SEC Petition Evaluation Report 

Petition SEC-00102 

Report Rev #_0_ Report Submittal Date 2/15/2008 

Subject Expert(s): Monica Harrison-Maples 

Site Expert(s): N/A 

Petitioner Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition A 

Receipt Date DOE/AWE Facility Name 

SEC-00102 83.14 November 19, 2007 SAM Laboratories, Columbia University 

Proposed Class Definition 

All employees of the Department of Energy (DOE), its predecessor agencies, and DOE contractors or 

subcontractors who worked in the Pupin, Schermerhorn, Havemeyer, Nash, or Prentiss buildings at the SAM 

Laboratories of Columbia University in New York City, New York, from August 13, 1942 through December 

31, 1947, for a number of work days aggregating at least 250 work days, occurring either solely under this 

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

of employees in the SEC. 

Related Petition Summary Information 

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

None 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

None 

ORAU Lead Technical Evaluator: 

Monica Harrison-Maples 

ORAU Review Completed By: 

Michael Kubiak 

Peer Review Completed By: [Signature of file] 

 LaVon Rutherford 

02/19/2008 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

2/19/2008 

Date 

SEC Evaluation Approved By: [Signature on file] 

 Larry Elliott 

02/20/2008 

Date 
SEC-00102 02-15-08 SAM Laboratories 

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SEC-00102 02-15-08 SAM Laboratories 

Evaluation Report Summary: SEC-00102, SAM Laboratories 

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. 

NIOSH-Proposed Class Definition 

The NIOSH-proposed class includes all employees of the DOE, its predecessor agencies, and DOE 

contractors or subcontractors who worked in the Pupin, Schermerhorn, Havemeyer, Nash, or Prentiss 

buildings at the SAM Laboratories of Columbia University in New York City, New York, from 

August 13, 1942 through December 31, 1947, for a number of work days aggregating at least 250 

work days, occurring either solely under this employment or in combination with work days within 

the parameters established for one or more other classes of employees in the SEC. 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.14(b), NIOSH has established that it does not have sufficient 

information to complete dose reconstructions for individual members of the class with sufficient 

accuracy. NIOSH lacks personnel monitoring, area monitoring, and source term data for SAM 

Laboratories, making reconstruction of internal and external radiation doses infeasible. 

Health Endangerment Determination 

The NIOSH evaluation did not identify evidence supplied by the petitioners or from other sources that 

would establish the class was exposed to radiation during a discrete incident likely to have involved 

exceptionally high-level exposures, such as nuclear criticality incidents or other events involving 

similarly high levels of exposures. However, the evidence reviewed in this evaluation indicates that 

some workers in the class may have received external exposure to ionizing radiation as well as 

potential internal exposures to radiation through the intake of radiological materials. Therefore, 42 

C.F.R. § 83.13(c)(3)(ii) requires NIOSH to specify that health may have been endangered for those 

workers covered by this evaluation who were employed for a number of work days aggregating at 

least 250 work days within the parameters established for this class or in combination with work days 

within the parameters established for one or more other classes of employees in the SEC. 

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SEC-00102 02-15-08 SAM Laboratories 

Table of Contents 

Evaluation Report Summary: SEC-00102, SAM Laboratories............................................................... 3 

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

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

3.0 NIOSH-Proposed Class Definition and Petition Basis................................................................ 8 

4.0 Radiological Operations Relevant to the Proposed Class ........................................................... 8 

4.1 Operations Description ....................................................................................................... 9 

4.2 Radiation Exposure Potential from Operations ................................................................ 10 

4.3 Time Period Associated with Radiological Operations.................................................... 10 

4.4 Site Locations Associated with Radiological Operations ................................................ 10 

4.5 Job Descriptions Affected by Radiological Operations ................................................... 11 

5.0 Summary of Available Monitoring Data for the Proposed Class .............................................. 12 

5.1 Internal Personnel Monitoring Data ................................................................................. 12 

5.2 External Personnel Monitoring Data ................................................................................ 12 

5.3 Workplace Monitoring Data............................................................................................. 13 

5.4 Radiological Source Term Data ....................................................................................... 13 

6.0 Feasibility of Dose Reconstruction for the Proposed Class ...................................................... 14 

6.1 Feasibility of Estimating Internal Exposures ................................................................... 14 

6.2 Feasibility of Estimating External Exposures .................................................................. 15 

7.0 Summary of Feasibility Findings for Petition SEC-00102........................................................ 15 

8.0 Evaluation of Health Endangerment for Petition SEC-00102................................................... 16 

9.0 NIOSH-Proposed Class for Petition SEC-00102 ...................................................................... 17 

10.0 Evaluation of Second Similar Class .......................................................................................... 17 

11.0 References ................................................................................................................................. 19 

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SEC-00102 02-15-08 SAM Laboratories 

SEC Petition Evaluation Report for SEC-00102
 

1.0 Purpose and Scope 

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

the data presented in this evaluation were made by the Oak Ridge Associated Universities Team Lead 

Technical Evaluator: Monica Harrison-Maples; Oak Ridge Associated Universities. These 

conclusions were peer-reviewed by the individuals listed on the cover page. The rationales for all 

conclusions in this document are explained in the associated text. 

This report evaluates the feasibility of reconstructing doses for employees who worked at a specific 

facility during a specified time. It provides information and analysis 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, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report. 

This evaluation, in which NIOSH provides its findings on both the feasibility of estimating radiation 

doses of members of this class with sufficient accuracy and on health endangerment, was conducted in 

accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14. 

2.0 Introduction 

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

Department of Health and Human Services to 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 proposed class of employees through NIOSH dose 

reconstructions.1 

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 the 

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

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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SEC-00102 02-15-08 SAM Laboratories 

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, 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 final decision process, the 

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

3.0 NIOSH-Proposed Class Definition and Petition Basis 

The NIOSH-proposed class includes all employees of the DOE, its predecessor agencies, and DOE 

contractors or subcontractors who worked in the Pupin, Schermerhorn, Havemeyer, Nash, or Prentiss 

buildings at the SAM Laboratories of Columbia University in New York City, New York, from 

August 13, 1942 through December 31, 1947, for a number of work days aggregating at least 250 

work days, occurring either solely under this employment or in combination with work days within 

the parameters established for one or more other classes of employees in the SEC. During this period, 

employees at the SAM Laboratories (SAM Labs) facility were involved in nuclear research, including 

uranium chemistry, uranium hexafluoride work, cyclotron research, and gaseous diffusion research. 

NIOSH has not located specific information describing the details of the nuclear research at SAM 

Labs, but available information does indicate that during such work, employees may have been 

exposed to various forms of uranium, radium, thorium, plutonium, fission products, other 

radionuclides used as tracers, and other exotic radionuclides sent to SAM Laboratories by other 

facilities for material identification and analysis. 

The evaluation responds to the Petition SEC-00102 which was submitted by an EEOICPA claimant 

whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient dosimetryrelated information. This claimant was employed as a Research Scientist/Chemist from 1944 through 

1946. NIOSH’s determination that it is unable to complete a dose reconstruction for an EEOICPA 

claimant is a qualified basis for submitting an SEC petition pursuant to 42 C.F.R. § 83.9(b). 

4.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize the radiological operations at the SAM Laboratories from 

August 13, 1942 to December 31, 1947 and the information available to NIOSH to characterize 

particular processes and radioactive source materials. Using available sources, NIOSH has attempted 

to gather process and source descriptions, information regarding the identity and quantities of 

radionuclides of concern, and information describing processes through which the radiation exposures 

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

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

information. 

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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4.1 Operations Description 

Columbia University was a major contributor throughout the early years of atomic research and 

development. Columbia University was involved in nuclear research prior to the creation of the 

Manhattan Engineer District (MED), established August 13, 1942. Absorption experiments to 

determine the feasibility of nuclear chain reactions began at Columbia in 1939 and the National 

Research Defense Committee began contracting with the university for nuclear research in 1940 

(FUSRAP Elimination, 1985). MED-related research included work on isotope separation, nuclear 

chain reaction, and an atomic pile. This work was conducted at the SAM Laboratories, also known as 

the Special Alloyed Materials Laboratories, or the Substitute Alloy Materials Laboratories. SAM 

Labs was comprised of five buildings: Pupin, Schermerhorn, Havemeyer, Nash, and Prentiss. All 

buildings were owned by Columbia University except Nash, which was leased for MED work from 

1943 to 1944 (FUSRAP Elimination, 1985). 

The isotope separation research at SAM Labs included the centrifuge process in which the lighter 

uranium-235 isotope concentrates near the center of a spinning centrifuge of gaseous uranium 

hexafluoride, from where it is removed. SAM Labs also did research on the gaseous diffusion process 

which exploited the different rates at which uranium isotopes in gaseous uranium hexafluoride diffuse 

through a porous barrier. SAM Labs helped develop an effective corrosion-resistant membrane for 

separating uranium isotopes and contributed significantly to the development of the large-scale 

gaseous diffusion process later employed for uranium enrichment (FUSRAP Columbia, pdf p. 91). 

NIOSH has not located documentation providing specific details of the isotopic separation research 

and processes at SAM Laboratories. 

SAM Labs conducted neutron cross-section research with plutonium shipped from what is now known 

as the Los Alamos National Laboratory (LANL). However, NIOSH has not been able to locate 

documentation specific to cross-section research operations. 

Generally, SAM Labs processes deemed successful were relatively well-documented; however, 

NIOSH has been unable to locate comprehensive records regarding work that was conducted but not 

adopted as part of the nuclear weaponization effort. This situation may be an outcome of the 

compartmentalized organization of SAM Labs and the entire MED effort. The administration of work 

was defined and segregated by project (Advisory Board, 1947). 

Weapons-related work at SAM Labs ended in 1947. Subsequent nuclear and radiological research at 

Columbia University included work focused on health effects and basic nuclear physics that were not 

directly related to the production of nuclear weapons. 

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4.2 Radiation Exposure Potential from Operations 

The potential for external radiation dose existed at the five buildings of the SAM Labs facility: Pupin, 

Schermerhorn, Havemeyer, Nash, and Prentiss. Based on the site operations outlined in Section 4.1, 

sources of external exposure included alpha and beta particles, photons, and neutrons emitted from 

materials containing uranium, radium, thorium (FUSRAP Columbia, pdf p. 18), plutonium 

(Plutonium, 1949), polonium, strontium, potassium, phosphorous, carbon, iodine, fission products, 

and other radionuclides used in nuclear research (Requests, 1947-48; Scope, 1945). Contractual 

documentation defining the scope of work for SAM Labs indicates research with “artificial 

radioactive materials used as tracers” (Scope, 1945, pdf p. 5), but NIOSH has not located 

documentation defining these materials. Columbia University also operated a cyclotron that was used 

in SAM Labs research. 

NIOSH has been unable to locate sufficient information to completely define the potential for internal 

radiation exposure at SAM Labs. NIOSH located a small number of air monitoring results taken in 

Pupin Hall a few years after the SAM Labs operational period. These air monitoring results were 

analyzed for radon concentration in the work spaces (Radon, 1950); however, no air monitoring 

results have been located for the 1942 through 1947 time period. NIOSH has located no 

contamination survey results, analyses of isotopic sources, or documentation of the physical state of 

radiological materials to which workers could have been internally exposed. 

4.3 Time Period Associated with Radiological Operations 

Per the DOE Office of Health, Safety and Security, the time period associated with EEOICPAcovered operations at SAM Laboratories is from 1942 through 1947 (DOE, 2007). EEOICPA-related 

work at SAM Labs is assumed to have started with the creation of the Manhattan Engineer District on 

August 13, 1942. NIOSH has been unable to locate information sufficient to determine a specific date 

in 1947 when MED-related radiological operations ceased; therefore, this evaluation assumes that the 

covered operations at SAM Labs ceased on December 31, 1947. 

4.4 Site Locations Associated with Radiological Operations 

NIOSH has found Formerly Utilized Sites Remedial Action Program (FUSRAP) documents 

indicating that the Pupin, Schermerhorn, Havemeyer, and Nash buildings were used for conducting 

nuclear research and development (FUSRAP Columbia, pdf pp. 23-26; FUSRAP Elimination, 1985). 

The history found in the FUSRAP Columbia database calls into question the inclusion of the Prentiss 

building as a radiological operations site (FUSRAP Columbia, pdf p. 25). The FUSRAP report of 

findings states that there is no evidence that MED-sponsored work was performed at Prentiss; 

furthermore, NIOSH has not located any documentation providing information about radiological 

work or storage at Prentiss. However, the DOE Office of Health Safety and Security website (DOE, 

2007) includes Prentiss in its description of MED-related sites at Columbia. 

•	 The Nash Building, located at 3280 Broadway at 133rd Street, was not owned by Columbia 

University, but was leased specifically for MED-related uranium hexafluoride work (FUSRAP 

Elimination, 1985, pdf p. 4). Some gaseous diffusion test cascade work involving uranium 

hexafluoride was performed at the Nash Building, but on a smaller scale than that conducted at the 

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Pupin (physics) Building (FUSRAP Columbia, pdf p. 24). The operation of a barrier production 

pilot plant (involving no radiological materials) was also explored at the Nash Building (FUSRAP 

Columbia). 

•	 The Pupin Building was used for nuclear research and storage of research quantities of radioactive 

materials (FUSRAP Columbia). A small cyclotron in Lab Room 128 was where fission was first 

demonstrated in the U.S. Gaseous diffusion research was conducted in Lab Room 110. Pupin 

also housed a 12-stage test cascade involving small quantities of uranium hexafluoride. Prior to 

1940, radium research was conducted on the 13th floor of the Pupin Building (FUSRAP 

Elimination, 1985, pdf pp. 8-9). 

•	 The Schermerhorn Building was the location of the earliest U.S. pile research (FUSRAP 

Elimination, 1985, pdf p. 9). Gaseous diffusion research and development and a barrier 

production pilot plant were located in a courtyard at Schermerhorn. 

•	 The Havemeyer Building housed some laboratory-scale research, and some chemistry work 

(FUSRAP Elimination, 1985, pdf p. 10). From the FUSRAP histories, it is unclear when SAM 

Labs work started in Havemeyer. 

•	 NIOSH has been unable to locate documentation on any MED-related radiological work 

performed in the Prentiss Building. 

NIOSH is unable to determine the locations of nuclear research operations with more specificity than 

the buildings themselves. NIOSH has found no information that either details or restricts the use of 

radionuclides in particular areas of the SAM Laboratories facilities. Without such information, 

NIOSH is unable to limit the SEC class based on work locations within SAM Labs. Consequently, 

the entire SAM Laboratories facility is included in the proposed SEC class. 

4.5 Job Descriptions Affected by Radiological Operations 

Very little is known about job titles, job descriptions, and/or job assignments related to the 

radiological research at SAM Labs. Available reports include references to chemical research, nuclear 

research, engineering design work, and medical research related to neutron dosimetry conducted with 

the Columbia College of Physicians and Surgeons. From these references, NIOSH assumes chemists, 

physicists, engineers, biologists or other medical professionals were employed by SAM Labs. NIOSH 

has minimal documentation regarding other job titles and/or job assignments associated with specific 

radiological locations at SAM Labs. Without additional specific information that links known worker 

job descriptions with specific work locations, it is not feasible to narrow listed job descriptions to only 

those workers with potential exposures to MED-related radiological operations. Therefore, it is not 

possible to determine that any specific work group was not potentially exposed to the MED-related 

exposures defined in this report, nor is it possible to use job descriptions to define the proposed SEC 

class. 

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5.0 Summary of Available Monitoring Data for the Proposed Class 

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring are unavailable, internal 

exposures can sometimes be estimated using more general area monitoring, process information, and 

information characterizing and quantifying the source term. 

This same hierarchy is used for determining the external exposures to the cancer site. Personal 

monitoring data from film badges or thermoluminescent dosimeters (TLDs) are the primary data used 

to determine such external exposures. If there are no personal monitoring data, exposure rate surveys, 

process knowledge, and source term modeling can sometimes be used to reconstruct the potential 

exposure. 

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available at: 

http://www.cdc.gov/niosh/ocas/ocasdose.html. 

To locate relevant records for SAM Labs, NIOSH conducted data capture efforts that included: visits 

to the National Archive and Records Administration (NARA) facilities in Atlanta, Georgia; and 

queries of the Fernald Legal Database, the OpenNet database, the Nuclear Regulatory Commission 

(NRC) Agency-wide Documents Access and Management System (ADAMS) database, and the Office 

of Scientific & Technical Information (OSTI) database. NIOSH sent a letter to the State of New York 

and contacted the state by telephone to determine if the state had any historical records relevant to 

SAM Laboratories; no relevant documents were identified. SAM Laboratories no longer exists, but 

the Columbia University Associate General Counsel and the Radiation Safety Officer were 

approached for any SAM Labs records; they stated that the university has none. 

5.1 Internal Personnel Monitoring Data 

As of December 26, 2007, there are eight SAM Labs claimants in the NIOSH claimant tracking 

system. None of the NIOSH claimant files have internal exposure monitoring records associated with 

employment at SAM Labs. NIOSH has not located any urinalysis results, breath samples, in vivo 

counting, fecal monitoring, or other bioassay monitoring results for SAM Labs employees. 

5.2 External Personnel Monitoring Data 

The only external personnel monitoring data located by NIOSH are film badge reports and film badge 

cards for individuals employed by Columbia University. The earliest of these reports dates from 

1950, three years beyond the end of the SAM Labs operational period. NIOSH has not located any 

external personnel monitoring data for SAM Labs employees. 

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5.3 Workplace Monitoring Data 

NIOSH has located minimal documentation of workplace monitoring at SAM Labs. The only air 

monitoring results located by NIOSH (Air, 1952; Radon, 1950) are two reports with only 12 radon 

sample results, all of which are from the 1950s (beyond the SAM Labs operational period). No 

contamination survey results for SAM Labs were located, and only one area monitoring report was 

located. This report (Survey, 1947) documents radiation levels monitored in areas and rooms 

surrounding the cyclotron on November 5, 1947. No further area monitoring for the cyclotron has 

been located. A proposal for building a Van De Graff generator was located (FUSRAP Columbia, pdf 

pp. 5-6); however, NIOSH located no confirmation that it was built or any monitoring data pertaining 

to this device. 

5.4 Radiological Source Term Data 

NIOSH has not located radiological source term documentation for SAM Labs of sufficient detail to 

assist in the development of dose reconstructions. SAM Labs was involved with a very broad scope 

of problems being investigated during the Manhattan Project. NIOSH is unable to identify with 

confidence the isotopes, material form, or quantities handled at SAM Labs. NIOSH has located some 

monthly accountability reports for April 1943 through January 1945, and a yearly summary for 1944. 

Because SAM Labs was managed as a very compartmentalized organization (Advisory Board, 1947, 

pdf pp. 9-10), the accountability reports tended to be by project and were more concerned with 

uranium-bearing materials shipped to or from the university (Accountability, 1943-45; Accountability, 

1945). 

The accountability reports located by NIOSH do not give a clear picture of the inventory of all 

radiological materials across SAM Labs. Reference is made to the following materials requested from 

Oak Ridge: polonium-210 derived from bismuth-210 (Requests, 1947-48, pdf p. 152); phosphorus32, sodium-24, calcium-45 and potassium-42 (Requests, 1947-48, pdf p. 166); strontium-89, carbon14, and iodine-131 (Requests, 1947-48, pdf p. 191); and indium-113 (Requests, 1947-48, pdf p. 78). 

No specific accountability or inventory information has been found regarding these radionuclides. 

Lacking further information, NIOSH assumes these materials were part of the SAM Labs MEDrelated research. 

NIOSH has also located documentation indicating the presence of deuterium (Requests, 1947-48, pdf 

p. 156), thorium (FUSRAP Columbia, pdf p. 18; Requests, 1947-48, pdf pp. 15-18), radium (Ra-Be 

Receipt, 1943, pdf p. 3), plutonium-239, and plutonium-240 (Plutonium, 1949; FUSRAP Columbia, 

pdf p. 64). During research on isotope separation, experimentation involving uranium ores, uranium 

slurries, uranium oxides, and uranium hexafluoride was conducted. The weekly reports for September 

1943 describe experiments to remove fission products from uranium oxide slurries (Bi-weekly, 1943, 

pdf p. 5). 

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6.0 Feasibility of Dose Reconstruction for the Proposed Class 

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient, 

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy. 

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible. 

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 

research and analysis is required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and whose only possible remedy under EEOICPA is the addition 

of a class of employees to the SEC. 

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions. 

6.1 Feasibility of Estimating Internal Exposures 

As indicated in Sections 5.1, 5.3, and 5.4, NIOSH does not have access to sufficient personnel 

monitoring, workplace monitoring, or source term data to estimate or bound internal exposures. 

NIOSH has not found bioassay data or relevant air monitoring data, and does not have enough 

information to develop credible internal exposure scenarios for SAM Labs employees. The available 

data are insufficient to support conclusions regarding the potential magnitude of any internal dose. 

Consequently, NIOSH is unable to estimate internal exposures based on the data available. 

NIOSH also lacks sufficient source term and process information relevant to the research conducted at 

SAM Labs. In order to estimate exposures using source term information, NIOSH needs information 

such as the quantity and physical form of the radioisotopes used in order to develop internal exposure 

pathways and bound potential internal exposure. 

Given the lack of personal internal monitoring data, workplace monitoring data, and complete source 

term descriptions for the various radiological hazards, it is not feasible for NIOSH to reconstruct with 

sufficient accuracy the internal doses that may have been received from potential exposures to 

radionuclides during the covered operational period at SAM Laboratories from August 13, 1942 

through December 31, 1947. 

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6.2 Feasibility of Estimating External Exposures 

As indicated in Sections 5.2, 5.3, and 5.4, NIOSH does not have access to sufficient personnel 

monitoring, workplace monitoring, or source term data to estimate or bound external exposures. The 

only external monitoring results located by NIOSH are film badge reports for work conducted after 

the SAM Labs covered period. NIOSH has no external personnel monitoring results related to the 

SAM Labs covered period. Consequently, NIOSH is unable to estimate external exposures based on 

the monitoring data available. 

NIOSH also lacks specific documentation on workplace monitoring, the research and process 

operations, and source term data. In order to estimate exposures using process knowledge and source 

term data, NIOSH needs information such as the identity of the radioisotopes, their quantity and form, 

and potential exposure scenarios (e.g., area monitoring data) to determine the highest exposure 

potential. 

Given the lack of personal external monitoring data, workplace monitoring data, and complete source 

term descriptions for the various external radiological hazards at SAM Laboratories, it is not feasible 

to reconstruct with sufficient accuracy the total external doses that may have been received from 

potential exposures to radionuclides during the covered operational period at SAM Laboratories from 

August 13, 1942 through December 31, 1947. 

NIOSH considers the adequate reconstruction of medical dose for SAM Labs feasible by using 

claimant-favorable assumptions as well as the applicable protocols in the complex-wide Technical 

Information Bulletin, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures (ORAUT-OTIB-0006). 

7.0 Summary of Feasibility Findings for Petition SEC-00102 

This report evaluated the feasibility for estimating the dose, with sufficient accuracy, for all 

employees of the DOE, its predecessor agencies, and DOE contractors or subcontractors who worked 

in the Pupin, Schermerhorn, Havemeyer, Nash, or Prentiss buildings at the SAM Laboratories of 

Columbia University from August 13, 1942 through December 31, 1947. NIOSH determined that it 

lacks the necessary personal and area monitoring data, source term data, and knowledge of potential 

exposure scenarios to reconstruct the total internal or external radiation doses at the facility during this 

time period. Consequently, NIOSH finds that it is not feasible to estimate with sufficient accuracy the 

total radiation dose received by members of this class of employees. 

Occupational medical exposures may be reasonably estimated by using claimant-favorable 

assumptions as well as the applicable protocols in the complex-wide Technical Information Bulletin, 

Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures (ORAUT-OTIB0006). 

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NIOSH has documented herein that it cannot complete the dose reconstruction related to this petition. 

The basis of this finding is specified in this report, which demonstrates that NIOSH does not have 

access to sufficient information to estimate either the maximum radiation dose incurred by any 

member of the class or to estimate such radiation doses more precisely than a maximum dose 

estimate. 

Members of this class at the SAM Laboratories Columbia University facilities may have received 

unmonitored internal and external radiological exposures from various fission products, thorium, 

uranium, and transuranic radionuclides. NIOSH lacks sufficient information, including sufficient 

personnel and workplace monitoring data and radiological source term information, which would 

allow it to estimate the potential total internal and external exposures to which the proposed class may 

have been exposed. 

8.0 Evaluation of Health Endangerment for Petition SEC-00102 

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

governed by EEOICPA and 42 C.F.R. § 83.14(c) and § 83.13(c)(3). Pursuant to these requirements, if 

it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH 

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

the health of members of the class. The regulations require NIOSH to assume that any duration of 

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

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

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

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

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

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

employees in the SEC. 

NIOSH has not obtained evidence from any source to indicate that members of the class were not 

exposed to radiation during a discrete incident likely to have involved levels of exposure similarly 

high to those occurring during nuclear criticality incidents. However, the evidence reviewed in this 

evaluation indicates that some workers in the class may have accumulated chronic radiation exposures 

through intakes of radionuclides and from direct exposure to radioactive materials. Consequently, 

NIOSH is specifying that health was endangered for those workers covered by this evaluation who 

were employed for a number of work days aggregating at least 250 work days within the parameters 

established for this class or in combination with work days within the parameters established for one 

or more other classes of employees in the SEC. 

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9.0 NIOSH-Proposed Class for Petition SEC-00102 

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all employees of the DOE, its predecessor agencies, and 

DOE contractors or subcontractors who worked in the Pupin, Schermerhorn, Havemeyer, Nash, or 

Prentiss buildings at the SAM Laboratories of Columbia University in New York City, New York, 

from August 13, 1942 through December 31, 1947, for a number of work days aggregating at least 

250 work days, occurring either solely under this employment or in combination with work days 

within the parameters established for one or more other classes of employees in the SEC. 

10.0 Evaluation of Second Similar Class 

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses are required. If a second class is 

identified, it would require additional research and analyses. Such a class would be addressed in a 

separate SEC evaluation rather than delay consideration of the current claim. At this time, NIOSH has 

not identified a second similar class of employees at the SAM Laboratories for whom dose 

reconstruction may not be feasible. 

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11 .0 Re fe re nces 

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

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

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

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

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

19392 

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

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

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

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

Program Act of 2000; as amended; OCAS website 

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

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

2004; SRDB Ref ID: 32022 

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

Procedures, Rev. 03 PC-1; Oak Ridge Associated Universities; December 21, 2005; SRDB Ref ID: 

20220 

Accountability, 1943-45, Monthly Accountability Reports – Materials Shipped to Columbia, Capt. L. 

L. Grotjan, Corps of Engineers; War Department; United States Engineer Office, New York; various 

dates, 1943-44; SRDB Ref ID: 31800 

Accountability, 1945, Monthly Accountability Reports – X Material Shipped to Columbia Area, Capt. 

M. L. Hecker, Corps of Engineers; War Department; United States Engineer Office, New York; 

March 1, 1945; SRDB Ref ID: 31054 

Advisory Board, 1947, Report of the Advisory Board on Relationships of the Atomic Energy 

Commission with Its Contractors, U.S. Atomic Energy Commission Advisory Board; June 30, 1947; 

SRDB Ref ID: 29956, pdf pp. 9-10 

Bi-weekly, 1943, Bi-Weekly Report for the Period September 1-15, 1943, Dr. H. C. Urey (Director of 

Research, SAM Labs); September 20, 1943; SRDB Ref ID: 31825 

DOE, 2007, DOE Office of Health, Safety and Security EEOICPA Web Page; 

http://www.hss.energy.gov/healthsafety/fwsp/advocacy/faclist/findfacility.cfm; last accessed on 

January 3, 2008 

FUSRAP Columbia, Columbia University FUSRAP Database Report, assorted historical documents 

regarding atomic work; U.S. Department of Energy; Formerly Utilized Sites Remedial Action 

Program; various dates; SRDB Ref ID: 9113 

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FUSRAP Elimination, 1985, Formerly Utilized Sites Remedial Action Program Elimination Report 

for Columbia University; New York, New York, U.S. Department of Energy; Office of Remedial 

Action and Waste Technology; November 15, 1985; SRDB Ref ID: 9128 

Plutonium, 1949, Plutonium Experiments at Columbia University, memo from B. S. Wolf (Medical 

Director) to R. F. Van Wye (Division of Technical Advisors); July 12, 1949; SRDB Ref ID: 9148 

Radon, 1950, Radon Data, U.S. Atomic Energy Commission, Health and Safety Division, New York; 

September 29, 1950; SRDB Ref ID: 10926 

Ra-Be Receipt, 1943, Receipt of One Gram of Radium Mixed with Beryllium, memo from Capt. S. H. 

Browne (Corps of Engineers) to Dr. H. C. Urey (Director of Research, SAM Labs); November 23, 

1943; SRDB Ref ID: 31815 

Requests, 1947-48, Requests by Columbia University for Radioisotopes from Oak Ridge, various 

names and dates; SRDB Ref ID: 31804 

Scope, 1945, Columbia University Scope of Work, Contract W-14-108-Eng-54, J. R. Dunning, 

Columbia University, Division of War Research; February 12, 1945; SRDB Ref ID: 31845 

Survey, 1947, Radiation Protection Survey November 5, 1947, memo from C. B. Breestrup 

(Consultant) to Dr. W. W. Havens, Jr. (Columbia University); November 10, 1947; SRDB Ref ID: 

9168 

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