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SEC Petition Evaluation Report

Petition SEC-00247

Report Rev Number: 0

Report Submittal Date: November 16, 2018

Subject Expert(s): Tim Kirkham, Mutty Sharfi

Site Expert(s): Not Applicable

Petition Administrative Summary

Petition Under Evaluation

Petition Number: SEC-00247

Petition Type: 83.13

Petition Receipt Date: May 1, 2018

Qualification Date: July 19, 2018

DOE/AWE Facility Name: Superior Steel Co.

Petition Class

Petitioner-Requested Class 

Definition:

All workers who worked in any area at the Superior Steel Co. facility in Carnegie, 

PA, during the period from January 1, 1952 through December 31, 1957.

Class Evaluated by NIOSH: All atomic weapons employees who worked in any area at Superior Steel Co. in 

Carnegie, Pennsylvania, during the period from January 1, 1952 through 

December 31, 1957.

NIOSH-Proposed Class(es) to be 

Added to the SEC:

None

Related Petition Summary Information

SEC Petition Tracking Number(s): Not Applicable

Petition Type: Not Applicable

DOE/AWE Facility Name: Not Applicable

Petition Status: Not Applicable

Related Evaluation Report Information

Report Title: Not Applicable

DOE/AWE Facility Name: Not Applicable

ORAU Preparation and Review

ORAU Lead Technical Evaluator: Tim Kirkham

ORAU Peer Review Completed By: Michael Kubiak
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DCAS Review and Approval

Peer Review Completed By:

[Signature on File]

Megan Lobaugh

November 16, 2018

SEC Petition Evaluation Reviewed 

By: [Signature on File]

James W. Neton

November 16, 2018

SEC Petition Evaluation Approved

By: [Signature on File]

Stuart L. Hinnefeld

November 16, 2018
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Evaluation Report Summary: SEC-00247, Superior Steel Co. 

The National Institute for Occupational Safety and Health (NIOSH) prepared this evaluation report in 

response to a petition to add a class of workers at Superior Steel Co. to the Special Exposure Cohort 

(SEC). The Energy Employees Occupational Illness Compensation Program Act of 2000, as 

amended, (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, describe the process for adding new classes to the SEC. 

Petitioner-Requested Class Definition

NIOSH received petition SEC-00247 on May 1, 2018, and qualified it on July 19, 2018. The 

petitioner requested that NIOSH consider the following class: All workers who worked in any area at 

the Superior Steel Co. facility in Carnegie, PA, during the period from January 1, 1952 through 

December 31, 1957. 

Class Evaluated by NIOSH

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

the following class: All atomic weapons employees who worked in any area at Superior Steel Co. in 

Carnegie, Pennsylvania, during the period from January 1, 1952 through December 31, 1957. 

NIOSH Determination about the Proposed Class to be Added to the SEC 

NIOSH has obtained operational process data, and air sampling data performed periodically during 

uranium rolling operations at Superior Steel Co. during the period from January 1, 1952 through 

December 31, 1957. Based on its analysis of these available resources, NIOSH found no part of the 

class under evaluation for which it cannot estimate radiation doses with sufficient accuracy.

Feasibility of Dose Reconstruction

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

information to: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred in plausible circumstances by any member of 

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

the maximum dose. Information available from the site profile and additional resources is sufficient 

to estimate the maximum internal and external potential exposure to members of the evaluated class 

under plausible circumstances during the specified period. 

The NIOSH dose reconstruction feasibility findings are based on the following: 

• NIOSH finds that it is feasible to reconstruct occupational medical dose for Superior Steel Co.

employees with sufficient accuracy during the period from January 1, 1952 through December 31, 

1957. Medical dose is not assigned after 1957 after the AWE covered period for Superior Steel 

Co. 

• The period under evaluation includes the entire AWE operations period for Superior Steel Co. 

The effective date of the AEC contract with Superior Steel Co. was June 27, 1952, therefore, no 
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operational internal or external exposures associated with rolling activities will be assessed prior 

to June 27, 1952. 

• Principal sources of internal radiation for members of the proposed class included inhalation of 

uranium dust produced from the manipulation and oxidation of uranium metal during rolling and 

related processes. NIOSH estimates that Superior Steel Co. processed over 60,000 pounds of 

uranium metal for AEC contracts. Superior Steel Co. also performed a non-AEC test-scale rolling 

operation with 700 pounds of thorium metal in March or April 1956 for a commercial customer. 

• NIOSH has process-related air monitoring data collected by the AEC during four uranium rolling 

campaigns; two in 1953 and two in 1955. NIOSH has determined that the available air monitoring 

data are sufficient to determine the bounding uranium alpha air exposures for the highest 

potentially exposed workers at Superior Steel Co. for the period January 1, 1952 through 

December 31, 1957. 

• NIOSH has determined that it has sufficient process information to derive airborne thorium 

concentrations based on the mass loading calculated from the AEC air sampling results associated 

with the 1955 uranium rollings. Given the large-scale nature of the site’s uranium work and the 

small-scale nature of the thorium work, this is considered a favorable estimate of thorium-related 

exposure from the single test-scale thorium campaign.

• NIOSH finds that it is feasible to reconstruct with sufficient accuracy the internal radiation doses 

from uranium and thorium metal rolling operations for Superior Steel Co. employees during the 

period from January 1, 1952 through December 31, 1957. 

• Principal sources of external radiation for members of the proposed class included direct exposure 

from being in proximity to the uranium ingots, exposure from contaminated surfaces, and 

submersion in air contaminated with dust generated via the processing of uranium metal for the 

AEC. Superior Steel Co. workers also received such exposures during the non-AEC test-scale 

rolling operation with 700 pounds of thorium metal in March or April 1956 for a commercial 

customer.

• For AWE sites such as Superior Steel Co. that handled uranium metals, NIOSH procedure 

Battelle-TBD-6000 presents methods for bounding worker doses due to external exposure from 

rolling operations with uranium metal. NIOSH has determined that it has sufficient applicable 

site-specific information, using the methods of Battelle-TBD-6000, to model Superior Steel Co. 

worker doses due to uranium and thorium metal rolling operations during the period from January 

1, 1952 through December 31, 1957. 

• NIOSH finds that it is feasible to reconstruct with sufficient accuracy the external radiation doses 

from uranium and thorium metal rolling operations for Superior Steel Co. employees during the 

period from January 1, 1952 through December 31, 1957. 

• Pursuant to 42 C.F.R. § 83.13(c) (1), NIOSH determined that there is sufficient information to 

either: (1) 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 (2) estimate the radiation doses of members of the class more precisely 

than a maximum dose estimate. 
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Health Endangerment Determination

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

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

the evaluated class.
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Table of Contents

Evaluation Report Summary: SEC-00247, Superior Steel Co. ............................................................... 4

Table of Contents .................................................................................................................................... 8

1.0 Purpose and Scope ........................................................................................................................ 10

2.0 Introduction .................................................................................................................................. 10

3.0 SEC-00247, Superior Steel Co. Class Definitions ....................................................................... 11

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 11

3.2 Class Evaluated by NIOSH ................................................................................................. 12

3.3 NIOSH Determination about the Proposed Class to be Added to the SEC ......................... 12

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 12

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 13

4.2 ORAU Technical Information Bulletins (OTIBs) ............................................................... 13

4.3 Facility Employees and Experts .......................................................................................... 14

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

4.5 NIOSH Site Research Database .......................................................................................... 14

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 14

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 15

5.1 Superior Steel Co. Plant and Process Descriptions ............................................................. 15

5.1.1 Uranium Processing ................................................................................................. 16

5.1.2 Thorium Processing ................................................................................................. 17

5.2 Radiological Exposure Sources from Superior Steel Co. Operations ................................. 17

5.2.1 Internal Radiological Exposure Sources ................................................................. 18

5.2.1.1 Uranium .................................................................................................... 18

5.2.1.2 Thorium .................................................................................................... 18

5.2.2 External Radiological Exposure Sources ................................................................ 19

5.2.2.1 Photon ....................................................................................................... 19

5.2.2.2 Beta ........................................................................................................... 20

5.2.2.3 Neutron ..................................................................................................... 20

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 21

6.1 Available Superior Steel Co. Internal Monitoring Data ...................................................... 21

6.2 Available Superior Steel Co. External Monitoring Data ..................................................... 22

6.3 Available Superior Steel Co. Remediation Workplace Monitoring Data ........................... 22

6.3.1 Uranium ................................................................................................................... 22

6.3.2 Thorium ................................................................................................................... 23

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 24

7.1 Pedigree of Superior Steel Co. Data .................................................................................... 25

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 25

7.1.2 External Monitoring Data Pedigree Review ............................................................ 25

7.2 Evaluation of Bounding Internal Radiation Doses .............................................................. 25

7.2.1 Evaluation of Bounding AWE Period Internal Doses ............................................. 26

7.2.2 NIOSH Proposed Methods for Bounding AWE Period Internal Doses .................. 30

7.2.3 Internal Dose Reconstruction Feasibility Conclusion ............................................. 32

7.3 Evaluation of Bounding External Radiation Doses ............................................................. 34

7.3.1 Evaluation of Bounding AWE Period External Doses ............................................ 34

7.3.2 NIOSH Proposed Methods for Bounding External AWE Period Doses ................. 35

7.3.3 External Dose Reconstruction Feasibility Conclusion ............................................ 36
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7.4 Evaluation of Petition Basis for SEC-00247 ....................................................................... 37

7.4.1 Lack of Personnel Urinalysis Data .......................................................................... 37

7.4.2 Lack of External Dosimetry Data ............................................................................ 37

7.5 Summary of Feasibility Findings for Petition SEC-00247 .................................................. 38

8.0 Evaluation of Health Endangerment for Petition SEC-00247 ...................................................... 38

9.0 Class Conclusion for Petition SEC-00247 ................................................................................... 39

10.0 References .................................................................................................................................... 40

Attachment One: Data Capture Synopsis .............................................................................................. 46

Attachment Two: Thorium Contamination ........................................................................................... 52

Tables

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

Table 5-1: Superior Steel Co. Processing Areas ................................................................................... 15

Table 5-2: Beta Surface Exposure Rates from Equilibrium Thickness of U Metal Compounds .......... 20

Table 6-1: General Area Air Concentrations ......................................................................................... 21

Table 6-2: Breathing Zone Air Concentrations ..................................................................................... 22

Table 6-3: Radiological Surveys Performed at the Superior Steel Site ................................................. 22

Table 7-1: Rolling Notes from Reference Documents .......................................................................... 26

Table 7-2: Summary of Feasibility Findings for SEC-00247 ............................................................... 38

Table A1-1: Summary of Holdings in the SRDB for Superior Steel Co. .............................................. 46

Table A1-2: Database Searches for Superior Steel Co. ......................................................................... 49

Figures

Figure 5-1: Processing Areas (Myrick, 1981) ....................................................................................... 16

Figure 5-2: Layout of Hot Strip Uranium Mill Operation at Superior Steel Co., 1955 (Myrick, 1981) 16
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SEC Petition Evaluation Report for SEC-00247

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

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

Kirkham, Oak Ridge Associated Universities (ORAU). The rationales for all conclusions in this 

document are explained in the associated text.

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing radiation doses for all atomic weapons 

employees who worked in any area at Superior Steel Co. in Carnegie, Pennsylvania, during the period 

from January 1, 1952 through December 31, 1957. It provides information and analyses germane to 

considering a petition for adding a class of employees to the congressionally-created SEC. 

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

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

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

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

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

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

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

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 (DHHS) 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

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 on the NIOSH Radiation Dose Reconstruction Program webpage. 

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

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

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

estimate of the maximum radiation dose.

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

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

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

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

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

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

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

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

or more other SEC classes. 

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

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

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

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

consider the NIOSH evaluation report, together with the petition, petitioner(s) comments, and other 

information the Advisory Board considers appropriate, in order to make recommendations to the 

Secretary of DHHS 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 Advisory Board, the Director of NIOSH will 

propose a decision on behalf of DHHS. The Secretary of DHHS will make the final decision, taking 

into account the NIOSH evaluation, the advice of the Advisory Board, and the proposed decision 

issued by NIOSH. As part of this decision process, petitioners may seek a review of certain types of 

final decisions issued by the Secretary of DHHS.

2

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

available on the NIOSH Radiation Dose Reconstruction Program webpage.

3.0 SEC-00247, Superior Steel Co. Class Definitions

The following subsections address the evolution of the class definition for SEC-00247, Superior Steel 

Co. When a petition is submitted, the requested-class definition is reviewed as submitted. Based on 

its review of the available site information and data, NIOSH will make a determination whether to 

qualify for full evaluation all, some, or no part of the petitioner-requested class. If some portion of the 

petitioner-requested class is qualified, NIOSH will specify that class along with a justification for any 

modification of the petitioner’s class. After a full evaluation of the qualified class, NIOSH will 

determine whether to propose a class for addition to the SEC and will specify that proposed class 

definition. 

3.1 Petitioner-Requested Class Definition and Basis

NIOSH received petition SEC-00247 on May 1, 2018, and it qualified on July 19, 2018. The 

petitioner requested that NIOSH consider the following class: All workers who worked in any area at 

the Superior Steel Co. facility in Carnegie, PA, during the period from January 1, 1952 through 

December 31, 1957. 

The petitioners provided information in support of their proposal that records and information may be 

inadequate for dose reconstruction for the Superior Steel Co. employees in question. The basis for 

their proposal was that certain radiation exposures and doses to the class were not monitored. NIOSH 

deemed the following information sufficient to qualify SEC-00247 for evaluation: 
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• The petitioner provided NIOSH statements made in ORAUT-TKBS-0034, Rev 00-PC-1 

that “individual uranium urinalysis data are unavailable for Superior Steel workers and 

none are known to exist” and “no external dosimetry results are available for Superior Steel 

employees.” 

NIOSH concluded that there is sufficient documentation to support, for at least part of the petitionerrequested time period, the petition basis that internal and external radiation exposures and radiation 

doses were possibly not adequately monitored at Superior Steel Co., either through personal 

monitoring or area monitoring. Based on its Superior Steel Co. research and data capture efforts for 

area monitoring, NIOSH determined that it has access to air monitoring data during uranium rolling 

operations for Superior Steel Co. employees during the period under evaluation. However, for 

personnel monitoring, NIOSH also determined that internal and external personnel radiological 

monitoring data records are not available for any radionuclides during the period under evaluation. 

The information and statements provided by the petitioner qualified the petition for further 

consideration by NIOSH, the Advisory Board, and DHHS. The details of the petition basis are 

addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH

Based on its preliminary research, NIOSH accepted the petitioner-requested class because of the need 

to further evaluate the availability of personnel and workplace monitoring data and related 

information for estimating radiation doses due to uranium, and potentially thorium, exposures at the 

facility. Therefore, NIOSH defined the following class for further evaluation: All atomic weapons 

employees who worked in any area at Superior Steel Co. in Carnegie, Pennsylvania, during the period 

from January 1, 1952 through December 31, 1957. 

3.3 NIOSH Determination about the Proposed Class to be Added to the SEC

NIOSH has air and workplace monitoring data obtained during uranium rolling operations at Superior 

Steel Co. during the period under evaluation. Based on its analysis of these available resources, 

NIOSH found no part of the class under evaluation for which it cannot estimate radiation doses with 

sufficient accuracy.

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class

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

regarding Superior Steel Co. The database search included the DOE Legacy Management Considered 

Sites database, the DOE Office of Scientific and Technical Information (OSTI) SciTech Connect 

database, and the Hanford Declassified Document Retrieval System. In addition to general Internet 

searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, the Nuclear 

Regulatory Commission (NRC) Agency-wide Documents Access and Management (ADAMS) web 

searches, Savannah River Site (SRS) Electronic Document Workflow System (EDWS), and the DOENational Nuclear Security Administration-Nevada Site Office-search. Attachment One includes a 

summary of Superior Steel Co. documents. The summary specifically includes data capture details 

and general descriptions of the documents retrieved. 
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In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

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

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

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

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

4.1 Site Profile Technical Basis Documents (TBDs)

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

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

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

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

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

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

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

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

Superior Steel Co.: 

• An Exposure Matrix for Superior Steel, Carnegie, Pennsylvania, Period of Operation: January 1, 

1952 through December 31, 1957, ORAUT-TKBS-0034; Rev. 00 PC-1; August 9, 2005; SRDB 

Ref ID: 20182 

• Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, Battelle-TBD-6000; 

Rev. 1; June 17, 2011; SRDB Ref ID: 101251 

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:

• Dose Reconstruction from Occupational Medical X-ray Procedures, ORAUT-OTIB-0006, Rev. 

05; effective August 13, 2018; SRDB Ref ID: 172596

• Internal Dose Overestimates for Facilities with Air Sampling Programs, ORAUT-OTIB-0018, 

Rev. 01; effective August 9, 2005; SRDB Ref ID: 19436

• Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Employer 

Facilities, ORAUT-OTIB-0070, Rev. 01; effective March 5, 2012; SRDB Ref ID: 108851

• Guiding Reconstruction of Intakes of Thorium Resulting from Nuclear Weapons Programs, 

ORAUT-OTIB-0076, Rev. 00; effective July 10, 2014; SRDB Ref ID: 133669

• Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays Administered Off 

Site, ORAUT-OTIB-0079, Rev. 02; effective June 15, 2017; SRDB Ref ID: 166967
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4.3 Facility Employees and Experts

Interviews for the specific purpose of supporting this SEC-00247 evaluation were not considered 

likely to produce new information for the period under evaluation. Therefore, additional interviews 

were not conducted by NIOSH. 

4.4 Previous Dose Reconstructions

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

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

evaluation. Table 4-1 summarizes the results of this review. (NOCTS data available as of October 2, 

2018) 

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

Description Totals

Total number of claims submitted for dose reconstruction 35

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

(January 1, 1952 through December 31, 1957) 35

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

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

for final approval).

35

Number of claims for which internal dosimetry records were obtained for the time period in the evaluated

class definition 0 

Number of claims for which external dosimetry records were obtained for the time period in the evaluated

class definition 0 

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

records could be obtained for the employee. No incidents were reported by claimants and no personal 

monitoring records were provided.

4.5 NIOSH Site Research Database

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

assessment of the evaluated class. NIOSH identified 308 documents in this database as pertaining to 

Superior Steel Co. These documents were evaluated for their relevance to this petition. The 

documents include historical information regarding the uranium rolling process, dates of rolling 

campaigns, air monitoring data, and Atomic Energy Commission (AEC) radiological licensing 

requests and granting documents. 

4.6 Documentation and/or Affidavits Provided by Petitioners

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

petitioners:

• An Exposure Matrix for Superior Steel, Carnegie, Pennsylvania, Period of Operation: January 1, 

1952 through December 31, 1957, Rev. 00 PC-1; ORAUT-TKBS-0034; ORAU Team Dose 

Reconstruction Project for NIOSH; effective August 9, 2005; SRDB Ref ID: 20182
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5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH

The following subsections summarize both radiological operations at Superior Steel Co. from January 

1, 1952 through December 31, 1957, and the information available to NIOSH to characterize 

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

and workplace monitoring data obtained during uranium rolling operations at Superior Steel Co. 

during the period under evaluation, historical radiological licensing information, and site remediation 

survey data. The information included within this evaluation report is intended only to be a summary 

of the available information. 

5.1 Superior Steel Co. Plant and Process Descriptions 

Superior Steel Co. was located in Carnegie, Pennsylvania, on a 25-acre site. The AEC awarded a 

contract to Superior Steel Co. on June 27, 1952, because it was one of the few companies that had the 

technical expertise to roll and clad metal strip and plate (ORAUT-TKBS-0034; SROO, 1979; Young, 

1985). The initial contract (AT(30-1)-1412) originated from the AEC New York Operations Office. 

The contract was transferred for administration to the Oak Ridge Operations Office and on October 

15, 1954, was transferred to the Savannah River Operations Office (Young, 1985; SROO, 1979). 

Records indicate they rolled, cut, and finished uranium metal into strip under a cost-plus-fixed-fee 

contract, and that the contract was terminated on or about September 30, 1957 (Young, 1985; SROO, 

1979). Superior Steel Co.’s source and fission material accounting station authority withdrawal was 

recorded on November 27, 1957 (Young, 1985). 

Table 5-1 shows a summary of approximate size and functions for Areas A, B, and C of the Superior 

Steel Co. metal processing facilities. Figures 5-1 and 5-2 below, show the layout of the former 

Superior Steel Co. facility. Figure 5-2 shows Area A where the majority of the metal handling is 

believed to have occurred. Note that in both figures, the process started at the right of the drawing 

with the salt bath.

Table 5-1: Superior Steel Co. Processing Areas

Area

Approximate 

Size

(ft2)

Area Functions 

A 24,000

This is the location where the majority of the uranium metal handling and shaping is 

believed to have occurred. This area contained the salt bath, roughing mill, brushing 

station, finishing stands, and shear.

B 8,250

This area was considered the “clean” side of the mill where the atmosphere was 

controlled to provide proper conditions for motor and instrument operations. This area 

housed the motor room and control panels for the mill.

C 12,000

This was the end of the mill process where metal was rolled for shipping prior to 

further handling. Two pits indicate locations of the bliss downcoiler (to coil the metal) 

and an upender (to tilt the material to 90 degrees).

Source: Myrick, 1981
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Figures 5-1 and 5-2 below, show the layout of the former Superior Steel Co. facility. Figure 5-

2 shows Area A where the majority of the metal handling is believed to have occurred. Note 

that in both figures the process started at the right of the drawing with the salt bath.

Figure 5-1: Processing Areas (Myrick, 1981)

Figure 5-2: Layout of Hot Strip Uranium Mill Operation at Superior Steel Co., 1955 (Myrick, 1981) 

5.1.1 Uranium Processing

The AEC performed security inspections related to the source and fission material accounting station 

at Superior Steel Co. in November 1954, May 1955, November 1955, June 1956, and in January 1957 

(Young, 1985; SROO, 1979; Reardon, 1957). Available AEC Health and Safety reports show four 

rolling dates monitored by the AEC: May 13, 1953, August 3, 1953, May 9, 1955, and September 19, 

1955 (Klevin, 1953a, b; AEC, 1955a, b). The last three reports mention the number of uranium slabs 

rolled: 23, 32, and 30, respectively. AEC reported that six of the slabs rolled on May 9, 1955, were 

enriched uranium (1.5% U-235) (Angerman, 1955; AEC, 1955a). NIOSH’s exposure matrix indicates 

that the general Superior Steel Co. process involved the following (ORAUT-TKBS-0034; Klevin, 

1953a, b; AEC, 1955a):

• A 1-inch thick slab of uranium, from 61 to 89 inches long and from 5.5 to 7 inches wide, was 

placed into a rectangular steel vessel containing a salt bath (50% LiCl and 50% KCl by volume).

• The salt bath was heated in a gas-fired furnace to a working temperature of approximately 1200°F 

for 45 minutes and then removed from the furnace. In 1953, a new furnace was installed that 

included a salt bath. 

• The slab was moved by overhead crane to the rolling mill table. 
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• The slab was passed through a roughing roll five times and sent through the finishing stands. 

• The strip was then cut as desired and transferred with tongs to a cooling area. 

• The final thickness was between 182 and 191 mils (E. I. du Pont, 1954). 

5.1.2 Thorium Processing

In addition to the work performed for AEC, Superior Steel Co. was licensed (AEC license No. C3480) on March 27, 1956, to receive possession of and/or title to 700 pounds of thorium metal to 

perform development studies for Babcock & Wilcox Company with an expiration date of April 1, 

1957 (Johnson, 1956a). The license was amended one month later (April 30, 1956) for forging, roll 

cogging, finish rolling, and cutting unlimited quantities of thorium metal for the Babcock & Wilcox 

Company with an expiration date of April 30, 1958 (Johnson, 1956b). An April 20, 1956 

correspondence for this thorium-related license amendment to Superior’s License No. C-3480 states 

“... we are currently evaluating the data secured in connection with our test rollings” (Ferguson, 

1956), indicating that at least a portion of the 700 pounds of thorium metal was rolled. To date, 

NIOSH has not located any documentation indicating any production-scale rollings of thorium metal 

at Superior Steel Co. Due to the limited size of the Superior Steel Co. facilities and its production 

capacities, it is assumed that both commercial work and work performed for AEC was done on the 

same equipment and process line (Adams, 2001; Johnson, 1957). 

The AEC C-3480 license allowed Superior Steel Co. to receive source material (thorium metal), 

owned by Consolidated Edison (Ferguson, 1956) from another commercial licensee (Babcock & 

Wilcox Company under license No. C-3465) and process it into the desired shape for use in a critical 

experiment at Babcock & Wilcox Company (Ferguson, 1956). The work performed by Babcock & 

Wilcox was likely part of their Critical Experiment Laboratory in Lynchburg, Virginia, for the 

Consolidated Edison Thorium Reactor (Babcock & Wilcox, 1962). According to the NRC, the 

Superior Steel Co. AEC license expired in 1958 and records indicate that there was neither a closeout 

survey nor inspection of the facility to support termination of this license (USACE, 2007). 

The United States Army Corps of Engineers (USACE) in accordance with the Comprehensive 

Environmental Response, Compensation and Liability Act (CERCLA) and the National Oil and 

Hazardous Substance Pollution Contingency Plan (NCP) performed a Preliminary Assessment (PA) of 

the former Superior Steel Co. site (USACE, 2007). The purpose of this PA was to review information 

to determine the need for further action by USACE under the Formerly Utilized Sites Remedial 

Action Program (FUSRAP) to ensure the protection of human health and the environment. The scope 

of the assessment included a review of existing information about the site and a site visit on August 

29, 2006. In its PA, USACE states that any residual radioactive contamination associated with 

commercial operations involving thorium metal is not eligible for cleanup under FUSRAP, which 

indicates to NIOSH that Superior Steel Co.’s thorium-metal operations during the AWE operations 

period were determined by USACE to not be AEC-related. 

5.2 Radiological Exposure Sources from Superior Steel Co. Operations

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

Superior Steel Co. class under evaluation.
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5.2.1 Internal Radiological Exposure Sources

The potential for internal radiation dose existed at the Superior Steel Co. facility in all areas where 

radioactive materials were handled or stored. Based on the site operations, sources of radionuclide 

internal exposure included dust generated from the uranium and thorium ingots processed at the site. 

The principal source of internal radiation exposure at Superior Steel Co. during the period under 

evaluation was inhalation of uranium dust produced from the manipulation and oxidation of uranium 

metal during production-scale rolling and related processes. A secondary source of internal exposures 

is the resuspension of settled uranium dust. Natural and enriched uranium were rolled at Superior 

Steel Co. and it is also possible that Superior Steel Co. rolled recycled uranium after 1952. The 

potential for similar inhalation of thorium dust also existed during smaller-scale test rollings of 

thorium during a three-week period in 1956. 

AEC Health and Safety Laboratory (HASL) performed several visits and air sampling campaigns to 

review the airborne uranium concentration at the Superior Steel Co. during operations (Klevin, 1953a, 

b; AEC, 1955a, b). Information regarding HASL recommendations to install additional ventilation 

and make changes to work practices in order to decrease airborne uranium concentrations, as well as 

implementation of such recommendations, are available.

5.2.1.1 Uranium 

The Superior Steel Co. radiological source term consisted primarily of natural uranium metal, uranium 

oxides, and natural uranium’s short-lived progeny. The source term was produced from the 

manipulation and oxidation of uranium metal during rolling and related processes. Long-lived 

progeny in the uranium series prevent significant ingrowth past U-234 in the U-238 decay series and 

beyond Th-231 in the U-235 decay series.

After 1952, small quantities of primarily alpha (Pu-239, Np-237, and Th-232/228) and beta (Tc-99) 

emitting radionuclides found their way into uranium metal via recycling. Assumed activity fractions 

per unit uranium are presented in Battelle-TBD-6000, and any associated internal doses are assigned 

as appropriate after 1952. 

5.2.1.2 Thorium 

The current exposure matrix for Superior Steel Co. (ORAUT-TKBS-0034) does not address potential 

thorium exposures at the site. During this evaluation, although there is no evidence of large-scale 

thorium metal handling, NIOSH determined that the site amended its radioactive material license with 

the AEC to allow for the commercial rolling of thorium metal. As presented in Section 5.1.2 above, 

Superior Steel Co. was licensed (AEC license No. C-3480) on March 27, 1956, to receive possession 

of and/or title to 700 pounds of thorium metal to perform development studies for Babcock & Wilcox

Company (Johnson, 1956a). In a subsequent amendment request on April 20, 1956, Superior Steel 

Co. requested license for forging, roll cogging, finish rolling, and cutting unlimited quantities of 

thorium metal (Johnson, 1956b). In the April 20, 1956 correspondence the site stated “... we are 

currently evaluating the data secured in connection with our test rollings” (Ferguson, 1956), indicating 

that at least a portion of the 700 pounds of thorium metal was processed between March 27, 1956 and 

April 20, 1956. This is the only indication of thorium metal processing found by NIOSH in this 

evaluation. NIOSH has not located any documentation indicating any production-scale rollings of 

thorium metal at Superior Steel Co.
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To further review potential for large-scale thorium operations at Superior Steel Co., NIOSH reviewed 

the results of four radiological surveys performed for remediation purposes. Given the timeframe for 

the potential thorium metal rolling (1956-1958) and the years of the remediation radiological surveys 

available to NIOSH (1980, 2000, 2003, and 2014), enough time had passed, regardless of the age of 

the thorium at rolling, that any thorium contamination could be measured and calculated using the 

daughter products of Th-232, assuming equilibrium similar to that of natural thorium. Since the 

radiological surveys didn’t detect thorium, NIOSH assumes production-level rolling of thorium didn’t 

occur. 

Thorium has three abundant naturally-occurring radionuclides: Th-232, Th-230, and Th-228. These 

three isotopes decay by alpha decay with some associated weak intensity photons. 

5.2.2 External Radiological Exposure Sources 

The potential for external radiation dose existed at the Superior Steel Co. facility in all areas where 

radioactive materials were handled or stored. Based on the site operations, sources of external 

exposure included photon and beta radiation emitted from the uranium and thorium ingots processed 

at the site. Due to the type of metal being processed, neutron exposure was not significant, as 

examined below. 

The principal potential sources of external dose for the Superior Steel Co. facility employees during 

the period under evaluation (January 1, 1952 through December 31, 1957) were direct exposure from 

being in proximity to the uranium ingots, exposure from contaminated surfaces, and submersion in air 

contaminated with dust generated via the processing of uranium ingots in the areas described in 

Section 5.1 herein (Areas A, B, and C). The potential for similar external exposures from thorium 

metal also existed during smaller-scale thorium test rollings during a three-week period in 1956. 

No detailed descriptions of how ingots were handled at Superior Steel Co. (e.g., hands-on handling 

time vs. crane handling time) were located by NIOSH. No site-specific information is available to 

NIOSH to determine the amount of time a worker spent near the uranium forms versus just being in 

the general area. For Superior Steel Co., it was stated that stamping numbers into each plate was 

performed by hand (AEC, 1955b), therefore some time would have been spent by laborers in closer 

proximity to the plate than during the remote handling operations. External dosimetry records 

(personnel monitoring) and area monitoring records for Superior Steel Co. employees are not 

available to NIOSH for the period under evaluation. In the absence of site-specific process data, 

Battelle-TBD-6000 presents assumptions to be made about a worker's exposure conditions. 

5.2.2.1 Photon 

The photon exposures for Superior Steel Co. were from processing uranium and, for a short period in 

1956, thorium. The work involved rolling uranium slabs (1-inch thick, 61 to 89-inches long, and 5.5 

to 7-inches wide) into plates (approximately 0.185-inches thick and 25 to 37-feet long, cut into 

sections of about 6-feet); therefore largely requiring the use of cranes. 

The majority of photons from natural uranium metals are in the 30 to 250 keV energy range. 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, such as a thick plate, to have 

energies greater than 250 keV. 
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5.2.2.2 Beta

Uranium metal and compounds emit beta and electron radiation that can irradiate the skin, and to a 

more limited extent, the shallow organs of the body. Table 5-2, taken from DOE-STD-1136 (DOE, 

2004), shows the measured beta surface dose rates from uranium metal and selected uranium 

compounds, illustrating that dose rates from uranium metal exceed the dose rates from other uranium 

compounds. 

Table 5-2: Beta Surface Exposure Rates from Equilibrium Thickness of U Metal Compounds

Source Beta Surface Exposure Rate 

(mrad/h)a

U-natural metal slab 233

UO2 207

UF4 179

UO2(NO3)26H2O 111

UO3 204

U3O8 203

UO2F2 176

Na2U2O7 167

a Beta surface exposure rate in air through a polystyrene filter 7 mg/cm2 thick

When uranium metal is melted, impurities can separate from the metal matrix. Differences in 

densities and melting points can then cause impurities (i.e., Th-234, Pa-234m, decay products of U238, magnesium, slag, hydrogen) to separate from the molten uranium metal and concentrate on the 

surfaces. The process then causes a high concentration of these beta emitters in the top and other 

surfaces of the cast ingot, increasing the surface beta dose. These beta emitters have relatively short 

half-lives, therefore the ingot decays to a normal dose rate rather quickly (e.g., 240 days).

After 1952, small quantities of primarily alpha (Pu-239, Np-237, and Th-232/228) and beta (Tc-99) 

emitting radionuclides found their way into uranium metal via recycling. Because of their primarily 

non-penetrating radiation types, relatively low activities, and relatively low external radiation hazard 

when compared to that of their uranium matrix, their contribution to dose is considered adequately 

addressed by the uranium external dose estimates. A quick check of the relative penetrating dose 

from an overestimate of recycled uranium contaminants in ground surface contamination shows that 

they contribute less than 1% to penetrating dose (Battelle-TBD-6000). The non-penetrating doses 

from uranium are sufficiently large to bound any small contribution from Tc-99 (Battelle-TBD-6000). 

5.2.2.3 Neutron 

Battelle-TBD-6000 states that for uranium oxides “the neutron dose rate is about 0.07% of the 

beta/photon dose rate and need not be included in dose rate calculations. For uranium metal, the 

neutron dose rate is even less important” (Battelle-TBD-6000). Because uranium metal is the major 

radionuclide of concern at the Superior Steel Co. site, neutron exposures from uranium were not a 

significant hazard during the period from January 1, 1952 through December 31, 1957. Similarly, 

neutrons from thorium metal are not considered a significant hazard during the same period, due to 
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thorium’s lower rate of spontaneous fission. Neutron exposures will not be discussed throughout this 

report.

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH

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

for the Superior Steel Co. class under evaluation. 

6.1 Available Superior Steel Co. Internal Monitoring Data

No personal internal monitoring data have been found for the Superior Steel Co. workers for the 

evaluated period. NIOSH has found no indication that internal personnel monitoring was performed 

at Superior Steel Co. during the AWE operations period under evaluation. 

Air Monitoring Data

Air sampling was performed at Superior Steel Co. during some of the uranium rolling operations 

(Klevin, 1953a, b; AEC, 1955a, b). The air samples consisted of collection on filters of radioactive 

particulate from breathing zones (BZs), and general areas (GAs) during processing. The alpha activity 

measured on the filter was used to determine airborne alpha-activity concentrations. When multiple 

samples at a location were collected, AEC used the mean air concentration in subsequent calculations. 

At most facilities, AEC matched air concentration determinations with information about worker 

categories, locations, tasks, and workers’ time at each location or task; however, AEC noted that this 

was not feasible at Superior Steel Co. (Harris, 1953), but did not include the reasoning for this 

conclusion. 

Four AEC HASL reports of measured uranium air concentrations have been found for Superior Steel 

Co. (Klevin, 1953a, b; AEC, 1955a, b). The data from those four sets of measurements are

summarized in Tables 6-1 and 6-2. The data appear to have a bi-modal distribution with the first year 

of measurement (i.e., 1953) being an order of magnitude greater than the later year (i.e., 1955). 

NIOSH attributes this to implementation of AEC process-improvement recommendations following 

the first air evaluation. 

Table 6-1: General Area Air Concentrations

Date of Sample

Highest 

Alpha 

Recorded 

(dpm/m3) 

Lowest Alpha 

Recorded

(dpm/m3) 

Location of Highest Value Number of 

Samples

SRDB 

Ref ID

May 13,1953 13,200 Not detectable Between finish roll #4 and #5 north 

side 28 6898

August 3,1953 49,110 64 West end of roughing roll, over 

roll 33 6899

May 9, 1955 1,800 Not detectable Shear vicinity 61 6877

September 19, 1955 3,320 0.5

Midway between roughing roll 

hood and newly installing brushing 

station

38

6888, 

9677
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Table 6-2: Breathing Zone Air Concentrations

Date of Sample

Highest 

Alpha 

Recorded 

(dpm/m3)

Lowest Alpha 

Recorded

(dpm/m3) 

Location of Highest Value Number of 

Samples

SRDB 

Ref ID

May 9, 1955 38,500 592 BZ - stamping plate (manual 

operation) 9 6877

September 19, 1955 18,000 450 BZ - stamping 3 sections of plate 6 6888, 

9677

Details regarding the sample measurement analyses used and the associated minimum detectable 

activities are not available. 

6.2 Available Superior Steel Co. External Monitoring Data

No external monitoring data have been found for the Superior Steel Co. site. NIOSH has found no 

indication that external personnel monitoring was performed at Superior Steel Co. during the AWE 

operations period under evaluation. There is also no indication that pre-employment, employment, or 

post-employment medical x-ray examinations were required or performed. 

6.3 Available Superior Steel Co. Remediation Workplace Monitoring Data

Although the periods of site remediation for Superior Steel Co. facilities are not within the period 

under evaluation, the following sections examine remediation data for legacy contamination due to 

AEC and non-AEC operations performed during the site’s AWE period under evaluation. 

6.3.1 Uranium

Surveys performed at the Superior Steel Co. site show that uranium contamination is still present at 

this time. There is no evidence available that decontamination or decommissioning of Superior Steel 

equipment or facilities was performed at the end of the AEC contract (Adams, 2001). There are five 

known radiological surveys done in support of clean-up efforts that took place after the end of the 

AEC contract (Table 6-3).

Table 6-3: Radiological Surveys Performed at the Superior Steel Site

Survey Purpose Year Locations Measurements SRDB 

Ref ID 

Preliminary 

Site Survey

Provide information on 

the present condition and 

use of the former mill 

area and to determine the 

need for a detail survey

1980 Former mill area (Area 

A), former motor 

room (Area B), and 

former rolling area 

(Area C)

Alpha, beta and gamma 

scans on surfaces, gamma 

spec on soil and residue 

samples

161092

Superbolt 

contracted 

Applied 

Health 

Physics Inc.

Preliminary radiological 

characterization due to 

limited historical data

1997 Peripheral areas 

outside of buildings 

and secondary surveys 

inside former rolling 

area

Unknown – copies of 

reports are not available

78280
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Survey Purpose Year Locations Measurements SRDB 

Ref ID 

NRC ESSAP 

Phase 1

Determine if significant 

radiological 

contamination remained 

on the site and to provide 

survey documentation to 

further support future 

remediation and/or 

removal of the site from 

the ORNL database

2000 Former mill area (Area 

A), former motor 

room (Area B), and 

former rolling area 

(Area C)

Gross alpha, beta, and 

gamma scans; beta surface 

activity measurements; 

exposure rate 

measurements; gamma spec 

of soil sampling; and 

miscellaneous samples

78280

NRC ESSAP 

Phase 2

Determine if significant 

contamination remained 

on other portions of the 

site and to provide 

additional survey 

documentation for 

previously surveyed areas 

to support future 

remediation of 

contaminated areas or to 

identify areas suitable for 

unrestricted release

2003 Building Complex 

Number 23 areas: 

23A, 23B, 23C, 23D 

and 23E

Surface scans, soil 

sampling, and 

miscellaneous sampling 

(residue, brick, and dust 

samples); soil and 

miscellaneous samples were

analyzed by gamma 

spectroscopy 

172190

USACE 

FUSRAP

AEC-related impacts (i.e., 

uranium) and other 

potential radiological 

impacts

2014 Accessible portions of 

the ground surfaces of 

the site

Gamma scan surveys (NaI) 167784

6.3.2 Thorium

To assess whether there are indications of large-scale thorium processing at the Superior Steel Co. site 

during the evaluation period, NIOSH performed a literature search to determine the residual quantities 

of thorium detected during remediation work. 

In order to assess the amount of contamination at the Superior Steel Co site, a preliminary survey by 

Oak Ridge National Lab (ORNL) was performed. The results of that survey led to four more site 

surveys to determine the extent of contamination: details of the initial and follow-up surveys are found 

in Attachment 2.

Thorium Conclusion, 1952-1957 

Due to the limited size of the Superior Steel Co. facilities and its production capacities, it is assumed 

that both commercial work and work performed for AEC were done on the same equipment and 

process line (Adams, 2001; Johnson, 1957). Therefore, contamination from commercial thorium 

work would be found in similar locations to the uranium contamination (i.e., spatially distributed 

similarly to uranium contamination), allowing for use of the uranium surveys to provide some insight 

into potential thorium contamination. Data presented in the scoping and remedial investigation 

surveys indicate uranium contamination, as expected due to the known AEC contract work. While 

these investigations were not specifically looking for thorium, gamma spectra were reviewed to 

identify other radionuclides that could be present in the samples. Thorium is detected via the Ac-228 

daughter 911keV photopeak, which is distinguishable from uranium, and is expected to be detected if 
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widespread thorium contamination was present. The soil and miscellaneous samples taken from inside 

the Superior Steel Co. buildings during the Preliminary Site Survey (Myrick, 1980) and the NRC 

ESSAP surveys (Adams, 2001; Adams, 2003) showed no evidence of thorium contamination. Results 

of the recent FUSRAP gamma scans survey indicate background levels of, and typical spatial 

distribution of, naturally-occurring thorium on the Superior Steel Co. grounds. This is in contrast to 

the uranium contamination levels and spatial distribution seen in those same surveys. Therefore, 

NIOSH sees no indication of residual levels of thorium contamination that would be indicative of 

previous large production-scale thorium operations.

NIOSH reviews indicate (1) a lack of information on thorium shipments to, receipts by, or rolling data 

in the document and database searches, and (2) a lack of detected thorium contamination despite the 

expectation it would be present due to the licensing for unlimited quantities, typical batch amounts of 

45,000 pounds (Ferguson, 1956), and known rolling operation dispersion. Consequently, NIOSH has 

determined that, even though Superior Steel Co. had a license to possess thorium source material in 

unlimited quantities, no large-scale use of that material was realized at Superior Steel.

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH

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

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

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

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

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

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

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

reconstructions. 

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

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

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

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

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

exposures experienced by groups or individual members of the class. This approach is discussed in 

NIOSH’s SEC Petition Evaluation Internal Procedures which are available on the NIOSH Radiation 

Dose Reconstruction Program webpage. 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-00247 as submitted by the petitioner. (Section 7.4) 
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7.1 Pedigree of Superior Steel Co. Data

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

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

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

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

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

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

feasibility evaluation presupposes that data pedigree issues have been settled.

7.1.1 Internal Monitoring Data Pedigree Review

As discussed in Section 6.1 above, HASL air monitoring data for four rolling campaigns are the only 

internal monitoring data available to NIOSH for the AWE period under evaluation. These data consist 

of AEC-tabulated air sample results in the units of dpm/m3. One 1953 report and two 1955 reports 

include the recorded raw data for statistics such as background count rate, sample counts, and sample 

count time. These original data records are considered primary data sources; therefore, further 

consistency checks of these air data for the years 1953 and 1955 are not required (Klevin, 1953b; 

AEC, 1955a; Klevin, 1955). 

Given the information in Table 7-1 regarding rolling times, number of slabs, and type of material, 

indications are that the four HASL-attended campaigns in 1953 and 1955 are representative of typical 

AEC uranium rolling campaigns at Superior Steel. NIOSH has determined that the radiological air 

monitoring data obtained from the HASL-attended uranium rolling operations at the Superior Steel 

Co. site adequately represent typical uranium rolling campaigns, and are of sufficient quantity, and are 

supported by sufficient original data records, to assure that the data adequately represent the evaluated 

class.

7.1.2 External Monitoring Data Pedigree Review

NIOSH has not found any external monitoring data for AWE employees at the Superior Steel Co. site 

during the AWE operations period under evaluation. In the absence of site-specific external data, to 

provide a realistic and accurate upper-bound estimate of external exposure to workers when 

monitoring data are absent, NIOSH utilizes documents previously developed by NIOSH for this 

purpose. These documents include the technical basis document Battelle-TBD-6000 for AWE sites 

that processed uranium metal. This document, and the adequacy of its underlying external data, have 

been reviewed by the Advisory Board and its contractor. 

7.2 Evaluation of Bounding Internal Radiation Doses

For internal dose reconstruction to be feasible, NIOSH must have reliable information about the intake 

amounts, intake material, and exposure time during the period under evaluation. The period under 

evaluation includes the entire AWE operations period for Superior Steel Co. from January 1, 1952 

through December 31, 1957. 

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

inhalation of uranium dust produced from the manipulation and oxidation of uranium metal during 

rolling and related processes. Superior Steel Co. also performed test-scale rolling operations with 

thorium metal in March or April 1956. 
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The following subsections address the ability to bound internal doses, methods for bounding doses, 

and the feasibility of internal dose reconstruction.

7.2.1 Evaluation of Bounding AWE Period Internal Doses

To perform an internal dose reconstruction, information such as a potential intake amount, a potential 

timeframe for when the intake occurred, and intake radionuclide data are needed. The following 

summarizes these assumptions. The period under evaluation includes the entire AWE operations 

period January 1, 1952 through December 31, 1957. The effective date of the AEC contract with 

Superior Steel Co. was June 27, 1952 (Mott, 1981; Kelley, 1952). For bounding of internal radiation 

doses, NIOSH will assume that all workers performed overtime (i.e., 2,500 work hours per year). 

Uranium

As discussed above, the AEC-related work involved rolling and handling uranium metal. 

Based on the contract information, uranium rolling at Superior Steel Co. was intermittent and not 

performed on a full-time basis (Young, 1985). The information presented in Table 7-1 is a summary 

of the data found regarding the rollings performed from May 1953 to mid-1957. The table shows that 

rolling campaigns were irregular both in timing and number of slabs processed. No definitive 

evidence could be located that bounded the amount of uranium processed at Superior Steel Co. 

However, the table does suggest that a minimum of 60,000 pounds of uranium metal was rolled along 

with approximately 700 pounds of thorium. 

Table 7-1: Rolling Notes from Reference Documents

Date of Rolling Material

No. of Slabs 

and/or 

Pounds

Notes Document Type SRDB 

Ref ID

May 13, 1953 Uranium Not Noted Hot strip rolling HASL Air Dust 

Monitoring 6898

August 1953

Wrought 

Uranium 

Plate

Not Noted Re: Kinetics of the beta 

transformation of uranium Technical Report 172157

August 1953 Uranium Not Noted Rolling conditioned uranium 

slabs for DuPont

Technical Report, 

February 11–April 10, 

1954

15189

Unknown, but 

prior to August 3, 

1953

Not Noted 18 slabs Superior Steel inventory as of 

June 1954

Correspondence from 

Production Division to 

DuPont

78256

August 3, 1953 Uranium 23 slabs Hot strip rolling HASL Air Dust 

Monitoring 6899

August 3, 1953 Uranium

24 slabs, 

14,380 

pounds

NLO P.O. 117 information 

provided in SRDB 29522

“NLO Resume of Activities 

for the Month Ending June 

30, 1953”

Correspondence from 

NLO 78252

August 3, 1953 Not Noted 10 slabs Superior Steel inventory as of 

June 1954

Correspondence from 

Production Division to 

DuPont

78256
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Date of Rolling Material

No. of Slabs 

and/or 

Pounds

Notes Document Type SRDB 

Ref ID

December 12, 

1953 (Goal), 

likely 1st week in 

January

Uranium 50 slabs

Fernald reported it couldn’t 

get slabs out until next year; 

DuPont order

Correspondence 

between AEC 

counterparts

78274

February 1954 

(scheduled 

rolling)

Not Noted Not Noted Scheduled rolling, Feb 1954 Monthly Report 101449

February 1954 Uranium 35 slabs Required February 11, 1954, 

arrival of slabs

Correspondence from 

AEC to AMF 93466

February 15 & 

16, 1954 Not Noted 52 slabs 35 slabs for DuPont Correspondence from AEC to Superior Steel 78254

February 22 & 

23, 1954 Uranium 52 slabs 35 for shearing; 17 for operating conditions

Technical Report, Flat 

Bonded Fuel Elements 

February 11–April 10, 

1954

15189

February 22, 

1954 Not Noted Not Noted Westinghouse (WAPDPWR)

Correspondence 

between AEC 

counterparts

172177

February 22, 

1954 Not Noted 36 slabs Superior Steel Inventory as of June 1954

Correspondence from 

Production Division to 

DuPont

78256

February 22, 

1954 Uranium Not Noted P.O. AX-3104

Correspondence 

between DuPont and 

AEC

11035, 

PDF p.

27

February 22, 

1954

Natural 

Uranium Not Noted Natural uranium Metallurgy Monthly Report 99468

July 1, 1954 to 

February 28, 

1955

Normal 

Uranium

31,506.2 

pounds

14,321 kg normal uranium 

received by Superior Steel

Survey of the Control 

Maintained over 

Source and Special 

Nuclear Materials 

NLO

77006

July 1, 1954 to 

February 28, 

1955

Normal 

Uranium

26,716.8 

pounds

12,144 kg normal uranium 

shipped from Superior Steel

Survey of the Control 

Maintained over 

Source and Special 

Nuclear Materials 

NLO

77006

April 1, 1954 Not Noted 9 slabs Superior Steel Inventory as 

of June 1954

Correspondence from 

Production Division to 

DuPont 

78256

Not Noted Uranium 50 slabs

May 19, 1954 shipment of 50 

U plates from Superior Steel 

to AMF

Correspondence from 

AEC to AMF 93463

July 1954 Uranium 50 slabs

Slabs sent to AMF then to be 

sent to Superior discussing 

work at end of July 1954

Telegram from AEC 

to AMF

69012, 

68997

July 1954 Uranium 50 slabs

Letter dated July 1, 1954, 

discussing work at Superior 

Steel end of July 1954

Correspondence from 

AEC to AMF 69000
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Date of Rolling Material

No. of Slabs 

and/or 

Pounds

Notes Document Type SRDB 

Ref ID

August 1954 Not Noted Not Noted

File: REA-(NRX)-U22-15

Plate 62A (Fernald slab 

#7737)

Plate 51A (Fernald slab 

#6838)

SRDB title mistakenly 

references thorium

Correspondence from 

DuPont to AEC SROO 58579

August 3, 1954 Not Noted 50 slabs Rolling temperature suggests 

the material is uranium

Rolling data from 

Superior Steel to AEC 

OROO

132695

December 6, 

1954

Natural 

Uranium 150 slabs For ANL-E EBWR, Rolling slabs to be shipped

Telegram from AEC 

OROO to AEC 

Fernald

132719

December 15, 

16-20, 1954 

(arrival of 3 U 

slabs)

Uranium Not Noted Shipping Uranium Slabs to 

Superior Steel

Telegram from AEC 

SROO to AEC OROO 

132695, 

PDF p. 2

Not Noted Not Noted

64 slabs;

13,815 

pounds

January 1955 shipment from 

Atlas Steels

Customs documents 

and tax document 

related to shipment

101428

May 9, 1955

“Normal” 

(Natural) 

Uranium

26 slabs Hot strip rolling HASL Air Dust 

Monitoring 6877

May 9, 1955 Enriched 

Uranium 6 slabs Hot strip rolling HASL Air Dust Monitoring 6877

Not Noted Uranium 

Metal

96 slabs;

21,699 

pounds

June 1955 shipment

Customs documents 

and tax document 

related to shipment

101407

Not Noted Uranium 

Metal

98 slabs;

22,865 

pounds

June 1955 Shipment to 

Superior Steel from Atlas 

Steels

Customs documents 

and tax document 

related to shipment

101416

September 19, 

1955

“Normal” 

(Natural) 

Uranium

30 slabs Hot strip rolling HASL Air Dust 

Monitoring 6888

1955 Normal 

Uranium

51,470 

pounds

Pounds of scrap material 

shipped in FY 1955 NLO Summary Report 44162

1955 Normal 

Uranium

6,200 

pounds

Pounds of scrap material in 

inventory at end of FY 1955 NLO Summary Report 44162

Not Noted Uranium 

Metal

50 slabs;

11,651 

pounds

January 1956 Customs documents 

related to shipment 101435

Not Noted Uranium 

Metal

45 slabs;

10,542 

pounds

March 2, 1956 Customs documents 

related to shipment 101438

February 1956 Uranium 

Metal

2,750 

pounds

2,750 pounds shipped to 

Superior Steel

Correspondence from 

AEC St. Louis OO to 

AEC OROO

132720

Not Noted Uranium Not Noted

Research programs in support 

of Savannah River, fiscal 

document to extend $200,000 

per year for next two FYs

Correspondence dated 

April 19, 1956, from 

DuPont to SROO

90056
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Date of Rolling Material

No. of Slabs 

and/or 

Pounds

Notes Document Type SRDB 

Ref ID

Not Noted Uranium 

Metal

111 slabs;

26,678 

pounds

Shipment April 30, 1956 Customs documents 

related to shipment

101395, 

101399

Not Noted Uranium 

Metal

28 slabs;

6,328 

pounds

Shipment July 1956 Customs documents 

related to shipment 101393

December 1956 Uranium 20,000 

pounds

Work for WAPD and KAPL

NOTE: “plant is organized 

for quantity production and 

processing of small lots (such 

as one 500 pound ingot)”

GE Hanford Trip 

Report, Zirconium 

Alloy Fabrication

172173, 

PDF p. 9 

Not Noted Uranium 

Ingots 22 slabs

December 6, 1956, shipment 

from Simonds Saw and Steel 

to Superior Steel Co.

Correspondence from 

NLO 81545

1956 Normal 

Uranium

48,600 

pounds

Expected scrap production 

for FY 1956 was 4050 

lb/month

NLO Summary Report 44162

April 1957 Normal 

Uranium

26,860 

pounds

26,860 pounds net, shipped 

4/29/1957 (NLO-SSC-23X) 

hard to read

Correspondence 

regarding completion 

of AEC Production 

Order A-60

81553

May 1957

Forged 

Uranium 

Slabs

20 slabs 25 shipped, 5 for later date

Correspondence from 

DuPont to Superior 

Steel

34495

Not Noted Uranium 

Metal

90 slabs; 

21,654 

pounds

May 28, 1957, shipment Customs documents 

related to shipment 101426

FY1953-FY1999 Depleted 

Uranium 0 pounds FY1953-FY1999 Receipts by SRS from Superior Steel

Report regarding 

recycled uranium at 

SRS

16499

FY1953-FY1999 Enriched 

Uranium

2,635.6 

pounds

1198kg EU FY1953-FY1999 

Receipts by SRS from 

Superior Steel

Report regarding 

recycled uranium at 

SRS

16499

FY1953-FY1999 Natural 

Uranium

133,625.8 

pounds

60,730kg NU FY1953-

FY1999 Receipts by SRS 

from Superior Steel—total 

may be less than expected, 

possibly only recycled 

uranium

Report regarding 

recycled uranium at 

SRS

16499

According to available documentation, the vast majority of the uranium work performed by Superior 

Steel Co. was associated with natural uranium (see Table 7-1). The only enriched uranium material 

identified by NIOSH was the rolling of six ingots of uranium enriched to 1.5% U-235 (Angerman, 

1955; Fisher, 1955). These rollings occurred on May 9, 1955 along with the rolling of 25 other 

normal uranium slabs. The enriched uranium rollings were a small portion of the overall material 

rolled in that campaign, and even less significant compared to the total amount of normal uranium 

rolled during Superior Steel Company’s AWE operational period. 

Thorium

As non-AEC work, the exposures associated with the commercial thorium rolling operations will be 

assigned only during the AWE period through December 31, 1957. Non-AEC-related exposures are 
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not considered during an AWE site’s designated residual radiation period. Based on the number of 

uranium rollings that Superior Steel Co. could complete in a day (Table 7-1), and the small scale of 

the single thorium test rolling, involving four ingots at most (Reardon, 1956), the thorium test rollings 

are assumed to have occurred in a single workday (i.e., 10 hours). 

As presented in Section 5.1, during this evaluation NIOSH determined that the site was licensed on 

March 27, 1956, to receive possession of and/or title to 700 pounds of thorium. 

7.2.2 NIOSH Proposed Methods for Bounding AWE Period Internal Doses 

The following information summarizes the methods for bounding internal dose at Superior Steel Co.

during the period from January 1, 1952 through December 31, 1957. Specific methods regarding the 

post-1957 residual radiation period are not addressed in this report. NIOSH intends to implement the 

dose reconstruction methodologies summarized below in a revision to ORAUT-TKBS-0034. The 

effective date of the AEC contract with Superior Steel Co. was June 27, 1952 (Mott, 1981; Kelley, 

1952). Therefore, no operational exposures associated with rolling activities will be assessed prior to 

June 27, 1952. NIOSH has reviewed its telephone interviews with Superior Steel Co. dose 

reconstruction claimants and determined that overtime was common during the period under 

evaluation. 

Uranium

Because uranium exposures were AEC-related at Superior Steel Co., the exposures associated with the 

uranium rolling operations must be assigned during both the AWE period and the residual radiation 

period from January 1, 1958 through present. 

According to contract information, the total amount paid to Superior Steel Co. through fiscal year 

(FY) 1957 was $356,849 (SROO, 1952–1957). Superior Steel Co. had a cost-plus-fixed-fee contract 

that included payments for equipment upgrades (SROO, 1952–1957). Based on the annual payments 

for FY 1954 through FY 1957, the year with the maximum payment was FY 1956 at $217,246. 

However, the payments for the other three years were all consistently in the range of $40K to $55K. 

Based on the rolling data presented in Table 7-1, NIOSH sees no indication that the production rate 

for FY 1956 was significantly different than the other years under evaluation. The highest payment in 

the other three years was for FY 1957 at $54,632. NIOSH assumes that the entire payment for FY 

1957 was associated with mill work. NIOSH considers it reasonable to conclude that the Superior 

Steel Co. hourly billing rate was similar to that of Vulcan Crucible for a 1949 AEC contract (SRDB 

11996, PDF p. 99), at $132 per mill-hour. Assuming $132 per mill-hour billing rate, the number of 

Superior Steel Co. mill hours would be approximately 414 mill-hours for FY 1957. NIOSH will 

assume 500 mill-hours per year as a bounding estimate for AEC-related uranium rolling operations 

during the AWE period under evaluation. This estimate of mill-hours is comparable to the rolling 

information in Table 7-1. An additional 250 pre-rolling hours and 250 post-rolling hours (total of 500 

hours) will be assumed by NIOSH to account for time the material was stored onsite before and after 

any rolling operations. 

Airborne contamination data for the 1953 and 1955 HASL-attended uranium rollings will be used to 

estimate the 95th percentile uranium alpha air concentration levels. NIOSH intends to consider only 

the process and breathing zone air data, and to exclude the general area air data.
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The geometric mean associated with the 1953 air data is statistically higher than for the 1955 air data. 

Therefore, NIOSH concludes that they represent separate exposure distributions. NIOSH reviews of 

post-operations reports indicate that the site instituted improvements to the engineering controls after 

evaluation of lessons learned from each HASL-attended rolling (AEC, 1955a,b; Klevin, 1953a,b). 

NIOSH has found no specific dates of implementation for these process improvements. 

Consequently, NIOSH intends to use the more claimant-favorable 1953 data for exposures up until the 

May 9, 1955 rolling date. NIOSH intends to use the 1955 data for exposures starting on May 9, 1955 

and continuing through the end of AWE operations on December 31, 1957. 

The 95th percentile uranium alpha air exposures will be assigned to all operator and laborer job 

categories. The post-rolling slab stamping work, performed by hand, represents work likely 

associated with the laborer category, and resulted in some of the higher air data results. NIOSH has 

not found justification to assume that the exposures for the operator and laborer categories were 

different. Consequently, laborers will be assigned the same exposure as operators based on a NIOSH 

analysis of the air data. Supervisor and administrative exposures will be prorated based on guidance 

in Battelle-TBD-6000 to account for differences in occupancy time in the production areas. 

Potential exposure to contaminants in recycled uranium will be assigned based on guidance in 

Battelle-TBD-6000. Assumed ingestion intakes values will be based on guidance in NUREG/CR5512. 

NIOSH will assume worker exposure to operational rolling airborne levels for 500 hours per year. The 

remaining 2000 hours of the assumed 2500 hours work year, will be considered to be non-uranium 

mill hours. Non-uranium mill exposures will be based on the following: 

• 2000 non-uranium mill hours per year;

• Air concentrations will be based on dust-settling calculations;

• Post-rolling surface contamination levels will be determined assuming 500 uranium mill-hours of 

contamination was deposited on the surface of the facility at a rate of 0.00075 m/s; 

• A resuspension factor of 1E-5 m-1 will be applied to the post-rolling surface contamination levels 

to determine post-rolling airborne contamination levels;

• Operators and laborers will be assigned the full value, and supervisor and administrative 

exposures will be prorated; and 

• Long-term residual uranium exposure will be decreased based on guidance in ORAUT-OTIB0070. 

Thorium

As non-AEC work, the exposures associated with the commercial thorium rolling operations must be 

assigned only during the AWE period through December 31, 1957. Non-AEC-related exposures are 

not considered during an AWE site’s designated residual radiation period. 

Assuming the specific activity for natural uranium, and using the HASL gross-alpha air sampling 

results associated with the 1955 uranium rollings, NIOSH can determine a mass dust load associated 

with the rolling process. Assuming the same mass load for thorium as for uranium, a bounding 

thorium activity airborne concentration can be determined by using the specific activity of Th-232 

(because most of the thorium mass would be associated with Th-232). Given the large-scale nature of 
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the uranium work and the small-scale nature of the thorium work, this is considered a claimantfavorable estimate of thorium-related exposure. A similar approach used by NIOSH for Bridgeport 

Brass has been reviewed by the Advisory Board Subcommittee on Dose Reconstruction. Associated 

with the Subcommittee’s review, the Board’s contractor reported “SC&A agrees that, for dose 

reconstruction, the assumption that the mass of processed thorium is 10% of the mass of processed 

uranium is bounding and claimant favorable” (Mauro, 2017). In the case of Superior Steel Co., 

NIOSH is assuming the thorium mass loading is equal to that of the uranium rollings, rather than 

making an assumption of the total mass of thorium work compared to the total mass of uranium work 

(i.e., rather than assuming only 10% of the uranium loading as was approved for Bridgeport Brass). 

NIOSH will assume that the thorium is natural, assuming that the thorium daughters (Ra-228, Ac-228, 

Th-228, and Ra-224) are in secular equilibrium with the Th-232. Because NIOSH is assuming that all 

of the mass suspended in the air is Th-232, the resulting dose associated with natural thorium is higher 

than if calculated assuming triple-separated thorium. This is due to the fact that natural thorium 

would have more Th-232 daughter activity in equilibrium. This additional daughter activity would 

also result in a higher external dose. Therefore, for the approach being implemented at Superior Steel, 

the assumption of natural thorium is considered more favorable to the claimant than triple-separated 

thorium. 

Based on the number of uranium rollings that Superior Steel Co. could complete in a day (Table 7-1), 

and the small scale of the single thorium test rolling, involving four ingots at most (Reardon, 1956), 

the thorium test rollings are assumed to have occurred in a single workday (i.e., 10 hours). Based on 

the short duration and small scale of the thorium test rolling work, thoron exposure is assumed to be 

negligible. Assumed thorium ingestion intake values will be based on guidance in NUREG/CR-5512. 

Thorium post-rolling exposures will be based on: 

• Thorium air concentrations derived with dust-settling calculations; 

• Post-rolling surface thorium contamination levels will be determined assuming 10 mill-hours of 

contamination was deposited on the surface of the facility at a rate of 0.00075 m/s; 

• A resuspension factor of 1E-5 m-1 will be applied to the post-rolling surface contamination levels 

to determine post-rolling thorium airborne contamination levels;

• Operators and laborers will be assigned the full value, and supervisors and administrative 

exposures will be prorated; and 

• Post-rolling residual thorium exposure will be decreased based on guidance in ORAUT-OTIB-070 

and will only be assigned until the end of the AWE operations period on December 31, 1957. 

7.2.3 Internal Dose Reconstruction Feasibility Conclusion

For internal dose reconstruction to be feasible, NIOSH must have enough reliable information about 

the intake amounts, intake material, and exposure time during the period under evaluation to be able to 

bound the dose. The period under evaluation includes the entire AWE operations period for Superior 

Steel Co.: January 1, 1952 to December 31, 1957. 

For AEC uranium rolling operations at the Superior Steel Co.: (1) NIOSH has reliable air 

concentration data, which provides data for calculating bounding uranium intake amounts, (2) NIOSH 

has reliable process information about uranium rolling operations to determine bounding uranium 
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intake material assumptions (i.e., uranium enrichment, potential uranium contaminants), and (3) 

NIOSH has reliable process information to determine bounding exposure time assumptions (i.e., 

exposure hours per day/year). For commercial thorium rolling operations at the Superior Steel Co. 

during the evaluation period: (1) NIOSH has reliable process information about the commercial 

thorium test rolling to use uranium rolling air mass concentrations to calculate bounding thorium 

intake amounts, (2) NIOSH has reliable process information for thorium rolling operations to 

determine bounding thorium intake material assumptions (i.e., thorium isotopic compositions), and (3) 

NIOSH has reliable process and license information to determine bounding exposure time 

assumptions (i.e., exposure hours per day/year). 

NIOSH has airborne contamination data for AEC-monitored uranium rollings in 1953 and 1955. 

NIOSH has determined that the available air monitoring data are sufficient to allow NIOSH to model 

the 95th percentile uranium alpha air exposures for the highest potentially exposed operator and 

laborer job categories at Superior Steel Co. for the period from January 1, 1952 through December 31, 

1957. For the period from January 1, 1952 through December 31, 1957, NIOSH has determined that 

it has sufficient information to derive airborne thorium concentrations based on the mass loading 

calculated for the HASL air sampling results associated with the 1955 uranium rollings. Given the 

large-scale nature of the site’s uranium work and the small-scale nature of the thorium work, this is 

considered a favorable estimate of thorium-related exposure. A similar approach used by NIOSH for 

Bridgeport Brass has been reviewed by the Advisory Board Subcommittee on Dose Reconstruction. 

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

inhalation of uranium dust produced from the manipulation and oxidation of uranium metal during 

rolling and related processes. The vast majority of the uranium work performed was associated with 

natural uranium. The only enriched uranium material identified by NIOSH was the rolling of six 

ingots of uranium (enriched to 1.5% U-235) on May 9, 1955. The enriched uranium rollings were a 

small portion of the overall material rolled in that campaign, and even less significant compared to the 

total amount of normal uranium rolled during Superior Steel’s AWE operational period. Between 

March 27, 1956 and April 20, 1956, Superior Steel Co. conducted one test rolling operation with up to 

700 pounds of thorium metal to perform development studies for its commercial client Babcock & 

Wilcox Company. 

Since uranium exposures were AEC-related at the Superior Steel Co., the exposures associated with 

the uranium rolling operations will be assigned during both the AWE period, and the residual 

radiation period from January 1, 1958 through present. As non-AEC work, the exposures associated 

with the commercial thorium rolling operations will be assigned only during the AWE evaluation 

period through December 31, 1957. Non-AEC-related exposures are not considered during an AWE 

site’s designated residual radiation period.

Because the effective date of the AEC contract with Superior Steel Co. was June 27, 1952, no 

operational exposures associated with rolling activities will be assessed prior to June 27, 1952. 

NIOSH has determined that overtime was common during the period under evaluation, and will 

assume that all workers performed overtime (i.e., 2,500 work hours per year) during the period under 

evaluation. 

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

cannot estimate internal radiation doses with sufficient accuracy, including potential exposures to 

uranium and thorium metals. This class includes: all atomic weapons employees who worked in any 
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area at Superior Steel Co. in Carnegie, Pennsylvania, during the period from January 1, 1952 through 

December 31, 1957. 

7.3 Evaluation of Bounding External Radiation Doses

For external dose reconstruction to be considered feasible, NIOSH must have enough reliable 

information about the amounts of material, form of material, exposure distances, and exposure time 

during the period under evaluation. The period under evaluation includes the entire AWE operations 

period for Superior Steel Co.: January 1, 1952 to December 31, 1957. Since external monitoring data

has not been found and is not thought to exist for Superior Steel Co., this section provides a discussion 

of the ability to bound external doses for Superior Steel Co. workers. 

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

exposure from being in proximity to the uranium ingots, exposure from contaminated surfaces, and 

submersion in air contaminated with dust generated via the processing of such. Superior Steel Co. 

also performed test-scale rolling operations with thorium metal in April 1956. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external radiation dose reconstruction. 

7.3.1 Evaluation of Bounding AWE Period External Doses

To perform sufficiently accurate external dose reconstructions, information such as a potential 

distance between the worker and the source of exposure, a potential timeframe in which the exposure 

occurred, and exposure radionuclide data are needed. The following summarizes these assumptions. 

Uranium

As stated above in Section 7.2.1 for Internal Doses, because uranium exposures were AEC-related at 

the Superior Steel Co., the external exposures associated with the uranium rolling operations will be 

assigned during both the AWE period, and the residual radiation period from January 1, 1958 through 

present. NIOSH has enough reliable process information to determine the uranium enrichment, 

typical uranium amounts, and exposure time information to determine bounding external doses for the 

Superior Steel Co. using the default worker assumptions in Battelle-TBD-6000. 

Thorium

As presented in Section 7.2.1 for Internal Doses, between March 27, 1956 and April 20, 1956, 

Superior Steel Co. conducted one test rolling operation with up to 700 pounds of thorium metal to 

perform development studies for its commercial client Babcock & Wilcox Company. This small-scale 

test rolling is the only indication of thorium metal processing found by NIOSH for the period under 

evaluation. NIOSH has determined it has enough reliable thorium process information to determine 

the exposure material makeup, type, and exposure time to determine bounding external doses for the 

Superior Steel Co. using the default assumptions in Battelle-TBD-6000. 

Occupational Medical X-ray Examinations 

Per ORAUT-OTIB-0079, NIOSH has found no historical evidence that occupational medical X-ray

examinations were performed offsite and no claimant statements were made regarding X-ray 

examinations. In the absence of information, NIOSH Dose Reconstruction Guidance documents (e.g., 
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Technical Information Bulletins) provide enough information to bound occupational medical x-ray 

doses at the Superior Steel Co. 

7.3.2 NIOSH Proposed Methods for Bounding External AWE Period Doses 

The following information summarizes the methods for bounding external dose during the AWE 

period under evaluation at Superior Steel Co. during the period from January 1, 1952 through 

December 31, 1957. NIOSH intends to implement the dose reconstruction methodologies 

summarized below in a revision to ORAUT-TKBS-0034. The effective date of the AEC contract with 

Superior Steel Co. was June 27, 1952; therefore, no operational exposures associated with rolling 

activities will be assessed prior to June 27, 1952. NIOSH has determined that overtime was common 

during the period under evaluation, and will assume that all workers performed overtime (i.e., 2,500 

work hours per year). 

Uranium

For AWE sites such as Superior Steel Co. that handled uranium metals, Battelle-TBD-6000 presents 

methods for bounding estimation of worker doses from: 1) submersion in contaminated air; 2) 

contaminated surfaces; 3) whole-body penetrating radiation emitted from uranium metal surfaces; and 

4) non-penetrating radiation emitted from uranium metal surfaces. NIOSH intends to use the methods 

specified in Battelle-TBD-6000 with the following site-specific assumptions:

• 500 hours per year of external dose associated with rolling operations in Battelle-TBD-6000; 

• 500 hours per year of external dose associated with submersion in rolling operations airborne 

contamination, based on Dose Conversion Factors in EPA-FGR-12; 

• 500 hours per year of external dose associated with storage of on-site material based on external 1-

meter dose rates in Battelle-TBD-6000; and 

• 2,000 hours per year of external dose associated with submersion in post-rolling airborne 

contamination and direct exposure associated with post-rolling surface contamination, based on 

Dose Conversion Factors in EPA-FGR-12. 

Thorium

As presented above, Superior Steel Co. conducted one non-AEC-related test rolling operation with up 

to 700 pounds of thorium metal between March 27, 1956 and April 20, 1956. NIOSH intends to 

perform MCNP modelling of thorium metal-related exposures in accordance with the methods 

presented in Battelle-TBD-6000. NIOSH intends to use the methods specified in Battelle-TBD-6000 

with the following site-specific assumptions for potential thorium metal handling exposures: 

• 10 hours of external dose associated with thorium rolling operations in 1956 will be calculated 

using MCNP and guidance in Battelle-TBD-6000; 

• 10 hours per year of external dose associated with submersion in rolling operations airborne 

contamination in 1956 will be calculated based on Dose Conversion Factors in EPA-FGR-12; 

• 190 hours per year of external dose associated with storage of on-site thorium material based on 

MCNP calculations at 1 meter (190 hours assumes exposure to thorium for all of the 19 workdays 

between March 27, 1956 and April 20, 1956); and 
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• For the remainder of 1956 (post-March 27, 1956) and all of 1957, external dose associated with 

submersion in post-rolling airborne contamination and direct exposure associated with post-rolling 

surface contamination, will be assigned based on Dose Conversion Factors in EPA-FGR-12. 

Occupational Medical X-ray Examinations 

NIOSH intends to assign pre-employment, annual, and termination medical X-ray doses for all 

employees during the AWE operational period. No medical X-ray doses will be assigned during the 

site’s residual radiation period. Medical X-ray doses will be based on guidance in ORAUT-OTIB0006. 

7.3.3 External Dose Reconstruction Feasibility Conclusion

For external dose reconstruction to be feasible during the period under evaluation, NIOSH must have 

enough reliable information about the exposure time, the distance from the source of the exposure, 

and the radionuclide concentrations providing the external exposure to be able to bound the dose. The 

period under evaluation includes the entire AWE operations period for Superior Steel Co.: January 1, 

1952 to December 31, 1957. The following provides the known information regarding the external 

source of exposure. 

The principal sources of external radiation doses for members of the class under evaluation were

direct exposure from being in proximity to the uranium and thorium ingots, exposure from 

contaminated surfaces, and submersion in air contaminated with dust generated via the processing of 

such. The vast majority of the uranium work performed was associated with natural uranium. The 

only enriched uranium material identified by NIOSH was the rolling of six ingots of uranium 

(enriched to 1.5% U-235) on May 9, 1955. The enriched uranium rollings were a small portion of the 

overall material rolled in that campaign, and even less significant compared to the total amount of 

normal uranium rolled during Superior Steel Co.’s AWE operational period. Between March 27, 

1956 and April 20, 1956, Superior Steel Co. conducted one test rolling operation with up to 700 

pounds of thorium metal to perform development studies for its commercial client Babcock & Wilcox 

Company. 

Because uranium exposures were AEC-related at the Superior Steel Co., the external exposures 

associated with the uranium rolling operations will be assigned during both the AWE period, and the 

residual radiation period from January 1, 1958 through present. As non-AEC work, the external 

exposures associated with the commercial thorium rolling operations will be assigned only during the 

AWE evaluated period through December 31, 1957. Non-AEC-related exposures are not considered 

during an AWE site’s designated residual radiation period. 

The period under evaluation includes the entire AWE operations period from January 1, 1952 through 

December 31, 1957. Because the effective date of the AEC contract with Superior Steel Co. was June 

27, 1952, no operational external exposures associated with rolling activities will be assessed prior to 

June 27, 1952. NIOSH has determined that overtime was common during the period under 

evaluation, and will assume that all workers performed overtime (i.e., 2,500 work hours per year) 

during the period under evaluation. 

For AWE sites such as Superior Steel Co. that handled uranium metals, Battelle-TBD-6000 presents 

methods for bounding estimation of worker doses from rolling operations with uranium metal. 

NIOSH has determined that it has sufficient applicable site-specific information, using the methods of 
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Battelle-TBD-6000, to model Superior Steel Co. worker doses due to uranium and thorium metal 

rolling operations during the period from January 1, 1952 through December 31, 1957. 

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

cannot estimate external radiation doses with sufficient accuracy, including potential exposures to 

uranium and thorium metals, and occupationally required medical X-ray examinations. This class 

includes: all atomic weapons employees who worked in any area at Superior Steel Co. in Carnegie, 

Pennsylvania, during the period from January 1, 1952 through December 31, 1957. 

7.4 Evaluation of Petition Basis for SEC-00247

The following subsections evaluate the assertions made on behalf of petition SEC-00247 for Superior 

Steel Co.

7.4.1 Lack of Personnel Urinalysis Data

Petitioner Issue: The petitioner quoted text in NIOSH’s 2005 exposure matrix for Superior Steel Co., 

ORAUT-TKBS-0034: “individual uranium urinalysis data are unavailable for Superior Steel 

Workers and none are known to exist.”

Response: NIOSH qualified the petition for evaluation based on the petitioner’s assertion. NIOSH 

reviewed the methods in the current ORAUT-TKBS-0034, which uses air monitoring data obtained 

during Superior Steel Co. uranium rolling operations to assign internal doses associated with uranium 

metal rolling operations. In instances when personal internal monitoring data are unavailable, NIOSH 

uses air-monitoring data from worker breathing zones and work areas, in accordance with NIOSH’s 

OCAS-IG-002, Internal Dose Reconstruction Implementation Guideline. As presented in Section 7.2 

above, NIOSH has determined that it has sufficient site-specific air monitoring data and process data 

to allow it to estimate worker internal uranium doses with sufficient accuracy. 

In the course of its evaluation, NIOSH determined that Superior Steel Co. also conducted commercial 

rolling operations with thorium metal. As with the site’s uranium rolling operations, NIOSH does not 

have evidence of any personal internal monitoring for thorium at Superior Steel Co. for the period 

from 1952 through 1957. As presented in Section 7.2 above, NIOSH has determined that it can apply 

airborne mass loading calculations to available uranium process air monitoring data to allow NIOSH 

to estimate worker internal thorium doses with sufficient accuracy. This approach has been used by 

NIOSH for Bridgeport Brass dose reconstructions, and has been reviewed by the Advisory Board 

Subcommittee on Dose Reconstruction.

7.4.2 Lack of External Dosimetry Data 

Petitioner Issue: The petitioner quoted text in NIOSH’s 2005 exposure matrix for Superior Steel Co., 

ORAUT-TKBS-0034: “no external dosimetry results are available for Superior Steel employees.”

Response: NIOSH qualified the petition for evaluation based on the petitioner’s assertion. NIOSH 

reviewed the methods in the current ORAUT-TKBS-0034, which uses AEC data available for a 

surrogate uranium processing site, Simmonds Saw and Steel Co. in Lockport, NY. As presented in 

Section 7.3, NIOSH has determined that it now has sufficient applicable site-specific information, 

using the methods of Battelle-TBD-6000, to better model potential external uranium exposures. 
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NIOSH also intends to use similar MCNP modelling of thorium metal-related exposures in 

accordance with the methods presented in Battelle-TBD-6000.

7.5 Summary of Feasibility Findings for Petition SEC-00247

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

Steel Co. from January 1, 1952 through December 31, 1957. NIOSH found that the available 

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

dose reconstructions for the evaluated class of employees.

Table 7-2 summarizes the results of the feasibility findings at Superior Steel Co. for each exposure 

source during the period from January 1, 1952 through December 31, 1957. 

Table 7-2: Summary of Feasibility Findings for SEC-00247

January 1, 1952 through December 31, 1957

Source of Exposure Reconstruction Feasible (Yes or No)

Internal1 Yes

Uranium Yes

Thorium Yes

External Yes

Gamma Yes

Beta Yes

Neutron Yes

Occupational Medical X-ray Yes 1 Internal includes an evaluation of airborne dust data. 

As of October 2, 2018, a total of 35 claims have been submitted to NIOSH for individuals who 

worked at Superior Steel Co. during the period under evaluation in this report. Dose reconstructions 

have been completed for 35 individuals (100%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00247

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 employees 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. 
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NIOSH has determined that it has sufficient site-specific process data and available process air 

monitoring data. NIOSH’s evaluation determined that it is feasible to estimate radiation dose for 

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

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

9.0 Class Conclusion for Petition SEC-00247

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

cannot estimate radiation doses with sufficient accuracy. This class includes all atomic weapons 

employees who worked in any area at Superior Steel Co. in Carnegie, Pennsylvania, during the period 

from January 1, 1952 through December 31, 1957. 

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 SRDB, for information relevant to SEC00247. In addition, NIOSH reviewed its NOCTS dose reconstruction database to identify EEOICPArelated dose reconstructions that might provide information relevant to the petition evaluation. 

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

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

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

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

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

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

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

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

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

for the class under evaluation.
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10.0 References

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

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

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

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

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

19392 

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

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

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

Abrams, 1954, Shipment of Uranium Slabs from Superior Steel to American Machine and Foundry, 

Telegram; L. A. Abrams; June 30, 1954; SRDB Ref ID: 69012 & 68997 

Adams, 2001, Radiological Scoping Survey of Portions of the Former Superior Steel Company, 

Carnegie, Pennsylvania, Final Report; W. C. Adams; May 2001; SRDB Ref ID: 78280 

Adams, 2003, Radiological Scoping Survey for Portions of the Superbolt Facility (Formerly Superior 

Steel Company) Phase 2, Carnegie, Pennsylvania, Final Report; W. C. Adams; November 2003; 

SRDB Ref ID: 172190

AEC, 1955a, Superior Steel Company Air Dust Monitoring of Hot Strip Rolling of Uranium; U.S. 

Atomic Energy Commission (AEC) Health and Safety Laboratory (HASL); issued July 1, 1955; 

SRDB Ref ID: 6877

AEC, 1955b, Superior Steel Company Air Dust Monitoring of Hot Strip Rolling of Uranium; U.S. 

Atomic Energy Commission (AEC) Health and Safety Laboratory (HASL); issued November 15, 

1955; SRDB Ref ID: 6888 

Angerman, 1955, Enriched Uranium Plate, correspondence; C. L. Angerman; August 10, 1955; 

SRDB Ref ID: 174288 

Babcock & Wilcox, 1962, Babcock & Wilcox Company Application for Facility Construction Permit 

Class 104 and SNM and Byproduct Material License, all related documents; The Babcock & Wilcox 

Company (Babcock & Wilcox); cover letter dated July 10, 1962; SRDB Ref ID: 119505 

Barclay, 1957, Process Requirements for the Twelfth Uranium Rolling, correspondence; T. D. 

Barclay, Jr.; April 26, 1957; SRDB Ref ID: 34495 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, Rev. 

1; Division of Compensation Analysis and Support; effective June 17, 2011; SRDB Ref ID: 101251 

Boyer, 1954, Rolling Data for August 3, 1954; R. C. Boyer on cover letter; cover letter dated August 

12, 1954; SRDB Ref ID: 132695, PDF pp. 3-15 

Customs Docs, Jan1955, Shipping Receipts, Summary of Entered Values Document, Government Bill 

of Lading, Shipper Export Declaration, and Form M-A, documents related to shipment involving 
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Atlas Steels in Welland, Canada, and Superior Steel; documents with various dates in January 1955; 

SRDB Ref ID: 101428 

Customs Docs, May1955, Treasury Department Correspondence, Shipping Receipts, Summary of 

Entered Values Document, Government Bill of Lading, Shipper Export Declaration, and Form M-A, 

documents related to shipment involving Atlas Steels in Welland, Canada, and Superior Steel; 

documents with various dates in May 1955; SRDB Ref ID: 101407 

Customs Docs, Jun1955, Shipping Receipts, Summary of Entered Values Document, Government Bill 

of Lading, Shipper Export Declaration, and Form M-A, documents related to shipment involving 

Atlas Steels in Welland, Canada, and Superior Steel; documents with various dates in June 1955; 

SRDB Ref ID: 101416

Customs Docs, Jan1956, Treasury Department Correspondence, Summary of Entered Values 

Document, Government Bill of Lading, Shipper Export Declaration, and Form M-A, documents 

related to shipment involving Atlas Steels in Welland, Canada, and Superior Steel; documents with 

various dates in January 1956; SRDB Ref ID: 101435 

Customs Docs, Mar1956, Treasury Department Correspondence, Summary of Entered Values 

Document, Government Bill of Lading, and Consumption Entry Permit, documents related to 

shipment involving Atlas Steels in Welland, Canada, and Superior Steel; documents with various 

dates in March 1956; SRDB Ref ID: 101438 

Customs Docs, Apr1956, Government Bill of Lading, Treasury Department Correspondence, 

Summary of Entered Values Document, Consumption Entry Permits, Shipper Export Declaration, and 

Form M-A, documents related to shipment involving Atlas Steels in Welland, Canada, and Superior 

Steel; documents with various dates in April 1956; SRDB Ref ID: 101395 & 101399 

Customs Docs, Jul1956, Shipment Invoice Form, document related to shipment involving Atlas Steels 

in Welland, Canada, and Superior Steel; documents with date of July 1956; SRDB Ref ID: 101393 

Customs Docs, May1957, Shipment Invoice Form, Consumption Entry Forms, Summary of Entered 

Values Form, Government Bill of Lading, Shipper Export Declaration, and Form M-A, documents 

related to shipment involving Atlas Steels in Welland, Canada, and Superior Steel; documents with 

various dates in May 1957; SRDB Ref ID: 101426 

Cuthbert, 1953, Rolling at Superior Steel Corporation, correspondence; F. L. Cuthbert; July 31, 1953; 

SRDB Ref ID: 78252

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

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

SRDB Ref ID: 94768 

DOE, 2004, DOE Standard Guide to Good Practices for Occupational Radiological Protection in 

Uranium Facilities, DOE-STD-1136-2004; U.S. Department of Energy (DOE); December 2004; 

SRDB Ref ID: 18881

Dowling, 1954, Machining of Slabs, correspondence; F. R. Dowling; July 1, 1954; SRDB Ref ID: 

69000 
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Dunlap, 1954, Superior Steel Inventory as of June 1954, correspondence; G. E. Dunlap; June 10, 

1954; SRDB Ref ID: 78256 

E. I. du Pont, 1954, Report No. 5, Flat Bonded Fuel Elements, Period February 11-April 10, 1954, 

DWP-54-19-5; E. I. du Pont de Nemours & Co. Inc. (E. I. du Pont); preparation date not provided; 

SRDB Ref ID: 15189

Ferguson, 1956, Licensing Amendment to Process Thorium, correspondence (2); John C. Ferguson; 

April 20, 1956 and April 23, 1956; SRDB Ref ID: 78262 & 75651 

Fisher, 1954, Distribution of Uranium Plates Sheared at Jessop Steel Company March 2, 1954, 

correspondence; R. E. Fisher; March 11, 1954; SRDB Ref ID: 11035, PDF p. 27 

Fisher, 1955, Trip Report to Superior Steel Corporation, May 9, 1955, correspondence; R. E. Fisher; 

July 11, 1955; SRDB Ref ID: 174296 

Harris, 1953, Survey Report Superior Steel-2, correspondence to G. E. Dunlap; W. B. Harris; 

September 21, 1953; SRDB Ref ID: 6899, PDF p. 1 

Johnson, 1955, Summary Report on a Nationwide Survey of Normal Uranium Scrap Materials, 

NLCO-579; E. R. Johnson and M. D. Harvey; September 23, 1955; SRDB Ref ID: 44162 

Johnson, 1956a, License to Possess Thorium, Thorium Source Material License correspondence; Lyall 

Johnson; March 27, 1956; SRDB Ref ID: 78263 

Johnson, 1956b, Revised License to Possess Thorium, Thorium Source Material License 

correspondence; Lyall Johnson; revised April 30, 1956; SRDB Ref ID: 78261 

Johnson, 1957, Trip Report—Zirconium Alloy Fabrication; Dale E. Johnson; February 7, 1957; SRDB 

Ref ID: 172173 

Kaulbach, 1953, Request for Uranium: Slabs for Next Rolling at Superior Steel Corp., 

correspondence; E. M. Kaulbach; November 10, 1953; SRDB Ref ID: 78274 

Kaulbach, 1954a, Surface Conditioning of Uranium Slabs by Superior Steel Company for Fernald, 

correspondence; E. M. Kaulbach; February 1, 1954; SRDB Ref ID: 93466 

Kaulbach, 1954b, Orders for Rolling of Slabs, correspondence; E. M. Kaulbach; February 9, 1954; 

SRDB Ref ID: 78254

Kaulbach, 1954c, Rolling at Superior Steel Corporation, correspondence; E. M. Kaulbach; February 

16, 1954; SRDB Ref ID: 172177, PDF p. 3 

Kelley, 1952, Supporting Memorandum for Findings and Determination Metals & Controls 

Corporation – Contract AT(30-1)-1413, correspondence; W. E. Kelley; December 31, 1952; SRDB 

Ref ID: 73892 

Kirk, 1954a, Monthly Report for January 1954, correspondence; R. L. Kirk; January 26, 1954; SRDB 

Ref ID: 101449 
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Kirk, 1954b, Machining of Plates, correspondence; R. L. Kirk; May 19, 1954; SRDB Ref ID: 93463 

Klevin, 1953a, Superior Steel Company Air Dust Monitoring of Hot Strip Rolling of Uranium; Paul B. 

Klevin, Industrial Hygiene Branch Health and Safety Division; issued May 22, 1953; SRDB Ref ID: 

6898 

Klevin, 1953b, Superior Steel Company Air Dust Monitoring of Hot Strip Rolling of Uranium; Paul B. 

Klevin, Industrial Hygiene Branch Health and Safety Division; issued September 8, 1953; SRDB Ref 

ID: 6899, PDF pp. 2-12 

Klevin, 1955, Air Dust Sample Results for Superior Steel; results routed to Paul Klevin; received 

September 29, 1955 and reported October 19, 1955; SRDB Ref ID: 9677, PDF pp. 1-8 

Lively, 2015, New Approach to Gamma Scans for Processed Natural Uranium at a FUSRAP Site15470; Jeffrey Lively, Heath Downey, Alejandro Lopez, Andrew Lennox, and Amec Foster Wheeler; 

WM2015 Conference, March 15-19, 2015; SRDB Ref ID: 172350 

Mauro, 2017, A Review of NIOSH’s Program Evaluation Report DCAS-PER-061: Bridgeport Brass 

Company, Draft; John Mauro, Stephen L. Ostrow, Nicole Briggs, and Robert Anigstein; July 2017; 

SRDB Ref ID: 174361

McCarty, 2000, Historical Generation and Flow of Recycled Uranium at the Savannah River Site, 

ESH-PEQ-2000-00059; Louis E. McCarty; June 2000; SRDB Ref ID: 16499 

McCreery, 1957, Completion of AEC Production Order A-60, correspondence; P. N. McCreery; June 

3, 1957; SRDB Ref ID: 81553 

McDonell, 1957, Kinetics of the Beta Transformation of Uranium; W. R. McDonell; September 1957; 

SRDB Ref ID: 172157 

Mott, 1981, Modifications Since Superior Steel Survey Report, correspondence; William E. Mott; 

October 28, 1981; SRDB Ref ID: 161092, PDF p. 8 

Myrick, 1980, Preliminary Site Survey Report for the Former Superior Steel Mill at Carnegie, 

Pennsylvania; T. E. Myrick and C. Clark; survey conducted July 31, 1980; SRDB Ref ID: 161092, 

PDF pp. 27-30 

Myrick, 1981, Preliminary Site Survey Report for the Former Superior Steel Mill at Carnegie, 

Pennsylvania; T. E. Myrick and C. Clark, Oak Ridge National Laboratory; April 1981; SRDB Ref ID: 

14657 

NUREG-1720, Re-evaluation of the Indoor Resuspension Factor for the Screening Analysis of the 

Building Occupancy Scenario for NRC’s License Termination Rule, Draft Report for Comment, 

NUREG-1720; U.S. Nuclear Regulatory Commission; published June 2002; SRDB Ref ID: 22400 

NUREG/CR-5512, Vol. 2, Residual Radioactive Contamination from Decommissioning, 

NUREG/CR-5512, Vol. 2; U.S. Nuclear Regulatory Commission; published April 2001; SRDB Ref 

ID: 40435 
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ORAUT-OTIB-0006, Dose Reconstruction from Occupational Medical X-ray Procedures, Rev. 05; 

ORAU Team Dose Reconstruction Project for NIOSH; effective August 13, 2018; SRDB Ref ID: 

172596 

ORAUT-OTIB-0018, Internal Dose Overestimates for Facilities with Air Sampling Programs, Rev. 

01; ORAU Team Dose Reconstruction Project for NIOSH; effective August 9, 2005; SRDB Ref ID: 

19436 

ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities, Rev. 01; ORAU Team Dose Reconstruction Project for NIOSH; 

effective March 5, 2012; SRDB Ref ID: 108851 

ORAUT-OTIB-0076, Guiding Reconstruction of Intakes of Thorium Resulting from Nuclear Weapons 

Programs, Rev. 00; ORAU Team Dose Reconstruction Project for NIOSH; effective July 10, 2014; 

SRDB Ref ID: 133669

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

Administered Off Site, Rev. 02; ORAU Team Dose Reconstruction Project for NIOSH; effective June 

15, 2017; SRDB Ref ID: 166967 

ORAUT-TKBS-0034, An Exposure Matrix for Superior Steel, Carnegie, Pennsylvania, Period of 

Operation: January 1, 1952 through December 31, 1957, Rev. 00 PC-1; ORAU Team Dose 

Reconstruction Project for NIOSH; effective August 9, 2005; SRDB Ref ID: 20182 

Osterwald, 1956, Uranium Compounds, February 1956, correspondence; H. R. Osterwald; March 1, 

1956; SRDB Ref ID: 132720 

Reardon, 1956, License Change to Process Thorium Granted, correspondence; Eugene J. Reardon; 

March 13, 1956; SRDB Ref ID: 78264 

Reardon, 1957, Security Inspection, shows dates of inspections made in 1954 through 1956; facility 

security agent is E. J. Reardon; remarks include date of May 10, 1957; SRDB Ref ID: 161092, PDF p. 

20 

Sapirie, 1954, Rolling Slabs to be Shipped to Superior Steel for Final Fabrication, Telegram; S. R. 

Sapirie; surrounding document indicates likely issued in November 1954; SRDB Ref ID: 132719, 

PDF pp. 2-3 

Schiltz, 1956, Uranium Slab Shipment from Lockport, New York, correspondence; J. F. Schiltz; 

November 27, 1956; SRDB Ref ID: 81545 

SROO, 1952–1957, Review of Contract AT(30-1)-1412 with Specific Contract Terms; Savannah River 

Operations Office (SROO); Contract effective June 27, 1952 and completion date of September 30, 

1957; SRDB Ref ID: 161092, PDF pp. 23–24 

SROO, 1979, Formerly Utilized MED/AEC Site Radiological Survey Program (Former Superior Steel 

Company Activities), correspondence with attachments; Savannah River Operations Office (SROO); 

August 28, 1979; SRDB Ref ID: 78340 
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Stanford, 1954, Rollings at Superior, correspondence; R. E. L. Stanford; February 8, 1954; SRDB Ref 

ID: 172177, PDF p. 2 

Superior Steel, 1954, Metallurgy Section Monthly Report, April 1954; Superior Steel Co.; April 1954; 

SRDB Ref ID: 99468 

Survey, 1955, Survey of the Control Maintained over Source and Special Nuclear Materials, National 

Lead Company of Ohio, Fernald Area, select pages including amounts from July 1, 1954 to February 

28, 1955; Unknown author; September 2, 1955; SRDB Ref ID: 77006 

USAEC, 1954, Shipping Uranium Slabs to Superior Steel, Telegram; U.S. Atomic Energy 

Commission (USAEC); received December 14, 1954; SRDB Ref ID: 132695, PDF p. 2 

USACE, 2007; Preliminary Assessment, Superior Steel Corporation, Scott Township, Pennsylvania; 

U.S. Army Corps of Engineers (USACE); February 2007; SRDB Ref ID: 167784 

Watson, 2016, Comparison of Laboratory Analytical Methods for Uranium Analysis, Superior Steel 

FUSRAP Site; Natalie Watson, Scott McCabe, Jeffrey Lively, and Nelson Walter; WM2016 

Conference, March 6-10, 2016; SRDB Ref ID: 173745 

West, 1955, Shipment of Materials for AECL to Fabricate Plate Elements, correspondence; W. W. 

West; February 3, 1955; SRDB Ref ID: 58579 

Worthington, 1956, Research Programs in Support of Savannah River, correspondence; Hood 

Worthington; April 19, 1956; SRDB Ref ID: 90056 

Young, 1985, Authority Review – The Former Superior Steel Corporation Site – AEC Contract NO. 

AT(30-1)-1412, correspondence to Arthur Whitman with attachments; Charles D. Young; September 

30, 1985; SRDB Ref ID: 14655
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Attachment One: Data Capture Synopsis

Table A1-1: Summary of Holdings in the SRDB for Superior Steel Co.

Data Capture Information Data Capture Description Date 

Completed 

Number

Uploaded 

into SRDB

Primary Site/Company Name: Superior Steel Co.

AWE 1952-1957; Residual Radiation 1958-March 1, 

2011

Alternate Site Names: Copperweld, Inc. and Lot and 

Block 102J210

Physical Size of the Site: 25 acres, Building/Area 

23a~25,000ft2

; 23d~13,000ft2 and 23e~14,000ft2

Site Population: Hot Strip Mill had approximately 

100 personnel including labor, management, and 

operating personnel in 1953.

The PA Department of Environmental Protection indicated any relevant records, if still in 

existence, would be likely to reside with the U.S. Army Corps. of Engineers (USACE), who 

have been contacted. Note: Please see United States Army Corps of Engineers (USACE) row 

below.

09/18/2018 0

State Contacted: [Contact information redacted] No relevant data identified. 09/18/2018 0

Babcock & Wilcox Babcock & Wilcox is searching for related material, but initially indicated they do not 

anticipate finding information from the 1950’s period.

OPEN Not 

Applicable

Carnegie Library of Pittsburgh Excerpts from annual reports to stockholders for years 1952-1956. 10/10/2018 1

DOE Germantown Radiological history and summary, radiological survey, elimination report and distribution of 

uranium plates, and an authority review for the former Superior Steel Company.

03/07/2011 11

DOE Legacy Management - Grand Junction Office Accountability for uranium slabs, commercial facilities used by National Lead Company of 

Ohio, companies occupying former Superior Steel Co. sites, comprehensive radiological 

survey, conditioning uranium slabs, expert system license evaluation report for license C03480, thorium licensing, final radiological scoping survey of portions of the former Superior 

Steel Company, hot strip mill procedure and sample data for rolling operations, inventory 

information, licensing amendments to process thorium, machining of plates - contract AT(30-

1)-1247, monthly reports for 1952-1954, orders for rolling of slabs, rolling at Superior Steel

Co., shipment of uranium, thorium source material license, and working draft historical 

summaries.

03/07/2011 82

DOE Legacy Management - Morgantown Resurvey program and an assessment of contaminated properties. 04/04/2016 2

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

Notice of change to source and Special Nuclear Materials accountability station symbols 

listing, resumption of activities for the month ending June 20, 1953, research and 

development expenditures, and completion of AEC production order A-60.

05/13/2010 7
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Data Capture Information Data Capture Description Date 

Completed 

Number

Uploaded 

into SRDB

DOE Oak Ridge Operations Records Holding Task 

Group (RHTG)

Supplement to Production Division monthly activity report 1952. 04/05/2011 1

Hagley Museum and Library Research programs in support of Savannah River Site. 09/28/2010 1

Hanford Activity #132 has been submitted requesting additional key word searches be conducted on 

all Hanford databases to supplement what has been obtained to date.

Monthly reports and transfer to Oak Ridge contract AT(30-1)-1412.

OPEN 4

Health and Safety Laboratory (HASL) Thorium sampling and storage. 03/08/2005 1

Internet - Defense Technical Information Center 

(DTIC)

No relevant data identified. 09/20/2018 0

Internet - DOE Legacy Management Site management guide 2012. 01/28/2014 2

Internet - DOE Legacy Management Considered Sites No relevant data identified. 05/17/2018 0

Internet - DOE National Nuclear Security 

Administration (NNSA) - Nevada Site Office

No relevant data identified. 09/20/2018 0

Internet - DOE Noncompliance Tracking System No relevant data identified. 09/20/2018 0

Internet - Occurrence Reporting and Processing 

System

No relevant data identified. 09/20/2018 0

Internet - DOE OpenNet Trip report and a quarterly report of Working Committee on Uranium Quality and 

Fabrication.

05/15/2018 2

Internet - DOE OSTI Energy Citations Report 3, Flat Plate Bonded Fuel Elements 1953. 03/25/2010 1

Internet - DOE OSTI Information Bridge Material tasks and advanced material program. 04/01/2013 1

Internet - DOE OSTI SciTech Connect Analysis of the extended Zero Power Experiments on the Army Package Power Reactor 

(ZPE-2), Argonne National Laboratory annual report for Metallurgy Division, boiling water 

reactor technology status report, mechanical properties of uranium plate, plutonium recycle 

program monthly report, and a Reactor Engineering Division quarterly report.

05/15/2018 13

Internet - Energy Employees Claimant Assistance 

Project (EECAP)

No relevant data identified. 09/20/2018 0
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48 of 55 

Data Capture Information Data Capture Description Date 

Completed 

Number

Uploaded 

into SRDB

Internet - Google Status of decommissioning program-annual update, AEC research programs in support of 

Savannah River, Formerly Utilized Sites Remedial Action Program (FUSRAP) fact sheet and 

update, new approach to gamma scans for processed natural uranium at a FUSRAP site, 

residual radioactivity summary, status of the decommissioning program annual report, and a 

Superior Steel description.

09/20/2018 63

Internet - Hanford Declassified Document Retrieval 

System (DDRS)

Monthly activity report. 01/11/2008 1

Internet - Health Physics Journal No relevant data identified. 09/20/2018 0

Internet - Journal of Occupational and Environmental 

Hygiene

No relevant data identified. 09/20/2018 0

Internet - National Academies Press (NAP) No relevant data identified. 05/17/2018 0

Internet - National Environmental Publications 

Internet Site (NEPIS), U.S. Environmental Protection 

Agency (EPA)

No relevant data identified. 05/17/2018 0

Internet - National Institute for Occupational Safety 

and Health (NIOSH)

Report on residual radioactive and beryllium contamination at Atomic Weapons Employer 

Facilities and Beryllium Vendor Facilities.

08/31/2011 3

Internet - NRC Agencywide Document Access and 

Management (ADAMS)

Briefing on decommissioning activities and status, extension of contract AT(30-1)-1412 with 

Superior Steel, records search for Superior Steel, preliminary site survey report, request for 

uranium slabs for rolling, shipment of slabs to American Machine & Foundry Co. and 22 

slabs to Superior Steel, application for amendment to source material license C-3480, and 

uranium rolling 1954.

09/20/2018 51

Internet - Oak Ridge National Laboratory Library Aircraft Nuclear Propulsion Project quarterly progress report. 07/06/2012 1

Internet - USACE/FUSRAP Fact sheet and a preliminary assessment. 05/17/2018 4

Internet - Washington State University (U.S. 

Transuranium and Uranium Registries)

No relevant data identified. 05/17/2018 0

National Archives and Records Administration 

(NARA) - College Park

Uranium rolling at Superior Steel and contract information. 10/18/2018 6

National Archives and Records Administration 

(NARA) - Kansas City

Assessment of Superior Steel. 04/01/2005 1

Oak Ridge Associated University (ORAU) Records review and evaluation report for the former Superior Steel site. 09/28/2018 1
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49 of 55 

Data Capture Information Data Capture Description Date 

Completed 

Number

Uploaded 

into SRDB

Oak Ridge National Laboratory (ORNL) Procedure manual for radiological survey activities. 03/28/2008 1

ORAU Team ORAUT-OTIB-0004 Estimating The Maximum Plausible Dose To Workers At Atomic 

Weapons Employer Facilities, ORAUT-TKBS-0034 Exposure Matrix for Superior Steel, and 

ORAUT-OTIB-0079 Guidance On Assigning Occupational X-ray Dose Under EEOICPA 

For X-rays Administered Off-Site.

06/16/2017 6

Savannah River Site Process requirements for uranium rolling, health physics area survey report, shipment of 

thorium plate elements, and a monthly progress report.

09/22/2018 20

United States Army Corps of Engineers (USACE) USACE Buffalo District has been contacted and is performing search for additional 

information.

OPEN Not 

Applicable

Unknown Air dust, breath, water, smears, and urine sample results (1952-1964), Battelle Memorial 

Institute site operations and facility descriptions, data analysis results 1951 through 1963, 

Report 5 flat bonded fuel elements period (1954), survey sheet (1953), and Sylvania Corning 

Plant and Fernald recycled uranium receipts and shipments.

01/12/2005 21

TOTAL Not Applicable Not 

Applicable

308

Table A1-2: Database Searches for Superior Steel Co.

Database/Source Keywords

Number 

of 

Hits

Number

Uploaded 

into SRDB

Defense Technical Information Center (DTIC)

COMPLETED 09/20/2018

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Attachment Two: Thorium Contamination

Oak Ridge National Laboratory (ORNL) 1980 Preliminary Site Survey

In July 1980, at the request of DOE, a preliminary radiological survey at the former Superior Steel Co. 

plant was conducted by members of the Health and Safety Research Division of ORNL. The 

objective was to “provide information on the present condition and use of the former mill area and to 

determine the need for a detailed survey” (Myrick, 1980, PDF p. 27). This survey covered the former 

mill area (referred to as Area A), the former motor room (referred to as Area B), and the former

rolling area (referred to as Area C). Preliminary Site Survey Report for the Former Superior Steel 

Mill at Carnegie, Pennsylvania (Myrick, 1980) states that the survey consisted of the following five 

methods: 

1. External-gamma scan of floor and lower-wall surfaces in all buildings via gamma scintillation 

survey meter; 

2. Fixed alpha measurements on floor and wall surfaces in random locations in all areas via an alpha 

scintillation survey meter; 

3. Beta-gamma dose rate measurements at selected locations via beta-gamma sensitive GM tube with 

open/closed window option; 

4. External gamma and fixed alpha measurements on original machinery surfaces via gamma 

scintillation survey meter and alpha scintillation survey meter; and 

5. Sampling and analysis of mill residues via laboratory analysis (Myrick, 1980, PDF p. 28).

The first four survey methods would result in gross data, not yielding radionuclide-specific 

information. Only the fifth method, sampling and analysis of mill residues via laboratory analysis, 

could yield radionuclide-specific results; thus NIOSH’s ORNL 1980 site survey data review would 

focus on results from method 5. 

A sample of residues from the bottom of the rolling area pit was taken and sent to ORNL for analysis. 

The sample was a combination of steel shavings, soil, and various other unidentified materials. There 

are no details on the instrumentation or procedures used for the sample analysis. The only 

radionuclide identified by ORNL was U-238; it was indicated that “no other radionuclides were 

present in sufficient quantities to be detected” (Myrick, 1980, PDF p. 29). Another sample was taken 

under the wooden floor of the storage shed in this same former rolling area. The results of the 

analysis indicated the material under the floor was similar in makeup to that found in the pit (i.e., U238 and the statement “no other radionuclides were detected” (Myrick, 1980, PDF p. 30). 

Based on the results of this survey, it was recommended that a formal, detailed survey of the building 

be conducted (Myrick, 1980, PDF p. 30). According to a memo dated October 28, 1981, from DOE 

Environmental and Safety Engineering Division (EP-32) to the State of Pennsylvania, the full 

radiological survey of Superior Steel Co. would be postponed, because the contaminated areas had 

been made inaccessible by the current owner of the property (Mott, 1981). 
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NRC Environmental Survey and Site Assessment Program (ESSAP) Phase 1

In 2000, at the request of the NRC Division of Waste Management, Oak Ridge Institute for Science 

and Education (ORISE)’s ESSAP performed radiological scoping survey activities on various portions 

of the Superbolt facility during the period of August 28 through September 1, 2000 (Adams, 2001). 

These ORISE Phase 1 ESSAP survey activities were performed in the former mill area (same as 

ORNL Area A), former motor room (same as ORNL Area B), and former rolling area (same as ORNL 

Area C) and consisted of the following: 

1. Alpha, beta, and gamma surface scans of 25% of the floors in the former mill area and former 

rolling area, as well as 25% of the lower walls in the former rolling area; 

2. Gamma/beta surface activity measurements and smear surveys for removable gross alpha and 

gross beta in 37 areas of elevated radiation levels determined by the surface scans; 

3. Exposure rate measurements in 5 locations within the former rolling area; 

4. Soil sampling for laboratory analysis of locations in the former mill and rolling areas; and 

5. Miscellaneous sampling for laboratory analysis from areas of elevated activity determined in 

direct measures of the former rolling area and former mill area.

Survey methods 1-3 provide gross or total activity information and are not radionuclide-specific. 

Survey methods 4 and 5 can provide radionuclide-specific information. Therefore, NIOSH’s NRC 

ESSAP Phase I data review focused on results from methods 4 and 5. Forty-six soil samples 

(approximately 1kg each) were taken from the following: 

• Under four flooring excavations/backfill removal above former trenches/pits; 

• Subsurface samples (under concrete flooring, asphalt, and concrete roadway) in various sections of 

Areas A, B, and C;

• Excavated trenches with Area A;

• Excavated trench in the salt bath area; and 

• Randomly selected locations inside and outside of the facility. 

The miscellaneous samples consisted of the following: 

• Five dust and residue samples collected from horizontal surfaces in the overhead beams and lower 

walls in Area C;

• Two paint/primer/concrete chip samples from the floor of Area C;

• One concrete rubble sample collected from the former storage shed area; and

• One water sample from Trench Pit #2 in Area A.

Samples were prepared per the ESSAP procedures and analyzed at ORISE’s ESSAP laboratory in 

accordance with the ORISE/ESSAP Laboratory Procedures Manual. The soil and miscellaneous 

samples were analyzed by gamma spectroscopy using HP Extended Range Intrinsic detectors and 

multichannel analyzers. Background and Compton stripping, peak search, peak identification, and 
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concentration calculations were performed using the computer capabilities inherent in the analyzer 

system. All photopeaks were reviewed for consistency of activity. Detection limits, or minimum 

detectable concentrations (MDC), were based on 3 plus 4.65 times the standard deviation of the 

background count. Samples results less than the MDC were reported as less than the MDC for 

counting purposes. Uranium-235 was measured directly via the 143keV photopeak (10.96%); U-238 

was measured indirectly via daughter products and assuming secular equilibrium: Th-234 with 63keV 

photopeak (4.8%) or Pa-234m with 1001keV photopeak (0.83%) (Adams, 2001). According to 

Adams, 2011, “The radionuclide of interest was uranium; however, spectra were reviewed for other 

identifiable total absorption peaks (photopeaks).” NIOSH has concluded that if thorium 

contamination were present, it did not exceed the maximum detectable concentration and therefore is 

not a significant contributor to exposure. 

After gamma spectroscopy, some soil samples were selected for alpha spectroscopy and were 

prepared by a potassium fluoride and pyrosulfate fusion followed by a barium precipitation and 

liquid-liquid extraction for uranium (Adams, 2001). If thorium was present in the original sample it 

would have been removed during the separation phase of the uranium-specific sample. Therefore, the 

alpha spectroscopy preparation precludes the ability to make conclusions about any thorium presence. 

NRC ESSAP Phase 2

In August 2003, the NRC's Division of Waste Management requested that ORISE ESSAP perform 

additional radiological evaluations of portions of the Superbolt (i.e., Superior Steel Co.) facility that 

were not addressed during Phase 1 (Adams, 2001). This survey was performed in accordance with a 

site-specific survey plan created in line with the ORISE/ESSAP Survey Procedures and Quality 

Assurance Manual and approved by the NRC. The areas evaluated included all five Superbolt 

warehouses that comprised Superbolt Building Complex Number 23: 23A (former mill area, ORNL 

Area A), 23B (not previously surveyed, but was used as AHP remediation/radiological waste storage), 

23C (not previously surveyed), 23D (former rolling area, ORNL Area C), and 23E (former motor 

room, ORNL Area B). ESSAP also reviewed existing site data associated with further evaluation and 

cost estimates for work required to perform studies to determine the radiological status of the underfloor trench that runs through Areas 23A and 23D (Adams, 2003).

This survey was limited in scope, but included: 

1. Alpha, beta, and gamma surface scans of the floor—80% surveyed in 23A and 23E, 90% surveyed 

in 23C and 23D, and 50% for 23B, as well as 25% of the lower walls and 5% of upper walls in all 

locations; 

2. Gross alpha and gross beta surface activity measurements and smear samples for removable 

contamination in locations of elevated radiation areas determined from surface scans; 

3. Exposure rate measurements throughout all areas; 

4. One surface soil sample taken from elevated radiation area within 23B for laboratory analysis; and 

5. Ten miscellaneous samples (residue, brick, and dust samples) collected from areas of elevated 

radiation determined by surface scans for laboratory analysis (Adams, 2003). 
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Survey methods 1-3 provide only total (gross) results and don’t provide radionuclide-specific results. 

Survey methods 4-5 can provide radionuclide-specific results; therefore, NIOSH’s NRC ESSAP 

Phase II data review focused on these results. Samples were analyzed and interpreted at the ESSAP 

laboratory in Oak Ridge, similar to the Phase 1 procedures. “Soil and miscellaneous material samples 

were analyzed by gamma spectroscopy... The radionuclides of interest were those associated with 

natural processed uranium; however, spectra were also reviewed for natural thorium and other 

identifiable total absorption peaks (photopeaks)” (Adams, 2003). NIOSH has concluded that if 

thorium contamination were present, it did not exceed the minimum detectable concentration and 

therefore is not a significant contributor to exposure.

USACE FUSRAP

In 2014, a Remedial Investigation survey was performed by the Amec Foster Wheeler Company at the 

request of USACE for FUSRAP purposes. The primary objective was to measure the nature and 

extent of AEC-related contamination across the site and determine other radiological impacts related 

to potential commercial work performed on site. The survey included a gamma scan using two types 

of spectroscopy-grade sodium iodide (NaI) detectors of accessible portions of the ground surfaces of 

the site (Lively, 2015). 

Because this survey was for FUSRAP purposes, thorium was not considered a primary contaminant of 

concern. However, radiological surface surveys were analyzed for thorium constituents in order to 

differentiate between the impacts at the site from FUSRAP-related contaminants of concern and other 

potential radiological impacts that might be present, such as those related to the commercial license 

authorizing possession of thorium for Babcock and Wilcox. Surveys were conducted using both 

custom NaI detectors, specifically engineered for detection of processed uranium metal (i.e., designed 

for detection of low-energy U-238 photon emissions) and 3x3-inch NaI detectors which are sensitive 

to thorium source material, Naturally Occurring Radioactive Material (NORM) constituents and other 

radionuclides associated with uranium metal. The array of detectors were placed next to each other so 

that the scans were simultaneously collecting data (Lively, 2015). 

Visually, the Th-232 had a spatial layout similar to the two isotopes representing the naturally 

occurring radioactivity: K-40 and Ra-226 (progeny of U-238 in soil), which had fairly consistent 

activity levels throughout the complex. The total gamma activity spatial plots showed distinct spatial 

patterns of high areas of radioactivity, unlike the naturally occurring radionuclides and thorium plots. 

This leads one to believe that the Th-232 detected could be due to the natural background; Th-232 is a 

primordial radionuclide present in earthen materials. A conclusion made by the document states, 

“Interestingly, there is no significant spatial structure observable in the Th-232 data set suggesting that 

radiological impacts in the near surface soils from licensed activities involving thorium at the site are 

insignificant” (Lively, 2015); thus, there were no indications of high thorium activity levels in any 

specific areas at the facility. 

Due to questioning of the accuracy of the data presented in the 2014 Remedial Investigation (Lively, 

2015), USACE and Amec Foster Wheeler performed a supplemental quality control test. Questions 

were raised about the low concentrations of uranium that were reported. The conclusion reached, by 

reanalyzing a subset of 18 samples on other gamma spectroscopy and ICP-MS counters, was that the 

original results were valid, lending credibility to the sample analysis performed in 2014 (Watson, 

2016).