do not consider ventilation in Bethlehem Steel dose reconstructions. 

• Simonds Saw and Steel was more labor-intensive and hands-on than the process conducted at the 

Lackawanna plant. Some of the highest air concentration levels at Simonds were observed during 

operations where rolled rods were dragged across the contaminated floor. The facilities at 

Lackawanna were state-of-the-art and designed to reduce the amount of labor involved in the 

production process. 

• Air sampling data were collected and analyzed at Simonds Saw and Steel by the same 

organization, HASL, using the same methods as those which would have been used at Bethlehem 

Steel (see Section 7.1.1). 
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• Breathing zone samples collected at Simonds Saw and Steel on October 27, 1948 were taken 

during the worst part of the process for short durations (~1 minute) during peak episodes, and thus 

provide an upper bound to the overall breathing zone estimates. 

• Simonds Saw and Steel became the rolling mill of choice for the AEC program; therefore, any 

rollings conducted at the Bethlehem Steel rolling mill in the 1949-1950 timeframe would have 

been small and experimental in nature compared to the volume rolled at Simonds. While rolling 

volume does not impact the breathing zone estimates, the amount of residual activity will be 

affected by the total amount of material rolled. 

• The amount of material run at the Lackawanna plant was a small fraction of the plant’s actual 

capacity. The application of a full 10-hour day for Bethlehem Steel at the monitored airborne 

levels associated with Simonds’ higher production rate is a substantial but reasonable 

overestimate. 

7.4.2 Blooming Mill Involvement 

SEC-00056: Other buildings were involved, including the Blooming Mill (Reference Wayne Range 

Letter of June 7, 1976). The purpose of the Blooming Mill was to reduce ingots to billets. 

The referenced letter states that a suitable Blooming Mill and Rolling Mill were present at 

Lackawanna; but the letter does not indicate or confirm the use of those facilities for uranium work. 

All documents reviewed by NIOSH describing uranium rollings indicate that all billets were roughrolled at a separate facility (e.g., Simonds Saw and Steel). 

7.4.3 Areas of High Uranium Concentration 

SEC-00056: NIOSH overlooked the 28,000 square feet of unmonitored high uranium concentrated 

area (sub-basement open under the Cooling Bed). They also overlooked the Cooling Bed above. 

While this area occupies a large portion of the facility, it does not represent a component that impacts 

the evaluation of dose at Bethlehem Steel. This area was evaluated as part of the updates to the 

Technical Basis Document, but was not found to be as limiting as the exposure models which were 

based on plausible worst-case occupational exposure conditions being assigned to all employees. 

Discussions with workers have also provided evidence that the occupation of this area was 

intermittent. The exposure model provides for a 10-hour exposure during rolling days and for 

exposure to residual contamination during non-rolling days. The dose model, therefore, accounts for 

exposures in all areas of the plant. 

7.4.4 Lack of Records for 1949-1950 

SEC-00056: For 1949-1950, no records exist....NIOSH had no knowledge of what went on in 1949 

through 1950. 

The covered period for Bethlehem Steel was based on a letter that indicated uranium rollings occurred 

between 1949 and 1951 (OCAS-TKBS-0003). Without the Range letter, there is no evidence of 

rollings occurring at Bethlehem Steel prior to 1951. However, NIOSH concluded that the recollection 
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of monthly rollings beginning in 1949, as cited in the Range letter, cannot be refuted. Thus, the 

Bethlehem Steel Site Profile was written to assume rollings started in 1949. 

7.4.5 Accurate Dose Reconstructions for Unprotected Workers 

SEC-00056: No personal protective equipment was issued at Bethlehem Steel, including: glovebox, 

masks, hoods, film badges, etc. How can accurate dose reconstructions be modeled without reliable 

air data or personal monitoring on workers? 

Dose reconstruction at Bethlehem Steel was based on modeling exposure conditions that used air 

monitoring results and production data. The Bethlehem Steel Site Profile provided consistent 

guidance to the dose reconstructor that no personal protective equipment was used at Bethlehem Steel. 

7.4.6 Lost Uranium 

SEC-00056: Using NIOSH’s figures to calculate the amount of lost uranium: lost uranium for 48+ 

rollings at eight-pounds per billet equals 13 tons of lost uranium in four years of rollings at 

Bethlehem Steel: 13 tons of radioactive material left on the site.... 

Because scrap recovery was an important component of the AEC uranium program, NIOSH does not 

believe that 13-tons of material were left behind by the AEC at Bethlehem Steel. In fact, it has been 

consistently reported in various documents and in interviews with Bethlehem Steel workers that as a 

valuable metal, fines and scraps of uranium were picked up and vacuumed. In addition, the amount 

that was speculated to have been lost also includes the ends of cropped billets. These cropped ends 

were also recovered as part of the scrap program but did not contribute to material which could be 

used in Hanford’s plutonium production program. The NIOSH exposure model accounts for the 

inhalation and ingestion of residual contamination after rollings, which in turn, accounts for the spread 

of uranium in the plant from rolling operations (OCAS-TKBS-0003). 

7.4.7 Salt Bath Leak on September 22, 1952 

SEC-00056: There was a four-hour loss of time with a salt bath leak on September 22, 1952: 

• 303 billets rolled, 9 billets at a time to charge in the salt bath

• 23 minutes average time to soak per charge

• 759 minutes total time for soaking

• 12.5 hours needed for soaking only

It is impossible for this work to be done in a 10-hour working day based on the time requirements. 

Fernald representatives reported in a document titled Production Report on The Rolling of Two 

Hundred and Twenty-Two Uranium Billets at Bethlehem Steel Corporation’s Lackawanna Plant on 

Saturday, April 12, 1952 that the rollers were running a billet every two minutes when they hit their 

stride (NLO, 1952). Because billets were removed one at a time and could be replaced to keep the 
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process moving, soaking time is not likely to be the limiting factor. NIOSH has developed an 

exposure model assuming that the employees worked 10-hours at each of the rollings. Even if there 

was some deviation on one rolling day in the time required, the profile provides a very claimantfavorable estimate for days when only 30 billets were rolled. 

7.4.8 Manual Labor at Bethlehem Steel 

SEC-00056: The manual labor at Bethlehem Steel, such as sledge-hammering uranium rods, moving 

rods across the salt bath with crowbars, and removing cobbles, far exceeds the rolling process at 

Simonds Saw and Steel. 

Manual processes were cited by the AEC as being one of the factors that elevated uranium exposures. 

And within that category, one of the largest factors involved dragging the rods between various 

stations and re-suspending the dust (this includes the example of reintroducing the rods). Simonds 

Saw and Steel rolled large quantities of uranium for long periods of time with no protective coating, 

resulting in significant amounts of uranium on the floor (this is why grating was later installed at 

Simonds). The application of the 95th percentile of the Simonds Saw and Steel air monitoring data for 

dose estimation during the early period at Bethlehem Steel, and the application of air monitoring data 

from the grinding of uranium at Bethlehem Steel for the latter period, present a bounding case for 

estimating dose at Bethlehem Steel. This estimate would exceed the dose potential at Bethlehem Steel 

from both sledge-hammering rods and moving rods across the salt bath with crowbars. Even so, 

NIOSH recognizes cobble removal and cutting as a valid exposure pathway and has included dose 

estimation methodologies for cobble-cutting in the Bethlehem Steel Technical Basis Document. 

Cobble-cutting dose methodology is described earlier in this document. 

7.4.9 Destroyed Records 

SEC-00056: When doing experimental work, you are working with the unknown. The government 

admits to destroying these records. 

The government’s admission that it destroyed records was provided in a letter from someone not 

involved in the program. In its own data capture efforts, NIOSH has obtained a significant number of 

documents regarding Bethlehem Steel from both HASL and Hanford. These documents indicate that 

the experimental work conducted at Bethlehem Steel occurred on a very limited basis. In spite of this, 

the Bethlehem Steel Site Profile has incorporated exposure conditions during which all employees are 

assumed to perform the highest exposure job for 10-hours per workday at the 95th percentile value. 

This assumptive exposure significantly overestimates the time required for an operation involving the 

small number of billets processed during the experimental phase. For the 1951 through 1952 period, 

air sample data, surface contamination data, and production records exist for the uranium rollings at 

Bethlehem Steel. 

7.4.10 Exposure to Uranium throughout the Facility 

SEC-00056: The work areas could not have been cleaned in one day. Workers were exposed to 

uranium throughout the facility. 
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The Bethlehem Steel Site Profile accounts for the re-suspension of uranium that was dispersed 

throughout the facility. It does not assume that the facility was decontaminated in one day. The Site 

Profile employs a model that accounts for both deposition and re-suspension of uranium dust from 

weekend uranium rollings and the added deposition of normal steel dust during the remainder of each 

week. As such, the amount of uranium available for re-suspension would be reduced over time by the 

dust generated during the normal steel manufacturing process. 

7.4.11 Areas of Highest Exposures at the Bethlehem Facility 

SEC-00056: Initially NIOSH stated that the highest dust levels were at the rollers, then later it was 

somewhere else. 

NIOSH’s extensive review of the rolling processes employed at Bethlehem Steel found that the salt 

bath technology employed during the later years significantly reduced air concentrations of uranium 

compared to the technology employed in the earlier period. The reduction was so significant that 

other operations became the bounding exposure scenario. 

7.4.12 Absence of Grinding in the Technical Basis Document 

SEC-00056: No grinding was recognized or incorporated in the Bethlehem Steel Technical Basis 

Document. 

During NIOSH’s extensive review of the rolling processes employed at Bethlehem Steel, it became 

obvious that the salt bath technology employed during the later years significantly reduced air 

concentrations of uranium over the technology employed in the earlier period. The reduction was so 

significant that other operations became the bounding exposure scenario. In keeping with the 

claimant-favorable assumptions used in the Bethlehem Steel Site Profile, NIOSH has adopted the 

highest exposure scenario for assigning intakes to workers in the later years. Based on its analysis of 

the measured air samples during this later period, grinding operations provide the highest potential for 

worker exposure. NIOSH will assume that all workers, regardless of job category, were exposed to 

these air concentrations 10-hours per day for each day of rolling. This exposure scenario is used to 

estimate maximum personnel doses for the later period of uranium rolling at Bethlehem Steel. 

7.4.13 Ingestion of Uranium from Eating and Drinking 

SEC-00056: Workers ate and drank in dusty areas, and could have ingested uranium. 

While it is possible that a worker could have ingested uranium while eating and drinking in an area 

with uranium surface dust, this exposure would have been considerably lower than the exposure 

applied in the Bethlehem Steel Site Profile. The Bethlehem Steel Site Profile does not take into 

account breaks and lunch times; rather, the Bethlehem Site Profile assumes a full 10-hour exposure at 

the 95th percentile for the maximally exposed worker. The ingestion dose model in the Site Basis 

Document uses claimant-favorable heavy worker breathing rates (which maximizes the estimated 

amount of ingested uranium), uses a claimant-favorable gastrointestinal absorption value of two 

percent, and assumes that workers ingested moderately soluble forms of uranium. The Bethlehem 

Steel Site Profile also incorporates ingestion and inhalation of residual contamination during nonrolling days. 
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7.4.14 Contaminated Clothing 

SEC-00056: Workers wore contaminated coveralls without being laundered. 

Dose methodology for wearing contaminated clothing has been incorporated into the Bethlehem Steel 

Site Profile. The methodology is based on contaminated clothing dose rate data collected at 

Mallinckrodt Chemical Company (HASL, 1958). The data represent a bounding condition because 

Mallinckrodt processed greater quantities of radioactive materials than Bethlehem Steel, and because 

those materials included significant quantities of radium that produces higher dose rates than the 

natural uranium metal processed at Bethlehem Steel. 

7.5 Other Issues Relevant to the Petition Identified During the Evaluation 

As previously noted, the current Bethlehem Steel Technical Basis Document (OCAS-TKBS-0003) 

supersedes the previous Bethlehem Steel Technical Basis Document (ORAUT-TKBS-0001), also 

referred to as the Bethlehem Steel Site Profile. The Technical Basis Document was rewritten to 

address issues communicated during worker outreach meetings/correspondences and through 

extensive review by the Board and its technical support contractor, Sanford Cohen & Associates 

(SC&A). SC&A’s review focused primarily on the first Bethlehem Steel Technical Basis Document 

(ORAUT-TKBS-0001). The objectives of the review were to evaluate the following: 

• Completeness of data sources 

• Technical accuracy 

• Adequacy of data 

• Consistency among site profiles 

• Regulatory Compliance 

SC&A’s findings and observations can be found in the document titled Review of NIOSH Site Profile 

for Bethlehem Steel Plant, Lackawanna, NY (SCA-TR-TASK1-0001). Findings and observations 

based on those observations are addressed in the document titled NIOSH Comments on the SC&A 

Review of the Bethlehem Steel Site Profile—Specific Responses to Findings, Observations and 

Procedural Non-Conformances, January 25, 2005. Both documents can be found at NIOSH’s 

website at: http://www.cdc.gov/niosh/ocas/bethst.html. 

The current Bethlehem Steel Technical Basis Document (OCAS-TKBS-0003) is a result of these 

reviews and incorporates associated updates to dose reconstruction methodologies for former 

Bethlehem Steel workers. 
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7.6 Summary of Feasibility Findings for Petition SEC-00056 

This report evaluates the feasibility for completing dose reconstructions for all Atomic Weapons 

Employer personnel at the Bethlehem Steel Corporation who were monitored or should have been 

monitored for exposure to uranium during uranium rolling activities at the Bethlehem Steel, 

Lackawanna, New York facility from January 1, 1949 through December 31, 1952. NIOSH found 

that the available monitoring records, process descriptions and source term data available are 

sufficient to complete dose reconstructions for the proposed class of employees. 

Table 7-7 summarizes the results of the feasibility findings at Bethlehem Steel Corporation for each 

exposure source during the time period January 1949 through December 1952. 

Table 7-7: Summary of Feasibility Findings for SEC-00056 

January 1949 through December 1952 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal1 X 

-uranium X 

External X 

-Gamma X 

-Beta X 

-Neutron X 

-Occupational Medical x-ray X 

1

 Internal includes an evaluation of potential inhalation or ingestion of uranium dust as detected in urinalysis 

(in vitro), airborne dust sampling data, and/or lung (in vivo) data 

As of February 7, 2007, a total of 735 claims have been submitted to NIOSH for individuals who 

worked at Bethlehem Steel Corporation. Dose reconstructions have been completed for 634 

individuals (~86%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00056 

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

employees in the SEC. 

NIOSH has determined that radiation doses can be estimated with sufficient accuracy using available 

monitoring data, surrogate monitoring data, and source term information. Our evaluation determined 

that it is feasible to estimate radiation dose for members of the proposed class with sufficient accuracy 

based on the sum of information available from available resources. A modification of the class 

definition regarding health endangerment and minimum required employment periods, therefore, is 

not required. 

9.0 NIOSH-Proposed Class for Petition SEC-00056 

Based on its research, NIOSH expanded the petitioner-requested class to define a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all Atomic Weapons Employer personnel at the Bethlehem Steel Corporation 

who were monitored or should have been monitored for exposure to uranium during uranium rolling 

activities at the Bethlehem Steel, Lackawanna, New York facility from January 1, 1949 through 

December 31, 1952. The class was expanded because NIOSH has determined that there is insufficient 

information available to determine, for the stated time period, every individual’s work title/function or 

work location and because NIOSH can estimate dose with sufficient accuracy for this class. 

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

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

technical resources and many other references, including the Site Research Data Base, for information 

relevant to SEC-00056. 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 principles in conducting these dose reconstructions are 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 that it would be feasible to reconstruct the dose for the class 

proposed in this petition. 
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10.0 References 

42 C.F.R. 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. 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. 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 

OCAS-TKBS-0003, Technical Basis Document: Basis for Development of an Exposure Matrix for 

Bethlehem Steel Corporation, Lackawanna, New York; Period of Operation: 1949-1952, Rev. 0, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; July 27, 2006; 

SRDB Ref ID: Not available in SRDB 

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

Employer Facilities; Oak Ridge Associated Universities, Oak Ridge, Tennessee; December, 2006; 

SRDB Ref ID: This version is not currently available in the SRDB 

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

Procedures, Revision 03 PC-1, Oak Ridge Associated Universities, Oak Ridge, Tennessee; December 

21, 2005; SRDB Ref ID: 20220

ORAUT-TKBS-0001, Basis for Development of an Exposure Matrix for Bethlehem Steel 

Corporation, Lackawanna, New York, Period of Operation: 1949-1952, Rev. 0, Oak Ridge 

Associated Universities, Oak Ridge, Tennessee; June 29, 2004; SRDB Ref ID: 19475 

ORAUT-TKBS-0001, Technical Basis Document: Basis for Development of an Exposure Matrix for 

Bethlehem Steel Corporation, Lackawanna, New York, Period of Operation: 1949-1952, Rev. 1, Oak 

Ridge Associated Universities, Oak Ridge, Tennessee; June 29, 2004; SRDB Ref ID: This version is 

not currently available in the SRDB 

ORAUT-TKBS-0032, Technical Basis Document: Site Profile for Simonds Saw and Steel Company, 

Lockport New York, Rev. 0, Oak Ridge Associated Universities, Oak Ridge, Tennessee; May 31, 

2005; SRDB Ref ID: 20181 

ABRWH Working Group, January 2003, The Advisory Board on Radiation and Worker Health; 

January 7 and 8, 2003; Transcript available on OCAS website, pages 63-86 

ABRWH Working Group, March 2004, The Advisory Board on Radiation and Worker Health; March 

24, 2004; Transcript available on OCAS website, pages 252-279 
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ABRWH, June 2, 2004, The Advisory Board on Radiation and Worker Health; June 2, 2004; 

Transcript available on OCAS website, pages 324-393 

ABRWH, June 3, 2004, The Advisory Board on Radiation and Worker Health; June 3, 2004; 

Transcript available on OCAS website, pages17-20 

ABRWH, December 2004, The Advisory Board on Radiation and Worker Health-27th meeting; 

December 14, 2004; Transcript available on OCAS website, pages 126-295 

ABRWH, February 7, 2005, The Advisory Board on Radiation and Worker Health; February 7, 2005; 

Transcript available on OCAS website, page 85-153; 171-180 

ABRWH, February 8, 2005, The Advisory Board on Radiation and Worker Health; February 8, 2005; 

Transcript available on OCAS website, page 125-146 

ABRWH, July 2005, The Advisory Board on Radiation and Worker Health; July 5, 2005; Transcript 

available on OCAS website, pages 12-24; 33-64; 237-252 

ABRWH, August,2005, The Advisory Board on Radiation and Worker Health; August 24, 2005; 

Transcript available on OCAS website, pages 181-193 

ABRWH, October 6, 2005, The Advisory Board on Radiation and Worker Health; October 6, 2005; 

Transcript available on OCAS website, pages 11-93; 103-115 

ABRWH, October 17, 2005, The Advisory Board on Radiation and Worker Health; October 17, 2005; 

Transcript available on OCAS website, pages 16-93 

ABRWH, October 18, 2005, The Advisory Board on Radiation and Worker Health; October 18, 2005; 

Transcript available on OCAS website, pages 13-59 

ABRWH, November 2005, The Advisory Board on Radiation and Worker Health; November 28, 

2005; Transcript available on OCAS website, pages 12-59 

ABRWH, January 2006, The Advisory Board on Radiation and Worker Health-34th meeting; January 

9, 2006; Transcript available on OCAS website, pages 12-48 

ABRWH, June 2006, The Advisory Board on Radiation and Worker Health; June 16, 2006; Transcript 

available on OCAS website, pages 180-182; 189-192; 242-255 

ABRWH, September 2006, The Advisory Board on Radiation and Worker Health-40th meeting; 

September 19, 2006; Transcript available on OCAS website, pages 96-98 

AEC, 1948, Simonds Saw and Steel Co. Occupational Exposure to Radioactive Dust, visit of October 

27, 1948; Atomic Energy Commission (AEC); October 27, 1948; SRDB Ref ID: 10226; 11996, page 

137; 12443 

AEC, 1949, Simonds Saw & Steel Co. Summary Report of Three Surveys, October 27, 1948 through 

February 15, 1949; U.S. Atomic Energy Commission (AEC); 1949; SRDB Ref ID: 23579 
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AEC, 1951-1952 Sample Sheets for Bethlehem Steel; SRDB Ref ID: 9543 

AEC, 1952 Sample Sheets for Bethlehem Steel; SRDB Ref ID: 9529 

Beck, 2006, Personal Communication with Don Lotocki and Ed Walker, telephone interview by Jack 

Beck and Libby Gilley; October 26, 2006; SECIS Ref ID: 112 and 113 

Bowman, 1952, Report on Trips to Bethlehem Steel Corporation; H. T. Bowman, P. E. Merrill, C. A. 

Schneider, A. S. Yocco; September 4, 1952; SRDB Ref ID: 17592 

Breslin, 1967, The Accuracy of Dust Exposure Estimates Obtained from Conventional Air Sampling; 

A. J. Breslin; January-February, 1967; SRBD Ref ID: 15809 

Coleman, 1983, Depth-Dose Curves for SR-90 and Natural and Depleted Uranium in Mylar; R. L. 

Coleman, C. G. Hudson, and P. A. Plato; April 1983; SRDB Ref ID: 12288 

Conference Call Notes, 2005a, Conference Call with NIOSH and SC&A to Discuss Bethlehem Steel 

Issues; November 9, 2005; SRDB Ref ID: 27970 

Conference Call Notes, 2005b, Conference Call with NIOSH and SC&A to Discuss Bethlehem Steel 

Issues; November 23, 2005; SRDB Ref ID: 27971 

DOE, 1982, EML Procedures Manual; Edited by Herbert L. Volchok and Gail de Planque; 1982; 

SRDB Ref ID: 28022 

DOE, 1985, Formerly Utilized Sites Remedial Action Program-Elimination Report for Bethlehem 

Steel Corporation; Department of Energy (DOE); 1985; SRDB Ref ID: 14130, page 65; 26844 

Fletcher, 1976, Inquiry from Bethlehem Steel Skeleton List; H. Doran Fletcher; June 2, 1976; SRDB 

Ref ID: 14806 

Gardner, 1952, Production Test 313-105-6-M Irradiation of Alpha Canned Uranium Slugs from Rods 

Salt Bath Beth Heat-Treated at Lackawanna; H. R. Gardner; June 27, 1952; SRDB Ref ID: 27954 

HASL, 1958, Symposium on Occupational Health Experience and Practices in the Uranium Industry;

October 15-17, 1958; Health and Safety Laboratory (HASL); October 1958; SRDB Ref ID: 7886, 

page 178 

Hershman, 1952, Transmittal of Monthly Progress Report for October; H. J. Hershman; October 21, 

1952; SRDB Ref ID: 10751 

ICRP, 1998, General Principles for the Radiation Protection of Workers, ICRP Publication 75; 

International Commission on Radiological Protection (ICRP); SRDB Ref ID: Not available in the 

SRDB-publicly available 
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Kattner, 1951, Trip Report-Visits to AEC New York Operations Office, Lackawanna Plant, Bethlehem 

Steel Company, Argonne National Laboratory-August 24-29, 1951; W. T. Kattner; September 12, 

1951; SRDB Ref ID: 16124 

Kattner, 1952a, Program for Developing Uranium Fabrication Processes; W. T. Kattner; January 16, 

1952; SRDB Ref ID: 28049 

Kattner, 1952b, Trip Report-Development of a Uranium Rolling Process for Fernald; W. T. Kattner; 

January 29, 1952; SRDB Ref ID: 16284 

Kattner, 1952c, Evaluation of Uranium Rods from the Fourth Experimental Rolling at Lackawanna, 

New York; W. T. Kattner; March 21, 1952; SRDB Ref ID: 16285 

Kosanovich, 1979, Letter to Robert Anderson Expressing Concern About Exposure Levels; Paul 

Kosanovich; October 19, 1979; SRDB Ref ID: 11582, page 36 

LaMastra, 1976, Investigation Report: Uranium Metal Rolling 10” Bar Mill, Lackawanna Plant; A. 

LaMastra; June 29, 1976; SRDB Ref ID: 14130, page 17; 11582, page 60 

Malone, 1951, Monthly Progress Report for November, Memo from Malone to Smith; F. W. Malone; 

November 26, 1951; SRDB Ref ID: 20759 

Newton, 1987, Collection and Characterization of Aerosols from Metal Cutting Techniques Typically 

Used in Decommissioning Nuclear Facilities; George Newton; November, 1987; SRDB Ref ID: 

28041 

NIOSH, 2005, NIOSH Comments on the SC&A Review of the Bethlehem Steel Site Profile—Specific 

Responses to Findings, Observations and Procedural Non-Conformances, January 25, 2005; National 

Institute of Occupational Safety and Health (NIOSH); January 25, 2005; SRDB Ref ID: 28013 

NIOSH, 2006, Summary Notes of Technical Issues Raised at the Bethlehem Steel Meeting Held in 

Hamburg, NY, 21 June 2006, final notes; National Institute of Occupational Safety and Health 

(NIOSH); July 23, 2006; SRDB Ref ID: 27972 

NLO, 1952, Production Report on the Rolling of Two Hundred and Twenty-Two Uranium Billets at 

Bethlehem Steel Corporation’s Lackawanna Plant on Saturday, April 12, 1952; National Lead 

Company of Ohio (NLO); April 28, 1952; SRDB Ref ID: 9670 

NLO, 1985, History of the Operation of the Feed Materials Production Center, National Lead 

Company of Ohio (NLO); September 1985; SRDB Ref ID: 26097 

ORNL, 1980, Preliminary Survey of Bethlehem Steel, Lackawanna, New York; Oak Ridge National 

Laboratory (ORNL); March, 1980; SRDB Ref ID: 26845 

Petition Form B, 2006, New Submission (SEC00056) with the Form B, correspondence; March 13, 

2006; SECIS Ref ID: 9576 
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Range, 1976, Response to May 17th Letter Concerning Activities Conducted for the AEC at Bethlehem 

Steel’s Lackawanna Plant, Letter from Wayne Range to David Anderson; Wayne Range; June 7, 

1976; SECIS Ref ID: 9576, page 11 

Reichard, 1951, Continuous Mill Uranium Rolling Test-Lackawanna Plant-Bethlehem Steel 

Company-April 26, 27, 1951; H. F. Reichard; May 18, 1951; SRDB Ref ID: 9517 

Riches, 1951, Experimental Rolling of Uranium, Lackawanna #3; J. W. Riches; December 13, 1951; 

SRDB Ref ID: 16128 

SC&A, 2004, Review of NIOSH Site Profile for Bethlehem Steel Plant, Lackawanna, NY (SCA-TRTASK1-0001); S. Cohen & Associates; October 14, 2004; SRDB Ref ID: Currently not available in 

the SRDB 

SC&A, 2005, Letter Report by SC&A Regarding the Basis for Development of an Exposure Matrix for 

Bethlehem Steel Corporation, Lackawanna, New York; S. Cohen & Associates; October 14, 2005; 

SRDB Ref ID: 27974 

Schneider, No date, Report on Rollings at Bethlehem Steel Corporation, Lackawanna Plant, Buffalo, 

New York; C. A. Schneider and A. S. Yocco; No date; SRBD Ref ID: 11582, page 35 

Stewart, 1952, Production Report Rolling of Uranium Billets at Bethlehem Steel Lackawanna Plant, 

Saturday, March 15, 1952; R. S. Stewart; March 21, 1952; SRDB Ref ID: 28015

Summary, 1950-1951, Summary of Experimental Rollings Relating to Fernald Operations; Author 

Unknown; 1950-1951; SRDB Ref ID: 9520 

Summary Notes, 2006, Technical Issues Raised at the Bethlehem Steel Meeting on June 21, 2006; 

Final Notes: July 23, 2006; SRDB Ref ID: 27972 

Thornton, 1977, ERDA Resurvey Program-Bethlehem Steel, Lackawanna, NY; William T. Thornton; 

March 16, 1977; SRDB Ref ID: 11582, page 62; 16443 

U.S. Army, 1989, Safety Procedures for Processing Depleted Uranium; U.S. Army Materiel 

Command; August, 1989; SRDB Ref ID: 16264