Page 1 of 4

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Superior Steel Co. SEC 

Petition: Responses to 

ABRWH Questions at 

Redondo Beach, 

December 13, 2018

Response Paper

National Institute for Occupational 

Safety and Health

January 10, 2019

Megan L. Lobaugh, PhD, CHP

Division of Compensation Analysis and Support
Response Paper Superior Steel SEC Petition: Responses to ABRWH Questions January 10, 2019

Page 2 of 4

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

This is follow-up to the Superior Steel Co. SEC-00247 Evaluation Report presentation made on 

December 13, 2018, at the meeting of the Advisory Board on Radiation and Worker Health. 

There were questions asked by the Board that NIOSH could not provide immediate answers to 

during the meeting and that may not be specifically addressed in the Evaluation Report, but that 

could be answered with little research.

QUESTION REGARDING THE NUMBER OF DOSE RECONSTRUCTION CLAIMS THAT 

HAD BEEN COMPENSATED

As a reminder, NIOSH doesn’t have the authority to calculate the probability of causation (POC) 

or to determine the final compensation decisions for EEOICPA claims; this authority resides 

with the Department of Labor (DOL). However, the dose reconstruction results, which NIOSH 

completes, are used by DOL for these purposes.

For Superior Steel Co., there have been a total of 35 claims referred to NIOSH for Dose 

Reconstruction. All 35 dose reconstruction claims been completed by NIOSH and final 

decisions adjudicated by DOL. 19 of these claims have POCs greater than 50% and the 

remaining 16 claims have POCs less than 50% (Table 1).

Table 1. Probability of Causation Statistics for Superior Steel Co. Dose Reconstruction Claims.

POC >50% 19 

POC <50% 16 

TOTAL 35 

QUESTION REGARDING THE NUMBER OF SURVIVOR VS EE CLAIMS 

Of the 35 dose reconstruction claims for Superior Steel Co., 5 of the claims were initially 

submitted by Energy Employees (EE). The remaining 30 claims were submitted by survivors. 

QUESTION REGARDING CONTROLS USAGE AT SUPERIOR STEEL CO. DURING THE 

EVALUATION PERIOD

All claim CATIs were reviewed for additional information regarding the protective measures 

discussed during the ER presentation discussion: respiratory protection, local ventilation, and 

coveralls. 

Of the 5 EE-submitted claims, only 4 EEs survived to complete the Computer Assisted 

Telephone Interview (CATI). This resulted in 31 claims with CATIs completed by a total of 56 

survivors and 4 claims with CATIs completed by 4 EEs. 

EE CATIs ask more specific questions regarding the work performed, the potential radionuclides 

present, potential exposure time, the precautions taken (e.g., PPE, controls), individual and 

workplace monitoring, occupational medical x-rays, as well as involvement in radiological 

accidents. The survivor CATIs ask fewer questions in the more broad areas regarding work, 
Response Paper Superior Steel SEC Petition: Responses to ABRWH Questions January 10, 2019

Page 3 of 4

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

individual and workplace monitoring, occupational medical x-rays, and EE involvement in 

radiological accidents.

Summary of the CATI information:

1. Respirator

a. 4 EE-completed CATIs 

i. 1 sometimes used respirators, specifically a ‘breathing mask’

ii. 3 never used respirators

b. 56 Survivor-completed CATIs 

i. No specific question regarding respirator use in survivor CATI, but 

survivors could discuss during the course of the interview and notes would 

be made within the documentation. 

ii. 1 survivor mentioned respirator use by EE. 

2. Local Ventilation

a. 4 EE-completed CATIs 

i. 4 never used local ventilation

b. 56 Survivor-completed CATIs 

i. No specific question regarding local ventilation use in survivor CATI, but 

survivors could discuss during the course of the interview and notes would 

be made within the documentation. 

ii. No mention of local ventilation use. 

c. Reminder: while the CATI information doesn’t provide indication of local 

ventilation use, there are ventilation recommendations from the AEC Health and 

Safety Laboratory and indication that ventilation was installed at some point 

during the AWE operations period. 

3. Coveralls 

a. 4 EE-completed CATIs 

i. No specific question regarding use of coveralls or company-supplied and 

laundered outer garments in the EE CATI. Nothing specific mentioned by 

EEs.

ii. There is a question about Anti-Cs (anti-contamination clothing) use; and 

all 4 EEs answered they were never used.

b. 56 Survivor-completed CATIs 

i. No specific question regarding use of coveralls in survivor CATI, but 

survivors could discuss during the course of the interview and notes would 

be made within the documentation. 

ii. 1 survivor mentioned EE use of special clothes that had to be laundered at 

the plant 

iii. 5 survivors mentioned EE wore dirty clothes home from the plant 
Response Paper Superior Steel SEC Petition: Responses to ABRWH Questions January 10, 2019

Page 4 of 4

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

QUESTION REGARDING WHY NO INTERVIEWS WERE MADE AS A PART OF THE SEC 

EVALUATION

The SEC petition evaluation reviewed the Superior Steel AWE operations period (1952 through 

1957). Since more than 60 years have passed, which in NIOSH’s experience limits the 

availability of EEs for interviews, it was decided to forgo interviews.

At the time of the receipt of the SEC petition for Superior Steel Co., only 3 of the dose 

reconstruction claim EEs were living, according to information available via the dose 

reconstruction claims. Note: 2 of these claims were compensated via dose reconstruction, so 

NIOSH would not have heard of Dates of Death post-claim finalization.