SEC Petition Evaluation Report 

Petition SEC-00177 

Report Rev #: 0 Report Submittal Date: February 4, 2011

Subject Expert(s): Monica Harrison-Maples, Mike Mahathy 

Site Expert(s): N/A 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Receipt Date 

Qualification Date DOE/AWE Facility Name 

SEC-00177 83.13 July 14, 2010 September 9, 2010 Vitro Manufacturing (Canonsburg) 

Petitioner Class Definition 

All employees who worked in any area at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during 

the time period from January 1, 1958 through April 30, 1960. 

Class Evaluated by NIOSH 

All employees who worked in any area at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during 

the time period from January 1, 1958 through December 31, 1959. 

NIOSH-Proposed Class to be Added to the SEC 

All Atomic Weapons Employer employees who worked at Vitro Manufacturing in Canonsburg, Pennsylvania, 

from January 1, 1958 through December 31, 1959, for a number of work days aggregating at least 250 work days, 

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

established for one or more other classes of employees in the Special Exposure Cohort. 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition 

Type DOE/AWE Facility Name Petition Status 

SEC-00134 83.14 Vitro Manufacturing 

(Canonsburg) 

Class added to the SEC for 

Aug. 13, 1942 through Dec. 31, 1957 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

SEC Petition Evaluation Report for Petition SEC-00134 Vitro Manufacturing (Canonsburg) 

ORAU Lead Technical Evaluator: Monica HarrisonMaplesORAU Peer Review Completed By: Michael Kubiak 

Peer Review Completed By: [Signature on file] 2/4/2011 

Gregory Macievic Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 2/4/2011

J. W. Neton Date 

SEC Evaluation Approved By: [Signature on file] 2/4/2011

David Sundin for Stuart L. 

Hinnefeld 

Date 
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Evaluation Report Summary: SEC-00177, Vitro Manufacturing 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition

Petition SEC-00177 was received on July 14, 2010, and qualified on September 9, 2010. The 

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

at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during the time period from January 

1, 1958 through April 30, 1960. 

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH divided the petitioner-requested class into two periods to be 

separately evaluated. The first period, evaluated herein, is from January 1, 1958 through December 

31, 1959, the period for which NIOSH was able to locate evidence of continuing operations on behalf 

of the Atomic Energy Commission (AEC), extending the site’s Atomic Weapons Employer (AWE) 

operations period through December 31, 1959. The other period, beginning on January 1, 1960, 

extends into the residual radiation period. NIOSH has documentation stating that the facility ceased 

operations and that personnel were no longer working at the site after May 1960, but further 

evaluation is required. In the interest of timeliness, NIOSH has reserved the feasibility evaluation for 

the residual radiation period beginning in January 1960. 

NIOSH evaluated the following class: All employees who worked in any area at the Vitro 

Manufacturing facility in Canonsburg, Pennsylvania, during the time period from January 1, 1958 

through December 31, 1959. 

NIOSH-Proposed Class to be Added to the SEC

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all Atomic Weapons Employer employees who worked at Vitro 

Manufacturing in Canonsburg, Pennsylvania, from January 1, 1958 through December 31, 1959, for a 

number of work days aggregating at least 250 work days, occurring either solely under this 

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

other classes of employees in the Special Exposure Cohort. The class under evaluation was 

recommended for inclusion in the SEC (see Section 3.0 below) because NIOSH lacks personnel 

monitoring data, air monitoring information, sufficient process information, and radiological source 

term information for the period under evaluation to allow it to estimate, with sufficient accuracy, the 

potential occupational exposures to uranium products and uranium progeny during processing at Vitro 

Manufacturing during the proposed SEC period. 
SEC Petition Evaluation Report 

Petition SEC-00177 

Report Rev #: 0 Report Submittal Date: February 4, 2011

Subject Expert(s): Monica Harrison-Maples, Mike Mahathy 

Site Expert(s): N/A 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Receipt Date 

Qualification Date DOE/AWE Facility Name 

SEC-00177 83.13 July 14, 2010 September 9, 2010 Vitro Manufacturing (Canonsburg) 

Petitioner Class Definition 

All employees who worked in any area at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during 

the time period from January 1, 1958 through April 30, 1960. 

Class Evaluated by NIOSH 

All employees who worked in any area at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during 

the time period from January 1, 1958 through December 31, 1959. 

NIOSH-Proposed Class to be Added to the SEC 

All Atomic Weapons Employer employees who worked at Vitro Manufacturing in Canonsburg, Pennsylvania, 

from January 1, 1958 through December 31, 1959, for a number of work days aggregating at least 250 work days, 

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

established for one or more other classes of employees in the Special Exposure Cohort. 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition 

Type DOE/AWE Facility Name Petition Status 

SEC-00134 83.14 Vitro Manufacturing 

(Canonsburg) 

Class added to the SEC for 

Aug. 13, 1942 through Dec. 31, 1957 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

SEC Petition Evaluation Report for Petition SEC-00134 Vitro Manufacturing (Canonsburg) 

ORAU Lead Technical Evaluator: Monica HarrisonMaplesORAU Peer Review Completed By: Michael Kubiak 

Peer Review Completed By: [Signature on file] 2/4/2011 

Gregory Macievic Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 2/4/2011

J. W. Neton Date 

SEC Evaluation Approved By: [Signature on file] 2/4/2011

David Sundin for Stuart L. 

Hinnefeld 

Date 
SEC-00177 02-04-2011 Vitro Manufacturing (Canonsburg)

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Evaluation Report Summary: SEC-00177, Vitro Manufacturing 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition

Petition SEC-00177 was received on July 14, 2010, and qualified on September 9, 2010. The 

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

at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during the time period from January 

1, 1958 through April 30, 1960. 

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH divided the petitioner-requested class into two periods to be 

separately evaluated. The first period, evaluated herein, is from January 1, 1958 through December 

31, 1959, the period for which NIOSH was able to locate evidence of continuing operations on behalf 

of the Atomic Energy Commission (AEC), extending the site’s Atomic Weapons Employer (AWE) 

operations period through December 31, 1959. The other period, beginning on January 1, 1960, 

extends into the residual radiation period. NIOSH has documentation stating that the facility ceased 

operations and that personnel were no longer working at the site after May 1960, but further 

evaluation is required. In the interest of timeliness, NIOSH has reserved the feasibility evaluation for 

the residual radiation period beginning in January 1960. 

NIOSH evaluated the following class: All employees who worked in any area at the Vitro 

Manufacturing facility in Canonsburg, Pennsylvania, during the time period from January 1, 1958 

through December 31, 1959. 

NIOSH-Proposed Class to be Added to the SEC

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all Atomic Weapons Employer employees who worked at Vitro 

Manufacturing in Canonsburg, Pennsylvania, from January 1, 1958 through December 31, 1959, for a 

number of work days aggregating at least 250 work days, occurring either solely under this 

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

other classes of employees in the Special Exposure Cohort. The class under evaluation was 

recommended for inclusion in the SEC (see Section 3.0 below) because NIOSH lacks personnel 

monitoring data, air monitoring information, sufficient process information, and radiological source 

term information for the period under evaluation to allow it to estimate, with sufficient accuracy, the 

potential occupational exposures to uranium products and uranium progeny during processing at Vitro 

Manufacturing during the proposed SEC period. 
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Feasibility of Dose Reconstruction

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it does not have access to 

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

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

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

estimate of maximum dose. Information available from additional resources is not sufficient to 

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

proposed class under plausible circumstances during the specified period. 

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

• NIOSH finds that it is likely feasible to reconstruct occupational medical dose for Vitro 

Manufacturing workers with sufficient accuracy. 

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

exposures to site contamination and residue piles containing uranium and uranium progeny, 

including radon. 

• There is currently a class of Vitro Manufacturing (Canonsburg) workers associated with the 

previous NIOSH evaluation of SEC petition SEC-00134 for a portion of the site’s Atomic 

Weapons Employer operations period (August 13, 1942 through December 31, 1957). The 

Secretary of the Department of Health and Human Services has designated the following class for 

inclusion in the Special Exposure Cohort: 

All AWE employees who worked at Vitro Manufacturing in Canonsburg ,Pennsylvania from 

August 13, 1942 through December 31, 1957, for a number of work days aggregating at least 

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

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

Special Exposure Cohort.

• The period currently being evaluated, January 1, 1958 through December 31, 1959, follows 

immediately after the already-designated SEC period for Vitro Manufacturing. NIOSH has 

determined that Vitro Manufacturing continued to process scrap and residues that could have 

resulted in the generation of airborne dust, surface contamination, and direct contact with bulk 

materials. The potential for unmonitored exposures continued at Vitro Manufacturing until site 

AWE operations concluded in 1959. 

• NIOSH does not have access to sufficient personnel monitoring, workplace monitoring, or source 

term data to estimate unmonitored internal and external exposures for Vitro Manufacturing 

workers during the period from January 1, 1958 through December 31, 1959. 

• Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient 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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• Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed 

at Vitro Manufacturing (Canonsburg) during the period from January 1, 1958 through December 

31, 1959, but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate dose for the members 

of the proposed class. 

NIOSH did not identify any evidence supplied by the petitioners or from other resources that would 

establish that the proposed class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high-level exposures. However, evidence indicates that some workers in the 

proposed class may have accumulated substantial chronic exposures through episodic intakes of 

radionuclides, combined with external exposures to gamma and beta radiation. Consequently, NIOSH 

has determined that health was endangered for those workers covered by this evaluation who were 

employed for at least 250 aggregated work days either solely under this employment or in 

combination with work days within the parameters established for one or more other SEC classes. 
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Table of Contents 

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

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

3.0 SEC-00177, Vitro Manufacturing Class Definitions .................................................................... 10

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

3.2 Class Evaluated by NIOSH ................................................................................................. 11

3.3 NIOSH-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 .......................................................................................... 13

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

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

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

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

5.1 Vitro Manufacturing Plant and Process Descriptions ......................................................... 15

5.2 Radiological Exposure Sources from Vitro Manufacturing Operations ............................. 19

5.2.1 Internal Radiological Exposure Sources from Vitro Manufacturing ...................... 19

5.2.1.1 Natural Uranium ....................................................................................... 19

5.2.1.2 Uranium Progeny ...................................................................................... 19

5.2.2 External Radiological Exposure Sources from Vitro Manufacturing ..................... 19

5.2.2.1 Photon ....................................................................................................... 20

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 ............................. 20

6.1 Available Vitro Manufacturing Internal Monitoring Data .................................................. 20

6.2 Available Vitro Manufacturing External Monitoring Data ................................................. 21

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 21

7.1 Pedigree of Vitro Manufacturing Data ................................................................................ 22

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 22

7.1.2 External Monitoring Data Pedigree Review ............................................................ 22

7.2 Evaluation of Bounding Internal Radiation Doses at Vitro Manufacturing ........................ 22

7.2.1 Evaluation of Bounding Internal Doses .................................................................. 22

7.2.2 Methods for Bounding Internal Dose at Vitro Manufacturing ................................ 23

7.2.3 Internal Dose Reconstruction Feasibility Conclusion ............................................. 23

7.3 Evaluation of Bounding External Radiation Doses at Vitro Manufacturing ....................... 24

7.3.1 Evaluation of Bounding External Doses ................................................................. 24

7.3.2 Vitro Manufacturing Occupational X-Ray Examinations ....................................... 24

7.3.3 Methods for Bounding External Dose at Vitro Manufacturing ............................... 24

7.3.4 External Dose Reconstruction Feasibility Conclusion ............................................ 24
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7.4 Evaluation of Petition Basis for SEC-00177 ....................................................................... 25

7.4.1 Monitoring Inadequacies ......................................................................................... 25

7.4.2 Working Conditions After 1957 .............................................................................. 25

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation ...... 26

7.6 Summary of Feasibility Findings for Petition SEC-00177 .................................................. 26

8.0 Evaluation of Health Endangerment for Petition SEC-00177 ...................................................... 27

9.0 Class Conclusion for Petition SEC-00177 ................................................................................... 27

10.0 References .................................................................................................................................... 29

Attachment One: Data Capture Synopsis .............................................................................................. 35

Tables 

Table 4-1: No. of Vitro Manufacturing Claims Submitted Under the Dose Reconstruction Rule ....... 14 

Table 5-1: Summary of Vitro Manufacturing (Canonsburg) Milestones .............................................. 18 

Table 7-1: Summary of Feasibility Findings for SEC-00177 ............................................................... 26

Figures 

Figure 5-1: Uranium Production Flow Diagram ................................................................................... 16
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SEC Petition Evaluation Report for SEC-00177 

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: 

Monica Harrison-Maples, Oak Ridge Associated Universities. 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 doses for all employees who worked in any area 

at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during the time period from January 

1, 1958 through December 31, 1959. 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, OCAS-PR-004.1

2.0 Introduction 

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

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2

 

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 

 

1

 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS). 

2

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

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 
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members of a class when it has been established that the class may have been exposed to radiation 

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

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

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

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 to the 

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

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.3 

3.0 SEC-00177, Vitro Manufacturing Class Definitions 

The following subsections address the evolution of the class definition for SEC-00177, Vitro 

Manufacturing in Canonsburg, Pennsylvania (sometimes referred to as ‘Vitro’ throughout this report). 

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. 

Per the DOE Office of Health, Safety and Security, the time period associated with AWE operations at 

the Vitro Manufacturing Canonsburg site is 1942 through 1959. However, prior to this petition 

evaluation, the period associated with AWE operations was defined as 1942 through 1957, with a 

residual radiation period designated for 1958 through 1985 (DOL, 2011a; DOL, 2011b). There is 

currently a class of Vitro Manufacturing workers associated with the previous NIOSH evaluation of 

SEC petition SEC-00134 for the site’s previously-designated AWE operations period (1942 through 

1957). The Secretary of the Department of Health and Human Services (DHHS) has designated the 

following class for inclusion in the Special Exposure Cohort: 

All AWE employees who worked at Vitro Manufacturing in Canonsburg, Pennsylvania from 

August 13, 1942 through December 31, 1957, for a number of work days aggregating at least 

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

3

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

available at http://www.cdc.gov/niosh/ocas. 
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days within the parameters established for one or more other classes of employees in the 

Special Exposure Cohort (DHHS, 2009). 

3.1 Petitioner-Requested Class Definition and Basis 

Petition SEC-00177 was received on July 14, 2010, and qualified on September 9, 2010. The 

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

at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during the time period from January 

1, 1958 through April 30, 1960. 

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

accurate dose reconstruction over time is impossible for the Vitro Manufacturing workers in question. 

NIOSH deemed the following information and affidavit statements sufficient to qualify SEC-00177 

for evaluation: 

The petitioner submitted an affidavit (Affidavit, 2010) stating that radiation exposures and 

therefore radiation doses potentially incurred by members of the proposed class were not 

monitored, either through personal or area monitoring. The petitioner also included information 

(Form B, 2010) on the Vitro Manufacturing site published by the United States Energy 

Information Administration and by NIOSH. The petitioner submitted two memoranda (Petition 

Supplement, 2010) in which the petitioner questioned the 1957 end date for the previouslydesignated SEC class, and indicated that the same radiological conditions that had resulted in the 

inability to reconstruct doses for the previously-designated AWE operations period continued to 

exist after 1957. 

Based on its Vitro Manufacturing research and data capture efforts, NIOSH determined that it has 

access to only limited process information and area surveys that occurred well beyond the time period 

requested for evaluation. NIOSH also determined that there are no personnel monitoring data 

available to NIOSH for the period requested for evaluation. NIOSH concluded that there is sufficient 

documentation to support the petition basis that internal and external radiation exposures and radiation 

doses may not have been adequately monitored at Vitro Manufacturing during the period for which 

the petition was submitted, either through personal monitoring or area monitoring. The information 

and statements provided by the petitioner qualified the petition for further consideration by NIOSH, 

the Board, and HHS. The details of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH divided the petitioner-requested class into two periods (the 

period from January 1, 1958 through December 31, 1959, and the post-1959 residual radiation period) 

because preliminary indications showed that the radiological activities during the period from 1958 

through 1959 were unmonitored and the potential for unmonitored occupational exposure did exist. 

The operations during 1958 and 1959 were consistent with the operations during the previouslydefined AWE operational period (1942-1957). Documentation located during NIOSH’s research 

provided evidence that the ongoing work also qualified as AWE operations. NIOSH presented this 

evidence to the Department of Labor (DOL) and DOL concurred that the period from 1958 through 

1959 should be reclassified as a period of AWE operations (DOL, 2011b). 
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Following the completion of the AEC contract, operations were directed toward shutdown activities. 

During NIOSH’s initial review of Vitro documentation, it became clear that additional research into 

the operations and conditions during 1960 and beyond was necessary to understand the potential for 

exposure that may have existed. While the petition specified April 30, 1960, as an end date for the 

evaluation, NIOSH located references to later dates in 1960 as the end of operations. References were 

made to the end of May (Inspection Responses, 1963, pdf p. 3) and a reference was made to July 1960 

(Zugschwerdt, 1981, pdf p. 12). Therefore, NIOSH is reserving the evaluation of operations at Vitro 

Manufacturing starting in 1960 in order to proceed with its evaluation of January 1, 1958 through 

December 31, 1959 in a timely manner. 

NIOSH defined the following class associated with this evaluation: All employees who worked in any 

area at the Vitro Manufacturing facility in Canonsburg, Pennsylvania, during the time period from 

January 1, 1958 through December 31, 1959. 

3.3 NIOSH-Proposed Class to be Added to the SEC 

Based on its research of the class under evaluation, NIOSH has defined a single class of employees for 

which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSH-proposed class 

to be added to the SEC includes all Atomic Weapons Employer employees who worked at Vitro 

Manufacturing in Canonsburg, Pennsylvania, from January 1, 1958 through December 31, 1959, for a 

number of work days aggregating at least 250 work days, occurring either solely under this 

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

other classes of employees in the Special Exposure Cohort. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

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

regarding Vitro Manufacturing. The database search included the DOE Legacy Management 

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

the Energy Citations database, the Atomic Energy Technical Report database, and the Hanford 

Declassified Document Retrieval System. In addition to general Internet searches, the NIOSH 

Internet search included OSTI OpenNet Advanced searches, OSTI Information Bridge Fielded 

searches, Nuclear Regulatory Commission (NRC) Agency-wide Documents Access and Management 

(ADAMS) web searches, the DOE Office of Human Radiation Experiments website, and the DOENational Nuclear Security Administration-Nevada Site Office-search. Attachment One contains a 

summary of Vitro Manufacturing documents. The summary specifically identifies data capture details 

and general descriptions of the documents retrieved. 

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. 
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4.1 Site Profile Technical Basis Documents (TBDs) 

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

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

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

individual monitoring data. A Site Profile 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. 

In the case of Vitro Manufacturing, a Site Profile document has not been written. 

4.2 ORAU Technical Information Bulletins (OTIBs) 

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

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

the following OTIBs as part of its evaluation: 

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

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

• OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, ORAUTOTIB-0006, Rev. 03 PC-1; December 21, 2005; SRDB Ref ID: 20220

• OTIB: Guidance on Assigning Occupational X-Ray Dose Under EEOICPA for X-Rays 

Administered Off Site, ORAUT-OTIB-0079; January 3, 2011; SRDB Ref ID: 89563

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH interviewed seven former Vitro Manufacturing employees. 

NIOSH selected individuals based on their known experience and likelihood that they would be 

knowledgeable about the operations and/or radiation monitoring practices at the Vitro site. All 

interviews were conducted by phone for the purpose of gaining additional information about any 

differences in work processes or health and safety procedures between the defined Atomic Energy 

Commission (AEC) operational period and the period under evaluation. 

• Personal Communication, 2010a, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; October 19, 2010, 9:30 a.m.; SRDB Ref ID: 90804 

• Personal Communication, 2010b, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; October 25, 2010, 10:00 a.m.; SRDB Ref ID: 90806 

• Personal Communication, 2010c, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; October 25, 2010, 11:00 a.m.; SRDB Ref ID: 90808 

• Personal Communication, 2010d, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; October 26, 2010, 3:00 p.m.; SRDB Ref ID: 90810 
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• Personal Communication, 2010e, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; October 27, 2010, 10:00 a.m.; SRDB Ref ID: 90812

• Personal Communication, 2010f, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; November 2, 2010, 9:50 a.m.; SRDB Ref ID: 90814 

• Personal Communication, 2010g, Personal Communication with Former Vitro Employee; 

Telephone Interview by ORAU Team; November 2, 2010, 1:00 p.m.; SRDB Ref ID: 90813 

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 January 24, 

2011) 

Table 4-1: No. of Vitro Manufacturing Claims Submitted Under the Dose Reconstruction Rule 

Description Totals 

Total number of claims submitted for dose reconstruction 27 

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

evaluation (January 1, 1958 through December 31, 1959) 14 

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) 9 

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

evaluated class definition 0 

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

evaluated class definition 0 

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

records could be obtained for each claimant. Based on the claim and information reviews performed 

to date, NIOSH has not located any internal or external monitoring data associated with Vitro 

Manufacturing energy employees within the time period of this evaluation. 

4.5 NIOSH Site Research Database 

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

assessment of the evaluated class. Seven hundred twenty-eight documents in this database were 

identified as pertaining to Vitro Manufacturing in Canonsburg, Pennsylvania. These documents were 

evaluated for their relevance to this petition. The documents include personnel data, historical 

background on Vitro operations and materials, contractual information, maps and surveys from the 

residual radiation period, and air monitoring information (although limited). 
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4.6 Documentation and/or Affidavits Provided by Petitioners 

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

petitioners: 

• Petition Form B for SEC-00177 with attached site summary documents; received on July 14, 

2010; OSA Ref ID: 112176, pdf pp. 2-9, 11-13 (Form B, 2010)

• Affidavit from Laboratory Technician; July 2, 2002; OSA Ref ID: 112176, pdf p. 10 (Affidavit, 

2002)

• Affidavit from Laboratory Technician; July 6, 2010; OSA Ref ID: 112176, pdf p. 1 (Affidavit, 

2010)

• Supplemental Information for SEC-00177 Petition; August 14, 2010; OSA Ref ID: 112455 

(Petition Supplement, 2010)

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize radiological operations at Vitro Manufacturing that may have 

had a radiological impact on the facility during the AWE operational period, and which would have 

contributed to worker exposure potential during the period under evaluation from January 1, 1958 

through December 31, 1959. From available sources, NIOSH has gathered process and source 

descriptions, information regarding the identity and quantities shipments of source materials of 

concern (to and from the site), inventory records, accountability surveys, contractual information, 

waste removal plans and reports, and information describing processes through which radiation 

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

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

information. 

5.1 Vitro Manufacturing Plant and Process Descriptions 

Vitro Manufacturing was located on an l8-acre site on Strabane Avenue in Canonsburg, Pennsylvania. 

The plant was built by the Standard Chemical Company. The facility had a total of 22 buildings, 

including a guardhouse, and three chemical storage sheds. NIOSH lacks clear documentation 

specifying the size of the workforce during the period evaluated. However, NIOSH does have 

workforce information for 1943 through 1953. The size of the workforce ranged from 50 to 82 

employees. In 1952 and 1953 there were approximately 80 workers at the site (Klevin, 1952a, pdf p. 

7; Klevin, 1952b, pdf p. 13; Klevin, 1953, pdf. p. 12; AEC, 1953, pdf p. 12). 

Processing and Recovery 

Domestic ores, African pitchblende, recoverable scrap materials, and Canadian residues were 

processed onsite throughout the history of Vitro. Because the feed materials were variable, there were 

many manual processes that would have resulted in high exposure potential. 
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From 1930 to 1942, the site was operated by Vitro Manufacturing and extracted radium and uranium 

salts from carnotite ore and residues for commercial purposes (Zugschwerdt, 1981, pdf pp. 10-13), 

resulting in contaminated site buildings even before AEC operations started (Snapp, 1951, pdf p. 53). 

Beginning in 1942, Vitro Manufacturing had begun processing African uranium ores and uranium 

concentrates for the Manhattan Engineer District (MED), the predecessor agency of AEC, to produce 

a feed concentrate in the form of U3O8 (Whitman, 1978). 

In November 1947, Vitro’s contract with AEC was supplemented to include processing uraniumbearing residues containing significant quantities of U3O8 that had been generated at other sites. Vitro 

Manufacturing assumed responsibility from the DuPont scrap recovery plant for processing these 

scrap and uranium-bearing residues from other AEC contractor sites (Snapp, 1951, pdf pp. 12, 42; 

Strod, Jan1949, pdf p. 30). 

By 1948, Vitro was receiving miscellaneous uranium scrap materials from AEC installations 

throughout the uranium production complex under Contract No. At-30-1-GEN-253 (Snapp, 1951, pdf 

p. 85). In 1948, Vitro processed 60 diverse lots of scrap and produced 23 lots with an overall 

recovery rate of 98.7%. 

Figure 5-1 provides examples of the material flow to and from various AEC sites. 

Source: Snapp, 1951, pdf p. 85 

Figure 5-1: Uranium Production Flow Diagram 
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On November 1, 1953, the AEC and Vitro contracted (contracts AT-(30-1)-1683 and AT-(30-1)-1241) 

to process government-owned materials at the Vitro site, thus obligating Vitro to store scrap materials 

and residues from those processes. 

In 1955, the AEC issued Vitro a series of source material licenses to import milling by-product 

residue material containing U3O8 from Canada (Zugschwerdt, 1981, pdf p. 10). Three shipments of 

these “Port Hope Wastes” were imported, with the first two for testing and the third for the fulfillment 

of AEC contract No. AT(49-6)-1158, which called for Vitro to extract the U3O8 from the material and 

sell it to the AEC. This contract was terminated in 1959. While under this contract, Vitro produced 

and sold 820 pounds of uranium in 1957; 54,951 pounds of uranium in 1958; and 144 pounds of 

uranium in 1959 (DOE, post-1962). 

In 1956, the AEC and Vitro planned the removal of the waste piles (some 10,000 "running tons") to 

the Blairsville, Pennsylvania disposal site (Zugschwerdt, 1981, pdf pp. 10-13). This was clearly a 

major loading operation. Vitro was to erect a wooden loading ramp (if necessary), construct 

temporary roads into the storage areas (i.e., to the waste piles), retrieve the materials from the waste 

piles, transport the wastes to the onsite rail spur, load the wastes into gondola cars, and weigh and 

transfer the wastes to the Pennsylvania railroad. Vitro was to supervise the entire operation in 

accordance with AEC instructions (Zugschwerdt, 1981, pdf pp. 10-13). 

Research 

In addition to the processing and recovery efforts that occurred throughout the years, there were 

personnel who worked in laboratory facilities and were involved with process control, research, 

development, and accountability. Vitro personnel performed various research and laboratory 

operations to find processes suitable for uranium recovery from the various scrap feed forms received 

at the site. They also worked to adapt extraction and recovery processes developed at other facilities. 

Before processing activities began, preliminary sampling and analysis determined the treatment or 

processing that would be used before the materials were introduced into the final refining stage (Vitro, 

1952). The pre-processing steps could have included burning, screening, grinding, and handpicking 

(Vitro, 1952), all of which had to be performed at the laboratory and pilot level first. 

At the end of December 1949, Vitro began performing assays of Mallinckrodt Chemical Works 

material lots under contract with the AEC. Vitro personnel performed research studies into methods 

for refining Mallinckrodt Chemical Works materials (C-Scrap and C-Liner), and worked on the 

development of a process for recovery of uranium from the Tonawanda wastes and the St. Louis 

wastes. During the course of the program, Vitro investigated twelve different wastes (Zugschwerdt, 

1981). 

Waste Piles 

The waste residues were all stored in bulk (i.e., undrummed) in the open without protection from the 

elements (Dowling, 1956). Vitro estimated that about five acres were being used for the storage of 

carb cake residues (Powell, 1955), while AEC stated that about 10 acres were being used for storage 

of all the waste piles (Wolf, 1948), apparently referring to the size of the plots of land the piles were 

on, and not to the sum of the areas of ground covered by the piles. The waste piles were surveyed by 

AEC on July 6, 1953 (Harris, 1953; Neumann, 1955). The results of this survey showed 

approximately 3,300 tons of the material were below the AEC-NYOO established disposal criterion of 
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0.2 mr/hr. NIOSH has not determined how much material, if any, was added to the residue piles after 

this survey, but the amount could have been considerable since Vitro was processing material from 

Hanford, Mallinckrodt, and Port Hope after July 1953. While the large older piles or parts of piles 

were likely mostly below the disposal criterion level, the newer material might not have been, as was 

suggested by one source (Harris, 1953). 

Table 5-1 provides a summary of Vitro milestones regarding processing, research, and the waste piles. 

Table 5-1: Summary of Vitro Manufacturing (Canonsburg) Milestones 

Table 5-1 spans two pages. 

Date Activity SRDB 

Ref ID 

1911-1922 The facility was run by Standard Chemical Co. to extract radium from carnotite ores 

(commercial). 16418 

1922 The facility was bought by Vitro Manufacturing Co. 16418 

1930-1942 Radium and uranium salts were extracted from pitchblende ores (commercial). 16418 

1942-1957 Under contract to the AEC, there were ongoing operations to recover uranium from 

residues and scraps. 

16418 

16071 

Prior to April 

1949 

Residues from any high-grade Belgian Congo ores refined at Vitro were returned to 

African Metals Corp. and were not stored in the U.S. Lower-grade residues were stored at 

Lake Ontario Ordnance Works. 

61040 

1956-1957 AEC approved the disposal of 11,610 tons of low-content uranium tailings at 

Pennsylvania Railroad Co. (Blairsville, Pennsylvania) industrial dump. 79085 

05/07/1956 All recovered product and plant clean-up materials had been shipped to National Lead of 

Ohio by this time. 79021 

1957 The primary contract with AEC (AT-(30-1)-1683) ended. 16418 

Jan. 1957 The removal of low-content uranium tailing residues was completed. 79021 

May 1959 The contract with AEC (AT(49-6)-1158) for the processing of the Port Hope residues was, 

by mutual agreement, terminated before all residues were processed. 78537 

1957-1966 The Vitro site and contamination were controlled under an AEC source material license. 

(License was terminated on Feb. 14, 1966.) 16418 

Jun 1960 Documentation states that Vitro personnel were no longer onsite after May 1960, but 

tailings were still present. 79085 

Dec. 1962 The initial license-release inspection and survey of the site began. 78537 

12/31/1962 The site was sold to private investors under the agreement that the piles of uraniumbearing residues stored on the premises were to remain the property of Vitro. 79085 

05/16/1963 

The State Division of Sanitary Engineering suggested that Vitro withdraw their request for 

removal of piles to Blairsville, Pennsylvania because they had received information that 

the Pennsylvania Railroad Co. would not accept the waste material for disposal at the 

dump site. 

79805 

07/24/1963 Vitro hired Allied-Crossroads Nuclear Corp. to survey the site. 79805 

08/14/1963 AEC approved an interim solution for "storage and decontamination" at the site. 79805 

10/14/1963 The new owners gave permission to perform "storage and decommission" activities. 79805 

11/07/1963 The state approved a "storage and decontamination" interim solution. 79805 

11/18/1963 Allied-Crossroads Nuclear Corp. began to implement the interim solution. 79805 

Aug. 1965 Allied-Crossroads Nuclear Corp. began remediation under contract to Vitro. 78537 

Nov. 1965 AEC conducted the final release inspection and survey. 78537 

Feb. 1966 AEC terminated the license and released the site. 78537 

1967 Canon Development Co. bought the property and leased it to tenant companies for light 

industrial use. 16418 
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5.2 Radiological Exposure Sources from Vitro Manufacturing Operations 

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

Vitro Manufacturing class under evaluation. 

5.2.1 Internal Radiological Exposure Sources from Vitro Manufacturing 

Sources of internal exposure included potential intakes of uranium and uranium decay chain 

radionuclides. Operations involved processing uranium ores to separate and concentrate the uranium 

into primarily U3O8 oxide, performing chemical sampling of materials and products, and storing and 

removing ore residues. These processing activities involved uranium and decay chain radionuclides 

being chemically separated from each other and re-concentrated so that they were frequently not in 

equilibrium (the degree of disequilibrium is not identifiable from site records). 

5.2.1.1 Natural Uranium

The principal source of internal exposure to natural uranium at Vitro Manufacturing was from the 

inhalation of dust and/or fumes generated during the processing of uranium residues and during the 

storage of ore and metal residues. Vitro Manufacturing employees were exposed to wastes and 

residues from processed scrap and uranium-bearing residues that had been received during the 

operations period (Strod, Jan1949, pdf p. 30). During the operations period, Vitro received uranium 

materials from Department of Energy (DOE) sites including, but not limited to, Hanford, 

Mallinckrodt, Massachusetts Institute of Technology, Middlesex, Tyson Valley Powder Farm, Y-12, 

and Oak Ridge National Laboratory. Some of the waste residues were removed from the Vitro site 

starting in 1956, but some residues remained through December 31, 1959, and were handled by Vitro 

Manufacturing workers (Inspection Responses, 1963). During operations at Vitro, uranium ores and 

wastes that were loaded and unloaded on railcars were weighed, sampled, agglomerated, crushed, and 

chemically processed. Each of these activities potentially generated airborne dust that could have 

been inhaled or ingested. Additional wastes that resulted from processing ore residues were also 

handled and stored by Vitro workers. Thus, workers were potentially exposed to airborne dust from 

re-suspension of uranium contamination and from direct contact with bulk materials. NIOSH does not 

have enough information to accurately quantify the volume of natural uranium at Vitro. 

5.2.1.2 Uranium Progeny

Since Vitro Manufacturing handled and processed uranium ore materials and residues, company 

workers were also potentially exposed to uranium progeny, which included thorium-230, thorium232, thorium-238, radium-226, protactinium-231, actinium-227, and radon daughters. African ores 

containing significant radium concentrations were also processed at Vitro Manufacturing Canonsburg 

(NIOSH, 2008). NIOSH does not have enough information to quantify the uranium progeny.

5.2.2 External Radiological Exposure Sources from Vitro Manufacturing 

Based on a review of the documented activities and potential exposures to source materials, NIOSH 

believes there was the potential for occupational radiological exposures to photons and beta particles 

from radionuclides in the uranium decay chain at Vitro. There are no indications that Vitro personnel 

had any potential for significant exposure to neutrons. 
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5.2.2.1 Photon

Photons from uranium are primarily from the thorium-234 daughter of uranium-238 and are in the 

energy range of 30-250 KeV (ORAUT-OTIB-0004). There are higher-energy photons, up to 1.00 

MeV, from another uranium-238 daughter, protactinium-234m, but the abundance of these photons is 

less than 1% (Rad Handbook, 1970). 

5.2.2.2 Beta

The majority of the beta exposures at Vitro Manufacturing would have resulted from exposure to 

uranium and its decay products. For processed natural uranium, the dominant beta radiation was 

likely due to uranium-238 decay products. In the uranium-series decay scheme, beginning with 

uranium-238, the short-lived isotope protactinium-234 emits the most energetic beta particle (2.28 

MeV). It is this beta particle that accounts for the shallow-dose hazard associated with handling 

uranium scrap and uranium residues. 

5.2.2.3 Neutron

Neutrons result from alpha-neutron reactions where the reactant is fluorine (which occurs during the 

production of UF4 and UF6) or oxygen that is present in uranium oxides. No indication of the use of 

fluorine as a reactant at Vitro was expected, nor has been discovered. While there is a possibility of 

neutrons resulting from spontaneous fission by uranium, NIOSH believes there would not be 

significant neutron exposures at the site. When necessary, NIOSH utilizes ORAUT-OTIB-0024, 

which provides information normally associated with the expected neutron dose rates from various 

forms of uranium compounds. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

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

monitoring data for the Vitro Manufacturing facility. Although all of these results occur outside the 

evaluated period, NIOSH believes it is pertinent to show the data that are available. 

6.1 Available Vitro Manufacturing Internal Monitoring Data 

NIOSH has not obtained bioassay data or air monitoring data collected during the period under 

evaluation, January 1, 1958 through December 31, 1959. NIOSH has obtained bioassay urinalysis 

results for the period between 1950 and 1954 (AEC, Feb-Jun 1950; AEC, 1949-1958; AEC, 1950-

1954; AEC, Jun-Nov 1950; AEC, 1950-1951). These samples were analyzed for uranium by 

fluorimetry, which yielded the total amount of uranium (by mass) in urine. Some records could not be 

correlated to individuals or specific time periods due to illegibility. 

NIOSH has not obtained air monitoring results collected during the period under evaluation. The air 

monitoring results (daily weighted area and breathing zone air sampling) that NIOSH has obtained 

were for monitoring conducted at approximately semiannual intervals for 1949 through 1953 

(Unknown, 1952; AEC, 1949-1952; AEC, 1949-1958; Klevin, 1949a; Klevin, 1951a; Klevin, 1952a; 
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Klevin, 1952b; Klevin, 1953; AEC, 1953; Vitro, 1951; Klevin, 1949b; Vitro, unknown date; Vitro, 

1953a; Klevin, 1951b). 

NIOSH has not obtained radon data for the period under evaluation, but NIOSH has obtained 

documentation of radon monitoring performed by Oak Ridge National Laboratory in 1977 (Haywood, 

1977) and in 1978 and 1979 by the Environmental Measurements Laboratory (Radon Results, 1979-

1980). 

6.2 Available Vitro Manufacturing External Monitoring Data 

There are no external whole-body dosimetry data available for the Vitro period under evaluation, 

January 1, 1958 through December 31, 1959. Comprehensive whole-body dosimetry records end for 

Vitro workers in 1954. This date appears to coincide with the discontinuation of the film reading 

service provided to the AWE sites by the Health and Safety Laboratory. However, there is 

correspondence between the AEC and Vitro regarding private firms competent to handle film badge 

supply and service. NIOSH has located a December 1955 National Lead of Ohio personnel 

monitoring report for Vitro’s Canonsburg site with results for November 10-24, 1955. 

NIOSH has not obtained radiation survey data for the period under evaluation, January 1, 1958 

through December 31, 1959. The radiation survey data that NIOSH has obtained were for some Vitro 

processes measured in 1950 (Piccot, 1950; Klevin, 1951b) and 1953 (Peterson, 1953; Vitro, 1953b). 

NIOSH has obtained radiological survey data of equipment measured in 1954 and 1955, during and 

after decontamination (Klevin, 1955). Additionally, NIOSH has access to various survey results 

performed after the facility closed in 1960, including the 1965 “close-out” survey performed by 

Allied-Crossroads following the removal of the waste piles. 

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 
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DCAS’s SEC Petition Evaluation Internal Procedures which are available at 

http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation Report examine: 

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00177 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Vitro Manufacturing 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 

NIOSH has been unable to locate internal monitoring data for Vitro Manufacturing workers for the 

period of this evaluation, January 1, 1958 through December 31, 1959. Neither bioassay monitoring 

results nor contamination survey results are available for Vitro during the evaluated period; therefore, 

an internal data sufficiency and pedigree evaluation is not possible for this data type. 

7.1.2 External Monitoring Data Pedigree Review 

NIOSH has been unable to locate personnel external monitoring records for Vitro Manufacturing 

workers for the period of this evaluation, January 1, 1958 through December 31, 1959. Neither film 

badge results nor area monitoring results are available for Vitro during the evaluated period; therefore, 

an external data sufficiency and pedigree evaluation is not possible for this data type. 

7.2 Evaluation of Bounding Internal Radiation Doses at Vitro Manufacturing 

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

contamination due to uranium and uranium progeny. 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 Internal Doses 

During the period under evaluation, many work activities were very similar to those in the previouslydesignated AWE operational years for which a class has already been included in the SEC (e.g., 

recovery of uranium from ore residues, sampling, and analysis of the source materials and the 

product) (DHHS, 2009). Other non-routine activities just as likely to generate airborne radioactivity 
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were ongoing from 1958 through 1959, such as removal of equipment from process areas and 

teardown operations. Vitro workers were potentially exposed to uranium contamination, re-suspended 

uranium dust, and uranium progeny. 

NIOSH has found no indications that bioassay measurements were collected for the period under 

evaluation. Air monitoring and contamination survey data are also not available for the 1958 through 

1959 period. While NIOSH has obtained area air sampling results for the time period from 1949 

through 1953, those results were found to be inadequate to bound internal intakes from uranium 

progeny through the end of 1957 (NIOSH, 2008) and are likewise found to be inadequate to bound 

internal intakes from uranium progeny during the period currently under evaluation, January 1, 1958 

through December 31, 1959. Those samples were analyzed for gross alpha activity only and the data 

are highly variable with insufficient information available to allow NIOSH to apply the general area 

air concentrations to specific individual breathing zones. 

Measurements of radon exposure in working levels were made in 1977 by Oak Ridge National 

Laboratory (Haywood, 1977) and in 1978 and 1979 by the Environmental Measurements Laboratory 

(Radon Results, 1979-1980). While an analysis of these radon data could be used to derive a 

concentration of radon, NIOSH cannot assume that some ore materials were not removed from Vitro 

Manufacturing during the period under review or after December 31, 1959, and therefore cannot 

verify that radon concentrations could not have been higher during the period under review. 

NIOSH has not identified sufficient documentation to define and quantify the total internal source 

term for Vitro Manufacturing during the period under evaluation, January 1, 1958 through December 

31, 1959. Without additional documentation, NIOSH cannot make assumptions about the relative 

amounts of materials that would have been encountered at the site during the evaluated period. 

Therefore, there is insufficient source term information available to NIOSH to bound internal 

exposures for the period from January 1, 1958 through December 31, 1959. 

7.2.2 Methods for Bounding Internal Dose at Vitro Manufacturing 

NIOSH has determined that it lacks sufficient bioassay, workplace monitoring, and source term data 

needed to bound internal doses that Vitro workers potentially received from natural uranium and 

uranium progeny. Therefore, NIOSH has not identified a method for bounding internal doses at Vitro 

Manufacturing for the period from January 1, 1958 through December 31, 1959.

7.2.3 Internal Dose Reconstruction Feasibility Conclusion 

NIOSH has established that it does not have access to sufficient information to bound internal doses 

that Vitro Manufacturing workers potentially received during the period from January 1, 1958 through 

December 31, 1959. 

Although NIOSH found that it is not possible to completely reconstruct internal radiation doses for the 

period from January 1, 1958 through December 31, 1959, NIOSH intends to use any internal 

monitoring data that may become available for an individual claim (and that can be interpreted using 

existing NIOSH dose reconstruction processes or procedures). Dose reconstructions for individuals 

employed at Vitro Manufacturing (Canonsburg) during the period from January 1, 1958 through 

December 31, 1959, but who do not qualify for inclusion in the SEC, may be performed using these 

data as appropriate. 
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7.3 Evaluation of Bounding External Radiation Doses at Vitro Manufacturing 

The principal sources of external radiation doses for members of the evaluated class were uranium and 

uranium progeny found in the uranium materials and wastes located on the property. Domestic ores, 

African pitchblende, recoverable scrap materials, and Canadian residues were processed onsite. 

Radium and its progeny would produce gamma radiation. Contaminated facilities and equipment 

would pose an external exposure hazard inside the buildings, while exposure to the waste storage piles 

and the contaminated soil would contribute to direct radiation exposure outside the buildings. 

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

and the feasibility of external dose reconstruction. 

7.3.1 Evaluation of Bounding External Doses 

While the supporting documentation available to NIOSH states that external monitoring was 

performed for a number of operational years at Vitro, NIOSH has been unable to locate any individual 

external monitoring data for the period evaluated in this report, January 1, 1958 through December 31, 

1959. NIOSH has access to a limited amount of general process and radiological source term 

information associated with uranium recovery work, but no specific information regarding the work at 

Vitro during the period under evaluation. NIOSH has been unable to locate any records of 

radiological surveys done following building cleanup at Vitro or of radiological surveys done 

following the removal of any waste pile material. 

7.3.2 Vitro Manufacturing Occupational X-Ray Examinations 

Occupational medical procedures are generally not noted in the Vitro Manufacturing records; 

however, documentation indicates that no routine X-ray examinations were performed before 1950, 

and that a routine program for chest X-rays had been established by May 1950 (Medical 

Correspondence, 1948-1953). NIOSH has found no indication that medical X-ray procedures were 

performed off the Vitro Manufacturing site. Without evidence of off-site medical X-ray exams, 

NIOSH assumes medical X-ray examinations were performed on the site and NIOSH will assign 

bounding medical doses in accordance with ORAUT-OTIB-0079 and ORAUT-OTIB-0006. NIOSH 

assumes that workers received an annual PA chest X-ray for each year of AWE employment 

beginning in 1950. NIOSH therefore concludes that it is likely feasible to reconstruct occupational 

medical dose for Vitro Manufacturing workers with sufficient accuracy. 

7.3.3 Methods for Bounding External Dose at Vitro Manufacturing 

NIOSH has determined that it lacks sufficient personnel monitoring data, area monitoring data, or 

source term data needed to bound external doses that Vitro workers potentially received from natural 

uranium and uranium progeny. Therefore, NIOSH has not identified a method for bounding external 

doses at Vitro Manufacturing for the period from January 1, 1958 through December 31, 1959.

7.3.4 External Dose Reconstruction Feasibility Conclusion 

NIOSH has established that it does not have access to sufficient information to bound external doses 

that Vitro workers potentially received during the period from January 1, 1958 through December 31, 

1959. 
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Although NIOSH found that it is not possible to completely reconstruct external radiation doses for 

the period from January 1, 1958 through December 31, 1959, NIOSH intends to use any external 

monitoring data that may become available for an individual claim (and that can be interpreted using 

existing NIOSH dose reconstruction processes or procedures). Dose reconstructions for individuals 

employed at Vitro Manufacturing (Canonsburg) during the period from January 1, 1958 through 

December 31, 1959, but who do not qualify for inclusion in the SEC, may be performed using these 

data as appropriate. 

7.4 Evaluation of Petition Basis for SEC-00177 

The following subsections evaluate the assertions made on behalf of petition SEC-00177 for Vitro 

Manufacturing. 

7.4.1 Monitoring Inadequacies 

Assertion: The SEC-00177 petitioner stated that radiation exposures and therefore radiation doses 

potentially incurred by members of the proposed class that relate to this petition were not monitored, 

either through personal or area monitoring.

Response: Personal monitoring and/or area monitoring results are not always absolutely necessary to 

develop an exposure model for a given facility. However, if these monitoring data are not available 

NIOSH must have access to source term information and detailed process information in order to 

develop a sufficiently accurate exposure model. NIOSH has determined that, to date, it does not have 

adequate internal or external monitoring data for members of the proposed class, nor does it have 

enough source term or process information applicable to the class to develop a sufficiently accurate 

model for the Vitro Manufacturing facility during the evaluated time period from January 1, 1958 

through December 31, 1959. 

7.4.2 Working Conditions After 1957 

 

Assertion: The SEC-00177 petitioner stated that the same working conditions that resulted in the 

inability to reconstruct doses for the AWE operations period existed after December 31, 1957. 

Response: NIOSH conducted interviews with seven contemporaneous former workers in an attempt to 

understand the working conditions after 1957 at the Vitro Manufacturing site in Canonsburg, 

Pennsylvania. While most were unsure of specific contractual details regarding the purpose and scope 

of the work conducted after 1957, the interviews did present a consistent picture of unchanging 

operations into the period being evaluated. 
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7.5 Other Potential SEC Issues Relevant to the Petition Identified During the 

Evaluation 

During the feasibility evaluation for SEC-00177, an issue was identified that needed further analysis 

and resolution. The issue and its current status are: 

• ISSUE: The SEC class associated with AWE operations from August 13, 1942 through December 

31, 1957 (DHHS, 2009) was based on the lack of monitoring data for non-uranium radionuclides 

in disequilibrium with uranium. In order to ascertain the disequilibrium conditions at Vitro, 

NIOSH attempted to determine the disequilibrium ratio associated with other sites (Tyson Valley 

Powder Farm, Hanford, Mallinckrodt Chemical Works, MIT Middlesex, Y-12, and Oak Ridge 

National Laboratory) that sent scrap and uranium-bearing residues to Vitro Manufacturing. 

RESPONSE: NIOSH researched all disequilibrium ratio information available for the sites known 

to have sent materials to Vitro for uranium recovery. While information was available for some of 

the sites, there is not a complete inventory of the materials sent to Vitro. Available data include 

examples of material types and volumes from memos and other contemporary documents. 

NIOSH was unable to locate enough information to attempt a meaningful derivation of assumed 

equilibrium ratios at Vitro Manufacturing based on the radionuclide ratios being introduced to the 

site. 

7.6 Summary of Feasibility Findings for Petition SEC-00177 

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

Manufacturing from January 1, 1958 through December 31, 1959. NIOSH found that the available 

monitoring records, process descriptions, and source term data available are not sufficient to complete 

dose reconstructions for the evaluated class of employees. 

Table 7-1 summarizes the results of the feasibility findings at Vitro Manufacturing for each exposure 

source during the time period January 1958 through April 1960. 

Table 7-1: Summary of Feasibility Findings for SEC-00177 

January 1, 1958 through December 31, 1959 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal X 

 - Natural Uranium X 

 - Uranium Progeny X 

External X 

 - Gamma X 

 - Beta X

 - Neutron N/A N/A 

 - Occupational Medical X-ray X 

As of January 24, 2011, a total of 14 claims have been submitted to NIOSH for individuals who 

worked at Vitro Manufacturing and who worked during the period evaluated in this report. Dose 
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reconstructions have been completed for 9 individuals, 5 claims were pulled because of the SEC 

designation associated with SEC-00134 (100%). 

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

Vitro Manufacturing (Canonsburg) during the period from January 1, 1958 through December 31, 

1959, but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 

8.0 Evaluation of Health Endangerment for Petition SEC-00177 

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

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

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

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

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

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

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

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

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

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

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

employees in the SEC. 

NIOSH lacks personnel monitoring data, air monitoring information, sufficient process information, 

and radiological source term information for the period to allow a sufficiently accurate estimate of the 

potential exposures to uranium products and uranium progeny at the Vitro Manufacturing site. The 

data that are available to NIOSH pre-date the evaluation period by multiple years, making any attempt 

to model potential internal exposures using those available data highly uncertain. Likewise, the postoperations data were collected multiple years after the cessation of evaluated operations and would not 

likely be representative of the period of concern. Therefore, NIOSH’s evaluation determined that it is 

not 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, the resulting 

NIOSH-proposed SEC class must include a minimum required employment period as a basis for 

specifying that health was endangered. 

9.0 Class Conclusion for Petition SEC-00177 

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class to be added to the SEC includes all Atomic Weapons Employer employees who 

worked at Vitro Manufacturing in Canonsburg, Pennsylvania, from January 1, 1958 through 
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December 31, 1959, for a number of work days aggregating at least 250 work days, occurring either 

solely under this employment or in combination with work days within the parameters established for 

one or more other classes of employees in the Special Exposure Cohort. NIOSH is reserving its 

feasibility evaluation for the Vitro Manufacturing residual radiation period beginning in January 1960. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00177. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation. 
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10.0 References 

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

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

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

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

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

19392 

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

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

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

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

Program Act of 2000, as amended 

AEC, 1949-1952, Vitro Air Sampling Results; U.S. Atomic Energy Commission (AEC); various dates 

from 1949 through 1952; SRDB Ref ID: 10370 

AEC, 1949-1958, Vitro Air, Dust, and Bioassay Data Results; U.S. Atomic Energy Commission 

(AEC); various dates throughout 1949-1958; SRDB Ref ID: 10375 

AEC, Feb-Jun 1950, Vitro Urine Sample Results; U.S. Atomic Energy Commission (AEC); various 

dates between February and June 1950; SRDB Ref ID: 10345 

AEC, Jun-Nov 1950, Vitro Breath Sample Results; U.S. Atomic Energy Commission (AEC); June 29, 

1950 and November 26, 1950; SRDB Ref ID: 10453 

AEC, 1950-1951, Vitro Urine Sample Results; U.S. Atomic Energy Commission (AEC); various dates 

throughout 1950-1951; SRDB Ref ID: 10454 

AEC, 1950-1954, Vitro Urine Sample Results; U.S. Atomic Energy Commission (AEC); various dates 

throughout 1950-1954; SRDB Ref ID: 10452 

AEC, 1953, Vitro Manufacturing Company Occupational Exposure to Airborne Contaminants,

Atomic Energy Commission (AEC), Industrial Hygiene Branch, Health and Safety Division; October 

29, 1953; SRDB Ref ID: 10419 

Affidavit, 2002, Affidavit from Laboratory Technician; July 2, 2002; OSA Ref ID: 112176, pdf p. 10

Affidavit, 2010, Affidavit from Laboratory Technician; July 6, 2010; OSA Ref ID: 112176, pdf p. 1 

DHHS, 2009, HHS Designation of Additional Members of the Special Exposure Cohort under the 

Energy Employees Occupational Illness Compensation Program Act for Vitro Manufacturing 

Canonsburg, Pennsylvania; Department of Health and Human Services (DHHS); January 16, 2009; 

SRDB Ref ID: 90591 
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DOE, post-1962, Receipts of U3O8 from Phosphate and Other Miscellaneous Domestic Sources, 

spreadsheet-type document showing various sites and shipments of materials for fiscal years 1953 

through 1962; Department of Energy (DOE); unspecified date, but created sometime after 1962; 

SRDB Ref ID: 40645 

DOL, 2011a, Evidence of Years of Coverage for Vitro Manufacturing Require Revision, 

correspondence to Patricia R. Worthington, Department of Energy; Rachel P. Leiton, Department of 

Labor (DOL), Director of the Division of Energy Employees Occupational Illness Compensation; 

January 19, 2011; SRDB Ref ID: 91671 

DOL, 2011b, Covered Time Period for Vitro Manufacturing in Canonsburg to be Revised to Cover 

1942 - 1959, correspondence to Stuart Hinnefeld, Division of Compensation Analysis and Support; 

Rachel P. Leiton, Department of Labor (DOL), Director of the Division of Energy Employees 

Occupational Illness Compensation; January 19, 2011; SRDB Ref ID: 91672 

Dowling, 1956, Waste Residues Located at Vitro Rare Metals Company in Canonsburg, 

Pennsylvania, correspondence to F. H. Belcher with attachment; F. R. Dowling; July 23, 1956; SRDB 

Ref ID: 10288, pdf pp. 732-734 

Form B, 2010, Petition Form B for SEC-00177 with Attached Site Summary Documents; received on 

July 14, 2010; OSA Ref ID: 112176, pdf pp. 2-9, 11-13 

Hammer, 1966, Survey of Buildings #14 and #16 Vitro-Canonsburg, PA 1966, D. Hammer; March 21, 

1966; SRDB Ref ID: 16414 

Harris, 1953, Decontamination at the Vitro Manufacturing Company, correspondence to A. W. 

Neumann; W. B. Harris; July 15, 1953; SRDB Ref ID: 78990 

Haywood, 1977, Information Supplementary to Preliminary Report of Radon and Radon Daughter 

Measurements at the Former Vitro Rare Metals Plant, correspondence to H. W. Dickson; F. F. 

Haywood; May 11, 1977; SRDB Ref ID: 16419 

Inspection Responses, 1963, 1963 Inspection Non-Compliance Issues, select pages from a document; 

unspecified author; unspecified date, post-November 1963; SRDB Ref ID: 79085 

Klevin, 1949a, Vitro Manufacturing Co. Occupational Exposure to Radioactive Dust September 30 to 

October 1, 1949, P. B. Klevin; November 18, 1949; SRDB Ref ID: 10390 

Klevin, 1949b, Vitro Manufacturing Company Occupational Exposure to Radioactive Dust September 

30 to October 2, 1949, P. B. Klevin; November 16, 1949; SRDB Ref ID: 10428 

Klevin, 1951a, Vitro Manufacturing Co. Occupational Exposure to Radioactive Dust April 3 to 5, 

1951, P. B. Klevin; July 2, 1951; SRDB Ref ID: 10392 

Klevin, 1951b, Air Sampling and HP Info, P. B. Klevin; January 11, 1951; SRDB Ref ID: 11468, pdf 

pp. 1-5 
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Klevin, 1952a, Vitro Manufacturing Company Occupational Exposure to Radioactive Dust February 

5-7, 1952, P. B. Klevin; July 1, 1952; SRDB Ref ID: 10395 

Klevin, 1952b, Vitro Manufacturing Co. Occupational Exposure to Radioactive Dust July 15-16, 

1952, P. B. Klevin, M. S. Weinstein, P. Loysen; September 25, 1952; SRDB Ref ID: 10404 

Klevin, 1953, Vitro Manufacturing Co. Occupational Exposure to Radioactive Dust February 3-5 and 

19, 1953, P. B Klevin and M.S. Weinstein; July 6, 1953; SRDB Ref ID: 10405 

Klevin, 1955, Vitro Manufacturing Documents (1953-1955), P. B. Klevin; August 10, 1955; SRDB 

Ref ID: 10336, pdf. pp 1-5 and 13-24 

Medical Correspondence, 1948-1953, Various Correspondence Regarding Medical X-Rays and 

Physicals at Vitro Manufacturing; various authors; various dates between 1948 and 1953; SRDB Ref 

ID: 10376 

Neumann, 1955, Process Residues Located at Vitro Rare Metals Company, Canonsburg, PA, 

correspondence to F. R. Dowling; A. W. Neumann; March 15, 1955; SRDB Ref ID: 79001 

NIOSH, 2008, SEC Petition Evaluation Report for Petition SEC-00134, Vitro Manufacturing 

(Canonsburg); National Institute for Occupational Safety and Health (NIOSH); December 9, 2008; 

SRDB Ref ID: 89402 

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

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

2004; SRDB Ref ID: 32022 

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

Employer Facilities, Rev. 03 PC-2; ORAU Team Dose Reconstruction Project for NIOSH; December 

6, 2006; SRDB Ref ID: 36191 

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

Procedures, Rev.03 PC-1; ORAU Team Dose Reconstruction Project for NIOSH; December 21, 

2005; SRDB Ref ID: 20220 

ORAUT-OTIB-0079, Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays 

Administered Off Site, Rev. 00; ORAU Team Dose Reconstruction Project for NIOSH; January 3, 

2011; SRDB Ref ID: 89563

Personal Communication, 2010a, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; October 19, 2010, 9:30 a.m.; SRDB Ref ID: 90804 

Personal Communication, 2010b, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; October 25, 2010, 10:00 a.m.; SRDB Ref ID: 90806 

Personal Communication, 2010c, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; October 25, 2010, 11:00 a.m.; SRDB Ref ID: 90808 
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Personal Communication, 2010d, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; October 26, 2010, 3:00 p.m.; SRDB Ref ID: 90810 

Personal Communication, 2010e, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; October 27, 2010, 10:00 a.m.; SRDB Ref ID: 90812 

Personal Communication, 2010f, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; November 2, 2010, 9:50 a.m.; SRDB Ref ID: 90814 

Personal Communication, 2010g, Personal Communication with Former Vitro Employee; Telephone 

Interview by ORAU Team; November 2, 2010, 1:00 p.m.; SRDB Ref ID: 90813 

Peterson, 1953, Health Physics Reports and Related Documents (1951-1953), W. R. Peterson, A.M. 

Johnson, A. Messina, W. A. Bain, W. B. Harris; February 27, 1953; SRDB Ref ID: 10333 

Petition Supplement, 2010, Supplemental Information for SEC-00177 Petition; August 14, 2010; OSA 

Ref ID: 112455 

Piccot, 1950, Radiologic Survey - Vitro Manufacturing Company, A. R. Piccot; January 17, 1950; 

SRDB Ref ID: 11475 

Powell, 1955, Response to Article 1, Paragraph 1 of Contract AT(30-1)-1683, correspondence to F. R. 

Dowling of the AEC; R. T. Powell; December 13, 1955; SRDB Ref ID: 10288, pdf pp. 382-383 

Rad Handbook, 1970, Radiological Health Handbook, Revised Edition; compiled and edited by the 

Bureau of Radiological Health and the Training Institute Environmental Control Administration; 

January 1970; SRDB Ref ID: 75017 

Radon Results, 1979-1980, Vitro Radon Reports and Monitoring Results; Various dates ranging from 

September 25, 1979 through November 7, 1980; SRDB Ref ID: 42181 

Snapp, 1951, Atomic Energy Commission-The Production of Uranium Feed Materials; Roy B. Snapp; 

May 22, 1951; SRDB Ref ID: 4125 

Strod, Jan1949, Report on Extraction of Uranium from Slags and Ore; A. J. Strod, H. Fleck, and G. 

Rennich; January 1949; SRDB Ref ID: 10290, pp. 29-46 

Unknown, 1952, Air Dust Samples Collected at Vitro; various dates from February 5, 1952 through 

July 19, 1952; SRDB Ref ID: 10336, pdf pp. 6-13 

Vitro, unknown date, Vitro Manufacturing Company Occupational Exposure to Radioactive Dust, 

Vitro Manufacturing; unknown date; SRDB Ref ID: 10430 

Vitro, 1951, Air Dust Medical Division Forms (1951), Vitro Manufacturing Company; July 24, 1951; 

SRDB Ref ID: 10426 

Vitro, 1952, A Comprehensive Review of the Technique and Economics of Uranium Extraction from 

Waste Materials; Vitro Manufacturing; February 29, 1952; SRDB Ref ID: 10288, pdf pp. 735-791 
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Vitro, 1953a, Dust Samples - Vitro, Vitro Manufacturing Company; September 14, 1953; SRDB Ref 

ID: 10448 

Vitro, 1953b, Smear Samples, Vitro Manufacturing; September 14, 1953; SRDB Ref ID: 10450 

Whitman, 1978, Decontamination and Decommissioning: Review of Manhattan District History 

(Classified Documents)-MED; Arthur J. Whitman; February 1, 1978; SRDB Ref ID: 9769 

Wolf, 1948, Health and Safety Review, correspondence to H. Marshall Chadwoll; B. S. Wolf; October 

27, 1948; SRDB Ref ID: 78195 

Zugschwerdt, 1981, Narrative Summary of Facts Relevant to Liability of Former Operators or Site 

Owners for Cleanup Expenses for UMTRCA Remedial Action Site at Canonsburg, PA (Taken from 

DOE and NRC Documents); David W. Zugschwerdt; June 18, 1981; SRDB Ref ID: 78537, pdf pp. 3-

28 
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SEC-00177 02-04-2011 Vitro 

Attachment One: Data Capture Synopsis 

Table A1-1: Summary of Holdings in the SRDB for Vitro Manufacturing (Canonsburg) 

Data Capture Information Data Capture Description 

Primary Site/Company Name: Vitro Manufacturing 

Other Site Names: Vitro Rare Metals Co. 

Successor History:

GEC merged with British Aerospace to form BAE Systems in 1999 General Electric Company - 1998 Merged with TAS formed Tracor Systems Technologies -1993 Tracor Applied Sciences - 1993 Penn Central Corporation - 1981 Renamed to GK Technologies - 1978 General Cable Corporation - 1978 Automation Industries - 1968 Vitro Manufacturing Company 

BAE Systems, successor company, Legal Counsel confirmed that a search of records and archives had been performed and that no information relating to any Vitro site had been found. No relevant data located. 

State Contacted: PA Office Bureau of Radiation Protection (Contact: Director PA Dept. of Environmental Protection) 

No relevant data identified. 

Department of Labor/Paragon Lake Ontario Ordnance Works (LOOW) reports which identify Vitro 

residues, FUSRAP briefing material, and Tonawanda Sub-Office reports which discuss Vitro residues. 

DOE Environmental Measurements Laboratory/Health And Safety Laboratory 

Site visits, annual report, thorium sampling and storage, and symposium V on aerosols. 

DOE Germantown NYOO uranium operations flow chart, monthly field report, radiological 

surveys, air sampling and radon in breath exposure data, biological effects 

of radioactivity near plant, reports documenting Vitro as an AEC uranium supplier, miscellaneous letters, memos and lists, and an accident report. 

DOE Hanford Scrap shipments to Vitro. No additional relevant records were identified 

during Hanford's search for Vitro Manufacturing records (Activity 31, initiated, 09/14/2010, search results forwarded to ER Team Lead 12/20/2010). 

35 of 40 
SEC-00177 02-04-2011 Vitro 

Table A1-1: Summary of Holdings in the SRDB for Vitro Manufacturing (Canonsburg) 

Data Capture Information Data Capture Description 

DOE Legacy Management - Grand Junction Office Tonawanda area Sub-Office and Niagara Frontier Atomic Weapons 

Employer reports which discuss Vitro residues and scrap, shipments of scrap to Vitro, residue and scrap processing at Vitro, site visits, dose rate 

surveys, film badge results, air sample results, contract documents, process descriptions, radiological environmental surveys, Canonsburg litigation documents, radon monitoring, Cleveland area Vitro reports, 1953 site decontamination, monthly production reports, engineering assessments, vicinity property surveys, FUSRAP documents, radon mitigation, UMTRA reports, US NRC comments and reviews of remediation plans and reports, draft environmental impact statement and comments, public and project meeting notes, contract flow charts, documentation of uranium produced for sale to Britain, and remedial action plan documents. 

DOE Legacy Management - Morgantown 1951 summary of uranium production, LOOW surveys which mention ore 

received from Vitro, and summary lists of uranium production sites. 

DOE Legacy Management - MoundView (Fernald Holdings, includes Fernald Legal Database) 

Radon monitoring plan and results, film badge correspondence, HP and operating procedures, Th-230 air samples, environmental TLD's, urinalysis results, radiological survey of the former Vitro Rare Metals Plant, NYOO health and safety field activities reports, production of uranium feed materials, project management plan for remedial action, designation of vicinity properties, and an annual report. 

DOE Oak Ridge Operations, Records Holdings Task Group Vault 

Uranium dust exposure information, 1944-1945 work reports with exposure monitoring data, and the report of a 2002 NIOSH reconnaissance. 

DOE Oak Ridge Operations, Records Holdings Task Group Vault/SC&A 

Film badge results, 1952 

DOE Savannah River Site 1962 and 1963 thorium reports which discuss thorium metal received from 

Vitro. 

[Name Redacted] via NIOSH A 1984 list of documents produced for litigation regarding Vitro. Federal Records Center - Kansas City Weekly Manhattan Engineer District reports, late 1942 and 1946. Internet - Amazon.com 1st of a Kind WMD's, ETC, a history of Vitro and Kellex. Internet - Comprehensive Epidemiologic Data Resource (CEDR) 

No relevant data identified. 

Internet - Division of Compensation Analysis and Support Department of Health and Human Services notice documenting the addition 

of a class of Vitro workers to the Special Exposure Cohort. 

Internet - DOE Hanford Declassified Document Retrieval System (DDRS) 

Trip report on uranium scrap processing at the Vitro Manufacturing Co., Canonsburg, PA. 

Internet - DOE Health Safety and Security Worker Advocacy Site 

Site description. 

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SEC-00177 02-04-2011 Vitro 

Table A1-1: Summary of Holdings in the SRDB for Vitro Manufacturing (Canonsburg) 

Data Capture Information Data Capture Description 

Internet - DOE Legacy Management Considered Sites Canonsburg disposal site fact sheet, long-term site surveillance plans, and a

Tonawanda area progress report which documents the shipment of a ball mill and dust collector to Vitro. 

Internet - DOE OpenNet 1949 NYOO monthly status and progress reports, the Manhattan District 

History, Book I, Volume 7, and Linking Legacies Appendix B. 

Internet - DOE OSTI Energy Citations A 1949 Hanford monthly report that documents the shipment of 19 tons of 

uranium oxide to Vitro, a report on uranium extraction with organic solvents, and a report on the problems of leaching uraniferous slag. 

Internet - DOE OSTI Information Bridge Monthly report, UMTRA Project water sampling plan, engineering 

feasibility analysis for in-situ stabilization of residues, proceedings of a 

decontamination conference, UMTRA annual reports to stakeholders, a risk assessment of ground water contamination, reports on the problems of leaching uraniferous slag and refining uraniferous residues. 

Internet - Google Poisoned workers and places: part 2/3, Canonsburg site descriptions and 

histories, an epidemiological study, news stories, and analysis of institutional responsibilities for the long-term management of contaminant isolation facilities. 

Internet - HP Journal No relevant data identified. Internet - Journal of Occupational and Environmental Health 

No relevant data identified. 

Internet - National Academies Press (NAP) No relevant data identified. Internet - National Archives No relevant data identified. Internet - National Nuclear Security Administration (NNSA) - Nevada Site Office 

No relevant data identified. 

Internet - NRC Agencywide Document Access and Management (ADAMS) 

Canonsburg ground water concentrations, request for NRC approval to delete institutional controls, prelicensing and annual inspections, data validation packages, proposals for erosion control and stream bank stabilization, long term surveillance plans, ground water contaminant concentrations, and a radiological release survey plan. 

Internet - NRC Agencywide Document Access and Management (ADAMS) Public Library 

A 1994 report which discusses the removal of residues, NRC comments on an erosion control plan, and notice of the issuance of a license for longterm care of the Canonsburg site. 

Internet - Washington State University (United States Transuranium and Uranium Registries) 

No relevant data identified. 

Missouri Department of Natural Resources Historical storage of radioactive material, and a final environmental impact 

statement. 

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SEC-00177 02-04-2011 Vitro 

Table A1-1: Summary of Holdings in the SRDB for Vitro Manufacturing (Canonsburg) 

Data Capture Information Data Capture Description 

National Archives and Records Administration - Atlanta Film badge results, radon breath measurements, air samples and radon data, 

gamma radiation at Vitro, Vitro contract AT(30-1)-1241 (1951), 1949 and1950 trip reports, reports and correspondence on uranium ore, receipts of scrap at Vitro, pitchblende processing, and periodic progress reports. 

National Archives and Records Administration - College Park 

1948 weekly film badge report, 1951 Kellex report which discusses recovery of uranium from process residues, 1948 memo regarding the markings on a new film badge design, flow chart of NYOO uranium operations, and a reviewer's notes from a College Park data capture. 

National Archives and Records Administration - Kansas City 

Radiation surveys, waste disposal, solid waste treatment, disposal of uranium bearing residues, radiological survey plan, close out survey, 

survey of buildings #14 and #16, environmental radiation surveys, radon monitoring data, phase II radiological survey, radiological survey of the former Vitro Rare Metals Plant, and an evaluation of radiation exposures. 

NIOSH Department of Labor letters extending the covered period to 1959. NOCTS Claim file CATI extracts with: brief job/process description for filter press 

operator, ore process, Belgium Congo material process, Canadian ore processing description, site date information, list of most hazardous positions, cubic yards of onsite uranium, newspaper clippings and site timeline, DOE radiological survey memo, newspaper clipping with amount of contaminated waste buried onsite, and other claimant documents to support Vitro work post-1957. 

ORAU Team Project spreadsheet, monitoring data, and documented communications 

with process knowledge sources. 

Unknown Air dust samples, film badge reports, medical records, monthly status and 

progress reports, NYOO Health and Safety Division monthly reports of field activities, radiological survey of the former Vitro Rare Metals Plant in 

Canonsburg, alpha smears, summary of Manhattan Project, uranium flow sheet, safety evaluations, Vitro correspondence, material transactions with other sites, NYOO Medical Division health hazards report, and urinalysis 

reports. 

Unknown/SC&A Merits of keeping dosimetry badges on site, film badge reports and 

correspondence, process and hazard descriptions. 

US Army Corps of Engineers, Buffalo District A 1950 report with limits on unaccounted losses at Vitro and other 

facilities. 

US Army Corps of Engineers, St. Louis District North County uranium residues historical synopsis, St. Louis, MO, which 

discusses the history behind Vitro residues in the St. Louis area. 

Total 

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SEC-00177 02-04-2011 Vitro 

Table A1-2: Database Searches for Vitro Manufacturing (Canonsburg) 

Database/Source Keywords 

NOTE: Database search terms employed for each of the databases listed below are available 

in the Excel file called “Data Capture Synopsis for Vitro Manufacturing Canonsburg.” 

CEDR http://cedr.lbl.gov/ COMPLETED 03/27/2008 

See note above 

DOE Hanford DDRS http://www2.hanford.gov/declass/ COMPLETED 09/24/2010 

See note above 

DOE Legacy Management Considered Sites http://csd.lm.doe.gov/ COMPLETED 10/05/2010 

See note above 

DOE OpenNet http://www.osti.gov/opennet/advancedsearch.jsp COMPLETED 01/03/2008 

See note above 

DOE Energy Citations http://www.osti.gov/energycitations/ COMPLETED 03/28/2008 

See note above 

DOE OSTI Information Bridge http://www.osti.gov/bridge/advancedsearch.jsp COMPLETED 10/04/2010 

See note above 

Google http://www.google.com COMPLETED 10/04/2010 

See note above 

HP Journal http://journals.lww.com/healthphysics/pages/default.aspx COMPLETED 10/04/2010 

See note above 

Journal of Occupational and Environmental Health http://www.ijoeh.com/index.php/ijoeh COMPLETED 10/04/2010 

See note above 

National Academies Press http://www.nap.edu/ COMPLETED 03/09/2008 

See note above 

39 of 40 
SEC-00177 02-04-2011 Vitro 

40 of 40 

Table A1-2: Database Searches for Vitro Manufacturing (Canonsburg) 

Database/Source Keywords 

National Archives http://search.archives.gov/query.html COMPLETE 01/03/2008 

See note above 

NNSA - Nevada Site Office www.nv.doe.gov/main/search.htm COMPLETED 03/14/2008 

See note above 

NRC ADAMS Public Legacy Library http://adamspublic.nrc.gov/FNOpenClient/FnLogin.aspx?Library=PL_ADAMS^PBNTAD08&Op=Logon&ReturnURL=%2fFNOpenClient%2fFnBrowsePage.aspx%3fLibrary%3dPL_ADAMS%5ePBNTAD08%26Op%3dBrowse&Error=10001 COMPLETED 10/04/2010 

See note above 

NRC ADAMS Public Library http://adamspublic.nrc.gov/FNOpenClient/FnLogin.aspx?Library=PU_ADAMS^PBNTAD01&Op=Logon&ReturnURL=%2fFNOpenClient%2fFnBrowsePage.aspx%3fLibrary%3dPU_ADAMS%5ePBNTAD01%26Op%3dBrowse&Error=10001 COMPLETED 10/04/2010 

See note above 

NRC ADAMS Reading Room http://www.nrc.gov/reading-rm/adams/webbased.html COMPLETED 09/24/2010 

See note above 

U.S. Transuranium & Uranium Registries http://www.ustur.wsu.edu/ COMPLETED 03/27/2008 

See note above