ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute of Occupational Safety and Health

Review of NIOSH Site Profile 

for 

Bethlehem Steel Plant, Lackawanna, NY 

Contract No. 200-2004-03805 

Task Order No. 1

SCA-TR-TASK1-0001 

Prepared by 

S. Cohen & Associates 

6858 Old Dominion Drive, Suite 301 

McLean, Virginia 22101 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

October 2004
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Document No. 

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S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 0 

REVIEW OF NIOSH SITE PROFILE FOR 

BETHLEHEM STEEL PLANT, 

LACKAWANNA, NY 

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Task Manager: ____________________________ 

 Joseph Fitzgerald 

Date: October 14, 2004____

Supersedes: 

N/A 

Project Manager: __________________________ 

 John Mauro 

Date: October 14, 2004____
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TABLE OF CONTENTS 

EXECUTIVE SUMMARY ............................................................................................................ 5 

Results................................................................................................................................. 5 

Conclusions......................................................................................................................... 7 

ACRONYMS AND ABBREVIATIONS....................................................................................... 9 

1.0 INTRODUCTION ............................................................................................................ 10 

2.0 ASSESSMENT CRITERIA AND METHOD.................................................................. 12 

2.1 Objective 1: Completeness of Data Sources........................................................ 12 

2.2 Objective 2: Technical Accuracy......................................................................... 12 

2.3 Objective 3: Adequacy of Data............................................................................ 12 

2.4 Objective 4: Consistency Among Site Profiles.................................................... 13 

2.5 Objective 5: Regulatory Compliance................................................................... 13 

3.0 FINDINGS........................................................................................................................ 15 

3.1 Finding 1 ............................................................................................................... 15

3.2 Finding 2 ............................................................................................................... 16

3.3 Finding 3 ............................................................................................................... 19

3.4 Finding 4 ............................................................................................................... 20

3.5 Finding 5 ............................................................................................................... 22

3.6 Finding 6 ............................................................................................................... 24

3.7 Finding 7 ............................................................................................................... 25

3.8 Finding 8 ............................................................................................................... 29

4.0 OBSERVATIONS ............................................................................................................ 33

4.1 Observation 1........................................................................................................ 33 

4.2 Observation 2........................................................................................................ 33 

4.3 Observation 3........................................................................................................ 35 

4.4 Observation 4........................................................................................................ 36 

4.5 Observation 5........................................................................................................ 38 

4.6 Observation 6........................................................................................................ 39 

4.7 Observation 7........................................................................................................ 39 

5.0 PROCEDURAL CONFORMANCE ................................................................................ 40 

5.1 Procedural Conformance Issue 1 .......................................................................... 40 

5.2 Procedural Conformance Issue 2 .......................................................................... 41 

5.3 Procedural Conformance Issue 3 .......................................................................... 44 

6.0 STRENGTHS ................................................................................................................... 46 

7.0 REFERENCES ................................................................................................................. 47 
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ATTACHMENTS 

Attachment 1: Conference Call with NIOSH and SC&A 

Attachment 2: Bethlehem Steel Questions Submitted to NIOSH 

Attachment 3: Summary of Site Expert Interviews 

Attachment 4: Statistical Approach Regarding Analysis of Air Concentration Data 
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EXECUTIVE SUMMARY 

S. Cohen and Associates (SC&A) evaluated the ORAUT-TKBS-0001, Technical Basis 

Document for Development of an Exposure Matrix for Bethlehem Steel Corporation (Bloom 

2004) and OCAS-TIB-009, Estimation of Ingestion Intakes (OCAS 2004) prepared by Oak 

Ridge Associate Universities (ORAU) and approved by the National Institute for Occupational 

Safety and Health (NIOSH). The evaluation focused on the completeness, technical accuracy, 

adequacy of data, and compliance with stated objectives, as stipulated in SC&A Standard 

Operating Procedure for Performing Site Profile Reviews approved by the Advisory Board on 

March 18, 2004. (A fifth objective, “consistency among various site profiles,” cannot be 

addressed until more reviews are completed.) 

The NIOSH technical basis documents (TBDs), which together constitute the NIOSH site 

profiles for specific Department of Energy and Atomic Weapons Employer sites, are designed to 

support the conduct of individual dose reconstructions under the Energy Employee Occupational 

Illness Compensation Program Act of 2000. This is accomplished by compiling and analyzing 

data such as that related to facility operations and processes over time, radiological source term 

characterization, chemical and physical forms of the radionuclides, historic workplace conditions 

and practices, and incidents and accidents involving potential exposures. As the Advisory 

Board’s support contractor, SC&A has been charged with independently evaluating the approach 

taken in NIOSH site profiles (encompassing technical basis documents and supporting technical 

information bulletins as they apply to the TBDs) to gauge their adequacy, completeness, and 

validity. This information will be used by the Advisory Board to advise the Secretary of Health 

and Human Services on the “scientific validity and quality” of dose reconstruction efforts 

performed. 

RESULTS 

The Bethlehem Steel site profile has clear strengths, including its focus on inhalation dose, the 

use of claimant-favorable solubility class for the respiratory tract, and the use of a minimum dose 

estimate to expedite favorable compensation claims. The decision to use operational air 

concentration data from the Simonds Saw and Steel (Simonds) plant to attempt to construct a 

maximum dose estimate for rolling days was also appropriate. NIOSH also took worker and site 

expert feedback into account by including an ingestion model in Revision 1 of ORAUT-TKBS0001. However, this evaluation indicates that the site profile is not sufficiently claimant 

favorable and scientifically sound on several important points. 

NIOSH and ORAU have applied the triangular distribution to various internal exposure scenarios 

based on field characterization data and published dose rates for uranium. Dose estimates 

include dose from inhalation, ingestion, submersion, electron exposure (shallow dose), photon 

exposure (deep dose), and dose from diagnostic x-rays. Air monitoring data were subdivided 

into either lower bound or upper bound estimates, which were in turn used to calculate internal 

inhalation dose. The intent of the profile was to make conservative assumptions that were 

claimant favorable and technically robust. 
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Despite the intent to adopt a conservative approach in the Bethlehem Steel site profile, the 

document is incomplete or technically inappropriate on several accounts. SC&A identified 

technical issues regarding statistical approach, lack of actual long-term breathing zone data, lack 

of conservatism in the TBD as compared to a previously published technical information bulletin 

(ORAUT-OTIB-0004), intake assumptions, exposure duration, and conditions that, either 

individually or in combination, may substantially influence the outcome of dose reconstruction. 

Dose reconstruction accuracy is directly dependent on the accuracy of the site profile. The most 

significant issues that are likely to influence the outcome of dose reconstructions in nonclaimant-favorable directions include the following: 

Air concentration data were not critically evaluated. The available air concentration data are 

all short-term data. Many are general area air samples. Uncertainties in measurements are not 

discussed in the TBD. No direct, long-term breathing zone data are available. International 

Commission on Radiological Protection Publication 75 (ICRP 75), General Principles for 

Radiation Protection of Workers, recommends that datasets like the ones at Bethlehem Steel and 

Simonds used in the site profile should be evaluated and adjusted as necessary for application to 

individual worker doses. The site profile has not accomplished this effectively. 

Statistical methods are not appropriate for the data available. SC&A’s analysis shows that 

the use of the triangular distribution is not an appropriate statistical approach for the upper bound 

scenario, given the nature of the data. The use of the triangular distribution is complicated by the 

selection of statistically inappropriate values for the maximum parameters. Furthermore, the 

data used to generate the values have not been fully utilized or evaluated for uncertainty in the 

measured values. 

Non-conservative assumptions regarding intake of radioactive material have been made.

There was no indication of independent evaluation of worker dose due to involvement in highrisk jobs, incidents, or incident recovery. Assumptions such as the use of nasal versus oro-nasal 

breathing and use of the ICRP default values may lead to underestimation of inhalation dose. 

Further, the ingestion model does not properly represent the fraction of material ingested by the 

workers via large flakes and particles being deposited on food or ingested via hands. 

External and internal dose from residual contamination is not appropriately considered in 

the site profile. Questionable and unrepresentative surveys were used to demonstrate the lack of 

residual contamination between and after rollings. In contrast, data from similar uranium 

processing facilities support the potential for exposure from residual radioactivity. Post-rolling 

resuspension was not taken into account. 

Procedural nonconformances were identified. In development of a site profile, one of the 

objectives is to insure conformance with applicable regulations and internal procedures. The 

“worst-case” assumptions were not applied to dose reconstructions where compensation was 

denied. In another case, the more claimant-favorable methodologies outlined in Technical 

Information Bulletin: Technical Basis for Estimating the Maximum Plausible Dose to Workers 

at Atomic Weapons Employer Facilities (Anderson 2003), were not incorporated into the site 

profile. 
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CONCLUSIONS 

The Bethlehem Steel site profile represents a reasonable approach to evaluating and estimating 

historic worker radiation dose at a late-1940s, early-1950s era uranium processing facility for 

which no or few dosimetry records exist. Clear strengths exist with respect to how inhalation 

dose is addressed, and how data from a similar operation at Simonds are applied to bridge the 

dearth of actual records at Bethlehem Steel. However, the site profile falls short in 

accomplishing its goal of assuring a claimant-favorable set of facility dose estimates, because it 

fails to adequately address inherent uncertainties in both the Bethlehem Steel and Simonds data, 

and it applies a statistical approach that is questionable given the actual data available for 

consideration. Assuming it can be appropriately corroborated, the input of former workers needs 

to be given particular attention as a source of historic operational reconstruction that can fill 

existing gaps in the standing record. As a “living document,” the Bethlehem Steel site profile 

can be improved as a fundamental basis for dose reconstruction analysis by consideration of the 

findings, observations, and issues presented in this review. 
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OVERVIEW OF OPPORTUNITIES FOR IMPROVEMENT 

Apply the procedures and standards as discussed in this review, including use of ICRP 75 and 

appropriate portions of ORAUT-OTIB-0004. While 42 CFR 82 affords latitude in how NIOSH 

implements its requirements as reflected in its technical guidance documents on external and internal 

dosimetry, it is incumbent on NIOSH to adhere to recognized standards and established procedures, unless 

justification is provided in the site profile to support alternative approaches or procedures. 

Assure that appropriate statistical methods are applied in analyzing air concentration data after 

adjustment according to ICRP 75. The triangular distribution is not the appropriate statistical treatment for 

the data used to construct the maximum exposure scenario in the TBD (Table 3). Further, the selection of the 

values for the maximum parameters is methodologically incorrect in both Tables 2 and 3. 

Take oro-nasal breathing into account in inhalation doses. The dose conversion factors for light and heavy 

breathing should take account of the fact that many workers switch from nasal to oro-nasal breathing as the 

work becomes heavier. An upward adjustment to the percentage of heavy exercise and the consideration of 

oro-nasal breathing would ultimately increase the total uptake of uranium, and be more claimant favorable 

given the uncertainties involved. 

Take into account ingestion of large particles via hands and via deposition on food, as well as ingestion 

during non-rolling periods. Attention needs to be given to several routes of additional ingestion exposure 

that would likely exceed that assumed by the site profile. These would include ingestion of large particles 

deposited on food via hands, and ingestion between rolling periods and after the rollings were completed. 

Perform further document retrieval efforts to locate pertinent documents in relation to rollings during 

1949 and 1950, and potential rollings post-1952. Although a records search was conducted at various 

locations, including the Fernald records center, the Environmental Measurements Laboratory, and various 

DOE record holdings, it is likely that pertinent records for the periods in question may exist at other locations, 

including Hanford, Savannah River, and other DOE sites. 

Evaluate the potential impact of residual contamination between rollings and after completion of all 

rollings, and include this in both external and internal doses. Internal alpha radiation doses due to 

resuspension through the years 1949 to 1952 should take more careful account of continuous exposure from 

residual contamination. Internal doses from resuspension would also affect the period after the rollings were 

completed, although substantial attenuation would be expected over time given subsequent cleanup efforts. 

As discussed in this review, it may be possible to use available data to construct air concentration distributions 

between rollings, as well as to derive a decay parameter after rollings were complete. 

Take into account site expert information and investigate worker accounts. With records and other 

documentation not available, it becomes particularly critical to interview former workers whose first-hand 

experience and association with Bethlehem Steel enable them to provide original perspectives and information 

concerning site practices and exposure history. While an initial meeting was conducted in July 2004, it is 

imperative that NIOSH fully review the information received on a timely basis and attempt to substantiate it 

for application in the site profile.

Create a list of high-risk jobs and incidents for consideration as a complement to the site profile to 

inform the individual dose reconstruction process. 

Evaluate and update other Atomic Weapons Employer profiles as necessary in light of the findings, 

observations, and procedural nonconformances identified in this report. 

 
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ACRONYMS AND ABBREVIATIONS 

Advisory Board NIOSH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapon Employers 

BLU Best Linear Unbiased 

DOE Department of Energy 

DPUI Dose Per Unit Uptake 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

FUSRAP Formerly Utilized Sites Remedial Action Plan 

ICRP International Commission on Radiological Protection 

IREP Interactive RadioEpidemiologic Program 

MAC Maximum Allowable Concentration 

MLE Maximum Likelihood Estimate 

NIOSH National Institute for Occupational Safety and Health 

OCAS Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities 

ORNL Oak Ridge National Laboratory 

PA Posterior-Anterior 

PFG Photofluorography 

PPE Personnel Protective Equipment 

SC&A S. Cohen and Associates 

Simonds Simonds Saw and Steel 

TBD Technical Basis Document 

UCL Upper Confidence Limit
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1.0 INTRODUCTION 

This evaluation is directed at the ORAUT-TKBS-0001, Technical Basis Document for 

Development of an Exposure Matrix for Bethlehem Steel Corporation (Bloom 2004) and OCASTIB-009, Estimation of Ingestion Intakes (OCAS 2004) prepared by Oak Ridge Associate 

Universities (ORAU) and approved by the National Institute for Occupational Safety and Health 

(NIOSH). S. Cohen and Associates (SC&A), in direct support of the Advisory Board on 

Radiation and Worker Health (Advisory Board), has evaluated the approach taken in the site 

profile to gauge the adequacy, completeness, and validity of the information. The review is 

directed at “sampling” the site profile analysis and data for validation purposes. The review does 

not provide a rigorous quality control process, whereby actual analysis and calculations are 

duplicated or verified. The scope and depth of the review are focused on aspects or parameters 

of the site profile that would be particularly influential in deriving dose reconstructions, bridging 

uncertainties, or correcting technical inaccuracies. This review does not explicitly address the 

issue of radiation exposures to cleanup workers and decommissioning workers beyond the 

rolling period. This review does address the issue of post-rolling exposures due to resuspension 

of uranium. 

The site profiles serve as “site-specific guidance documents used in support of dose 

reconstructions.” These site profiles provide the health physicists who conduct dose 

reconstructions on behalf of NIOSH with consistent general information and specifications to 

support their individual dose reconstructions. This report was prepared by SC&A to provide the 

Advisory Board with an evaluation of whether and how the site profile (also referred to as the 

technical basis document or TBD) can support dose reconstruction decisions. The criteria for 

evaluation include whether the TBD provides a basis for scientifically supportable dose 

reconstruction in a manner that is adequate, complete, efficient, and claimant favorable. 

Specifically, these criteria were viewed from the perspective of whether dose reconstructions 

based on the TBD would provide for robust compensation decisions. 

The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed, and determine the level of exposure the worker received in that 

environment through time. The hierarchy of data used for developing dose reconstruction 

methodologies is dosimeter readings and bioassay, coworker data and workplace monitoring 

data, and process description information or source term data. In the case of Bethlehem Steel, 

dosimeter and bioassay results were not available, while workplace monitoring data were 

present. This is further complicated by the illegibility of some of the available records. Air 

monitoring data was used to develop internal dose and submersion dose. Dose rate information 

from Handbook of Safety Procedures for Processing Depleted Uranium (U.S. Army 1989) and 

Depth-dose Curves for 90Sr and Natural and Depleted Uranium in Mylar (Coleman et al. 1983) 

were used to derive external dose. In several areas, listed below, the TBD has done a 

commendable and successful job of addressing a series of technical challenges. In other areas, 

the TBD exhibits shortcomings that will influence some dose reconstructions in a substantial 

manner. 

During a May 11-13, 2004, meeting with NIOSH and ORAU in Cincinnati, Ohio, SC&A was 

informed that the goal was to make the process of dose reconstruction scientifically robust from 
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the point of view of the compensation decision. The approach of achieving the “best” estimate 

dose was not the goal, since that may, in many cases, take an enormous amount of resources 

without making a material difference to the compensation decision – that is, to deciding whether 

an organ dose was below or above the level where the probability of causation is 50%. Site 

profiles are considered “living documents” that are iterative in nature. The review takes these 

conditions into consideration. 

A “minimum/maximum” approach for dose reconstruction has been adopted by NIOSH for the 

sake of dose reconstruction “efficiency.” A minimum dose is estimated for those cases where a 

cancer appears likely to be compensable. If a minimum dose estimate is above the compensable 

limit, then the compensation decision and the corresponding dose estimate are regarded as 

robust, because any further refinement in the dose would lead to an even higher dose and 

increase the probability of causation even more above 50% than with the minimum dose 

estimate. 

A maximum dose for those cancers that are likely to be non-compensable is also defined. If the 

largest possible dose that is scientifically reasonable and supportable results in a probability of 

causation that is less than 50%, then the denial decision and the dose on which it is based are 

regarded as robust. Since the dose is regarded as a maximum that cannot be adjusted upward in 

a technically defensible manner, the denial and the dose estimate on which it is based are 

regarded as robust. 

The principal issues are divided into four categories: (1) findings, which are significant issues 

likely to impact dose reconstructions and for which substantiating records, analysis or 

corroboration exist; (2) observations, which are weaknesses or deficiencies in the TBD approach 

that deserve further investigation to determine the potential impact on dose reconstruction (these 

may also include inaccuracies in the TBD and findings that were not sufficiently substantiated by 

SC&A during its review); (3) procedural conformance issues, which address discrepancies or 

inconsistencies in approach as they relate to requirements outlined in guidance documents, 

quality assurance program plans, and applicable procedures; and (4) program strengths, which 

recognize those aspects of the TBD approach that are particularly insightful and technically 

sound. 
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2.0 ASSESSMENT CRITERIA AND METHOD 

S. Cohen and Associates (SC&A) is charged with evaluating the approach set forth in the site 

profiles, which is used in the individual dose reconstruction process. These documents are 

reviewed for their completeness, technical accuracy, adequacy of data, and compliance with the 

stated objectives, as defined in SC&A Standard Operating Procedure for Performing Site Profile 

Reviews, approved by the Advisory Board on March 18, 2004. A fifth objective, “consistency 

among various site profiles,” cannot be addressed until more reviews are completed. A review 

of ORAUT-TKBS-0001 and OCAS-TIB-009 is complete. This review is specific to the 

Bethlehem Steel site profile and supporting technical information bulletins; however, items 

identified in this report may be applied to other facilities. The review consisted of the following: 

2.1 OBJECTIVE 1: COMPLETENESS OF DATA SOURCES 

The available information referenced in the site profile was examined for applicability to 

operations at the Bethlehem Steel plant. A limited search for additional documents was 

completed based on the data made available by NIOSH to the SC&A team in August 2004. Data 

from facilities with similar operations to the Bethlehem Steel plant (i.e., Simonds Saw and Steel) 

were also reviewed. 

2.2 OBJECTIVE 2: TECHNICAL ACCURACY 

A critical assessment was made of how the sources of data identified in the site profile were used 

in developing technically defensible guidance or instruction. This included evaluating 

workplace-monitoring data (i.e., air sampling, survey); technical reports, including production 

reports, standards, and guidance documents; and literature related to uranium processing and 

handling. 

2.3 OBJECTIVE 3: ADEQUACY OF DATA 

Presentations and discussions with respect to site profile scope and dose reconstruction activities 

were held during a meeting with NIOSH and ORAU in Cincinnati, May 11 to 13, 2004. 

Furthermore, specific discussions were held with NIOSH regarding the Bethlehem Steel 

technical basis document (TBD). In this discussion, NIOSH was offered the opportunity to 

explain assumptions made and to clarify issues concerning application of the site profile. 

Attachment 1 summarizes the conference call between NIOSH and the SC&A team. Attachment 

2 provides written questions sent to NIOSH during the course of the audit. Several site expert 

interviews were performed to obtain a more detailed understanding of the uranium rolling 

process. Written questions were provided to those site experts not readily accessible by phone. 

The SC&A team were also invited by NIOSH to attend a meeting with former Bethlehem Steel 

workers and their families during the July 1, 2004, workshop organized by NIOSH and ORAU in 

Hamburg, New York. A summary of site expert interviews, written responses, and information 

provided during the Hamburg meeting is provided in Attachment 3. 

After compiling site expert interviews, documentation, and NIOSH input, issues raised were 

carefully evaluated. An assessment was conducted of the resultant data and guidance contained 
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in the site profile to ascertain whether they are sufficiently detailed and complete for use in dose 

reconstruction. In addition, since there was limited data available for the Bethlehem Steel 

profile, the defensibility of the overall approach was also evaluated. 

2.4 OBJECTIVE 4: CONSISTENCY AMONG SITE PROFILES 

The Bethlehem Steel TBD review is the first to be issued. Limited comparisons between this 

and some other TBDs have been performed. As site profile reviews progress, further 

examination of common issues affecting more than one site will be noted and inconsistencies 

between TBDs will be documented by the audit team. 

2.5 OBJECTIVE 5: REGULATORY COMPLIANCE 

The Bethlehem Steel TBD was evaluated against the requirements outlined in the stated policy 

and directives contained in Methods for Radiation Dose Reconstruction Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000 (42 CFR 82), and the 

guidance and protocols defined in the OCAS-IG-001, External Dose Reconstruction 

Implementation Guideline (OCAS 2002a) and the OCAS-IG-002, Internal Dose Reconstruction 

Implementation Guideline (OCAS 2002b). It was also evaluated against the procedures set forth 

by NIOSH for estimating Atomic Weapons Employers (AWEs) doses in ORAUT-OTIB-0004, 

Technical Information Bulletin: Technical Basis for Estimating the Maximum Plausible Dose to 

Workers at Atomic Weapons Employer Facilities (Anderson 2003).

The Bethlehem Steel TBD was reviewed in relation to the following issues. 

• Adequacy of air concentration data for individual dose estimation 

• Internal dose assumptions, parameters, and conditions 

• Statistical issues 

• Uranium rolling history 

• External exposure from contact with uranium 

• Potential impact of exposure to residual contamination 

• Medical x-ray doses 

• Other considerations 

Site expert input was used to assist the team in obtaining a comprehensive understanding of the 

uranium rolling process and the exposure conditions at the time to help identify areas where 

further investigation was needed, and to determine additional sources of data. Site experts 

provided additional documentation regarding Bethlehem Steel uranium rolling operations. The 

site expert summary (Attachment 3) was reviewed by the site experts themselves for accuracy of 

interpretation. 

Information provided in the conference call by NIOSH was evaluated against the preliminary 

findings and observations to finalize the list of issues addressed in the audit report. This 

information also served to correct potential misinterpretations of the TBD by the audit team. 
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There are a number of findings and observations addressing the issue of how minimum and 

maximum doses are estimated for efficiency purposes. This is largely because the inherent 

asymmetry between minimum dose and maximum dose calculations has not been adequately 

addressed in the TBD. In the case of minimum doses, it is acceptable to leave out complex 

factors and take only a few data points that are consistent with minimum dose estimation. While 

there are many different ways to do this, it is possible to come up with parameters that could be 

generally accepted as minimal under the circumstances. Since no denials are based on the 

minimum calculations, the screening done by this approach can be made efficiently without 

compromising robustness of the compensation decision. As a result, compensation decisions can 

be relatively rapid and robust. 

Estimating a maximum dose is a different matter. First, and most important, the dose must be a 

technically defensible maximum, since this estimate is used mainly to deny compensation, in the 

expectation that the result for probability of causation (PC) will be less than 50%. Since some 

values for the PC are in the 40% to 49% range, it is essential that the maximum dose estimate be 

both technically defensible in regard to completeness and adequacy of method and demonstrably 

claimant favorable. In other words, all potentially significant factors need to be evaluated for 

the maximum dose. This requires an exploration of many factors, some of which may turn out to 

be important, while others may not. Furthermore, there may be situations where even relatively 

minor factors may make a difference if the PC is at 48% or 49%. We have explored many issues 

in some detail in this Site Profile Review partly because of the concern that when compensation 

is denied at levels so close to 50%, the maximum dose estimate must be above reproach on the 

grounds of scientific soundness, as well as claimant favorability. 

The Bethlehem Steel TBD does not meet the criteria for scientifically supportable and robust 

maximum dose estimates on several counts. The problems stem from a number of different 

sources, including an inadequate consideration of site expert testimony. The revised TBD was 

published 2 days prior to the worker meeting organized by NIOSH and ORAU in order to elicit 

technical information from workers. A considerable amount of information actually was 

developed at that meeting that could have been profitably used with the documentation that 

NIOSH and ORAU already have. Further, the revised TBD also inexplicably did not apply the 

more conservative approaches in ORAUT-OTIB-0004, even though they were clearly more 

claimant favorable than that set forth in the TBD. 

There were three levels of review for this report. First, the report was reviewed internally by the 

SC&A team. Second, SC&A appointed Mike Thorne, who did not participate in the preparation 

of this document, as an internal reviewer to go over all aspects of this report. Third, SC&A gave 

NIOSH and ORAU an opportunity to comment on the final draft from the standpoint of factual 

accuracy. This is an important safeguard against missing key issues or misinterpreting some 

vital piece of information or calculation that NIOSH and ORAU may have done. Comments 

have been addressed and incorporated into this report as deemed appropriate by the SC&A team. 
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3.0 FINDINGS 

There were a number of findings identified in the Bethlehem Steel site profile and the supporting 

technical information bulletin. In general, the findings related to the completeness of data 

sources, technical accuracy, and adequacy of data. As previously mentioned, comparisons 

between other site profiles were limited. 

3.1 FINDING 1 

In the absence of personnel monitoring data, workplace air monitoring data were the 

principal basis for dose estimates. The applicability of such data to individual workers, 

and the quality and reliability of the data were not addressed in the TBD. 

The rate of airflow in the samplers and, in many cases, the total volume of air samples taken was 

relatively small for air samples at Bethlehem Steel. Overall, the data from Bethlehem Steel are 

too sparse to enable a defensible dose reconstruction. For instance, few data points are available 

for many locations and none for others. There are no data for most of the rollings. Bethlehem 

Steel data has been complemented with Simonds Saw and Steel (Simonds) data to create air 

concentration distributions. This is a reasonable approach, notwithstanding the important 

caveats cited below. 

However, it is important that the Simonds data be used in a manner that is scientifically 

appropriate. The use of data from similar facilities may, under certain circumstances, enhance 

the quality of a dose reconstruction; in others it may detract from it. In this specific instance, 

there is no reason to rule out the use of Simonds data as unhelpful. Both Simonds and 

Bethlehem Steel were rolling uranium bars for the Atomic Energy Commission (AEC), using 

similar methods and equipment. However, a detailed comparability is desirable prior to use of 

such data. For instance, the comparability of workplace factors such as ventilation, the manner 

in which the uranium was treated, the physical arrangements of the rolling mill, and cleanup 

practices are important. The TBD does not discuss the issue of how comparability, beyond 

similarity in operational process and time period, was established. 

Both Bethlehem Steel and Simonds rolled uranium at moderately hot temperatures. In both 

cases, water was sprayed on the uranium during the rolling to keep the uranium temperature from 

rising. However, ventilation was installed at Simonds before the referenced December 1, 1948, 

survey, but after the indicated October 27, 1948, visit. There was no ventilation at Bethlehem 

Steel. Therefore, the only clearly usable Simonds dataset is the one from October 27, 1948. 

However, Simonds appears to have had some exhaust ventilation even on October 27, 1948, as 

indicated by sample L716 (NYOO 1948). 

Bethlehem Steel reportedly had 18 roller stands. At least six rollers were used for uranium 

rolling. Two or three roller stands were used at Simonds, and the uranium was brought around 

and re-fed into the first stand. Bethlehem Steel operations included both experimental and 

production runs. Uranium was heated in a salt bath designed to reduce scaling at later times, and 

at times may have had a different coating than that at Simonds. 
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Both Simonds and Bethlehem Steel data indicate that the roller stands were the most, or among 

the most, contaminated workstations. There are no Bethlehem Steel data for most rollings. 

While the Simonds re-feeding would tend to increase the dust at roller number 1, the larger 

number of roller stands at Bethlehem Steel indicate that it may have had a larger number of 

stations with higher breathing zone contamination. Bethlehem Steel may also have had higher 

air concentrations than Simonds during incidents such as cobbles, since the larger number of 

rollers may have led to a greater rate of cobbling. SC&A has not investigated this issue, since a 

detailed study of the Simonds facility is beyond the scope of this review. 

In summary, there are some factors that would tend to make the use of Simonds data claimant 

favorable for Bethlehem Steel workers, but others that would tend to make it claimantunfavorable. The broad comparability of process, as well as the same general period during 

which the rolling took place, generally indicates the use of Simonds data is an appropriate way to 

construct a claimant-favorable distribution for Bethlehem Steel for rolling days, provided 

appropriate technical and statistical cautions are observed. 

The TBD does not discuss the reliability of air sampling data used to determine the air 

concentration values. Total air sampling error includes error produced during collection and 

analysis of the air sample. One source of error for air samples from a dusty environment is selfabsorption due to burial of the alpha particle in the filter. This may have been mitigated 

somewhat by the relatively short periods of sampling ranging from 4-45 minutes for the air 

sampling results from the January 26, 1952, rolling (Quigley and Heatherton 1952). Low air 

sampling velocity (0.02 m3

/min) and short collection periods resulted in low volume air samples. 

For instance, a 10-minute sample would take in 0.2 m3

 (typical for many samples), meaning that 

for each Maximum Allowable Concentration (MAC) of 70 disintegrations per minute per m3, the 

deposition of alpha emitters on the filter would be only about 14 dpm (0.23 Bq). 

There is also some error associated with assuming that general area air samples are indicative of 

the airborne concentration the workers inhaled. In this respect, the TBD has not taken ICRP 75, 

General Principles for Radiation Protection of Workers, recommendations into account. This 

issue is discussed under Section 5.1, Procedure Conformance Issue No. 1. This issue should be 

kept in mind when reading Findings 2 and 3 below. These findings take the air concentration 

data at face value and are intended, therefore, as a methodological evaluation of the Bethlehem 

Steel TBD. A reconstruction of the air concentration would also have to take into account the 

relevant aspects of ICRP 75 discussed in Section 5 of this report. 

3.2 FINDING 2 

The triangular distribution in Table 3 is not a statistically sound representation of the 

October 27, 1948, Simonds dataset. The upper bound of Table 3 is not claimant favorable. 

The TBD uses a triangular distribution to represent the distribution of possible air concentration 

values and external exposure potential. The same distribution is also used to represent ingestion 

and external air submersion doses. The central purpose of analyzing air concentration data is to 

enable the calculation of individual radiation doses in a manner that is scientifically defensible 

and claimant favorable. This means that the doses for individual workers with specific job 
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assignments need to be estimated. These assignments would, in general, tend to be in the 

vicinity of assigned job locations, which generally would not correspond to a random sampling 

of the facility air over the course of a typical workday. Examining data taken throughout the 

facility is part of this process. In the present instance, there are few data for individual 

workstations. There are no true breathing zone data in the sense of data taken from personal air 

samplers. This situation makes it necessary to examine the entire facility as well as individual 

workstation data to make inference about claimant favorable and scientifically defensible dose 

reconstructions for individuals. 

Data from the whole facility represented in a distribution that gives a facility air concentration 

profile is part of this process. A particular frequency for air concentration in the profile itself 

represents the probability that a person would encounter that air concentration if the various 

locations were visited at random. But this is not how individuals typically experience the 

workplace. As a result, in the absence of detailed and adequate individual workstation data, 

there are two basic questions that statistical analysis must address. First, how well does the 

chosen distribution represent the facility air concentration data? Second, how is this distribution 

used in conjunction with data from specific workstations to estimate doses to individual workers 

in a way that is both scientifically defensible and claimant favorable? These are the central 

issues addressed in Findings 2 and 3 below and in Attachment 4. 

The TBD has two tables showing air concentrations. They are Tables 2 and 3 of the TBD. 

NIOSH describes these tables as follows: 

Tables 2 and 3 list the internal exposure matrix for the Bethlehem Steel site. Table 

2 is a lower bound for estimating internal exposure and Table 3 is an upper 

bound. (TBD, pg. 5) 

This statement implies that the two tables represent the minimum expected facility air 

concentrations (Table 2) and the maximum expected facility air concentrations (Table 3). 

However, these same distributions are used to calculate internal doses experienced by 

individuals, and therefore appear to be treated as minimum and maximum individual exposure 

matrices since these distributions are used in individual dose reconstructions. Table 2 is not used 

to deny compensation, but to compensate claimants without further investigation. Table 3 

appears to be used to both compensate and to deny compensation, depending on whether the 

probability of causation is greater than or less than 50%.

There are two related statistical issues regarding how the available air concentration data have 

been used in the TBD (assuming all data can be taken at face value). These relate to the choice 

of the probability distribution used to fit the data, and the choice of parameters. These general 

issues relate to both Tables 2 and 3. The primary focus of Table 3 in this set of findings derives 

from the fact that Table 3 is used to estimate maximum doses. Since this estimate is used to 

deny compensation, it is crucial to consider all relevant factors. Some comments on Table 2 are 

made in the subsequent finding. It is important to stress here that the statistical analysis takes the 

air concentration data at face value without adjustments recommended by ICRP 75. These 

adjustments would need to be considered for a reconstruction of an air concentration distribution 

that is technically sound in terms of the ICRP 75 recommendations, and statistically sound in 
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terms of representing the available data by an appropriate distribution and parameters of that 

distribution. The questions of the nature and validity of air concentration data are discussed 

briefly in Section 5 and in Attachment 4. 

The issues of the type of distribution and the choice of parameters are related. First the choice of 

distribution is considered followed by the issue of parameter values used in Table 3. 

Figure A4-1 in Attachment 4 shows a Q-Q plot for the October 27, 1948, Simonds air 

concentration data for a fitted triangular distribution. This plot indicates that a triangular 

distribution is a poor choice of distribution for estimating an air concentration profile from the 

October 27, 1948, air concentration data. Figure A4-2 shows a Q-Q plot for the triangular 

distribution used in Table 3 of the TBD, assuming it represents Simonds October 27, 1948, data 

and indicates the same conclusion.1 Even if the approach of using a mode of 2xMAC that the 

TBD states were based on Bethlehem Steel data, it does not change the essential result. Both 

figures also indicate that the triangular distribution is not demonstrably claimant favorable at the 

highest values of air concentration. Finally, the choice of parameters in Table 3 of the TBD is 

not in accordance with the basic principles of constructing a triangular representation of a set of 

data. Specifically, the upper bound of the distribution in Table 3 is less than the maximum 

measurement of about 1,070xMAC. The mode should be derived by a more explicit analysis 

that relates to the dataset being analyzed. However, it should be noted that this methodological 

issue does not have a significant impact in the present instance, since the choice of mode is 

unlikely to affect the overall computations significantly in this case. 

Two approaches can be considered to address the issue of how the data regarding the most 

contaminated workstation can be analyzed. In the first approach, the points from the most 

contaminated workstation (of those measured on October 27, 1948, at Simonds) can be treated as 

coming from a distinct distribution, since the two highest readings are from Roller #1 (i.e., 

samples L709 and L710) and the third reading (L711) from that workstation is within the top five 

values. This allows us to estimate an upper bound for the air concentration at Simonds on that 

date. Unfortunately, there are only three measurements for the Roller #1 workstation, and an 

assumption must be made for a distribution to represent them. There is no a priori defensible 

way with which to fit these three points to a distribution. Various ways in which an upper bound 

can be derived yield varying estimates. For instance, the 95% confidence upper bound estimate, 

assuming a uniform distribution, is 1,785xMAC. A loguniform distribution for the same data 

yields an estimate of 3,375xMAC. One can also choose an unbounded distribution to represent 

three data points. These results are discussed in Part 3 of Attachment 4 (see Table A4-2). The 

basic statistical problem with this approach for estimating an upper bound for the air 

concentration at Roller #1 is that there are only three data points. The most comparable 

estimates to the upper bound of Table 3 would be the ones derived from the bounded 

distributions. They range from about 1,450xMAC to almost 3,400xMAC (rounded). 

Methodological details of these results are discussed in Attachment 4. 

 

1

 SC&A notes that Table 3 does not purport to represent the October 27, 1948 dataset. A sound 

methodology requires that it should. Hence, SC&A analyzed the distribution in Table 3 to examine whether it was a 

good fit of the data it should represent. 
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A second approach is to construct a distribution for the rolling operation as a whole on the date 

in question, and then adjust for the fact that some workers are at a greater risk because of their 

work locations. Figure A4-3 in Attachment 4 shows that a lognormal distribution to represent 

the October 27, 1948, data is a much better fit than a triangular distribution. The 

inappropriateness of a triangular distribution to represent this dataset is further discussed in 

Attachment 4. 

However, the lognormal representation of the many workstations at the lower end of the air 

concentration range is not claimant favorable. This issue can be addressed by using the 95th 

percentile of this distribution as the basis for estimating the uranium intake. This value is about 

570xMAC. However, this value is not claimant favorable for the most contaminated 

workstation, which is likely to be Roller #1, where the average of the three measured values is 

700xMAC. 

The procedure can be made claimant favorable for workers whom we know were at the more 

contaminated workstations and for those for whom there is no workstation information by using 

the 95th percentile value of the tail of the facility lognormal distribution. A suitable way to do 

this would be to assume that further measurements at the most contaminated workstation are 

bounded below by the lowest of the three air concentration measurements at that station. This 

value is given by the data point L711 and is 320xMAC. The 95th percentile estimate of the tail 

of the distribution can then be made. This is 4,350xMAC. This value would be exceeded in the 

most contaminated area at most 5% of the time. This point lies at about 99.3 percentile of the 

facility lognormal distribution. Effectively, we are using only the tail of the facility distribution 

to make the procedure claimant favorable for workers at high risk or for those with no 

workstation data. 

As noted above, these values of 570xMAC and 4,350xMAC are not recommended values but 

methodological illustrations. Specifically, they do not take ICRP 75 recommendations into 

account. Attachment 4 covers statistical issues related to the October 27, 1948, dataset and 

Table 3 of the TBD in more detail. Some discussion of ICRP 75 is provided later in this report. 

3.3 FINDING 3 

The selection of the maximum value in the Lower Bound Internal Exposure Matrix (Table 

2) is not technically sound. 

SC&A has not performed a statistical analysis of the Bethlehem Steel data along the lines 

suggested above to examine whether the choice of a triangular distribution to represent the data 

is appropriate. Since the methodology is discussed extensively for Table 3, SC&A has not 

attempted to repeat the analysis for Table 2. These comments are limited to the choice of the 

maximum for the triangular distribution chosen for Table 2 of the TBD, which most affects the 

dose computations. 

The available Bethlehem Steel air monitoring data has not been fully utilized to construct Table 

2 of the TBD. The rationale for choice of parameters in Table 2 of the TBD is as follows: 
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For 1949 through 1952, the most likely value, or mode, was assumed to be 

140 dpm/m3

, which corresponds to 2 MAC. The minimum value was assumed to 

be 0 dpm/m3

, which considers the possibility that there was no exposure. The 

maximum value for the lower bound matrix was assumed to be 4,900 dpm/m3

 

(70 MAC), which is the maximum reading found in Bethlehem Steel air 

monitoring data (AEC 1951-1952). 

The TBD states that a value of 4,900 dpm/m3

 is the maximum value of air concentration found in 

Bethlehem Steel air monitoring data. SC&A found three readings above this value: 6,800, about 

13,000, and 29,766 dpm/m3

 (Heatherton 1951, Miller 1951a and 1951b). The last two quoted 

values are not very legible and represent SC&A’s best reading of the datasheets. There are other 

air sampling results that are only partially legible or not legible at all. 

Table 2 of the TBD is not claimant favorable because the highest data points have been omitted. 

The maximum value in Table 2 should reflect the highest values of Bethlehem Steel air 

concentration measurements. Moreover, the upper bound of the triangular distribution cannot be 

less than the largest measurement. In general, the true upper bound will be greater than the 

largest measurement of the dataset, especially if the number of measurements is limited. A 

statistical analysis of the data is needed to determine the parameters. However, such analysis for 

the Bethlehem Steel dataset may be rendered very difficult because (1) there are no data for most 

rollings, (2) much of the data is illegible, and (3) measurements may not have been made for all 

relevant workstations. In addition, the ICRP 75 considerations discussed in this report would 

need to be taken into account. 

It may be sufficient to use the simple approach chosen in Table 2 for the sake of efficiency, since 

workers are not denied compensation based on Table 2 estimates. However, even if a simple 

approach is used, it is still essential that it be scientifically and statistically defensible. For 

instance, the theoretical restraints for determining the upper and lower bound of the triangular 

distribution should be observed. That means that, in the case of Table 2, the upper bound 

parameter of the triangular distribution should not be less than the largest measurement of about 

425xMAC. In contrast, the upper bound parameter in Table 2 of the TBD is 70xMAC. At the 

very least, the algorithm used for fitting the triangular distribution should be specified. Further, 

it does not seem more complex to use the approaches described in Attachment 4 than to fit a 

triangular distribution for the Bethlehem Steel data in a claimant-favorable way for use for 

minimum dose estimations that are the objective of Table 2. 

3.4 FINDING 4 

The assumption of nasal rather than oro-nasal breathing is not claimant favorable and 

defensible given the conditions of steel mill work. 

With respect to the breathing rate applied for internal dose calculations, page 6 of 13 of the TBD 

states: 

The breathing rate was calculated from the volume of air breathed for an adult 

light worker shown in International Commission on Radiological Protection 
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(ICRP) Publication 66 (ICRP 1994, Table 6, p. 23). This category assumes an 

activity distribution of one-third sitting and two-thirds light exercise. The 

minimum and mode intakes, in pCi, were calculated by multiplying the 

appropriate air concentration by the breathing rate and the hours worked, and 

dividing by 2.2 dpm/pCi. Maximum intakes calculations used the same method 

but substituted the breathing rate for an adult heavy worker, which assumes an 

activity distribution of seven-eighths light exercise and one-eighth heavy exercise. 

The ICRP default of 1.7 m3 per hour air breathing rate was used for the maximum dose 

distribution (Table 3). This consisted of an activity distribution of seven-eighths light exercise 

and one-eighth heavy exercise for the upper bound matrix. This consisted of the workers being 

involved in heavy work only 12.5% of the time. At the time of the rollings, the Bethlehem Steel 

mill had no ventilation in the rolling facility. The work environment was hot due to the use of 

furnaces in the work area. Steel mill work during the applicable period of time involved heavy 

labor without the benefit of current-day computer automation. The dose conversion factor for 

light and heavy breathing should take into account the fact that many workers switch from nasal 

to oro-nasal breathing as the work becomes heavier. 

In addition, due to the atmospheric conditions in the steel mill and the level of work, it is likely 

that workers were oro-nasal breathing rather than nasal breathing. There is large variability in 

normal respiratory parameter values between individuals, and for any individual there can also 

be large variations according to the activity undertaken. These can affect the dose per unit intake 

(DPUI) through their effect on regional deposition, but can also affect the intake (and hence 

dose) per unit exposure through change in the ventilation rate. 

To illustrate this, values of the fraction of air passing through the nose for a mouth breather are 

given in Table 1 below. The term “nasal augmenter” refers to a normal nose breather. 

Table 1: Fraction of Total Ventilatory Airflow Passing Through the Nose Fn

(Reproduced from Table 3.1, ICRP Supporting Guidance 3) (ICRP 2002) 

Fn

Level of Exertion 

(exercise) Nasal Augmenter Mouth Breather 

Sleep 1.0 0.7 

Rest (sitting) 1.0 0.7 

Light Exercise 1.0 0.4 

Heavy Exercise 0.5 0.3 

According to ICRP guidance on the application of the respiratory tract model (Supporting 

Guidance 3, ICRP 2002, pp. 35-36): 

(65) Generally, for both subjects, total and regional deposition does not vary 

markedly between the different levels of exercise. The main effect is that 

deposition in the bronchial (BB) region increases with increasing exercise. This 

is most noticeable for the nose breather during heavy exercise because of the 
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switch to oro-nasal breathing. Since deposition in the mouth is lower than in the 

nose, there is greater penetration to, and hence deposition in, the BB region. 

Similarly, regional deposition does not vary markedly with age. There is a clear 

systematic difference between nose and mouth breathers, the latter having lower 

extrathoracic deposition and correspondingly higher deposition in the thoracic 

(lung) regions. The difference is particularly great for 5 μm AMAD aerosols 

inhaled during light exercise, for which deposition in each of the thoracic regions 

BB, bb and AI is several times higher for mouth breathers than for nose 

breathers. Thus DPUI are unlikely to be very sensitive to differences in 

respiratory parameters, unless mouth breathing is involved. 

(66) The ventilation rate, which determines the intake for exposure to a given air 

concentration, however, varies considerably according to the level of exercise. 

As an example, for an adult male, reference values for sleep, sitting, light, and 

heavy exercise are: 0.45, 0.54, 1.5 and 3.0 m3 h-1, respectively...

The ICRP guidance then discusses the effect of exertion level for Type M 234U specifically as an 

illustration (ICRP 2002, p. 36): 

The dose per unit intake does not change much, less than a factor of two in most 

cases. Generally doses are somewhat (10–50%) higher for mouth breathers than 

for the default nose breathers. However, for a 5 μm AMAD aerosol at light 

exercise, the dose is about three times higher for mouth breathers. The dose per 

unit exposure varies more, because the volume of air inhaled increases with 

increasing exercise. 

An upward adjustment to the percentage of heavy exercise and the consideration of oro-nasal 

breathing would ultimately increase the total uptake of uranium. The default assumptions made 

with respect to breathing are not claimant favorable and should be reevaluated based on the 

working conditions in a steel mill (ICRP 66) and the associated guidance document (ICRP 

2002). 

3.5 FINDING 5 

The ingestion dose estimates in Table 4 of the TBD represent only a fraction of potential 

dose from ingestion of radioactive material. 

The source of uranium dust was continuous in the mill during operation. Dust was made 

airborne by the milling and finishing process. It also dropped from the crane area either during 

movement of material or as a result of residual contamination. Bethlehem Steel did not have 

lunchrooms. Lunch and coffee breaks were taken adjacent to the operations. Workers used 

furnaces to heat their food. Water was supplied to the workers in the production area (Dimitroff 

2004). This situation created a significant potential for ingestion of radioactive material by 

consumption of contaminated food and beverages, as well as swallowing dust. 
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The TBD considered ingestion via the settling of dust onto food and coffee. The deposition 

velocity used appears to correspond to 1-micron particles. This is one component of the 

ingestion dose. However, it is unlikely to be the main contributor to the ingestion dose. Table 4 

estimates do not account for several routes of likely significant ingestion exposure, including 

ingestion of large particles deposited on food via hands, and ingestion between rolling periods 

and after the rollings were completed. 

The rolling process at Bethlehem Steel produced particles highly variable in size. For instance, 

there were spallation flakes that developed when the material was rolled. Large particles on the 

floor also likely became briefly airborne during cleanup operations, such as hosing down floors. 

This would provide another mechanism for large-particle surface contamination. The 

assumption in OCAS-TIB-009 that the “primary” source of ingestion via the hands is from fine 

particles settling on surfaces from the air (p. 2) is questionable because this misses the large 

particle pathway, which is likely to be more significant under the circumstances of Bethlehem 

Steel. 

These factors indicate that it is likely that surface dust directly deposited on food or ingested via 

hands becoming contaminated due to contact with contaminated surfaces consisted mainly of 

particles of relatively large size. The presence of large particles also raises questions about the 

assumption of equilibrium between deposition and removal assumed in OCAS-TIB-009, which 

is the basis for the Bethlehem Steel ingestion dose calculation. Finally, the assumption in 

OCAS-TIB-009 that food is covered all the time and therefore direct deposition on food need not 

be considered is not justified in view of the potential for large particle deposition. 

In view of the foregoing, the results in Table 4 are likely to be considerably underestimated; they 

are not claimant favorable. Further, Table 4 estimates are about 50 times less than the estimates 

in the procedure specified by NIOSH for dose calculations for AWEs working with uranium 

metal. 

Using the average of the distribution in Table 4, the total ingestion derived over 4 years of rolling 

calculated for rolling days amounts to only 7.0x105 pCi, which equals about 1 gram. This 

appears to be a considerable underestimate. For instance, in considering construction workers 

(not directly comparable but broadly similar due to the dusty environment at Bethlehem Steel), 

NCRP 129, Recommended Screening Limits for Contaminated Surface Soil and Review of 

Factors Relevant to Site-Specific Studies, Table 5.19, recommends a soil ingestion rate of 100 

mg per day by adults. This can be used as a point of reference for ingestion of workplace dust. 

The data in NCRP 129 indicate that inadvertent consumption of more than 100 mg of dust per 

day can occur without, for example, rendering food unpalatable (NCRP 1999). 

Not all the dust ingested via hands and deposition of large particles on food will be pure 

uranium, of course, but a large fraction can be expected to be uranium on rolling days. The 

NCRP 129 assumption of 100 mg per day can provide a reasonable upper bound for this part of 

the ingestion dose on rolling days. For 48 rolling days, the result would be 4.8 grams of uranium 

(NCRP 1999). Finally, ingestion of uranium particles also likely occurred on non-rolling days, 

since surfaces were not free of uranium once it was deposited. An argument can be made that 

ingestion doses via hands may have been as large or larger on the days immediately following 
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rollings due to suspension and re-deposition of large particles on work surfaces during hosing 

operations. 

Taken together, these factors are likely to have an upward effect on estimates of ingestion doses 

compared to the estimates in Table 4 of the TBD. The significance of these corrections would 

have to be evaluated by NIOSH and ORAU. 

3.6 FINDING 6 

The use of ICRP default particle deposition parameters is not claimant favorable for all 

organs. 

The following statement is made with respect to uranium mill health issues in Rolling Mill 

Report Hanford Works (General Electric 1950). 

The oxide, as it breaks loose from the rod surface, has a wide range of particle 

size all the way from flakes approximately 1⁄2′′ in diameter to particles so fine that 

they will remain airborne in still air for several hours. 

To the extent that fine metal uranium particles are not oxidized before they are breathed, with an 

AMAD smaller than 5 micron, a higher dose to systemic organs can be projected. Using the 

ICRP CD-ROM, Database of Dose Coefficients: Workers and Members of the Public (ICRP 

1998) the following results were obtained: 

• For Type F 234U – The 50-year committed doses for the adrenals (used as an 

example of a nonmetabolic organ) for 0.01 μm particles are 2.8 times higher than 

for 1 μm particles and 2.3 times higher than for 5 μm particles. The 50-year 

committed doses for the adrenals for 0.1 μm particles are 1.6 times higher than for 

1 μm particles and 1.3 times higher than for 5 μm particles. Similar results are 

obtained for bone surfaces. 

• For Type M 234U – The 50-year committed doses for the adrenals (used as an 

example of a nonmetabolic organ) for 0.01 μm particles are 2.7 times higher than 

for 1 μm particles and 3.7 times higher than for 5 μm particles. The 50-year 

committed doses for the adrenals for 0.1 μm particles are 2.2 times higher than for 

1 μm particles and 3.1 times higher than for 5 μm particles. Similar results are 

obtained for bone surfaces. 

• For Type S 234U – The 50-year committed doses for the lungs for 0.01 μm 

particles are 5.8 times higher than for 1 μm particles and 10 times higher than for 

5 μm particles. The 50-year committed doses for the lungs for 0.1 μm particles 

are 2.8 times higher than for 1 μm particles and 4.9 times higher than for 5 μm 

particles. 

Thus, neither a 5-micron nor a 1-micron particle size assumption is claimant favorable by itself 

under all applicable circumstances. Particle size and solubility considerations should be 
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examined for claimant-favorability with regard to the specific organ for which the dose is being 

estimated. 

3.7 FINDING 7 

The rationale for exclusion of external and internal dose from exposure to residual 

contamination is questionable. 

Rolling operations generate airborne radioactivity as demonstrated by the positive air samples 

taken at both Bethlehem Steel and Simonds. Following the rolling operations, the dust in the air 

would “fall out.” Given that uranium dust particles were created in the rolling and finishing 

operations, there is a potential for internal contamination in the equipment given that there 

apparently had not been any attempt at the time to dismantle the equipment and clean the inside. 

Equipment contamination is further indicated by analysis of grease samples, such as the one 

completed from the April 26-27, 1952, rolling (Heatherton 1952a). Simonds data, which are 

more plentiful, indicate that residual contamination was a concern between rollings (NYOO 

1949). 

The TBD does not include assignment of dose from potential exposure to residual contamination 

between and after the cessation of uranium rolling activities. On page 3 of 13, the TBD states: 

Because of material accountability procedures, scale, residue and cropped ends 

were collected and fine debris was vacuumed, packaged, and returned to the AEC 

(LaMastra 1976; Range 1976; ORNL 1980[a]; DOE 1985). Radiological surveys 

in 1976 and 1980 of the original facility and equipment, which were still in 

existence, identified no residual contamination above natural background levels 

(LaMastra 1976; ORNL 1980[a]; DOE 1985). 

Based on the 1976 and 1980 Formerly Utilized Sites Remedial Action Program (FUSRAP) 

surveys, the TBD indicates that residual contamination was not a source of exposure. The 1976 

and 1980 surveys are not relevant to the situation prevailing during the period when the rollings 

took place. The purpose of these surveys was to evaluate Bethlehem Steel for inclusion in the 

FUSRAP. The Survey of Rolling Mill Used by Bethlehem Steel Corporation, Lackawanna, New 

York issued in September 1980 by the Health and Safety Research Division (ORNL 1980b) 

states the following: 

The following conditions were present at the site of the bar mill at the time of the 

present survey: (1) the original bar mill used at the time of Atomic Energy 

Commission (AEC) activities was stored as scrap and was removed for recycling 

within the last six months; (2) the floor and pit where the bar mill was located 

during operations was covered by a new concrete floor varying in thickness up to 

a maximum of approximately 1 m; (3) the stand and shoe plates associated with 

the bar mill were removed and scrapped. The only remaining equipment at the 

Lackawanna Plant used during AEC activities is a shear used for cropping the 

3.8-cm uranium rods. However, the shear was not located in its original location 

at the time of AEC-related operations. 
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Maintenance and repair were performed on the equipment in the rolling mill over the period of 

operations, which means that original parts may not have existed in 1976 and 1980 when the 

surveys were performed. Performing surveys decades after the actual operations on equipment 

that may or may not have been used at the time of operations is not representative of the 

radiological contamination conditions during or immediately after operations. Area and 

personnel contamination surveys of the time would be more representative of the level of 

residual contamination. It is also relevant to note that the NIOSH Technical Information Bulletin 

ORAUT-OTIB-0004 utilizes a more claimant-favorable approach for addressing residual 

contamination. The decay constant for residual radioactivity persistence in the workplace 

assumed in that report is 0.01 per day. This means that residual contamination would be about 

2.6% after 1 year and less than 0.1% after 2 years. After two decades, no detectable 

contamination would be expected even if the original contamination was very high. We have not 

evaluated the validity of the decay constant as yet, but note here that the TBD is not consistent 

with other parts of NIOSH technical work. 

Limited survey data relating to surface contamination on and around the equipment before and 

after the cleaning following the September 1952 rolling are available (Heatherton 1952b). There 

are a number of limitations with respect to the September 1952 survey data: 

• The smear samples relate to only one rolling. 

• There are a limited number of survey samples available to demonstrate lack of 

contamination. 

• Direct survey readings have not been provided. 

• The exact location of the smears is unknown. For instance, the location of the 

floor samples is unknown. As another example, the roller stand samples do not 

identify whether the smear was taken on the roller or at a location near it that 

would be more representative of dust deposition on the clothing of workers. 

• The units of measure for the smears are listed in dpm/m3

 rather than activity per 

unit area. Details of the smear analysis (i.e., counting instrument and smear area) 

are not available, so recalculation is not possible to correct the problem. 

• The air concentration data during this rolling were lower than concentrations from 

previous rollings, ultimately affecting the level of contamination. 

The values identified in the “after cleaning” survey were higher than those of the “before 

cleaning” survey. But the nature of the “cleaning” – that is what was being cleaned – is 

unspecified on the sample sheets. The TBD contains no discussion or analysis of the sample 

sheets or even a reference to them. The sample values may have indicated less than the 

radiological control limits of the time, but these radiological control limits have not been defined. 

In light of the wrong units and lack of details that would enable recalculation of the 

contamination per unit area, the uncertainties related to sample locations, and the absence of 

direct survey measurements, reliance on the September 1952 survey to rule out exposure to 
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residual contamination is not scientifically appropriate or claimant favorable. In addition to 

these problems, there is also an absence of contamination survey values related to personnel and 

personal effects that would indicate potential exposure to individuals. 

Data from Simonds Saw and Steel indicate serious residual contamination. For instance, the 

Simonds Saw and Steel, Summary of the Three Surveys, October 27, 1948 to February 15, 1949 

(AEC 1949b) states (emphasis added): 

Readings were taken of the working area on October 27th and December 1st, 

during the period of rolling. The results of these readings show a considerable 

quantity of alpha radiation when the meter was held in direct contact with the 

floor. The readings on the floor in general vary between 10,000 and 40,000 

alpha disintegrations per minute on both of these days. Readings taken on the 

benches and desks in the area at the same time showed a concentration of 2500-

3000 alpha d/m. On February 15, during an interim period between two rolling 

cycles, a similar set of readings was taken. No uranium was being handled at this 

time. The readings at this time varied between 3,000 and 35,000 d/m, somewhat 

lower than the previous results but still showing a considerable degree of 

contamination. The results of these studies are shown in Table II. Beta and 

gamma readings that were taken coincident with the alpha measurements show a 

maximum of 15 mr/hr in direct contact with the floor. However, most of the 

readings are 2 mr/hr or less. It was found that the highest radiation 

measurements both in alpha and beta-gamma were found when the instrument 

was in direct contact with the dirt floor, which exists in many operating areas. 

The steel floor on which the rolling is carried out showed a much lower radiation 

figure (NYOO 1949). 

The referenced Table II of the 1949 Atomic Energy Commission (AEC) report, referring to 

Simonds data, is reproduced below for convenience. 

Table 2: Radiation Measurements in the Mill Area (Reproduction of Table II, AEC 1949b) 

During Rolling (10/27/48) During Rolling (12/1/48) After Rolling (2/15/49) 

α * βγ ** α βγ α

East Roller 1 50,000 10.0 12,000 1.0 12,000 

East Center Line 25,000 2.0 16,000 1.0 18,000 

East Bench 5,000 0.5 10,000 0.5 3,000 

Desk 2,500 --- 2,500 --- 2,500 

West Roller 2 15,000 0.5 11,000 --- 8,000 

West After Vacuum 5,000 0.5 11,000 --- --- 

West Roller 1 35,000 2.0 35,000 --- 3,000 

West Center Line 18,000 2.0 7,500 --- 5,000 

Furnace Area 50,000 12.0 80,000 15.0 10,000 

Shear 30,000 10.0 25,000 1.5 6,000 

West Bench 3,000 0.5 3,000 --- 2,500 

Shipping & Receiving 40,000 --- 30,000 4.5 --- 

* Values are in units of dpm/100 cm2. 

** Values are in units of mrep/hr. 
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These data from Simonds indicate that residual contamination on the ground a month-and-a-half 

after a rolling was only moderately diminished. The conclusion in the TBD that no significant 

residual contamination was present at Bethlehem Steel is questionable and deserves further 

consideration. 

Klevin (1950), in reference to Simonds Saw and Steel, states: 

Without major process modifications, it will probably not be possible to reduce 

airborne uranium during operations significantly below 150 micrograms/cubic 

meter (3x MPL). 

Klevin (1950) further states the following in regard to airborne concentration levels after 

cleanup. 

An airborne concentration of approximately 15 micrograms/ cubic meter 

(0.3xMPL) is the level below which it will be extremely difficult to clean the 

present plant between operations. 

These data indicate that workers outside regular uranium rolling periods experienced external 

beta-gamma radiation, as well as internal alpha radiation exposure. There is no comparable 

dataset from Bethlehem Steel. In light of this evidence from Simonds regarding residual 

contamination, the use of limited and questionable smear sample data or data taken decades after 

the end of rolling at Bethlehem Steel cannot be considered claimant favorable unless there are 

more and better smear data that are subjected to a rigorous analysis. In the absence of such data, 

which do not appear to be available, using data from Simonds in a claimant-favorable manner for 

making estimates regarding internal and external exposure during the periods between rollings 

and for a finite period after rollings ceased would be scientifically reasonable. 

Internal alpha radiation doses due to resuspension throughout the years 1949 to 1952 should take 

into account continuous exposure from residual contamination. Although dust levels due to 

resuspension are expected to be lower than the higher readings that occurred during the rollings, 

the time-integrated exposures between rollings may be higher given the longer time of exposure. 

A claimant-favorable assumption about the exposure time due to resuspension would be the 

entire working year. 

Internal doses from resuspension would also affect the period after the rollings were completed. 

Hosing down and other methods of partial cleanup would result in some attenuation of ground 

contamination after 1952. The rate of attenuation will be difficult to determine because the steel 

dust would be deposited on top of the uranium dust. Worker testimony and an examination of 

the literature regarding steel plant operation and maintenance of the time should be essential 

components in any attempt to estimate the attenuation rate. The unsettled question of the rollings 

that may have occurred in 1955 and/or 1956 will complicate this study. 

In summary, there is a potential for both internal and external doses from resuspension of 

residual contamination. The rationale for excluding doses from residual contamination is 

questionable. Dose reconstructions cannot be regarded as claimant favorable if residual 

contamination is not addressed more fully with representative data and analysis. 
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3.8 FINDING 8 

The external dose (beta and gamma) due to various modes of contact with uranium, 

including handling, inspections, finishing of the material, and heavy dust loading on 

clothing and skin, has not been evaluated in the TBD. 

The TBD discusses assignment of surface dose from beta emission, deep dose from photon 

emission, and external dose from submersion in uranium dust. Uranium and its daughters have a 

wide distribution of beta and gamma emissions. The radionuclide of highest dose consequence 

is 234mPa, which emits a 2.29 MeV beta (maximum energy) at a high yield. The contact beta 

dose rate for natural uranium is 230 mrad/hour per the TBD. The Guide to Good Practices for 

Occupational Radiation Protection at Uranium Facilities, Figure 6-3, (DOE 2000) states that the 

contact gamma dose rate is less than 10 mrem/hour. Although gamma radiation is not the 

primary external exposure hazard, the gamma dose rate can become significant in areas where 

large quantities of uranium are stored. In addition, the brehmstrahlung contribution from 234mPa 

can contribute a significant portion of the gamma dose. The D(0.07) dose rate from a slab of 

natural uranium metal at 1 cm is 1.99 mSv/hour (199 mrem/hour) with no shielding (DOE 2000). 

The use of an upper bound distribution to calculate external doses due to immersion in 

contaminated air is appropriate. However, the upper bound distribution in Table 3, as discussed 

in detail below, does not represent a maximum distribution that fully reflects available data and 

sound statistical analysis. Since Table 3 of the TBD does not reflect an upper bound distribution, 

the values in Table 5 of the TBD are correspondingly lower than they should be. 

Moreover, the doses from immersion in uranium dust do not account for the doses from the 

deposition of uranium on the exposed parts of the body and on clothing or on the skin when dust 

got under clothing. Workers have indicated that they did not secure their clothing to their 

person; therefore, it is expected that dust would deposit inside their gloves, if worn, and clothing. 

Dust would also settle in their hair and on their faces. Workers reused clothing, as they were 

required to provide their own clothing from home. Some individuals would wash their clothes a 

few times per week, but others would wear them until they wore out and discarded them. In 

some circumstances, gloves were not available or not worn due to the nature of the work. In a 

dusty atmosphere such as a steel mill, dust would settle on worker clothing and on uncovered 

parts of the body, such as faces and hands. This is indicated by the film badge study done at the 

Simonds facility (NYOO 1949). This route of exposure would likely exceed the immersion 

doses calculated in Table 5 of the TBD, notably for the skin and organs close to the skin surface, 

such as gonads. 

An experiment at Simonds was completed using film badges to ascertain the external radiation 

dose rate due to deposition of resuspended particles on clothing. Twenty badges were positioned 

at a height of 5 feet and exposed for 192 hours. The experiment was described as follows: 

In order to determine the long-term direct radiation to individuals, 20 film badges 

were suspended at about a five foot level from the floor and left in the area for a 

period of about 192 successive hours. When recovered, these badges were found 

to be coated with a considerable film of dust. Although this was blown off before 
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transshipment to the laboratory, it is undoubtedly true that a great deal of the 

reading found on the badges was a result of dust contact. The maximum 

radiation level found on any of these films was 5.6 mr/hr of beta or 0.34 mr/hr of 

gamma. In view of the intense local radiation that would be caused by a film of 

dust, it is felt that the hazard from the direct radiation in this operation is 

insignificant. (NYOO 1949) 

These measurements provide data for external beta-gamma radiation and for residual uranium 

that would be deposited on the skin and clothing of a worker. Workers were not issued 

coveralls, but wore their own clothing. As the steel plant was rough on clothing, workers would 

use the same clothing for as many as two to three weeks without washing or discarding them. 

Many would leave their clothing at the plant and change before going home and wear the same 

clothing the next day. Hence, the film badge experiment at Simonds might describe the doses 

due to dust deposited on skin and clothing. The shielding provided by clothing, especially in the 

summertime may have been minimal for some parts of the body. Workers sometimes 

unbuttoned their shirts; others, especially in areas far from the toilets, would use the vicinity of 

the workplace as a toilet. 

The film badge experiment indicates that external doses from resuspended uranium that is redeposited on clothing may be higher than the dose due to air submersion discussed in Table 5 of 

the TBD. As a result, external dose due to resuspended dust in periods between rollings requires 

further evaluation. The resuspension rate will be a critical parameter that will need to be 

evaluated for the specific circumstances prevailing at Bethlehem Steel. 

The Trip Report to Simonds Saw and Steel Co., Lockport, New York (Heatherton et al. 1957) 

states that, although there were no large quantities of radioactive material found in the plant, the 

dose rate readings were slightly above background in all areas. Dose rates at 3 feet from the 

floor were 0.2 mrep/hour beta/gamma. Given this dose rate from residual contamination, 

workers could receive 10 mrep/week assuming a 50-hour work week. The readings above were 

taken in July 1957 after the facility had discontinued its uranium rolling operations. Dose rates 

from residual contamination during the period the facility was involved in uranium rolling would 

likely be higher due to the gradual buildup of uranium dust. The contribution to external dose 

caused by residual contamination after the completion of all rollings has not been considered in 

the TBD. This evaluation should include internal and external doses. The rate of attenuation of 

the residual contamination from washdown and vacuuming of the floor would be a critical 

parameter. 

High exposure episodes may also have occurred, as for instance during air hosing of the area. 

Site experts indicate that air hosing occurred using a central compressed air supply. Vacuuming 

was apparently done using a mobile vacuum cleaner. 

Regarding exposure from proximity to uranium, page 8 of 13 of the TBD states the following: 

A triangular distribution for electron exposure from uranium was determined in 

the following manner: 
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• The minimum was estimated by assuming the worker was 1 meter 

from an extended uranium source for 1 hour (per 10-hour shift). 

The estimated dose rate for this scenario was 90 mrad/hour (US 

Army 1989). 

• Survey data of the Simonds facility were used to estimate the mode. 

The highest value measured during those surveys was 15 mrad/hr 

(AEC 1949b). To be claimant favorable, this dose rate was 

assumed for an entire 10-hour shift. 

• A maximum value was estimated by assuming the worker was 0.3 

meter (1 foot) from an extended uranium source for 6 hours (150 

mrad/hr) and 1 meter away for 4 hours (90 mrad/hr). 

The highest measured value during surveys performed at Simonds from October 1948 through 

February 1949 was 15 mrad/hour (NYOO 1949). The measurements referred to were taken in 

direct contact with the floor. These measurements did not include survey points in the 

immediate vicinity of the stored uranium or uranium undergoing processing. The 15 mrad/hour 

dose rate, therefore, may not be indicative of process or finishing area dose rates and it should 

not be represented as such. 

The TBD assumes a triangular distribution for external exposure. The maximum parameter is 

determined by assuming a worker would be exposed to 150 mrad/hr for 6 hours and 90 mrad/hr 

for 4 hours. The shift total for this scenario is 1,260 mrad for a 10-hour shift. The mode is 

assumed to be 150 mrad and the minimum 90 mrad for a 10-hour shift. The average value for 

this distribution would be 500 mrad per shift. A worker in direct contact with natural uranium 

could receive beta exposure at a rate of about 230 mrad/hour shallow dose and less than 10 

mrem/hour deep dose. Many jobs required direct contact with uranium during rolling operations. 

Other operations required the worker to be in close proximity (within 1 foot) of the uranium. 

This was especially true for inspectors, chippers, scarfers, rollers, shearers, straighteners, and 

others involved in finishing work. The goal was to produce a billet within a tight tolerance, so 

all abnormalities on the billet would have to be examined and fixed. Given the nature of this 

work, it was not uncommon to handle material being rolled. Taking into account the surface 

dose rates for natural uranium, which is the claimant-favorable assumption, the maximum 

shallow and deep doses are underestimated by the current methodology in the TBD. 

A number of special external exposure conditions were identified by site experts, which were not 

considered or mentioned in the TBD: 

• Two to three men manually transferred billets against their abdomen to the 

secondary work area. 

• Straighteners were responsible for correcting bends or bows in the uranium. 

• Grinders removed jagged edges or seams to correct imperfections in the uranium. 
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• Furnace men worked in and around the furnaces to repair holes. 

• Guide setters, assistant rollers, and rollers were required to adjust the mills while 

they were rolling, placing them within 1 foot of the material. 

• Inspectors were involved in near proximity or contact evaluation of the billets. 

• Chippers and scarfers used air guns and torches, respectively, to eliminate slag or 

impurities from the uranium. 

• Individuals loaded and unloaded billets and ingots from the trucks or railcars. 

• Workers were involved in cleanup of the scale pits. 

• When cobbling occurred, the line was stopped and the cobbles had to be manually 

removed from the rollers. 

The workers at Bethlehem Steel were not told that they were working with uranium. Therefore, 

they did not know the additional precautions that needed to be taken to avoid radiation exposure. 

They were not trained in the principles of time, distance, and shielding, and did not realize that 

more pronounced beta exposure would result if they were in direct contact with the metal. What 

the workers knew was that this material had to be rolled to very strict tolerances. Mill and 

secondary area workers were in close proximity to (< 12”) or in contact with the uranium oxide 

on a frequent basis. The length of time during a shift they were in contact with the uranium 

metal depended on their specific job. In determining a maximum value for external exposure, 

this direct contact should be taken into account. These routes of external exposure, which are not 

specifically addressed in the TBD, may be especially significant for some nonmetabolic cancers, 

such as skin cancer and cancers of male genitalia. 
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4.0 OBSERVATIONS 

SC&A made a number of observations identified in its review of the Bethlehem Steel site profile 

and the supporting technical information bulletin. These observations relate to technical and 

process questions or issues concerning the completeness of data sources, technical accuracy, and 

adequacy of data. There were no observations related to regulatory compliance. 

4.1 OBSERVATION 1 

The input of the site experts has not yet been adequately evaluated to determine the impact of 

dose reconstruction efforts. 

Site expert information provided valuable understanding of operating conditions and non-routine 

occurrences. Input from site experts was not investigated and integrated into assumptions used 

for determining worker dose when the technical basis document (TBD) was first prepared, and 

with the exception of ingestion dose, when it was revised. This was an important contributor to 

some of the gaps and deficiencies that were identified in the TBD. Although a worker meeting 

was scheduled to be held in Hamburg, New York, on July 1, 2004, to allow workers to provide 

input with respect to the Bethlehem Steel TBD, NIOSH Revision 1 was issued on June 29, 2004. 

In addition, during the conference call with the audit team (see Attachment 1), NIOSH only 

stated that it was “reviewing this [July 1 meeting] information and looking for documentation to 

back up worker testimony.” NIOSH did not indicate specific plans to update the TBD based on 

information provided in Hamburg, such as those related to incidents like cobbling and related 

handling of uranium. 

4.2 OBSERVATION 2 

A comprehensive records search of relevant rolling operations documents was not performed to 

investigate worker testimony regarding additional rollings after 1952. 

Page 3 of 13 in the TBD describes rolling processes as follows: 

The rolling experiments generally took place on weekends because the mills were 

in full use 5 days per week. The work only involved the 10-in. bar mill and 

associated billet preparation and handling equipment (LaMastra 1976; Range 

1976; Thornton 1977; ORNL 1980[a]; DOE 1985). 

In Table 1 of the TBD, the number of rollings identified through documentation includes four 

experimental rollings, eight production rollings, and an additional rolling of unknown type. 

These rollings were performed from April 1951 through October 1952. In the absence of 

documented data, one rolling per month was assumed for 1949 and 1950 equating to 120 hours 

of exposure. In 1951 and 1952, a total exposure period of 130 and 110 hours, respectively, was 

assumed. Per the August 12, 2004, conference call between NIOSH and SC&A, NIOSH 

indicated that the assumption of 48 rollings is considered claimant favorable. 

Documentation clearly states that a contract was in place between Bethlehem Steel and the AEC 

in 1949: 
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In 1949, the U.S. Atomic Energy Commission (AEC) contracted with Bethlehem 

Steel Corporation (BSC) to develop improved rolling mill pass schedules. BSC 

conducted this work under contracts AT(30-1)-1279 and AT(30-1)-1156, which 

were subcontracts with National Lead of Ohio (DOE 1985). The pass schedules 

were for the rolling of 5-in. natural uranium billets into 1.5-in. rods for use in 

nuclear reactors (LaMastra 1976; DOE 1985) for production of plutonium. 

The absence of documentation from 1949 to 1950 for specific rollings creates an uncertainty 

about how many rollings were done in those years, rather than whether they were done. 

Therefore, it is difficult to assess whether the assumption of rolling on a single day per month in 

1949 and 1950 can be considered claimant favorable for those years. The assumption of 12 

rollings in 1949 and another 12 in 1950 is reasonable and may be claimant favorable in light of 

1951 and 1952 data. But there is no conclusive evidence that this assumption is actually 

claimant favorable. This reservation should be seen in light of the considerable acceleration in 

the U.S. nuclear weapons program that took place in the aftermath of the first Soviet nuclear 

weapon test on August 29, 1949. Overall, the total of 48 rollings can be considered reasonable 

and may also be considered claimant favorable for this period in light of available information in 

the April 1951 to October 1952 period. However, this claimant favorability cannot be definitely 

established, due to missing records and documents. 

The assumption about 48 rollings during the 1949-1952 period and its presumed claimantfavorability should not be used to make any statements outside of that period. Specifically, the 

summary provided in the elimination report states that the project was completed in 1952. This 

conclusion was reached without the benefit of site expert interviews and supporting 

documentation. The TBD acknowledges that there may have been some rolling in 1955, 

according to a letter from Paul Kansanovich (Compensation Agent, L.U.) to Robert Anderson 

(Bethlehem Steel) in 1979. Two former Bethlehem Steel employees have provided statements 

that uranium rollings took place at Bethlehem Steel in 1955 and 1956. These rollings are not 

being considered in the dose reconstruction, as they are outside the qualifying years of 1949-

1952. No documentation has been located with respect to post-1952 rollings, either in support of 

or in contradiction to the workers’ accounts. The decision to rule out rollings beyond 1952 is not 

a claimant-favorable assumption. 

Further, one site expert raised the possibility that National Lead of Ohio may have subcontracted rolling to Bethlehem Steel when their rolling mill was down and they needed to meet 

production quotas. Also, until the Fernald records center is searched for any pertinent records 

for these operations, the completeness of the records reviewed is questionable. NIOSH has 

claimed that the rollings in 1955 might have been of Navy material and would therefore not be 

covered under Energy Employee Occupational Illness Compensation Program Act of 2000 

(EEOIPCA). Such a supposition is inappropriate in the absence of evidence. 

There was an incomplete investigation of rollings at the Bethlehem Steel site. Although a search 

for records pertaining to Bethlehem Steel was performed at the Fernald records center, the DOE 

Office of Worker Advocacy, the Environmental Measurements Laboratory records storage, DOE 

Headquarters, and the DOE Germantown records facility, an equivalent search was not 

performed at other DOE facilities and records repositories. Given that the AEC managed the 
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inventory of uranium, Mallinckrodt Chemical Works may have a record of uranium supplied to 

the steel mills. Hanford, Chalk River Experiment, and the Savannah River Project, which 

received uranium billets for analysis and/or use (NLO 1952a), may also have records of receipt 

of this material. Argonne National Laboratory and DuPont may have been involved as 

demonstrated by their participation in the uranium rolling meeting held May 28, 1951 

(McCrosky 1951). A review of physical inventory records at these facilities may provide a more 

complete history of the rollings at Bethlehem Steel and other Atomic Weapons Employer (AWE) 

sites. 

In the preliminary record collection for evaluation of the site profile, several records were 

identified at the Hanford Declassified Document Retrieval System (DDRS). In these reports, 

they discuss the rolling of uranium at both Bethlehem Steel and Allegheny-Ludlum Steel. 

Additional reports from other sources also provided information on rollings at Bethlehem Steel. 

For example, Trip Report: Experimental Rolling of Thirty Tons of Uranium by the Simulated 

Fernald Process (Hanford Works 1952) indicates that 30 tons of case uranium billets were rolled 

to Hanford diameter at Allegheny-Ludlum Steel and Bethlehem Steel on February 16, 1952. 

This date is not included in the listed rollings and indicates that an exhaustive records search was 

not completed, as this document was available in the public domain. (SC&A notes that a rolling 

for February 1952 was added as an assumption in the TBD. The comment here applies only with 

regard to a lack of completeness in the search of relevant records and the potential for additional 

rollings to be found, if such a search were conducted.) Workers have also suggested that records 

may be available at the Saylorsburg, Pennsylvania, records storage facility of the former 

Bethlehem Steel Corporation. 

SC&A recognizes that the period for which workers are covered is not determined by NIOSH, 

but by the DOE. However, NIOSH can refer information and evidence to the DOE to consider 

as a basis for extending this period. While the worker testimony is uncorroborated by 

documentation so far, the document search is not complete. Therefore, a reference of the matter 

to the DOE for further evaluation and a more complete document search appears appropriate, 

especially given that there is an indicated willingness to provide testimony under oath. 

4.3 OBSERVATION 3 

The assumption of 10 hours of work per day may not be claimant favorable based on available 

documentation and statements provided by site experts. 

With respect to the length of exposure applied for internal and external dose calculations, page 5 

of 13 of the TBD states: 

The number of exposure hours per year was determined by assuming 12 10-hour 

workdays per year for 1949 and 1950. This assumption is conservative 

considering no documentation indicates any rollings took place during those 

years. If there were rollings, it is assumed they took place only on weekends. 

Reports from 1951 and 1952 indicate that, with the exception of the April 1951 

(Summary 1951), August 1952 (Bowman et al. 1952), and September 1952 
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(Schneider and Yocce no date) rollings, rollings occurred on only one weekend 

day per month. For 1951, an additional 10 hours was added to account for the 

additional weekday in April, resulting in 13 10-hour workdays. For 1952, in 

addition to the eight documented rollings, it was assumed that one rolling each 

took place in February, May, and June, resulting in 11 10-hour workdays. 

A 10-hour workday was assumed during rollings. However, the time to complete the rollings 

was dependent on the problems (e.g., salt bath leaks, cobbling, secondary finishing work) 

encountered during operations. Information from various reports (Hanford Works 1951 and 

1952, NLO 1952b and 1952c) indicates that cobbling frequently occurred during rollings, 

lengthening the time it took to complete the operations. Rolling and finishing operations were 

followed by cleanup. If cobbling took place in the first half of the stands, the recovery time 

could be several hours. Workers reported that they worked from 8-16 hours during these 

rollings. The assumption of 10-hours per day exposure may not be uniformly claimant favorable 

based on statements provided by several site experts.

4.4 OBSERVATION 4 

The TBD has not considered several pathways of internal exposure resulting from incidents such 

as cobbles, repairs of furnaces, salt bath leaks, and uptake via injuries (i.e., burns, cuts, scrapes). 

The TBD focuses on the potential internal exposures from routine operation of the rolling mills. 

Incidents at the facility were common and included formation of cobbles and subsequent 

mitigation, salt bath leaks, furnace repairs, and loss of uranium. The basis for the maximum 

value was an air sample taken adjacent to a rolling stand at Simonds Saw and Steel. This would 

not necessarily be representative of the exposures received during incidents and/or routine 

occurrences. Although the intent of the TBD is to address most of the claimant situations, there 

is no indication in the TBD when individualized dose estimates must be considered. 

4.4.1 Cobbles 

Uranium was more difficult to roll because it was not heated to as high a temperature as steel. 

During uranium rollings they often had what was called a cobbling. A cobbling results from a 

misfeed or a jam by the metal. When a cobble occurred, the workers had to clear the area to 

prevent burns from flying metal. A crane had to remove the cobble and workers with “hot 

gloves” would cut it into pieces with a torch until the mill was cleared. As the cobble was 

burned into small pieces, it also created slag and drips. The mill would not continue to operate 

when a cobble was in a roller. The time to remove the cobbles varied from 10 minutes to several 

hours. 

The potential routes of exposure include inhalation, direct incorporation of uranium metal and 

oxide fines via burns and scratches, and direct contact with uranium metal. The rods would have 

had some oxide scale. In addition, as the metal was being burned, it created metal oxide fines 

and metal fumes in close proximity to the worker. The lack of long-term breathing zone data 

increases the importance of taking these incidents into consideration. The triangular 
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distributions employed in the site profile do not necessarily capture the exposures associated 

with these incidents.

4.4.2 Salt Bath Leaks 

Salt baths were contained in steel pans held together by welds. These welds failed resulting in 

leakage from the salt baths. The salt baths were lined with fire brick and workers occasionally 

had to replace this brick (NLO 1952a). The leaks resulted in a cessation of work until repair and 

cleanup of the leaks were completed. This may have created exposure potential outside of the 

times required for rolling. 

4.4.3 Furnace Damage 

Two types of furnaces were used at Bethlehem Steel. A permanent furnace was used for the 

normal rolling process. A temporary furnace was used for billets that were received in 

“roughed” form from other steel mills. This was required because the billets were started at the 

finishing stands and not at the beginning of the process. The temporary furnaces had to be 

removed upon completion of the rollings. 

Occasionally there was a burnout or leak in the furnace. A group of workers were responsible 

for temporarily repairing holes or leaks while the mill was still operating. Once the mill was shut 

down for maintenance, the bricklayers could enter the furnace to complete a more permanent fix. 

This likely resulted in internal exposure from excessive amounts of dust and external exposure 

from direct contact with and submersion in uranium dust. 

4.4.4 Loss of Uranium 

During the August 27, 1951, uranium rolling operations, 100 lbs of oxide fell to the floor during 

air-cooling. Blisters of about 0.1 inch appeared at the point where the rod rested on the rails. 

The surface oxidized (Hanford Works 1951). It is not clear from the report how much of the 

uranium was recovered. In addition, uranium that fell into inaccessible places was not retrieved. 

The average loss per billet was determined by the weight difference between the ingot or 

roughed billet and the final billet. The average total loss of uranium was estimated at 88-94 lbs, 

depending on whether a round or square ingot was rolled (NLO 1952b). This indicates 

significant potential for large flake deposition on food, exposure between rollings and after the 

completion of rollings, and exposure to workers cleaning scale pits outside of the times when 

rollings were occurring. 

The air concentration distribution discussed in Findings 2 and 3 above applies directly to days in 

which rollings were done. The selected distribution of airborne dust concentrations at the facility 

represents an average distribution over time and space. Measurements from all over the facility 

(and in the case of NIOSH Table 3, from two facilities) are used in the TBD to construct a 

composite distribution. When actual individual exposure measurements are available at a 

facility, the range of individual mean exposures usually is quite broad, with a long tail due to 

infrequent, unanticipated "events" that result in high exposures to a few individuals. However, 

breathing zone data are not available in these cases. Therefore, the use of a facility distribution 

based on available plant-wide data may not be favorable to the claimant, unless specific steps are 
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taken to ensure that the chosen parameters actually include representation of the worst conditions 

that any single worker could have experienced. 

Among the cautions regarding the use of Table 3 for maximum doses should be a discussion of 

unusual work conditions that are not captured in air concentration data. Working in and around 

contaminated furnace areas is one example. NIOSH should therefore create a list of unusual 

working conditions as well as high hazard workplace areas, such as at rollers, furnaces, and 

secondary processing. This list can guide those who take worker interviews to assure that 

relevant information is solicited about these items. If these conditions apply to the dose 

reconstruction at hand, then specific adjustments will have to be made to the calculated dose 

using a combination of available data and analytical techniques. 

4.5 OBSERVATION 5 

The TBD makes no distinction between routine dose assignment conditions and unique exposure 

conditions, such as high-risk work (e.g., loading and unloading of uranium, routine maintenance 

of equipment, clean out of pits). 

Although the TBD is not considered all-inclusive, there is no reference to those activities that 

may require individualized dose reconstruction. There were a number of jobs performed in the 

steel mill. The relative exposure potential was highly dependent on the job an individual was 

performing. Many jobs required direct contact with uranium or work in the immediate vicinity 

of the metal. Those who were involved in rolling uranium and performing secondary finishing 

work, which involved machining on the metal, were likely exposed to a higher concentration of 

dust and scale than the average worker. Those workers who were very near rollers may have 

been exposed to even higher dust concentrations. 

There were cropping and cutting operations involved with uranium bar production as a part of 

routine operations or with failure of the bar to form. Cropping and cutting generated uranium 

dust resulting in a potential internal exposure. To the extent that this occurred during rolling 

hours, the dust concentrations would be part of the assumptions about workplace environment 

made by NIOSH and ORAU. However, cropping and other specific operations performed by 

particular workers raise the difficult statistical problem of how facility data on air concentrations 

and even workplace data on concentrations (some of which are available for Bethlehem Steel) 

can be translated into statistically defensible individual dose estimates. 

Cleanup and maintenance workers had a higher potential for inhalation of dust. Uranium billets 

were hosed down with water as the rolling was being done to wash off the scale. The steam 

dissipated into the air and the scale and dust were flushed into a sub-basement. The pits were 

cleaned out, likely resulting in exposure to cleanup workers, crane operators and railroad 

workers. Site experts indicated that the scale pit was manually shoveled about once in six 

months, perhaps creating an increase in the potential for exposure. The scale pit was cleaned out 

with a crane about once a week. This is based on site expert statements. Workers also 

participated in other cleanup activities, such as blowing lime off the walls, sweeping and/or 

vacuuming uranium dust, and cleaning out salt baths. These activities likely resulted in exposure 

to dust and material mixed with uranium. Further investigation is necessary regarding this issue. 
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Specifically, an evaluation of the validity of air sample data for specific workstations, including 

rolling stands, is needed, since spraying may result in a rapid falloff of air concentrations. This 

is indicated by a comparison of samples L709, L710, and L711 with sample L712 in the October 

27, 1948, Simonds dataset (see Table A4-1 in Attachment 4). 

4.6 OBSERVATION 6 

There is no mention of estimates of dose from environmental releases in the Bethlehem Steel 

TBD as there are in subsequent site profiles, such as those completed for Mallinckrodt Chemical 

Works, Savannah River Site, and Hanford. 

The lack of consideration of environmental doses for Bethlehem Steel is inconsistent with other 

site profiles that use environmental dose to assign dose to non-monitored workers who were not 

likely to receive exposure to radioactive material. The typical mode of disposal at the steel mill 

was to discharge waste to the air, ground, and to Lake Erie. Based on the policies and practices 

at Bethlehem Steel, there was a potential for environmental release and therefore environmental 

dose to workers. The contribution of this factor on dose outcomes is not clear, but should be 

further investigated. Regardless of whether this is determined to be a significant issue or not, it 

should be addressed in the technical basis document, if only briefly. 

4.7 OBSERVATION 7 

The Bethlehem Steel TBD assumes workers were given chest x-rays in a period of time when 

photofluorography was a prevalent technique. 

The assumption was made that Bethlehem Steel workers received annual chest x-rays based on 

documentation for Simonds Saw and Steel facility (Simonds 1948). A conventional chest x-ray 

posterior-anterior (PA) view rather than photofluorography (PFG), which was a standard 

technique during the years 1949-1952, was assumed with a default value of 0.2 cGy for dose 

calculations. Lateral views of the chest were also not assessed. It would be more claimant 

favorable to assume that workers on site during the covered period had photofluorographic 

examinations in the absence of evidence to the contrary. A review of the actual x-rays would 

indicate the type of x-ray given (i.e., 14 x 17 for PA chest x-rays, 35 mm film for 

photofluorographic units). The entrance skin kerma dose for photofluorography ranges from 

1-3 cGy, which is higher than the estimated doses in Table 7 of the TBD. ORAUT-OTIB-0006, 

Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedures (Kathren et al. 

2003), the generic DOE document for occupational medical x-rays, assumes a default value of 3 

cGy. If the use of photofluorography is ruled out, it should be based on positive evidence and 

documented in the TBD. 
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5.0 PROCEDURAL CONFORMANCE 

The dose reconstruction process must comply with the requirements of 42 CFR 82. As a method 

of effectively implementing these requirements, the National Institute of Occupational Safety 

and Health (NIOSH) has written technical guidance documents on external and internal 

dosimetry. Oak Ridge Associate Universities (ORAU) has committed to the use of these 

guidance documents in its quality assurance program plan. The issues identified below are cited 

circumstances where the Bethlehem Steel technical basis document (TBD) is not consistent with 

the guidance outlined in NIOSH’s external dosimetry guidance document. 

5.1 PROCEDURAL CONFORMANCE ISSUE 1 

The TBD did not take into account ICRP 75 in assessing the validity of air concentration data for 

estimating individual worker doses. 

ICRP 75 makes specific recommendations about the use of air concentration data of the type 

available for Bethlehem Steel and Simonds; that is, short-term air samples that are not true longterm breathing zone data for assignment of individual dose. Only two of the 38 Simonds 

samples are marked as breathing zone. Some of the Bethlehem Steel samples are marked as 

breathing zone, while others are general air. It is unclear whether any of the samples marked as 

“breathing zone” were actually breathing zone samples, such as those obtained by using lapel 

samplers. ORAUT-OTIB-0004 (p. 4) indicates that air samples of the time were not true 

breathing zone samples. All were short-term samples; in most cases they were a few minutes or 

a few tens of minutes. ICRP 75 addresses the accuracy of air samples for individual worker 

intake of radionuclides as follows: 

Two sources of airborne contamination are particularly important: localized 

releases, and the resuspension of surface contamination. Both can be directly 

generated by the work activities of individual workers. Airborne contamination is 

often localized and transient. In particular, there can be very significant 

differences between the activity concentration in the breathing zone of a worker 

and the level measured at some nearby fixed location, the concentration in the 

breathing zone usually being higher.... 

When area samplers are routinely used for quantitative determinations of intake, 

the representativeness of the results should be determined using a special 

monitoring program, often involving personal air samplers. Conversion factors 

relating the area measurement to the concentrations in the immediate breathing 

zone should be established and reviewed from time to time and after any 

significant changes to the operations. Despite this correction, area samplers, 

even if located close to the breathing zone of workers, may not always provide 

data that adequately represent the intake of each individual worker. This is 

particularly true in cases where the air contamination sources are localized and 

variable with time, often because they result from the workers’ own actions or 

movements.
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ICRP 75 further cautions that air samples, such as personal air samplers, can have a bias; 

therefore, long-term averages, rather than single results from a shift or even a week, are 

preferable (ICRP 1997). 

The TBD relies on the air samples to determine worker dose, and therefore should consider the 

accuracy and applicability of the air sample data. This is especially important given the limited 

nature of the data. The available air samples indicate that air concentrations were highly 

localized and variable with time. These are both situations in which a critical assessment of air 

concentration data is recommended. Moreover, critical evaluation of the Bethlehem Steel air 

data along the lines above is especially important because of the spraying of water on the 

uranium in the context of a lack of complete ventilation. 

Some sample calculations illustrating the kinds of adjustments that may be made to the data in 

light of ICRP 75 are discussed in Attachment 4. As noted there, these adjustments will 

inevitably contain a substantial amount of judgment, especially in light of the facts that (1) much 

of the Bethlehem Steel data is missing (such as data for 1949 and 1950) and many documents 

and records have been destroyed, (2) Bethlehem Steel air samples also show high variation in 

time and workstation location, making the available data more difficult to interpret with 

confidence, and (3) the Simonds facility is only broadly comparable to Bethlehem Steel and has 

only one usable dataset. 

Available data can be adjusted in a number of different ways in light of the ICRP 75 

recommendations above. The different methods of adjustment yield widely divergent results. 

This raises the issue of whether it might be more defensible to proceed in a different manner – 

that whether all AWEs uranium metal working should be treated as a group and making 

claimant-favorable choices in that context. NIOSH has done this in ORAUT-OTIB-0004, but 

this document was not used in the TBD. 

5.2 PROCEDURAL CONFORMANCE ISSUE 2 

The TBD did not take into account the more claimant-favorable methodologies set forth for 

metal working AWEs in ORAUT-OTIB-0004 (Anderson 2003). As a result, the maximum dose 

estimates for Bethlehem Steel are underestimated in the TBD as compared to that derived in 

ORAUT-OTIB-0004. 

ORAUT-OTIB-0004 was written explicitly for uranium metal working AWEs, and therefore 

applies to the Bethlehem Steel case. It defines its applicability as follows (p. 3): 

The processes at these facilities included reduction and recasting, rolling, 

machining, and extruding of uranium, fuel element fabrication, scrap recovery, 

and recovery of uranium from phosphoric acid. A large number of the facilities 

handled uranium metal. The facilities relevant to this document were privately 

owned and the AEC work was done on a part-time basis or in addition to their 

normal commercial operations. 

This document applies only to facilities that handled uranium metal and is not to 

be used for facilities that processed thorium, radium, or uranium ores. The intake 
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and dose rates in this exposure matrix are to be used in conjunction with the 

individual worker’s covered employment dates, date of birth, and date of cancer 

diagnosis. If it is necessary to pro-rate intake and dose rates, it is acceptable to 

use values for a full year as this is an over-estimation and, thus, claimantfavorable. Because worker bioassay and dosimetry data cannot be ignored, the 

worker’s data, if available, should be reviewed and it should be ensured that a 

dose reconstruction based on this exposure matrix is an overestimate and is, 

therefore, a claimant-favorable approach. 

The Appendix to ORAUT-OTIB-0004, which lists the facilities to which it is applicable, 

specifically includes Bethlehem Steel. Revision 1 of the Bethlehem Steel TBD was published on 

June 29, 2004, more than six months after ORAUT-OTIB-0004 was published. Therefore the 

revised Bethlehem Steel TBD should have fully investigated the methodologies used for dose 

determination in ORAUT-OTIB-0004 as compared to the TBD. 

SC&A will be reviewing the methodologies outlined in ORAUT-OTIB-0004 as part of the Task 

3 review of procedures. The comments here are therefore limited in nature as they specifically 

apply to the Bethlehem Steel TBD. Following the review of ORAUT-OTIB-0004, further 

consideration will have to be given to incorporating the recommendations into this procedure and 

other affected technical documents. 

There are important issues that are covered in ORAUT-OTIB-0004 that are not addressed in the 

Bethlehem Steel TBD: 

• ORAUT-OTIB-0004 recommends that a 2,000-hour work year be used, even 

when the metal working only occurred part-time. It explicitly states that “the 

operations at the facilities for which this document is applicable were smaller, 

mostly part-time operations” (p.4). This issue clearly applies to Bethlehem Steel. 

• ORAUT-OTIB-0004 recommends that a uranium dust level of 100xMAC be 

adopted for the entire year (p. 4). The TBD should have investigated whether this 

is more claimant favorable than the procedure adopted in Table 3 of the TBD. To 

be specific, the estimated exposure over four years (1949 to 1952) to 

contaminated air based on the average concentration derived from Table 3 of the 

TBD is 160,320 MAC-hours (334xMAC times 48 days of work at 10 hours per 

day). In contrast, ORAUT-OTIB-0004 yields an exposure estimate of 800,000 

MAC-hours for the same period. 

• Applying the full work year to part-time operations may allow for indirect 

consideration of resuspended uranium, as indicated on pg. 8 of ORAUT-OTIB0004. However, whether it does so in the specific instance of Bethlehem Steel is 

an open question that requires analysis. 

• ORAUT-OTIB-0004 notes that “early exposure studies were not very selective in 

terms of particle size (Stannard 1988). Also, the air concentration measurements 

represented the amount of uranium in the air where the workers were located, but 
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not necessarily what was taken into the lung or the body” (p. 4). Therefore the 

recommendations of ICRP 75 regarding air samples apply. SC&A will review 

this question generically as part of Task 3. For the Bethlehem Steel TBD, the 

appropriate procedure would be to compare the dose derived from uranium dust 

levels, expressed in terms of MACs over 2,000 hours, recommended in the TBD 

with the sum of claimant-favorable dose from a technically and statistically sound 

analysis of the October 27, 1948, Simonds dataset, and resuspension data from 

Simonds, as discussed above. The more claimant favorable of the two should be 

used in the Bethlehem Steel TBD. 

• ORAUT-OTIB-0004 makes provision for post-rolling doses from resuspended 

uranium. The Bethlehem Steel TBD does not cover this. This item should be 

included in the TBD. The specific parameters recommended in ORAUT-OTIB0004 for post-rolling exposure would need to be evaluated in light of residual 

contamination data from the Simonds facility. SC&A will evaluate post-rolling 

parameters (notably the decay parameter of 0.01 per day) as part of its Task 3 

review. 

• Table 4 of the Bethlehem Steel TBD takes ingestion doses into account only for 

days on which rollings took place (12 or 13 days per year). In contrast, ORAUTOTIB-0004 includes ingestion doses for 250 days per year. The annual ingestion 

of 3.14x106 pCi/year estimated in ORAUT-OTIB-0004 is about 50 times greater 

than the annual intake estimate indicated by the average of the triangular 

distribution in Table 4. SC&A notes that the ORAUT-OTIB-0004 estimate would 

be more claimant favorable than Table 4 of the TBD. However, SC&A 

recommends that the TBD take specific account of large particles and flakes 

settling on food in its evaluation of ingestion doses from rolling operations as 

noted above. An assessment of ingestion doses for the entire working year during 

and between rollings, taking flakes and large particles into account, is beyond the 

scope of this review. The same applies to post-rolling ingestion. 

The use of the general approach specified in ORAUT-OTIB-0004 in the case of Bethlehem Steel 

has the advantage of bypassing many of the difficult issues relating to the statistical 

representation of the highly incomplete Bethlehem Steel datasets and the application of the 

Simonds October 27, 1948, dataset to Bethlehem Steel. These issues are discussed in more detail 

in Attachment 4. We have not evaluated the specific parameters chosen to represent all uranium 

metal AWEs as part of this review, since they are beyond its scope. However, the general 

approach does suggest itself as potentially more defensible in that data from many facilities are 

being used to create a claimant-favorable approach. We would note one caution in this context. 

The application of any approach that is general, whether of a facility air concentration 

distribution or a set of parameters across AWEs, raises the risk that some workers in especially 

high-risk jobs (or high-risk facilities) may not be treated in a claimant-favorable way. Therefore, 

we note in this context as well, that a list of high-risk jobs and incidents for Bethlehem Steel 

would be a useful guide for individual dose reconstruction whatever approach may be chosen for 

estimating doses. 
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5.3 PROCEDURAL CONFORMANCE ISSUE 3 

42 CFR 82 requires that efficient approaches to estimating doses when compensation is denied 

should be worst-case estimates. The maximum dose estimation procedure in the Bethlehem 

Steel TBD is not defensible as a worst-case estimate that can be used to deny compensation. 

42 CFR 82.10(k)(3) requires NIOSH to make worst-case assumptions in cases where an efficient 

procedure is used to deny compensation: 

(3) Research and analysis indicated under steps described in paragraphs (f)–(j) of 

this section have been completed. Worst-case assumptions will be employed 

under condition 2 to limit further research and analysis only for claims for which 

it is evident that further research and analysis will not produce a compensable 

level of radiation dose (a dose producing a probability of causation of 50% or 

greater), because using worst-case assumptions it can be determined that the 

employee could not have incurred a compensable level of radiation dose. 

A review of two individual dose reconstructions for Bethlehem Steel indicates that NIOSH is 

using Table 3 of the TBD as the basis for satisfying the requirements for compensation under 42 

CFR 82.10(k)(1) “cumulative dose is sufficient to qualify the claimant for compensation (i.e., the 

dose produces a probability of causation of 50% or greater”), and also for “worst-case” 

calculations resulting in denial under 82.10(k)(3) above. While the use of the TBD under 

82.10(k)(1) for making affirmative compensation decisions is appropriate because Table 3 does 

not make worst-case assumptions as discussed in detail in the Findings above, its use for denial 

is inappropriate for the same reason. The workplace air concentration data for Bethlehem Steel 

are grossly incomplete. There are no data available for most rollings. Air concentration data are 

short-term samples that should not be used without the necessary adjustments based on ICRP 75. 

It will be very difficult to do this, given the incomplete nature of the Bethlehem Steel data. The 

data from a comparable facility (Simonds) are useful, but limited to one day of comparable data, 

with at most three samples from any specific location. Moreover, as previously noted, these data 

have not been analyzed in what SC&A considers a statistically defensible manner. Since these 

and other items noted in the findings above and in Attachment 4 indicate that the analysis in the 

TBD is incomplete in important respects, its representation as a “worst-case” exposure 

assessment is inappropriate. 

The problem can be addressed in one of two ways. NIOSH can attempt to re-do the analysis 

with Bethlehem Steel and Simonds data, using the analysis such as that provided in the findings 

and in Attachment 4, thereby attempting to make the TBD a reasonably complete document for 

estimating doses for compensation purposes. NIOSH can also use the general procedures set 

forth in ORAUT-OTIB-0004, which it has specifically designated “to provide guidance for 

estimating the maximum plausible dose to workers at Atomic Weapons Employers (AWEs),” 

including Bethlehem Steel. The general approach in ORAUT-OTIB-0004, which is based on 

pooling data from many uranium metal facilities, could be used as a substitute for re-analysis of 

the Bethlehem Steel and Simonds data, with appropriate cautions as discussed in Procedural 

Conformance 2 and incorporation of recommendations from the ORAUT-OTIB-0004 Task 3 

review. The differences in methods applied between the procedure in the TBD and those in this 
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review are great enough that they may affect compensation decisions in some cases, especially 

where the Probability of Causation is just below 50%. 

The detailed discussion in the findings and observations, as well as in the procedure 

conformance issues above, leads to the conclusion that the Bethlehem Steel TBD has not adopted 

worst-case procedures for estimating maximum doses as the basis upon which compensation is 

denied. 

Further, the TBD also does not adequately follow 42 CFR 82.17(b) and (c), which state: 

(b) A quantitative characterization of the radiation environment in which the 

covered employee worked, based on an analysis of historical workplace 

monitoring information such as area dosimeter readings, general area radiation 

and radioactive contamination survey results, air sampling data; or, 

(c) A quantitative characterization of the radiation environment in which the 

employee worked, based on analysis of data describing processes involving 

radioactive materials, the source materials, occupational tasks and locations, and 

radiation safety practices. 

The analysis in Findings 1 and 2, in Procedural Conformance Issues 1 and 2, and in Attachment 

4 shows that NIOSH has not properly characterized the workplace environment for the purposes 

of compensation dose estimation. For instance, no adjustments to air monitoring data for shortterm samples that are not true breathing zone samples were made, or even considered. As 

another example, no statistical and technical analyses were made for individuals who worked in 

the most hazardous jobs or workstations.
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6.0 STRENGTHS 

The site profiles developed under the Energy Employees Occupational Illness Compensation 

Program Act (EEOICPA) for use in dose reconstructions are considered living documents and 

therefore can be updated as new information becomes available. As such, each specific exposure 

situation is not intended to be addressed in the site profile. The dose reconstructor has the option 

to deviate from this standardized procedure should the individual claimant information indicate 

this approach should be taken. With this perspective in mind, there were a number of strengths 

identified in the Bethlehem Steel TBD. These strengths are listed below: 

• The TBD was developed to cover all eligible workers at Bethlehem Steel. This 

includes workers (1) who were involved with and who did not work in the area in 

which uranium rolling process (including associated activities such as 

maintenance, cleanup, loading of product, and unloading of raw material) was 

done and (2) those who were not. SC&A’s analysis regarding the aspects of the 

TBD that do not result in claimant-favorable dose reconstruction results does not 

apply to the latter group. 

• The use of air concentrations to evaluate minimum doses for lung and metabolic 

cancers in the absence of dosimeter and bioassay data is appropriate for those 

cases that are compensable. 

• The assumption that air contamination is a principal pathway for internal radiation 

when assessing dose to certain organs, such as the lung and respiratory tract, is 

technically sound. 

• The assumption about Type S for solubility for lung and respiratory tract doses is 

technically reasonable and claimant favorable 

• The minimum dose approach to making rapid decisions for favorable 

compensation claims is appropriate. Denial of compensation cannot be made on 

the basis of an admittedly minimum dose. NIOSH and ORAU are not doing this. 

The overall approach of using minimum dose estimates to make rapid favorable 

compensation decisions whenever possible is both efficient and technically sound. 

• The approach of complementing the limited Bethlehem Steel data with Simonds 

data and using the latter to construct a maximum dose distribution is also efficient 

and technically sound, albeit with the limitations discussed earlier. 
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7.0 REFERENCES 

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000, Code of Federal Regulations, May 2, 

2002. 

AEC (U.S. Atomic Energy Commission), 1949b. Simonds Saw and Steel Company, Summary 

Report of Three Surveys, (October 27, 1948-February 15, 1949), New York Operations Office 

Medical Division [pg. 9. 250-252, Simonds Saw and Steel Company.pdf]. 

Anderson, J.L., 2003. Technical Information Bulletin: Technical Basis for Estimating the 

Maximum Plausible Dose to Workers at Atomic Weapons Employer Facilities, ORAUT-OTIB0004, Oak Ridge Associated Universities, Oak Ridge, Tennessee. 

Bloom, C.W., 2004. Technical Basis Document: Basis for Development of an Exposure Matrix 

for Bethlehem Steel Corporation, Lackawanna, New York, Period of Operation: 1949-1952,

ORAUT-TKBS-001, Revision 1, June 29, 2004. 

Bowman, H.T., Merrill, P.E., Schneider, C.A., and Yocco, A.S., 1952. Report on Trips to 

Bethlehem Steel Corporation, Lackawanna Plant, Buffalo, N.Y., Production Division of National 

Lead Company of Ohio, September 4, 1952. 

Coleman, R.L., Hudson, C.G., and Plato, P.A., 1983. “Depth-dose Curves for 90Sr and Natural 

and Depleted Uranium in Mylar,” Health Physics, 44(4):395-402. 

Dimitroff, John (Retired, Bethlehem Steel) to Robertson-DeMers, K.A., 2004. Questions for 

Bethlehem Steel Experts, July 2004. 

DOE, 1985. Elimination Report for Bethlehem Steel Corporation, Lackawanna, New York, 

Department of Energy, Division of Facility Site Decommissioning Projects. 

DOE, 2000. Guide of Good Practices for Occupational Radiological Protection in Uranium 

Facilities, U.S. Department of Energy, Washington D.C. 

General Electric, 1950. Rolling Mill Report Hanford Works, Document No. GEH-16600, 

Hanford Works, Richland, Washington. 

Gilbert, R.O., 1987. Statistical Methods for Environmental Pollution Monitoring, John Wiley 

and Sons, New York, New York, Section 11.3 and Table A.3. 

Hanford Works, 1951. Trip Report Visits to AEC New York Operations Office, Lackawanna 

Plant, Bethlehem Steel Company, Argonne National Laboratory August 24-29, 1951, Document 

No. HW-22347, Hanford Works, Richland, Washington. 

Hanford Works, 1952. Experimental Rolling of Thirty Tons of Uranium By The Simulated 

Fernald Process, Document No. HW-23697, HAPO, Richland, Washington. 
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Hanford Works, 1952. Trip Report Experimental Rolling of Thirty Tons of Uranium by The 

Simulated Fernald Process, Document No. HW-23697, Hanford Works, Richland, Washington. 

Heatherton, R.C., 1951. “Various Sample Sheet,” Bethlehem Steel Air Dust Results for July 29, 

1951, Sample Req. No. 6437, July 31, 1951. 

Heatherton, R.C., 1952a. Analysis of Steel Roller Grease from April 26-27, 1952, Sample Req. 

No. 6604, March 6, 1952, New York Operations Office. 

Heatherton, R.C., 1952b. Survey Results from September 14, 1952, Industrial Hygiene No., 35, 

National Lead Company of Ohio, Health and Safety Division. 

Heatherton, R.C. to Quigley, J.A., 1957. Trip Report to Simonds Saw and Steel Co., Lockport, 

New York, National Lead Company of Ohio, July 12, 1957. 

ICRP, 1982. General Principles of Monitoring for Radiation Protection of Workers: A Report of 

Committee 4 of the ICRP, Annals of the ICRP, Volume 9, Number 4, Pergamon Press, Oxford, 

England. 

ICRP, 1983. Protection of the Patient in Diagnostic Radiology, ICRP Publication 34, Pergamon 

Press, Oxford, England. 

ICRP, 1994. Human Respiratory Tract Model for Radiological Protection, ICRP Publication 66, 

Pergamon Press, Oxford, England. 

ICRP, 1996. Conversion Coefficients for Use in Radiological Protection Against External 

Radiation. ICRP Publication 74, Pergamon Press, Oxford, England. 

ICRP, 1997. General Principles for the Radiation Protection of Workers, ICRP Publication 75, 

Pergamon Press, Oxford, England. 

ICRP, 1998. Database of Dose Coefficients: Workers and Members of the Public, ICRP CDROM Version 2.0.1, 1998-2001. 

ICRP, 2002. Supporting Guidance 3, Guide for the Practical Application of the ICRP Human 

Respiratory Tract Model, Vol. 32, No. 1-2, Pergamon Press, Oxford, England. 

Johnson, N.L., Kotz, S., and Balakrishnan, N., 1994. Continuous Univariate Distributions, 

Volume II, Section Edition, John Wiley and Sons. 

Kathren, R.L., Shockley, V.E., Thomas, E.M., and Taulbee, T.D., 2003. Dose Reconstruction 

from Occupationally Related Diagnostic X-ray Procedures, ORAUT-TIB-0006, Oak Ridge 

Associated Universities, Oak Ridge, Tennessee. 

Klevin, P.B., 1950. Simonds Saw and Steel Company, Occupational Exposure to Radioactive 

Dust January 6, 9, and 10, 1950, New York Operations Office, February 1, 1950. 
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LaMastra, A. (Bethlehem Steel Corporation) to D.L. Webster (Bethlehem Steel Corporation), 

“Investigation Report: Uranium Metal Rolling, 10” Bar Mill, Lackawanna, Plant,” June 29, 

1976. 

McCrosky, R.D., 1951. Uranium Rolling: NYOO Meeting May 28, 1951, DPW-2472, June 18, 

1951. 

Miller, D. and Breslen, A., 1951a. “Various Sample Sheet”, Bethlehem Steel Air Dust Results 

for April 26, 1951, Sample Req. No. 6190, April, 1951. 

Miller, D., 1951b. “Various Sample Sheet”, Bethlehem Steel Air Dust Results for April 26-27, 

1951, Sample Req. No. 6191, April, 1951. 

NCRP, 1999. Recommended Screening Limits for Contaminated Surface Soil and Review of 

Factors Relevant to Site-Specific Studies, National Council on Radiation Protection and 

Measurements, Publication 129, ISBN 0-929600-61-4. 

NLO, 1952a. The Rolling of Two Hundred Eighteen Uranium Billets at Bethlehem Steel 

Corporation’s Lackawanna Plant on Saturday, March 15, 1952, National Lead Company of 

Ohio, March 21, 1952. 

NLO, 1952b. Production Report on the Rolling of Two Hundred and Twenty-Two Uranium 

Billets at Bethlehem Steel Corporation’s Lackawanna Plant on Saturday, April 12, 1952, 

National Lead Company of Ohio, April 28, 1952, 

NLO, 1952c. Report on Trips to Bethlehem Steel Corporation, Lackawanna Plan, Buffalo, New 

York, April 12, 1952, National Lead Company of Ohio, September 4, 1952. 

NYOO, 1948. Simonds Saw and Steel Occupational Exposure to Radioactive Dust – Visit of 

October 27, 1948. New York Operations Office. 

NYOO, 1949. Simonds Saw and Steel Company Summary Report of Three Surveys (October 27, 

1948 – February 15, 1949), United States Atomic Energy Commission, New York Operations 

Office. 

OCAS, 2002a. External Dose Reconstruction Implementation Guideline, OCAS-IG-001, Office 

of Compensation Analysis and Support, August 2002. 

OCAS, 2002b. Internal Dose Reconstruction Implementation Guideline, OCAS-IG-002, Office 

of Compensation Analysis and Support, August 2002. 

OCAS, 2003. Error in Surrogate Organ Assignment Resulting in an Underestimate of X-ray 

Dose in SRS Dose Reconstructions, Pages 1-4, December 15, 2003. 

OCAS, 2004. Estimation of Ingestion Intakes, OCAS-TIB-009, Office of Compensation 

Analysis and Support, April 13, 2004. 
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ORAU, 2003. ORAU NIOSH Dose Reconstruction Project Quality Assurance Program Plan, 

ORAUT-PLAN-001, Oak Ridge Associated Universities, Oak Ridge, Tennessee, January 30, 

2003. 

ORNL, 1980a. Preliminary Survey of Bethlehem Steel Lackawanna, New York, Health and 

Safety Division, Oak Ridge National Laboratory, Oak Ridge, Tennessee, March 1980. 

ORNL, 1980b. Survey of Rolling Mill Used by Bethlehem Steel Corporation Lackawanna, New 

York, Health and Safety Division, Oak Ridge National Laboratory, Oak Ridge, Tennessee, 

September 1980. 

Quigley, J.A. and Heatherton, R.C., 1952. “Air Dust Results for Bethlehem Steel in 

Lackawanna, New York”, January 26, 1952. 

Range, Wayne (Energy Research and Development Administration) to David M. Anderson 

(Bethlehem Steel Corporation), letter of June 7, 1976. [pg. 71, Bethlehem Steel.pdf] 

SC&A, 2004. SC&A Standard Operating Procedure for Performing Site Profile Reviews, 

Revision 0, March 18, 2004. 

Schneider, C.A. and Yocce, A.S., “Report on Rollings and Bethlehem Steel Corporation, 

Lackawanna Plant, Buffalo, New York,” Abstract, FMPC-79 (no date) [pg. 35, Bethlehem Steel 

Site Profile.pdf] 

Sherwood, R.J., 1966. “On the Interpretation of Air Sampling for Radioactive Particles,” 

American Industrial Hygiene Association Journal, Volume 27, pp. 98-109. 

Simonds, 1948. Simonds Saw and Steel Co., Lockport, New York, EM FUSRAP Files, EM File 

Room, Folder on Simonds Saw and Steel. 

Spiegl,C.J., Stokinger, H.E., DeVolare, J., Lauterbach, K, Dzuibs, S., 1949. Air Contamination 

during Uranium Fabrication at Simonds Saw and Steel, Program Code S.M.3, Section 410. 

Stannard, J.N., Radioactivity and Health: A History, Volume 1, Laboratory Research, prepared 

for the U.S. Department of Energy, Office of Health and Environmental Research, 

DOE/RL/01830-T59, October 1988. 

Summary of Experimental Rollings Relating to Fernald Operations, 1951 [pg. 20, 

BethlehemSteel.pdf]. 

Thornton, W.T. (Energy Research and Development Administration) to R.H. Kennedy (Energy 

Research and Development Administration), “ERDA Resurvey Program – Bethlehem Steel, 

Lackawanna, NY,” March 16, 1977. 

U.S. Army, 1989. “Chapter 3: Safety Considerations for Processing, Handling, and Testing of 

DU Components,” Handbook of Safety Procedures for Processing Depleted Uranium, 

Department of Army, U.S. Army Laboratory Command, AMC HDBK 385-1.1-89, Washington, 

DC. 
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ATTACHMENT 1

Conference Call with NIOSH and SC&A2

Date: August 12, 2004 

Time: 10:00 am – 11:20 am 

Participants: 

John Mauro, Joe Fitzgerald, Kathy Robertson-DeMers, Arjun Makhijani, Tim Taulbee, Tom 

Tomes, Dave Allen, and Stu Hinnefield 

General Discussion 

The purpose of this conversation is to validate some of the key issues that we have identified. 

SC&A Inquiry: Where did you look for records? 

NIOSH Response: We searched for records related to Bethlehem Steel at the DOE Office of 

Worker Advocacy, the Fernald records center, the Environmental Measurements Laboratory 

records storage, DOE Headquarters (Robert Anders personal files), and the DOE Germantown 

records facility. 

SC&A Inquiry: What are you going to do with worker input from the July 1, 2004, meeting in 

Hamburg, New York? 

NIOSH Response: We are in the process of reviewing this information and looking for 

documentation to back up worker testimony. 

SC&A Inquiry: Where is Appendix B for October 27, 1948? Is this available for our review? 

This contains the raw air sampling data sheets. It is comparable to that available in the 

December 1948 report. 

NIOSH Response: This information is filed with the Simonds Saw data. Appendix B is 

available and will be provided to you. 

SC&A Inquiry: We need the NIOSH 2004 reference in order to review the ingestion dose 

calculations. 

NIOSH Response: We will e-mail this to John. 

 

2

 These meeting minutes were prepared by SC&A and provided to NIOSH for review on August 20, 2004. 

No comments were received other than a telephone call that indicated that airborne radionuclides concentration data 

that exceeded 1,000 MAC occurred in non-occupied locations at the facility. 
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SC&A Inquiry: Regarding NOSH comment on excluding data points over 1000xMAC in a 

triangular distribution, did NIOSH do a statistical analysis in determining the 1000xMAC? At 

least the highest measurement should be used and some percentage higher than this. There are air 

sampling measurements higher than 1000xMAC in the October 27, 1948, Simonds Saw trip 

report. 

NIOSH Response: The intent of NIOSH was to use the highest measurement at Simonds Saw 

for the maximum value in the upper bound matrix. They will review the October 27, 1948, data 

to determine if there are higher air sampling measurements than the one assumed in the TBD. It 

was not NIOSH’s intention to drop the highest value. NIOSH agreed in concept that the highest 

value should be used and indicated that they will get back to us on this matter. 

SC&A Inquiry: Did NIOSH consider using the oro-nasal breathing deposition and DCF 

factors from ICRP? There is a significant difference in the results between mouth breathing and 

nasal breathing. The mouth doesn’t retain the dust particles like the nasal hairs do. 

NIOSH Response: Nasal breathing was used as the default assumption. The only change made 

from Table 2 to Table 3 was the change in breathing rate from 1.2 to 1.7 m3

. We are using ICRP 

defaults whenever there is no other information. The default is nasal breathing. 

SC&A Inquiry: Did NIOSH consider using Simonds Saw data from 1948 to assess the mode for 

Table 3? How was 2xMAC determined? 

NIOSH Response: The averages for a few sets of data were determined. The mode for the 

upper bound matrix was taken as the highest average of Bethlehem Steel data. There were four 

days of air sampling data. 

SC&A Inquiry: We have investigated the engineering controls at both Bethlehem Steel and 

Simonds Saw. Simonds Saw had a number of engineering controls in place, including 

ventilation. Bethlehem Steel had no ventilation except the natural breeze. What is NIOSH’s 

feeling on not using data from 1949 and later? Did you use post-1948 data in your analysis? 

The data is not comparable after 1948. Have you considered using a mode from the 1948 

Simonds Saw data for Table 3? 

NIOSH Response: Our intent was to use the highest number for the upper bound of Table 3. 

SC&A Inquiry: Simonds Saw data indicates a lot of residual dust. All evidence in the TBD 

indicates all the dust, scale, and other waste was taken away. This does not appear to be a valid 

assumption. There were a lot of losses (i.e., ~ 70 to ~ 94 pounds per ingot), and some of the 

losses appear to be residual radioactivity, as indicated by Simonds Saw data. Have you 

considered using the Simonds Saw residual radioactivity data to account for residual 

radioactivity at Bethlehem Steel? There is indication that residual radioactivity existed between 

rollings. 

NIOSH Response: Most of the losses were from cropping of the uranium. Most of these crops 

were collected. 
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We have a survey of the area at Bethlehem Steel from 1952. The survey did not indicate 

significant residual contamination. It is our opinion that the difference in residual radioactivity 

between Simonds Saw and Bethlehem Steel is from the difference in production levels. The data 

from this September 14, 1952, survey was from before and after cleaning. This was the last roll 

performed at Bethlehem Steel. 

SC&A Inquiry: Where were the survey points taken? 

NIOSH Response: The points were taken at the approach to the shear, cooling table, Stands 1-6, 

floors, etc. The highest value was at the shear and was 979 dpm/smear. The survey results on 

the floor were in single and double digits. The shear appears to be the worst spot. 

SC&A Inquiry: Were there any survey points in the Secondary Finishing Area? 

NIOSH Response: There are no readings for the Secondary Finishing Area. There are two 

surveys, with one taken before cleaning and the other taken after. 

SC&A Inquiry: Simonds Saw badge experiment indicates high clothing deposition, and worker 

testimony indicates re-use of clothes for several days. Can NIOSH comment on external dose 

from dust deposition on clothes and the body? 

NIOSH Response: The Simonds Saw film badge data was not considered because the time 

period over which the film was exposed was not comparable to the time period when the rolling 

took place. The Simonds Saw data would also have more buildup of residual radioactivity in 

terms of production. 

We have a memo talking about how it was moved. The Pinkerton Agency guards escorted the 

material at all times. 

SC&A Inquiry: Did this data include time between rollings? 

NIOSH Response: The resulting dose rate from deposition on clothing is 5 mrad/hour. Given 

the limited exposure time, this did not amount to a significant exposure. 

SC&A Inquiry: According to the workers, they had to provide their own clothing for the job. 

Some workers took their clothes home once or twice a week for washing. Others wore their 

clothes for several weeks and then discarded them. This would contribute to the length of 

exposure. 

NIOSH Response: We will look into this. 

SC&A Inquiry: Many workers were in contact with uranium metal. Some reported sitting on 

the uranium. A Hooker was responsible for unloading uranium from the trucks. They stayed in 

the trucks until all the uranium was unloaded. The doses due to contact with uranium could have 

been higher than the external doses in the TBD. This activity may have also resulted in exposure 

outside the 10-hour period. 

NIOSH Response: We have documentation indicating that the material was escorted by guards. 
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As a result, we do not believe that workers sat on uranium billets. Statements by workers 

regarding sitting on billets may have applied to sitting on steel billets. Even if the workers sat on 

the uranium metal, it would not result in a significant dose to organs other than the skin and 

testicles. The surface gamma dose rate for uranium is 8 mrad/hour. Given the length of 

exposure, this would result in a dose of 60-100 mrem/year. This dose is not anywhere near the 

50-rem dose required to cause a PC of 50% for the bladder. The beta dose conversion factors for 

uranium are not significant for organs other than the skin and testicles. Beta dose would be on 

the order of microrads. 

SC&A Inquiry: It would not matter for some organs, but it would matter for others. It would 

matter for skin or male genitalia. 

NIOSH Response: The skin cancer would have to be in the exposed area. Skin cancer location 

doesn’t typically relate to the area of high external exposure. Most skin cancers we have are for 

the face. Also, most skin cancer claims have been paid. No attenuation for beta was assumed 

for skin dose reconstruction. 

SC&A Comment: Contact with uranium dose could be higher than the external doses in the 

TBD. Sitting on billets and handling uranium at various times was not always within the 10-

hour period. 

NIOSH Response: The material was under guard, and this was not considered because of that. 

There was no loitering. 

SC&A Inquiry: Many workers have reported that they worked up to two shifts in some cases 

during uranium rollings. Was this accounted for? 

NIOSH Response: We don’t have a real good indication of how long people actually worked. 

Double shifts were not uncommon. We were under the impression rollings took 8 hours, so we 

extended it to 10 hours. Some of this is compensated for when we assumed 48 rollings rather 

than merely going with the documented rollings. 

SC&A Comment: The length of the rolling was dependent on the incidents that occurred. 

Cobbling occurred frequently and would stop the line completely. If it cobbled at the end, it 

would be taken care of quickly. If the cobbling was at the beginning, it may have taken several 

hours to remove. 

NIOSH Response: Some of this is compensated for when we assumed 48 rollings rather than 

merely going with the documented rollings. There is only evidence of 13 rollings. The duration 

of the rollings should be weighted in context. 

SC&A Inquiry: Some workers may have had high exposure during maintenance, such as 

crawling into a furnace, cleaning out scale pits, and cleaning up salt bath leaks. Has NIOSH 

considered these activities? This maintenance work was likely outside the rolling time. 

NIOSH Response: There is not a lot of information on scale pits. Based on the survey data and 

the introduction of steel scale into those pits, the concentration of uranium would be negligible. 
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SC&A Inquiry: How does NIOSH propose to deal with sworn affidavits regarding 1955 and/or 

1956 rollings, especially when combined with the fact that (i) documents have been destroyed 

and (ii) there are archives that NIOSH has not looked at? 

NIOSH Response: There is no information available in the DOE records to support these 

claims. 

SC&A Inquiry: What is the procedure for incorporating affidavits into technical documents? 

Do you think that the Fernald data is complete? 

NIOSH Response: No data set is complete. 

SC&A Inquiry: Have you looked for records through Bethlehem Steel Corporation? 

NIOSH Response: Bill Murray was trying to make contact with Bethlehem Steel Corporation. 

We are unsure where they are with this process. 

SC&A Inquiry: Should we have the workers send a copy of the affidavits to you? 

NIOSH Response: Have them sent to Roger Anders of the DOE or the appropriate contact for 

that DOE site. 

SC&A Inquiry: Should we have a copy sent to you? 

NIOSH Response: You can send a copy to us, and we will make sure it gets to the right people. 

The covered employment period includes work for DOE and its predecessor. The work period is 

set up by DOE. If we encounter evidence to the contrary, we provide it to DOE. 

SC&A Inquiry: I understand that workers are offered a hearing by the DOL when they are 

denied. Has NIOSH received information from DOL hearings that might be useful in dose 

reconstructions? 

NIOSH Response: The DOL does send statements of facts or questions occasionally. 

SC&A Inquiry: What is your position on the deep dose issue from x-rays as provided by Hans 

Behling? 

NIOSH Response: We are still looking at it. 

SC&A Inquiry: Given the many factors that add to dose, does NIOSH think that its 

40%-plus cases are robust? Or that skin cancer and near-surface organ 

cancer cases are robust? 

NIOSH Response: A number of the cases between 40% and 50% have been held up. The ones 

that have gone through are robust. You must remember that the PC is not linear. To change the 

PC from 45% to 50%, you essentially have to double the dose. 
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SC&A Inquiry: Has NIOSH done any sensitivity testing of the triangular verses uniform 

distribution methodology for assessing dose? Is this something worth looking into? 

NIOSH Response: Note that if there is a significant change in the TBD, cases are reopened and 

reevaluated. We have done some sensitivity analysis to see how statistics change the outcome of 

the PC. 

SC&A Inquiry: Are there any Technical Information Bulletins for Bethlehem Steel? 

NIOSH Response: No, none other than the ingestion TIB that we intend to send you. 

Action Items: 

NIOSH has agreed to provide the following items to the SC&A team: 

Appendix B from the October 1948 Rolling 

Ingestion Technical Information Bulletin 

Bethlehem Steel Survey Data from 1952 

Pinkerton Guard Memo 

SC&A team agreed to provide the following items to NIOSH: 

Simonds Saw Data Sheet for December 1948 

(Kathy Robertson-DeMers provided filename and page number to John Mauro for forwarding to 

NIOSH.) 
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ATTACHMENT 2 

Bethlehem Steel Questions Submitted to NIOSH 

The evaluation of the Bethlehem Steel Site Profile has included review of some source records, 

interviews with former Bethlehem Steel workers, and an analysis of the rolling process in 

general. We are sending you this memorandum defining the issues that we consider important 

regarding the completeness and adequacy of the site profile, as part of our preparation for 

drafting our site profile review. For that reason we would appreciate an early response, 

especially as NIOSH and ORAU are already familiar with the comments of the workers during 

the July 1, 2004, meeting organized by NIOSH. 

The documents identified to date primarily include information gained from the FUSRAP site, 

labor unions, congressional staff, newspaper articles, uranium metallurgy reports, and reference 

books. These documents constitute only a fraction of the source information listed in Technical 

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

Corporation, ORAUT-TKBS-0001. The National Institute for Occupational Safety and Health 

(NIOSH) to date has not provided the source documentation available in their database. This 

includes critical information, such as the air sample data upon which NIOSH is basing its 

assumptions for internal dose. Not having access to these data has hampered our work. Please 

send us the source documentation so that we can proceed with our reviews in a timely manner. 

In addition to document review, Arjun Makhijani attended a July 1, 2004, meeting organized by 

NIOSH in Hamburg, New York, with some Bethlehem Steel workers, members of their families, 

and representatives from NIOSH and ORAU. The workers discussed the rolling process in some 

detail, including failures in the rolling process, facility cleaning operations, facility maintenance 

and repair, and potential sources of residual contamination in both the workplace and the 

environment. As a result of document reviews and interviews with workers, a number of issues 

with respect to the Bethlehem Steel technical basis document (TBD) have surfaced. What 

follows is a summary of these issues and questions. The questions relate to the list of issues. 

This memorandum discusses the issues first, followed by the questions we would like to discuss 

at our next conference call. 

I. ISSUES 

There are a number of routes of exposure that were not discussed in the Bethlehem Steel TBD. 

These routes include those from routine operations as well as incident situations. We recognize 

that the airborne radionuclide concentration distributions provided in the TBD were designed to 

capture the uncertainty in the range of operational conditions. Nevertheless, we would like to 

discuss how the following routine and off-normal operating conditions may have impacted some 

workers at the facility. 
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A. Potential Routine Exposures not in the TBD 

• Billets and product bars were stored on site, creating a potential for external 

exposure and possibly some internal exposure (due to fines and scale on the rods 

and billets). 

• Workers sat on uranium billets that were stored in the bar mill. Sitting on billets 

is of concern with respect to external dose, and could affect doses to several 

organs significantly, including skin, bladder, prostate, and testicles. (Note that 

one worker commented on unexplained swelling of testicles at the time.) 

• Ingestion doses from contamination of food and water due to uranium dust 

settling on their food and beverages. Workers ate in the bar mill. 

(Note: NIOSH indicated at the Advisory Board meeting in Buffalo that an 

ingestion model was under development. This model was not made available for 

review.) 

• Cleanup was not done properly; it was perfunctory. This creates the potential for 

long-term exposure for the four years of rolling and even afterwards. 

• The uranium was cleaned with brooms and water hoses. Air hoses were also used 

from time to time. This creates a potential for exposure of clean-up workers. It 

also creates a potential for re-suspension and re-deposition on working and other 

surfaces. 

• Uranium billets were hosed down with water as the rolling was being done to 

wash off the scale. The scale and dust were flushed into a sub-basement. The pits 

were cleaned out, likely resulting in exposure to clean-up workers, crane 

operators, and railroad workers. Worker testified that the scale pit was manually 

shoveled also about once in six months, perhaps creating an additional potential 

for increased exposure. The scale pit was cleaned out with a crane about once a 

week. 

• Doses from deposition of uranium on steel stored in the mill and subsequent resuspension. 

• Workers crawled into furnaces to repair them. This likely resulted in a substantial 

increase in internal and external exposures for some workers. 

• There was a high potential for internal contamination of equipment (e.g., 

furnaces) by uranium dust. The residual uranium could create the potential for 

exposure long after uranium operations were completed. 

• Workers blew lime off the walls, which may have been mixed up with uranium. 

• There were emissions via a roof vent or stack. 
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• It is unclear how the salt baths were cleaned out. It is assumed that the salt baths 

were emptied and the material was dumped. There would be some uranium 

contamination in the salt. 

• Workers handled billets and rods during loading and unloading and also 

sometimes to straighten them. 

• Repairs of breakdown during furnace operation were performed during operation. 

What might have been the particulate levels during repairs? Were repairs of this 

nature considered part of the rolling operation, and, if so, did they create the 

potential for increased exposures? 

• Dust from cranes came down on workers. Dust coming down after completion of 

rollings and after all rollings were done would have the potential for additional 

exposures. 

• Uranium dust settled on steel rolls and scrap, creating exposure potential. 

• Workers tracked contamination home on clothes and in their cars. Also, 

emissions created offsite dust. 

• The butts, scraps, and scale may have been fed into the blast furnace. This would 

cause a mixing of steel and uranium resulting in a potential for some exposure. 

• There were cropping and cutting operations involved with uranium billet 

production as a part of routine operations or with failure of the billet to form. 

Cropping and cutting can generate uranium dust resulting in a potential internal 

exposure. 

B. Potential Exposures due to Incidents 

1. Cobbles 

Billets that are being rolled sometimes get twisted during the rolling and the bars get completely 

tangled. This is called a cobble. Workers have to get out of the way and then cut up the cobble 

into small pieces, creating dust. The pieces were then loaded and transported offsite. The hot 

pieces led to burns and scratches. As the cobble is burned into small pieces, they also create slag 

and drips over gratings and sluiceways, which are then flushed into scale pits. 

In addition to exposure via the inhalation pathway, such transients create the potential for direct 

incorporation of uranium metal and oxide fines via burns and scratches. The rods would have 

had some oxide scale. 
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2. Salt Bath Leaks 

There were salt bath leaks. The welds on the steel pan containing the salt bath failed each time, 

according to Ed Walker, who cites a 1952 National Lead of Ohio (NLO) document to that effect. 

On one occasion, the leaks stopped the whole operation for four hours. The repair and cleanup 

of the leaks may have created exposure potential during time periods not explicitly addressed in 

the TBD. 

3. 1977 Fire 

If the 1976 ERDA documents are correct, there would be no exposure from the 1977 fire. 

However, worker testimony regarding lack of clean-up, scale pits, and contamination outside the 

building creates some doubt regarding the claims made by ERDA. This raises a question about 

how much residual uranium there may have been in the dust on site during the 1977 fire. The 

steel was covered with grease to prevent rust, and this led to a vigorous fire due to the oil and 

grease all over the site. 

II. GENERAL QUESTIONS RELATED TO BETHLEHEM STEEL 

1. We have prepared above a list of possible internal and external exposure potential 

situations at Bethlehem Steel that do not appear to be taken into account in the TBD. Can 

NIOSH/ORAU comment on each one as to whether it should be included in a revised 

TBD and in revised dose calculations? 

2. Page 2 the TBD states: “Because of material accountability procedures, scale, residue and 

cropped ends were collected and fine debris was vacuumed, packaged, and sent back to 

the AEC;” pg. 5 of the TBD identifies the following total number of 10-hour exposure 

workdays for the years 1949 through 1952: 

Year No. of Exposure 

Workdays (days) 

Total Exposure 

Time (Hours) 

1949 12 120 

1950 12 120 

1951 13 130 

1952 11 110 

In Tables 2a and 2b, the TBD derives annual intakes from inhalation based on the abovecited number of hours. 

In brief, the TBD not only assumes that internal exposure was limited to the inhalation 

pathway, but further assumes that this exposure was exclusively confined to those 

workdays when uranium billets were processed based on “accountability procedures.” 

NIOSH’s model assumptions raise serious questions regarding their validity and 

conservatism for the following reasons: 
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Description provided by W.H. Finkeledey in the April 3, 1950, report “Rolling Mill 

Report Hanford Works,” Document No. GEH-16600. 

The following passage on pp. 3-4 provides an insight about airborne environments 

associated with the uranium billet rolling process: 

 The health problem results from dispersion in the air of 

radioactive uranium oxide, a coating of which forms on the surface of the 

metal as it is being rolled. At the temperatures reached in rolling, 

oxidation of the metal is very rapid and even actual burning of the metal 

in local areas frequently occurs. The oxide scale layer builds up quickly 

to a relatively thick, brittle and non-adherent coating and the distortion of 

the billet and rod surface during the rolling mill operation, as well as the 

friction between the roll surfaces and the rod itself, causes the scale to 

readily flack off. The oxide, as it breaks loose from the rod surface, has a 

wide range of particle size all the way from flakes approximately 1⁄2” in 

diameter to particles so fine that they will remain air-borne in still air for 

several hours. Since any practical approach to the rolling mill operation 

rules out the use of an inert, non-oxidizing atmosphere to surround the rod 

at all stages of its rolling, the rolling of uranium metal is accompanied by 

the production of uranium oxide which takes place rapidly at all times as 

long as the metal is above 300 ̊ C. Another contributing factor to the 

formation of oxide occurs when the rod slides over a stationary surface 

during its rolling in the upper temperature range. The friction so 

developed frequently raises the temperature sufficiently to induce active 

burning of the metal to start at such contact points. [Emphasis added.] 

Since internal exposure through inhalation is dominated by micron-sized particles, as 

described above, the mere need for “material accountability” of tons of rolled uranium 

would not likely depend on the insignificant collection of micron-sized particles that were 

not likely to have been collected, but would remain in the workplace well beyond the 

episodic dates of rolling uranium billets. The assumption of total accountability as 

assumed by NIOSH is further contradicted by recent testimony of scale being flushed 

into the scale pit, provided by former workers at Bethlehem Steel (Arjun Makhijani, 

Notes of meeting in Hamburg, NY on Bethlehem Steel operations for AEC, July 1, 2004, 

meeting organized by NIOSH/ORAU.) Furthermore, according to the report Extraction 

and Metallurgy of Uranium, Thorium and Beryllium (Section 3.4.1), in the best 

circumstances, a metal loss of 0.9% could be expected, though much of this might be 

recovered, of course. 

Some doubt is also thrown on to the AEC claim that dust and fines were collected by a 

September 12, 1951, trip report (W.T. Kattner, Trip report: Visit to AEC New York 

Operations Office, Lackawanna Plant, Bethlehem Steel Company, Argonne National 

Laboratory, August 24-29, 1951. The starting page number for this document in the 

Hanford documents database is HW-22347). On page 2, the document states that 

“[d]uring air cooling, about 100 pounds of oxide fell on the floor and blisters about 1/10 

inch high appeared at the points where the rods rested upon the rails.” This is a huge 
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amount of dust from one operation involving a partial rolling of 23 bars, which had been 

reduced to 1.73 inch diameter at another location (Watervliet, NY -- see the same page in 

the document cited in this paragraph). This raises questions of how much uranium might 

have been discharged to the scale pit during the washing that accompanied each rolling. 

Note that the uranium dust on the floor would likely be mixed up with far larger amounts 

of steel dust. The description of this also puts the AEC claim regarding recovery of fines 

into question. Did NIOSH/ORAU make estimates of how much uranium may have been 

lost in this way? 

3. Table 1 on pg. 3 of 14 lists the documented rollings at the Bethlehem Steel Corporation 

in Lackawanna, New York. Hanford was one of the sites that received and analyzed the 

uranium billets. As a result, they documented the analysis. Trip Report: Experimental 

Rolling of Thirty Tons of Uranium By The Simulated Fernald Process (HW-23697) 

indicates that 30 tons of case uranium billets were rolled to Hanford specifications at 

Allegheny-Ludlum Steel and Bethlehem Steel on February 16, 1952. 

The TBD acknowledges that there may have been some rollings in 1955 according to a 

letter from Paul Kansanovich (Compensation Agent, L.U.) to Robert Anderson 

(Bethlehem Steel) in 1979. Worker testimony is that there was something that went on 

that was secret in 1956, probably uranium rolling. NIOSH/ORAU has the opinion that 

this might have been Navy work, which is not covered under the law. The only available 

documentation with respect to rollings post-1952 is two affidavits signed by two 

Bethlehem Steel workers. Furthermore, one worker, John Dimitroff, has raised the 

possibility that Fernald may have sub-contracted rollings to Bethlehem Steel when their 

rolling mill was down and they needed to meet production quotas. NIOSH/ORAU 

responded that this would show up in Fernald documents. This presumes that Fernald 

documents are complete and Fernald materials accounts sound. However, the latter are 

questionable. For instance, the Book-Physical Inventory Difference (B-PID) at Fernald 

over its operation ran into hundreds of tons. 

Has NIOSH/ORAU performed a comprehensive records review for records associated 

with Bethlehem Steel operations at facilities other than Fernald, such as Hanford, the 

Savannah River Site, and the Chalk River Experiment, which ultimately received the 

uranium rods from Bethlehem Steel? If so, how was the information included in the 

analysis? What is the claimant-favorable approach to the number of rollings in the post1952 operations? 

4. Workers claim that crops were put back into the furnace along with steel, and that 

uranium fines and scale from the scale pit were fed into the blast furnace. Has 

NIOSH/ORAU looked into this before accepting the AEC claim regarding careful 

materials accountability? 

5. The reliance on dose reconstruction on field data, including air samples, leads to 

questions regarding the effectiveness of instruments used at the time. What instruments 

were used to count the air sample activity? Were air sample analyses performed using 

portable or fixed instrumentation? What was the estimated minimum detectable activity 

for these instruments? Were the instruments fully functional in the field conditions 
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presented by rolling uranium? What correction factors were applied to the data (i.e., 

crossover, self-absorption, collection efficiencies, etc.)? 

6. Does NIOSH have any data on the uncertainties in the measurements of air 

concentrations in the late 1940s and early 1950s? They were generally reported as 

deterministic values. How does one determine if these are claimant favorable? SC&A 

would like copies of all the documents showing the air sampling data and any others that 

would shed some light on the reliability of the measurements, the method of analysis 

used, and the characteristic of the samplers (such as airflow rates and filter types). This 

request includes instrument manuals for the instruments used at the time. 

7. Given that this area of the country has an elevated radon background, what type of 

corrections were done to account for natural radon and thoron levels? 

8. NIOSH/ORAU has assumed an average number of hours of exposure as 120 per year, 

but this would account for only direct rolling time. Does the exposure time need to be 

changed by the many additional routes of exposure both during 1949-1952 and 

subsequent to termination of uranium rolling? For instance, if these other sources of 

routine air contamination amounted to 1.0xMAC for four work years, with 2,000 work 

hours per year, then the total exposure equivalent in MAC-hours would be 8,000 MAChours. This compares to an exposure of 960 MAC-hours over four years corresponding 

to the mode of the triangular distribution (2xMAC) used in the TBD. 

9. More generally, it would appear that a number of items in the list of issues above may 

significantly modify the time distribution of air concentrations of uranium and hence also 

of individual worker exposure. These items are not in the TBD. Has NIOSH evaluated 

this issue since the publication of the TBD? Which items does NIOSH believe are 

significant enough to lead to changes in facility radiological characterization or in 

estimates of individual worker radiation exposure? (We address the statistical aspects of 

these questions in Section III below.) 

10. Does the exposure time need to be changed with respect to the workers’ claims that they 

worked double shifts? 

11. Did NIOSH/ORAU investigate the level of activity performed by steel mill workers and 

take this into account in determining breathing rates? 

12. Why did NIOSH/ORAU choose to use a constant value for estimated maximum external 

dose due to submersion and use a triangular distribution for other types of exposure? 

13. Do the Table 3 skin doses take into account deposition of dust on skin? How much? 

How long? From bullet points on page 8 and the semi-infinite plane model discussed on 

page 7, it seems that skin deposition is not taken into account. Is this right? 

14. On pg. 8 of 14 NIOSH/ORAU refers to the use of a shielding factor for clothing in the 

case of male genitals and breast cancer. What shielding factor is being used? 

15. When calculating external photon exposure, what exposure time was assumed? 
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16. There appears to be a need for a default assumption regarding the appropriate electron 

organ dose conversion factor to apply at uranium facilities. What progress has NIOSH 

made in assigning appropriate organ dose conversion factors? 

17. One claimant indicated that her husband had worked with radioactive cobalt at 

Bethlehem Steel. Radioactive cobalt is used in the automotive industry to test steel 

quality. Has NIOSH/ORAU investigated whether radioactive cobalt was used in the 

uranium rolling process as some sort of quality check? 

The TBD does not address the potential for exposure from residual radioactivity. They reference 

surveys performed in 1976 and 1980 under the FUSRAP program, which showed no detectable 

contamination above background. The intent of these surveys was to demonstrate that there was 

no potential for radiological exposure at that time and following the time period the survey was 

performed. The survey was not comprehensive with respect to the entire rolling operation (e.g., 

furnaces, cranes, etc.). The floor and the pit where the bar mill was located was covered with a 

new concrete floor. Has NIOSH performed a comprehensive search of records relating to 

contamination and radiation surveys performed during uranium billet production operations? 

Has NIOSH/ORAU estimated potential dose from residual contamination on the floor, 

equipment, scrap metal, and building structures? 

18. There is no mention of environmental dose in the TBD. Has NIOSH/ORAU considered 

potential dose due to releases from the stacks or vents? 

19. Has NIOSH/ORAU investigated the waste disposal procedures for Bethlehem Steel and 

potential exposure from waste disposal sites? 

20. The x-ray dose assumptions in the TBD appear to have the same issues as we have raised 

before. Does NIOSH/ORAU agree? 

21. Does worker testimony indicate enough uncertainty regarding external and internal routes 

of exposure to warrant a re-examination of the assumption that certain cancers, such as 

prostate and bladder cancer, are not likely to be compensable for Bethlehem Steel 

workers? For instance, does NIOSH believe that doses from sitting on uranium billets 

during lunchtime or other breaks should be estimated? 

22. Worker testimony indicates that there may be documents at Saylorsberg, PA, Bethlehem 

Steel HQ. NIOSH/ORAU indicated at the July 1, 2004, meeting in Buffalo that it has not 

examined this possibility for documents and that it will do so. Is NIOSH going to 

undertake a document retrieval mission there and, if so, will it be possible for SC&A to 

designate one or two people to accompany the mission? 
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III. STATISTICAL QUESTIONS RELATED TO BETHLEHEM STEEL

We have several questions relating to statistical matters, other than those related to the validity of 

the measurements and uncertainties in the reported concentrations. 

1. The air concentration measurements are based on samples taken in particular areas for 

short time periods. How are the distributions in Tables 2a and 2b based on these 

measurements to be converted to distributions that represent individual exposure? 

2. Specifically, assuming that the data are valid and that credible confidence bounds (and an 

appropriate probability distribution) can be established, do we have sufficient air 

concentration data over (1) time, (2) space and (3) process type (in regard to coatings and 

method of heating) to come up with a claimant-favorable air concentration distribution or 

any credible air concentration distribution for the periods during which rollings occurred? 

What confidence bound would one use? 90%? 95%? 

3. What was the technical basis for selecting 140 dpm/m3 as the mode? (It should be noted 

that SC&A has not been able to obtain documents that contain the limited survey data 

referenced in the TBD.) Is it reasonable to assume a single mode for two distributions for 

which the maximum air concentrations varied by more than a factor of 14? Has 

NIOSH/ORAU done sensitivity calculations regarding the effect of the choice of the 

mode in Tables 2a and 2b on various types of cancers and various ages at which the 

cancers might be contracted? And has NIOSH/ORAU done sensitivity calculations as 

regards the choice of distribution? If so, could NIOSH/ORAU supply the results of its 

calculations to SC&A? We have performed a few preliminary sensitivity calculations for 

a couple of different cancer types (lung, prostate, bone). These calculations indicate that 

the choice of mode does not significantly affect the outcome regarding the probability of 

causation (PC) for the non-metabolic cancers that we looked at. This is because the PC 

appears to be dominated by the upper limit of the triangular distribution. For these cases, 

other routes and times of exposure (such as sitting on billets, re-suspension, accidents, 

and maintenance work may be more important – see below). On the other hand, the 

choice of mode may affect the PC in cases where the PC using Tables 2a or 2b is already 

large – that is, not far from 50%. Does NIOSH agree that such sensitivity calculations 

are a crucial check on the robustness of the PC result? What kind of sensitivity 

calculations should be performed? (We stress that our calculations are preliminary and 

were done only in order to explore what role this single factor, the choice of mode in 

Tables 2a and 2b, may play in the estimate of the PC in various circumstances.)

4. Given the many uncertainties, has NIOSH considered using a single upper bound number 

for air concentration, such as the 1,000xMAC in Table 2b, to calculate all doses, so far as 

the routine exposures during the times of production are concerned? 

5. Given the uncertainties and the many problems with using air concentration data, has 

NIOSH/ORAU considered any alternative approaches for estimating routine exposure 

during production? For instance, has NIOSH considered an estimation procedure based 

on production data and data on losses? If so, would NIOSH share the results of its 

investigation into alternative methods? 
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6. The issues and questions in Sections I and II indicate that there are a number of pathways 

and times of exposure that may be significant that are not considered in the TBD. At 

present, the TBD assumes a deterministic time for non-zero air concentrations for each 

year of rolling (see columns 1 and 6 of Tables 2a and 2b). These times of exposure are 

limited to the assumed annual integrated duration of the rollings for the facility as a 

whole. Incidents are not explicitly taken into account. Given the worker testimony that 

NIOSH and ORAU have heard since that time (including on July 1, 2004) and other 

feedback, would it be reasonable to attempt to create a new time distribution of uranium 

air concentrations that would include factors such as re-suspension and maintenance 

work? Should a new distribution be constructed for the rolling mill as a whole, or should 

different time-dependent distributions be estimated for workstations and/or for job 

descriptions? Would such profiles of air concentrations over time be deterministic (along 

the lines of the present TBD) or probabilistic? In the latter case, what would guide the 

choice of the distribution and its parameters? Finally, are Bethlehem Steel data or data 

from comparable facilities of sufficient quantity and quality to create a scientifically 

supportable, claimant-favorable air concentration profile(s)? 

7. How would new facility, work station, or job description profiles for uranium air 

concentrations over time be used to create individual worker exposure scenarios? For 

instance, how would incidents (such as cobbles or the 1977 fire), maintenance of furnaces 

and the rolling mill area, double-shift work, sitting on billets during breaks, ingestion, 

external doses due to immersion in contaminated air, etc. be integrated into overall, 

scientifically supportable internal and external dose estimates or probability distributions 

of internal and external doses for individual workers? What kind of probability 

distribution and claimant-favorable assumptions would need to be made for the various 

factors that may be important in individual exposure estimation? Finally, what are the 

sensitivity tests that would need to be done in order to test the robustness of the 

assumptions in regard to the determinations of the probabilities of causation for various 

metabolic and non-metabolic cancers? 
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ATTACHMENT 3 

Summary of Site Expert Interviews

Over the course of the audit on Bethlehem Steel, Arjun Makhijani and Kathy Robertson-DeMers 

have had an opportunity to talk to a number of site experts. These site experts included a Crane 

Operator, a Recorder, an Apprentice Bricklayer, and an individual who worked both in 

operations and environmental safety and health. Arjun Makhijani also attended the meeting 

sponsored by NIOSH in Hamburg, New York, on July 1, 2004. The information the workers 

provided has been invaluable in providing us with a working knowledge of how a steel mill 

works, what level of effort is involved in the work, and what the working conditions are in a steel 

mill. 

Below is a summary of various workers’ interviews as they relate to the vertical issues outlined 

in the Bethlehem Steel review. This information provided is not a verbatim discussion, but is a 

summary of information from several interviews with several individuals. Individuals have 

provided this information based on their personal experience. It is recognized that these former 

worker recollections and statements may need to be further substantiated before adoption in the 

TBD. However, they stand as critical operational feedback where records and other 

documentation are lacking. These interview notes are provided in that context; former worker 

input is similarly reflected in our discussion and, with the preceding qualifications in mind, has 

contributed to our findings and observations. 

Bethlehem Steel Company owned a number of steel plants, including the one in Lackawanna, 

New York. The home office of Bethlehem Steel was in Bethlehem, Pennsylvania. The 

Bethlehem Steel plant in Lackawanna, New York, extended a few miles along the Lake Erie 

shoreline and 1.5 miles on the other side of the road. There were over 100 buildings. The plant 

was like its own community with a hospital, restaurants, a fire department, and police. 

Approximately 25,000 employees worked at Bethlehem Steel. About 63 individuals per shift 

were required to operate the 10” mill and another 25 or so support employees were present. This 

did not include the individuals in the Secondary Work Area. The mill building was broken up 

into bays. The mill was about 120 feet x 1,000 feet x 90 feet. The building that the mill was a 

part of may have been as much as a third of a mile long. 

Under optimum conditions 300-400 tons of material per 8-hour shift could be processed through 

the mill. Several routine and non-routine situations slowed down the process with uranium. 

First, samples approximately 18” long were torched off the billet for examination. They were 

cooled in a cold-water trough and taken to a desk. The metal was examined as a quality control 

check. Secondly, non-routine situations such as cobbling, salt bath leaks, or power outages 

would stop rolling operations. The shutdown time for cobbling depended on the stand where the 

cobbling occurred. If the uranium was relatively thin, it took as little as 10 minutes to correct. If 

the uranium was early on in the process, it could take several hours to fix. 
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1. URANIUM ROLLING HISTORY 

Some workers clearly remember additional rollings in 1955 and 1956. Two former workers at 

Bethlehem Steel issued a Deposition of Fact that rollings took place post-1952. One individual 

indicated he was involved in a uranium rolling in April or May 1956, a few months before he 

was drafted into the Army. The second worker reported that several rollings occurred in 1955. 

Rollings usually only took one day, although there were multiple shifts. 

Workers are concerned about the absence of records on rollings that occurred at Bethlehem 

Steel. Some workers suggested that records may be available in Saylorsburg, Pennsylvania, 

where the records storage facility was located. Another worker suggested we talk to Bob Custer, 

who was the Assistant Superintendent of the mill. A number of workers have indicated that 

records were destroyed. 

2. EXTERNAL EXPOSURE FROM CONTACT WITH URANIUM 

Due to the nature of the milling process, workers handled the uranium metal at various stages of 

the shipping and receiving, milling, and secondary finishing work. Some of the jobs that 

required direct contact with the uranium included: 

• Inspectors who had to perform hands-on inspection of the metal 

• Chippers who were responsible for removing impurities or slag from the metal 

with an air gun 

• Scarfers who used a torch to remove deeper impurities from the metal with a torch 

• Shearers who had to manually feed the material into the blades 

• Laborers that would physically place the material in the shipping area after 

shearing 

• Straighteners who had to remove bulges from the product 

Due to the nature of the uranium, it often had to be manually fed into the rolls using levers, bars, 

or sledgehammers. The product was checked throughout the rolling process, as the tolerance 

was tight. In many cases the workers in the rolling process and secondary finishing area were 

within six inches to one foot of the uranium metal. At times the uranium was in direct contact 

with parts of the body. Specifically, uranium was handled with gloved and ungloved hands and 

carried against the abdomen to the finishing area. Some workers indicated that they sat on 

uranium billets stored in the rolling mill area. 

Workers did not know what the material was, although some of them noted that truck signage 

indicated it was radioactive material. Some workers were aware the material was used for the 

atomic bomb program. They were not provided radiation safety training. The only thing they 

were told was not to take it home; otherwise they would become sterile. Some men ignored this 

warning and took pieces home anyway. 
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Uranium was usually brought in several days before the rollings on trucks or railroad cars and 

staged in the Billet Yard. Workers indicated that this material was guarded. The overhead 

crane would come in with the chains, pick up the billets, and put them on the backside of the 

furnace (i.e., charging table). The Hookers who hooked chains to the uranium for unloading 

remained in the truck or railcar adjacent to the uranium until all the billets were unloaded. There 

were two types of rollings – right out of the furnace or the salt baths. The rollings from the salt 

baths were semi-finished billets, which were heated in salt baths and then fed into mill at around 

Stand 6. 

Internal Dose Assumptions, Parameters, and Conditions 

The workers brought up a number of issues that related to the potential dose from uptake of 

uranium. 

(a) Calculation of Intake 

Dust would commonly deposit in their nose and mouth. They often blew soot/dust out of 

their nose after work. There was dust buildup in their throats due to the dusty working 

conditions. One worker indicated that when he retired, it took him two weeks to finally 

clear his nose. Those workers who experienced both uranium and steel rollings indicated 

that uranium did not create as much dust as steel. 

The steel industry was one of the heaviest industries in existence at that time. The level 

of physical activity was very high. Men could sometimes lose 10 to 12 lbs of water 

weight during a shift and were given salt pills to counter this loss of water. It was not a 

pleasant place to work. The workers were involved in heavy labor as long as the mill was 

running. If there was a loss of power or a shutdown, they were allowed to take a break 

for the period of the shutdown. Some workers had to work at even harder or heavier jobs 

after a breakdown to get the mill going again. 

Employees worked one to two shifts (8-16 hours) during uranium rolling depending on 

their job. In addition, maintenance activities occurred outside the uranium rolling shifts. 

Often, maintenance was done on equipment during times when the mill was shutdown or 

when they were cleaning the scale pits. At times the workers would routinely be 

scheduled to work on holidays. Overtime would be optional if they wanted to make extra 

money. 

(b) Ingestion Dose 

The workers ate their meals in the production area, because they did not have a 

lunchroom. They typically ate sandwiches, leftovers, soup, etc. There were no stoves in 

the plant. They would cook or heat their meals on the furnace or the hot metal. Dust 

would settle on the food and in beverages if it wasn’t wrapped or covered. 

Workers did indicate that at the first two rollings, the industrial hygienist took samples of 

the drinking water. 

Additional ingestion probably occurred because of the dusty air. 
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(c) Routine Exposure Conditions 

Dust escaped into the ambient air. The largest concentration of dust was in the mill area. 

During activities when the mill was down, there was clear visibility. When they started 

rolling, the visibility was cut in half. 

Scale was formed on the uranium metal as it cooled down. Scale was actually bits and 

pieces of the metal. Scale was an issue in the Secondary Work Area. 

The mill proper did not have a stack. The furnace had a damper like a fireplace. There 

were windows up near the crane and fans without motors in the ceiling. The fans were 

not usable without the motors. Occasionally, a Crane Operator would open a window. 

The company was concerned about compliance issues so they made them close the 

windows. The steel on the side of the building sometimes blew off. 

There was no exhaust ventilation on the operating rollers. The mill was an open mill and 

did not have enclosures surrounding the rollers or descalers. The rollers did have grating 

underneath, so that water and scale would drop to the subbasement. The only “dust 

contaminant” measure taken was to hang old rags, pants, and burlap over the stands and 

to wet the metal with water. The rags were actually put there to prevent the workers from 

getting doused with water. The water used to control the temperature on the metal would 

either run down into the subbasement or dissipate in the air. The only ventilation came 

from the wind entering the building through the end of the mill opened to the Billet Yard. 

There was a portable vacuum system that was used to clean up periphery dust after 

uranium rollings. GM counters were used to locate larger pieces of uranium around the 

beds. Vacuuming was not always completed underneath equipment. There was no effort 

made to clean the inside of equipment. 

Workers had to supply their own clothing. The nature of the work made clothing get 

very dirty. Some workers took their clothes home once or twice a week for washing. 

Other workers wore their clothes two to three weeks and then discarded them. Some 

workers wore long underwear to keep them cool in the summer and warm in the winter. 

They also wore heavy socks to keep their feet from getting black. 

There was a changing room available with showers. The workers indicated that the dust 

would run off their bodies in the shower and color the water. Dust settled in their hair, so 

they had to wash their hair. Some workers changed and took showers prior to going 

home and others wore their clothes home. They would put on the same clothes the next 

workday. 

PPE for hot work involved asbestos gloves and suits. Leather gloves were used for 

laborious tasks. In some cases they provided workers with safety glasses and helmets. 

Bethlehem Steel provided gloves for the first uranium rolling, but discontinued this 

practice after the first rolling. Contact work with uranium metal was performed with and 

without gloves. The workers could feel abnormalities in the billets and perform 

inspections better without gloves. Gloves were not secured with tape. 
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Although there were bathroom facilities, some employees worked up to a half mile away 

from the bathrooms and chose to relieve themselves in the production areas. This saved 

time as there were production incentives, which would sometimes cause fistfights among 

workers. 

(d) Non-routine Exposure Conditions 

Several incidents or occurrences happened during the uranium rolling process. Uranium 

was more difficult to roll because it was not heated to as high a temperature. During 

uranium rollings, they often had what was called a cobbling. A cobbling results from a 

misfeed or a jam by the metal. When a cobble happened the men had to clear the area to 

prevent burns from flying metal. A crane had to remove the cobble and men with hot 

gloves would cut it into pieces with a torch until the mill was cleared. The mill would 

not continue to operate when a cobble was in a roller. The time to remove the cobbles 

varied from 10 minutes to several hours. 

The bricklayers were actively involved in maintenance of the furnaces at the plant. When 

there was a burnout or leak in the furnace, the “Hot Dog Gang” would be called in to 

perform an immediate repair. There was direct contact with the contents of the furnace. 

The operations continued during this time. During maintenance shutdown, they would let 

the furnace cool off and the regular bricklayers would come in and do a permanent fix on 

the furnace. 

The salt baths were contained in welded steel shells. The welds in the salt baths would 

fail at times and cause a leak in the salt bath. One time this stopped rolling for four 

hours. 

During shearing of the material, the uranium would spark resulting in a bright light, 

which in some cases hurt the worker’s eyes. Although steel did spark when sheared, the 

level of sparking and the brightness of the light were less than with uranium. 

3. POTENTIAL IMPACT OF EXPOSURE TO RESIDUAL CONTAMINATION 

The floor of the mill was made of varying materials. There was grating under the rollers, steel 

plates over openings to the subbasement (pits), and float-finished concrete. Float-finished 

concrete is rough to help prevent slipping. There was also an accumulation of dirt and oil on the 

floor. A power cleaner was used to hold the dust down. When you used it, dust would blow all 

over the place. When workers returned to the mill on a Monday after weekend rollings, there 

was still dust present. 

The water and scale would wash down through the grating into the scale pits. Water used to cool 

rolls and to clean was discharged into Lake Erie, which was approximately a half a mile away. 

The rollers were switched out prior to each rolling depending on the specifications required for 

the roll. When the rolls were worn out or broken, they were thrown into the scrap car. There 

were stands 1 though 18, and each one of these stands had two rolls. When rolls became worn, 
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the roll shop had lathes where the rolls were turned down. The shavings would go into the scrap 

pan. It would all eventually end up in the blast furnace. 

Cleaning the inside of equipment was not a part of the routine cleanup operation. They also did 

not remove the burlap or rags from the stands after rollings. The AEC was more concerned 

about retrieving bigger pieces. 

4. STATISTICAL ISSUES 

Workers indicated that there were air, water, and other samples taken during the first two 

rollings. They do not remember it after that. They made no comments on the use of the 

triangular distribution. They were very concerned about the use of Simonds Saw air sampling 

data, as they didn’t feel the facilities were comparable. 

5. MEDICAL X-RAY DOSES 

When asked if they had medical exams, most workers said that they did not. At least one worker 

remembers having an annual exam with x-ray, urinalysis and blood sampling. There is 

indication that some workers received exams and others did not. Bethlehem Steel did have its 

own hospital at one time called Moses Taylor Hospital. The plant also had its own infirmary, 

fire department, and police squad. 

6. ODDS AND ENDS 

(a) Rollers, Assistant Rollers, Mill Hands, Millwrights, Crane Operators, Laborers, Foremen, 

Cooling Bed Operators, Shearmen, Slipmakers, Gaugers, Cradle Men, Speed Operators, 

Looper Operators, Rougher Operators, Section Men, Chippers, Scarfers, and Inspectors 

were some of the individuals that were involved in the rolling process. There were also 

maintenance crews for the mill. 

(b) Workers have indicated that when they have tried to get records from the National 

Archives or from the International Steel Group, they have had no success. 

(c) Salt baths were cleaned by dumping the contents on the plant property. 

(d) Dust was visible on cars outside the mill. It was seen on the streets of Lackawanna. The 

dust was either metal dust from rolling or blast furnace dust. 

(e) Steel mill workers typically remained working at one steel mill and did not transfer to 

other mills. However, there were ups and downs where workers were laid off. 

(f) Water dripped from the uranium when it was removed from the salt bath. 

(g) Men were offered financial incentives for keeping the mill running. 

The workers did not make any comments with respect to the solubility of the material. 
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ATTACHMENT 4 

Statistical Approach Regarding Analysis of Air Concentration Data

This statistical appendix covers the following: 

• Some basic principles that should guide the use of data when statistical models 

are used to represent it 

• An analysis of whether the triangular distribution used in Table 3 is a statistically 

appropriate way to represent the data 

• An analysis of the data relating to the most contaminated workstation on October 

27, 1948, to the extent represented by air samples taken on that date 

• An approach to fitting the Simonds October 27, 1948, dataset by a distribution 

more appropriate than the triangular, along with computations illustrating 

adjustments that might be made to compensate for claimant favorableness at the 

most contaminated workstations 

The TBD has used triangular distributions to represent uranium air concentrations at Bethlehem 

Steel. Table 2 represents a distribution for estimating minimum inhalation dose. For reasons 

discussed in the body of this report, it is not discussed here. Table 3, which is used to calculate 

maximum inhalation doses, is the focus of this analysis. 42 CFR 82 requires maximum radiation 

doses determined “using worst-case assumptions” to be estimated in such a way that “it can be 

determined that the employee could not have incurred a compensable level of radiation dose” 

(42CFR82.10(k)(3)). 

1. SOME BASIC PRINCIPLES 

The dataset that is represented in one distribution should be coherent and internally consistent in 

that chosen distribution, and its application should be appropriate for determining individual 

doses of the claimants. As discussed in Finding 2, there are very few data points for individual 

workstations. As a result, the statistical issues relate to the combined use of a facility air 

concentration distribution and considerations of its use with workstation and other data to derive 

scientifically defensible, claimant-favorable dose estimates for individuals. The distribution 

chosen to represent the air concentration data points for the facility should be statistically sound. 

Table 3 of the TBD does not fit this criterion. The TBD states that the upper bound parameter is 

derived from air concentration data from the Simonds facility. As discussed in the main body of 

this report, Simonds data may be used for representing Bethlehem Steel concentrations, but this 

should be done with care. 

We focus here on the issue of the method by which an appropriate facility distribution can be 

determined, and also on how the choices of values for use in maximum dose calculations can be 

made claimant favorable. We note that since there are differences of detail between Simonds 

and Bethlehem Steel, within overall comparability, it is preferable to use the data from Simonds 

alone to determine the distribution for use in Table 3. But the analysis below regarding lack of 
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claimant favorability applies in any case, even if one considers only the single issue of how the 

data from Simonds are to be used to determine an upper limit for contamination in a uranium 

metal rolling facility. If NIOSH did not want to use Simonds data, it could have chosen other 

ways to address claimant favorability (for example by using the approach in ORAUT-OTIB0004, as discussed in Procedural Conformance Issue 2). But once the choice to use Simonds 

data was made, it was essential that statistically defensible procedures be used to represent it. 

We discuss (1) ways in which only the data from the most contaminated workstation can be used 

to determine a maximum contamination estimate, and (2) how the entire October 27, 1948, 

Simonds dataset can be used to derive claimant-favorable and statistically defensible air 

concentration estimates. The latter is a two-step process. First, a suitable air concentration 

distribution for the facility is determined. Second, data from highly contaminated workstations 

are used to determine claimant-favorable values for especially hazardous locations. 

The second basic principle is that the parameters chosen for the distribution should not violate 

the mathematical conditions required of the form of the distribution. 

The requirement that dose estimates should be claimant favorable requires a third basic principle 

to be respected. If the claimants are known to have consistently been exposed to unusually high 

levels of contamination, then specific adjustments need to be made to ensure claimant 

favorability (see Section 4 of this attachment). 

Finally, these statistical principles must be complemented by a technical analysis of the validity 

of the data for the purposes to which it is being applied. Specifically, Section 5 of the report 

discusses two questions – (1) the quality of the data (including uncertainties), and (2) the 

applicability of the general air and near workstation short-term samples to individual worker 

intake (ICRP 75). 

2. THE TRIANGULAR DISTRIBUTION 

The TBD uses an upper bound of 1,000xMAC for Table 3, a mode of 2xMAC and a minimum of 

zero. The minimum should be somewhat greater than zero, due to the detection limit of the 

instrument, but since this makes no material difference to the calculations, a zero value for the 

minimum can be used. 

There is no generally accepted method for fitting the triangular distribution. One way to test 

whether a triangular distribution is a good fit is to use the method of maximum likelihood, 

because it respects the constraints of the problem. These are that there should be no data larger 

than the fitted upper bound and none below the fitted lower bound. Further, in this context the 

lower bound should be non-negative. This method is well known as being best in many contexts. 

We have used a standard statistical technique called the Q-Q plot to assess whether the triangular 

distribution is a good fit for the October 27, 1948, Simonds dataset. The Q-Q plot for a 

triangular distribution derived by the method of maximum likelihood is shown in Figure A4-1. 

The October 27, 1948, data points are shown in Table A4-1. SC&A recognizes that NIOSH was 

not trying to fit this dataset, but to use the Simonds data to find a maximum for the triangular 

distribution for estimating maximum doses. The discussion in Sections 3 and part of Section 4 

of this attachment focuses on this crucial problem. In this section, we assess whether a triangular 
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distribution is an appropriate way to represent the October 27, 1948, Simonds dataset (the only 

one comparable to the conditions at Bethlehem Steel, where there was no ventilation). This is 

because finding a claimant-favorable way to assess the maximum dose or the upper limit of 

contamination at Simonds requires a representation of all or part of the dataset in a statistically 

appropriate way. 

The Q-Q plot compares the actual data (sorted in ascending order) shown on the vertical axis in 

Figure A4-1 with the fitted points shown on the horizontal axis. The quantile is the increment 

used to fit the data, which is simply equal to (1/(number of data points)). In this case the number 

of data points is 38. Evidently the triangular distribution results in a very poor fit. In a good fit, 

the points would lie more or less along the straight line. Figure A4-2 shows a Q-Q plot for the 

triangular distribution in Table 3 of the TBD, assuming it represents the Simonds data. It is 

almost the same as that in Figure A4-1 and also a very poor fit. The choice of a triangular 

distribution to represent the dataset in question is therefore methodologically incorrect. As an 

aside, we note that all points, except that corresponding to the largest measurement, lie below the 

line. The maximum value is somewhat above the line. This means that, all other things being 

equal (e.g., ignoring issues relating to the validity of the air concentration data points 

themselves), the chosen distribution would provide a claimant-favorable estimate for locations 

that represent low air concentrations, except for workers in the most contaminated locations. 

Moreover, since the Simonds and Bethlehem Steel facilities are different in that the latter has 

more roller stations, this problem could be compounded. The main issue that emerges from the 

Q-Q plot is that the triangular distribution is not a methodologically appropriate way to model 

the October 27, 1948, Simonds dataset. Simply choosing a number near the largest measurement 

is also not appropriate. Using the Simonds data to find a maximum value for contamination or 

for assessing upper limit doses requires some statistical modeling of part or all of the October 27, 

1948, Simonds dataset. This can be done in two ways that are discussed in the next two sections. 

Section 3 discusses the use of the data from the most contaminated workstation. Section 4 

discusses how a facility air concentration profile can be constructed and how it can be used to 

determine claimant-favorable values for most workers and also for workers in the most 

contaminated workstations. 

Another problem with the lack of fit at the high end of the distribution is that the October 27, 

1948, data include measurements at only two of the three roller stations. This is because only 

two rollers were used that day, as opposed to three at other times (Spiegl 1949). This may make 

this particular dataset, the only comparable one available, less representative of the more 

contaminated areas at Bethlehem Steel for at least some rollings. At least six rollers were used at 

Bethlehem Steel (Sanderson 1952). 
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Figure A4-1. Q-Q Plot for Triangular Distribution Fitted by the Method of Maximum 

Likelihood 

Figure A4-2: Q-Q plot for a Fitted Triangular Distribution with Parameters 0, 2xMAC, 

and 1,000xMAC 
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Table A4-1: October 27, 1948, Air Concentration Data: Simonds Saw and Steel 

Sample Numbers Type dpm/m3 xMAC 

L700 general air between furnace and rollers south end 1410 20.14 

L701 general air in front of furnace closed 42 0.60 

L702 general air [illegible] N.W. of rolling platform 24 0.34 

L703 mark U bars 2740 39.14 

L704 general air in front of weigh scales near furnace 675 9.64 

L705 remove scale and quench 3390 48.43 

L706 take bar out of furnace 1470 21.00 

L707 take bar out of furnace 1260 18.00 

L708 take bar out of furnace 1615 23.07 

L709 roller #1 49000 700.00 

L710 roller #1 75000 1071.43 

L711 roller #1 22400 320.00 

L712 general air near roller 1 9250 132.14 

L713 general air removing scale and quenching 1065 15.21 

L714 general air at SW side of rollers near collector exhaust 147 2.10 

L715 general air 8 ft SW and above first roller 63 0.90 

L716 air sample exhaust from dust collector sampled 6' stack 126 1.80 

L718 roller 2 14800 211.43 

L719 roller 2 23800 340.00 

L720 roller 2 27900 398.57 

L721 roller #2 opposite end 943 13.47 

L722 roller #2 opposite end 836 11.94 

L723 roller #2 opposite end 418 5.97 

L724 operators place rod thru descaler 9350 133.57 

L725 operators place rod thru descaler 16150 230.71 

L726 operators place rod thru descaler 2420 34.57 

L727 BZ sample 3 rods going thru descaler 354 5.06 

L728 general air middle of rolling west side 10' from roller 31 0.44 

L730 general air by shears operator cutting rods 353 5.04 

L731 general air center of locker room 24 0.34 

L732 operator takes rod through roller #1 (opp. end) 1255 17.93 

L733 operator takes rod through roller #1 (opp. end ) 236 3.37 

L734 operator takes rod thru roller #2 (opp. end) 2700 38.57 

L735 general air middle (opp. end) of rollers #1 and #2 in operation 231 3.30 

L736 general air rec. and ship weigh, drop rods to floor 330 4.71 

L737 general air box car while loading and dropping bars 2740 39.14 

L738 BZ scale man weighing bars dropping to floor 630 9.00 

L741 general air in front of crane front of scales crane, bars dropped 1700 24.29 

Note: Control measurements not included. 1 MAC = 70 dpm/m3. Workstation descriptions are abbreviated. 

Source Appendix B, NYOO 1948. 
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In summary, the most basic arguments against the chosen approach and parameters in Table 3 

are as follows: 

• The triangular distribution is a poor fit for the October 27, 1948, data 

• Table 3 does not respect the constraint that the fitted upper bound should be 

greater than the largest observed data point 

• Other approaches should be used to develop the parameters needed for maximum 

dose estimation 

3. MODELING THE UPPER BOUND OF AIR CONTAMINATION AT SIMONDS

It is possible to estimate an upper bound for the facility air concentration at Simonds by 

modeling the data at the most contaminated workstation. SC&A has done several different 

calculations to show how this can be done. All approaches result in values for the maximum air 

concentration greater than the value of 1,000xMAC chosen in Table 3. The most comparable 

values deriving from bounded distributions that have been estimated range from 1,447xMAC to 

3,375xMAC. A triangular distribution was not used to model this data, since there is no 

generally accepted way of deriving the parameters and its use would be questionable here, since 

the analysis involves only three data points. 

The workstation represented by sample points L709, L710, and L711 was probably the most 

contaminated workstation on October 27, 1948, at Simonds. The work there is noted as 

“Operator nearest furnaces places bar into 1st roller bar lengthened” (NYOO 1948). These three 

data points include the two highest measurements. All three are included in the five highest 

readings in the dataset. 

Due to the very small sample size, no single statistical estimation procedure can provide a 

reliable estimate of the upper bound of air concentrations at this location and therefore for the 

facility as a whole. Various estimates of the upper bound parameter are derived using several 

common probability distributions as models for the data. 

There are two general classes of probability distributions to consider, including bounded and 

unbounded families of distributions. Bounded distributions are defined on a finite interval. 

Examples of bounded distributions are the uniform(a, b), which is a flat distribution defined on 

the interval between a and b and the loguniform, which is a flat distribution but for the 

logarithms of the data points. The triangular distribution is also bounded, but for reasons stated 

above, we do not consider it here. In the case of the two types of bounded distributions 

considered here, estimation of the parameters of the distribution includes direct estimation of the 

upper bound parameter b. 

The lognormal (μ, σ

2

) distribution is a common example of an unbounded distribution, 

constructed using the logarithms of the data points. In this case, the estimates derived for μ and 

σ are used indirectly to make an estimate of the upper bound. Since the lognormal distribution is 

unbounded, a choice must be made to select a value for the upper bound parameter. The upper 

bound of a (one-sided) 95% prediction interval was selected to represent the upper bound of 
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exposures. On average, a future measurement has a 5% chance of exceeding the 95% prediction 

bound. 

Parameter estimates may be based on the maximum likelihood criterion (which may be biased in 

some cases), the minimum variance unbiased criterion, or the best linear unbiased criterion, 

among others. In general, maximum likelihood estimates are used in this discussion, unless a 

clear bias exists that is not claimant favorable. In these few cases, unbiased estimates are 

considered more appropriate. The parametric estimation process is best summarized as “fitting a 

distribution to the data using the selected criterion.” Once the parameters of the distribution are 

estimated, an estimate of the upper bound parameter is made based on the best-fitting probability 

distribution. 

3.1 Uniform Distribution 

There are standard procedures for estimating the lower and upper parameters a and b of a 

uniform probability distribution on an unknown interval. The maximum likelihood estimators 

(MLEs) of a and b are aMLE = Xmin and bMLE = Xmax, where Xmin and Xmax are the smallest and 

largest observed values, respectively. However, the MLEs are known to be statistically biased. 

The direction of this bias works against the claimant. 

The best linear unbiased (BLU) estimators for the lower and upper bounds of a uniform 

distribution have a wider spread than the MLEs:3

 aBLU = Xmin - range/(n-1), 

and 

 bBLU = Xmax + range/(n-1). 

The additional terms are a fraction of the range = Xmax - Xmin. The difference between the MLEs 

and BLU estimators is small for larger sample sizes, but the difference is very large for a sample 

size of n = 3. The BLU estimate for the upper bound parameter exceeds the maximum observed 

value (i.e., the MLE) by one-half of the range. 

The BLU estimators improve the situation to a condition of being unbiased, but not necessarily 

claimant favorable. The range of uncertainty in the estimated upper bound must also be 

addressed. An approximate (one-sided) 95% upper confidence limit for b is given by: 

UCL.95(b) = Xmax + range·(1 + z.95 Sn) / (n - 1), 

where z.95 = 1.645 is the 95th percentile of the standard normal distribution and Sn

2

 = n(n1)/((n+1)(n+2)). The 95% UCL for b has a larger fraction of the range added to the maximum 

observed value. For n=3, the result is UCL.95(b) = Xmax + range·(0.95). 

 

3

 Johnson, Kotz, and Balakrishnan, (1994), Continuous Univariate Distributions, Volume II, 2nd. Ed., John 

Wiley and Sons. All results are derived from equations 26.25a and 26.25b on page 286, using the alternative 

parameterization of equation 26.1 on page 276 with α = L and β = U. 
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The Simonds sample numbers L709, L710, and L711 were all taken at the same place; feeding 

the metal into roller # 1. The recorded alpha measurements for these samples were 49,000, 

75,000 and 22,400 dpm/m3, respectively. The three observations at roller #1 rank number 1, 2 

and 5 in the full data set for that day, indicating that exposure for a good part of the day at this 

workstation is probably the worst case for worker exposure at Simonds. The maximum value of 

75,000 dpm/m3

 is equivalent to 1071 MAC, while the range is 751 MAC. The maximum and

range are sufficient statistics for estimating the upper bound b and the 95% UCL for b. The 

upper bound estimate is: 

 bBLU = 1071 + 751/2 = 1447 MAC. 

The 95% upper confidence limit for b is: 

 UCL.95(b) = 1071 + (751)(0.95) = 1785 MAC.

3.2 Loguniform Distribution 

Since the air concentration data vary widely and are highly non-uniform, the above procedures 

for the upper bound of the uniform distribution may be applied to the logarithms of the observed 

values. If the sample values have a loguniform(a, b) distribution, then the logarithms of the 

values have a uniform distribution on the interval from ln(a) to ln(b), where the symbol ln 

denotes the natural logarithm. Estimates for the lower and upper bounds of the loguniform 

distribution are obtained from: 

 ln( a ) = ln(Xmin) - ln(Xmax / Xmin) / (n - 1). 

and 

 ln( b ) = ln(Xmax) + ln(Xmax / Xmin) / (n - 1). 

An approximate (one-sided) 95% upper confidence limit for the upper bound b is derived from: 

 ln(UCL.95(b)) = ln(Xmax) + ln(Xmax / Xmin) [ (1 + z.95 Sn) / (n - 1) ], 

where z .95 and Sn

2

 are defined as in Section 3.1. 

With the very small sample size, the uncertainties in estimating the upper bound of the 

distribution are large. This is particularly true for the loguniform model, due to the exponential 

effect of uncertainty. If we assume a loguniform distribution for the three Simonds observations, 

the corresponding results are significantly higher than were obtained using the uniform 

distribution. The estimated upper bound for the air concentrations at roller # 1 is: 

 ln( b ) = ln( 1071 ) + ln( 1071/320 ) / 2 = 7.580, 

 or b = exp{ 7.580 } = 1960 MAC. 

The 95% upper confidence limit for the upper bound is: 

 ln(UCL.95(b)) = ln(1071) + ln( 1071 / 320 ) (.95) = 8.124, 
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or UCL.95(b) = exp{ 8.124 } = 3,375 MAC. The loguniform estimates of the upper bound and 

the 95% UCL for the upper bound at the roller #1 workstation are substantially higher than the 

estimates generated using the uniform distribution. 

3.3 Normal Distribution 

Now consider two unbounded distributions for these same three data points; the normal 

distribution and the lognormal distribution. The normal distribution is an unlikely candidate for 

air concentration measurements, but provides a good example to introduce terminology used for 

the lognormal distribution. For unbounded distributions, a 95% prediction bound (p.95) is 

calculated for the next observation. 

The normal (μ, σ

2

) distribution is the most common of the unbounded distributions, with μ 

representing the mean of the distribution and σ

 2 representing the variance. Parameter estimation 

for the normal distribution is well known. The MLE for μ is the simple arithmetic average of the 

observed values, 

 μ

MLE = (X1 + ... + Xn ) / n. 

The MLE for μ is also an unbiased estimate of the mean and the median of the normal 

distribution. 

The standard deviation is calculated from the estimate for the variance σ

 2. Two common 

variance estimates are the maximum likelihood estimate and the unbiased estimate. The MLE 

for σ

 2 is: 

 S2 = Σ (Xi - μ

MLE )2

 / n. 

The MLE for the variance is biased. The unbiased estimate for σ

 2 is nS2

/(n-1). To be claimant 

favorable, the unbiased estimate of the variance is used as an alternative to the MLE. 

The mean of the normal distribution is estimated as 697 MAC. The unbiased estimate of the 

standard deviation is 376 MAC. The 95% prediction bound for a normal distribution with these 

parameter values is μMLE + kn t2,0.95 S, where t2,.95 = 2.92 is 95th percentile of the t-distribution 

with 2 degrees of freedom and kn = sqrt((n+1)/n) = 1.155. The estimated value of the 95% 

prediction bound is: 

 p.95 = 697 + (1.155)(2.92)(376) = 1965 MAC.

3.4 Lognormal Distribution 

The lognormal (μ,σ

 2) distribution is the most common distribution used as a model for shortterm air concentration measurements. Parameter estimation for the lognormal distribution is 

based on the logarithms of the observations. The parameter μ represents the mean of the 

logarithms, while σ

 2 represents the standard deviation of the logarithms. Using the theory for 

the normal distribution described above, the estimate for μ is the simple arithmetic average of the 

logarithms of the three measurements, 
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 μ

MLE = (ln(X1) + ... + ln(Xn) ) / n = 6.432. 

The value exp{μMLE} provides an estimate of the median of the lognormal distribution, but is not 

a good estimate of the mean of the distribution. The estimate of the mean of the lognormal 

depends on the estimates of the median and the standard deviation of the logarithms. 

Following the procedure for an unbiased estimate of the variance of the normal distribution, the 

usual estimate for σ

2

 of the lognormal distribution is: 

 S2 = Σ (ln(Xi) - μMLE )

2

/ (n-1) = 0.3757, 

and S = 0.6129 MAC is the estimated standard deviation of the logarithms. The 95% prediction 

bound for the next observation is estimated by exp{μMLE + kn t2,.95 S}, where t2,.95 = 2.92 is 95% 

of the t distribution with 2 degrees of freedom, and kn = sqrt((n+1)/n). The estimated value of the 

95% prediction bound for the lognormal distribution model is: 

 p.95 = exp{6.432 + (1.155)(2.92)(0.6129)} = 4910 MAC. 

Using the maximum likelihood estimate of the variance produces a more conservative estimate 

of the 95% prediction bound. Using the MLE, the estimate for σ

 2 of the lognormal distribution 

is: 

 S2

 = Σ (ln(Xi) - μMLE )

2

/n = 0.2505, 

and S = 0.5005 MAC is the estimated standard deviation of the logarithms. The 95% prediction 

bound for a lognormal distribution with the MLE parameter values is estimated by: 

 p.95 = exp{6.432 + (1.155)(2.92)(0.5005)} = 3360 MAC. 

3.5 Results 

Due to the small sample size used in this analysis, it is not possible to select a single probability 

distribution for the Roller # 1 measurements. The strategy of using many commonly 

encountered distributions demonstrates that a wide range of results is possible using a variety of 

standard statistical procedures. 

A variety of bounded and unbounded probability distributions were examined as possible modes 

for the three measurements at Roller #1, using both maximum likelihood and unbiased 

estimation procedures. As shown in Table A4-2, all estimates of the upper bound of the bounded 

distributions and all estimates of the 95% prediction bound for the unbounded distributions 

exceed the upper limit of the upper bound triangular distribution of 1,000 MAC reported in Table 

3 of the TBD. 

The various values for bounded distributions range from about 1,450xMAC to almost 

3,400xMAC. This set of estimates would most closely correspond to a choice of an upper bound 

for a facility air concentration based on a bounded distribution and the assumption that the above 

workstation is the most contaminated one. 
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Estimates of the 95% prediction bound for the unbounded distributions range from a low of 

1,965xMAC for the normal distribution up to 4,910xMAC for the lognormal distribution using 

the unbiased variance estimates. The range of over a factor of 3 between the lowest and highest 

estimates in Table A4-2 illustrates the difficulties presented by the small data set available for 

the most contaminated workstation. The point here is that given the limited data, it is possible to 

come up with a wide variety of estimates for the upper bound. Technical constraints such as data 

on uranium losses and/or visibility would have to be introduced to supplement the data to narrow 

the choice for the upper bound. 

Table A4-2. Estimates of the Upper Bound or 95% Prediction Bound for Airborne 

Uranium Concentrations in MAC Units for Selected Bounded and Unbounded Probability 

Distributions (1 MAC = 70 dpm/m3) 

Type of Distribution 

Estimate of 

Upper Bound 

(b) 

95% Upper Confidence 

Limit for b

UCL.95(b) 

Estimate of 95% 

Prediction Bound (p.95) 

Uniform(a,b) 1,447 1,785 -- 

Loguniform(a,b) 1,960 3,375 -- 

Normal(μ,σ2) -- -- 1, 965 

Lognormal(μ,σ2) - 

Use unbiased σ2 -- -- 4, 910 

Lognormal(μ,σ2) - 

Use MLE for σ2 -- -- 3,360 

4. A LOGNORMAL FACILITY AIR CONCENTRATION DISTRIBUTION 

An alternative approach to estimating a maximum of the facility air concentration distribution is 

to model the entire dataset using a lognormal distribution. The Q-Q plot for this is shown in 

Figure A4-3. The fit is done using the maximum likelihood method applied to the distribution of 

the log data; it has a mean μ = 2.82 and a variance σ2 = 4.57. 

Figure A4-3 is a plot showing the original data on the Y-axis and the fitted lognormal 

distribution also in multiples of MAC on the X-axis. It is evidently a much better fit for the 

dataset than the triangular distribution. Note that it does not represent the high end of the air 

concentrations well, but it is somewhat claimant favorable there. But it is not claimant favorable 

for the lower values of air concentration. 

The problem of lack of claimant favorability for workstations at the low end of reported air 

concentrations can be addressed by using the 95th percentile value of this distribution as a 

claimant-favorable estimate. This value is about 570xMAC. (This is without regard to the issue 

of the validity of using unadjusted air concentration data, as per ICRP 75, discussed below.) 

This can be compared to the average of the triangular distribution in Table 3 of the TBD, which 

is 334xMAC. 
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Figure A4-3. Q-Q Plot of the Original Data with Fitted Lognormal Distribution 

Note that the 95th percentile value is not claimant favorable for highly contaminated 

workstations. This is because we know that the average of the three measurements at Roller #1 

is 700xMAC, which is greater than the 95th percentile of the lognormal distribution. Therefore a 

claimant-favorable estimate for the most contaminated workstation must be considerably greater 

than 700xMAC, especially given that there are only three data points for this workstation. A 

claimant-favorable adjustment can made by making a specific modification for the upper bound 

of this distribution using these three data points (L709, L710, and L711). 

4.1 A Methodology for Adjusting Upper Bounds on Exposure of the Lognormal 

Distribution 

As before, we identify Roller # 1 as the source of the largest exposure. As noted above, the two 

highest air concentration measurements are at this station. The third measurement is among the 

top five, with the other two being at Roller #2. We identify the tail of the facility distribution as 

these top five measurements. It therefore includes all three points at Roller #1. 

We assume that the lowest measurement in the tail of the distribution, which consists of 

measurements at the two most contaminated workstations, is L. A claimant-favorable solution is 

to take L = 320xMAC, which is the lowest measured value of the five data points in question 

(L709, L710, L711, as well as L719 and L720). The 95th percentile point on this tail, calculated 
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using the t-distribution with 37 degrees of freedom of the logarithms of the 38 data points, would 

be about 8.379. This amounts to about 4,350xMAC.4

In sum, for exposure estimation of workers known not to be in highly contaminated areas, the 

95th percentile value of the entire facility distribution may be regarded as a claimant-favorable 

estimate. This is about 570xMAC. For workers for whom there is no information about 

workstations (as for instance when the claimants are family members and do not have the 

information) or for workers in the more contaminated workstations, the 95th percentile of the 

adjusted tail of the distribution may be regarded as a claimant-favorable estimate. This would be 

about 4,350xMAC. As noted in the report, these figures are given here to provide 

methodological illustrations and not as recommendations for use, since actual values depend on 

more than statistical methodology. In particular, they also depend on evaluation of air 

concentration data. 

5. AIR CONCENTRATION DATA 

The air concentration dataset of October 27, 1948, is a mixture of general air samples taken over 

a few minutes to a few tens of minutes, with samples marked as taken at specific workstations. 

Only two samples are marked as breathing zone samples. There are more breathing zone 

samples in the Bethlehem Steel datasets. However, it is unclear how breathing zone samples 

were taken during the late 1940s and early 1950s, and whether they represented true sampling of 

the breathing zone. The implications of each of these three for use of the data would be 

different. The TBD has not addressed these issues. 

ICRP 75 suggests that there are significant differences between the activity concentration in the 

worker breathing zone and the concentration measured at a fixed location, with the concentration 

in the breathing zone usually higher. ICRP 75 further recommends that conversion factors 

relating the area measurement to the concentrations in the immediate breathing zone should be 

established and applied. The use of such factors involves a great deal of judgment. There are no 

long-term data for validation. The air concentrations are highly variable with time and location. 

There was more than one process used at Bethlehem Steel. Much of the data is destroyed or lost. 

Some of the existing data is illegible. ICRP 35, General Principles of Monitoring for Radiation 

Protection of Workers: A Report of Committee 4 of the ICRP, the predecessor of ICRP 75, has 

suggested that under the circumstances at Bethlehem Steel, the actual breathing zone air 

concentrations may be two or three orders of magnitude different than general air samples (ICRP 

1982). Sherwood has shown that air concentrations employees are exposed to can vary by 100-

fold (Sherwood 1966). 

 

4

 The upper tail portion of the facility lognormal distribution was selected to represent the distribution of air 

concentrations near roller 1. The upper bound of a 95% prediction interval for this left-truncated distribution is 

located at the 99.3 percentile of the facility lognormal distribution. Hence, the 95% prediction bound for the roller 1 

work station can be estimated by using the 99.3 percentile of a t-distribution with 37 degrees of freedom 

(corresponding to 38 data points) = mean + (sqrt(39/38))*2.566*(standard deviation), where the mean and standard 

deviation are estimated from the logarithms of the data points. In this case these estimates are about 2.82 and 2.14, 

respectively (rounded). 
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For instance, if the general air samples and the two exhaust-duct-related samples from the 

October 27, 1948, dataset are dropped, a set that is related to workplaces only is obtained. This 

can be taken at face value. In this case, the 95th percentile of a lognormal distribution works out 

to about 810xMAC. If the data values are adjusted upward by an order of magnitude, the result 

obviously would be ten times higher at about 8,100xMAC. 

In view of the combined difficulties of the Bethlehem Steel, as well as Simonds datasets, the 

general approach that NIOSH developed in ORAUT-OTIB-0004 for all uranium metalworking 

AWE facilities is a possible attractive alternative. This is because instead of attempting to adjust 

the data on a facility-specific basis in light of ICRP 75, ORAUT-OTIB-0004 has used a different 

set of principles for examining all metalworking AWEs together to develop a claimant-favorable 

approach that might be more generally applicable. However, the constraint that some workers in 

highly contaminated areas may be exposed to more than the general procedure adopted must be 

kept in mind in making individual dose estimates. 

6. SUMMARY AND CONCLUSIONS 

The air concentration dataset from October 27, 1948, at Simonds has been modeled in order to 

assess the appropriateness of the distribution and the parameters used in Table 3 of the TBD to 

calculate maximum doses. In order to illustrate the method, these data have been taken at face 

value and no technical adjustments are made as recommended by ICRP 75. The results should 

be taken as illustrative of the methods we suggest, rather than definitive. More detailed 

discussion of the approaches for estimating dose is discussed in the main body of the report. In 

summary: 

• The triangular distribution in Table 3 of the TBD is not appropriate on three 

counts. First, its mode has not been selected from the Simonds dataset. Second, 

the triangular distribution is a very poor fit for the data. Third, the maximum 

value in Table 3 violates the rule that the estimate of the upper bound parameter 

of a triangular distribution must be larger than the largest data point. 

• A value for the upper bound of the facility air distribution can be obtained by 

modeling the most contaminated workstation as having its own air concentration 

distribution. A variety of widely differing estimates is possible, depending on the 

choice of distribution, since there are only three data points. The estimates for 

bounded distributions, which would be most comparable to the triangular case 

used in Table 3 of the TBD, range from about 1,450xMAC to almost 

3,400xMAC. 

• The entire facility air concentration can be modeled by a lognormal distribution. 

This is a much better fit for the data than a triangular distribution. The difference 

between this approach and the one just above is that, in this case, the air data for 

the most contaminated workstation are assumed to be part of a single facility air 

concentration distribution. In this illustration, the 95th percentile value of this 

distribution, which is about 570xMAC, may be used for assessing intake by 

workers who are not known to work in highly contaminated locations. But this is 

not claimant favorable for workers at the latter locations. In this case, the 95th
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percentile value of the tail of the distribution defined as the five highest 

concentrations can be used. This is about 4,350xMAC. 

• When air sampling issues are taken into account in light of ICRP 75, the entire 

estimation procedure becomes more complex and more disposed to subjective 

interpretation. A comparison of the application of ICRP 75 strictures to specific 

facilities with the approach taken in ORAUT-OTIB-0004 is needed to examine 

which approach is more scientifically defensible. Given the many difficulties 

with data from individual facilities, the general approach in ORAUT-OTIB-0004 

obtained by examining data at many uranium metal working AWEs may be an 

attractive alternative and more technically defensible. A comparison of the two 

approaches is beyond the scope of this review. SC&A will review ORAUTOTIB-0004 under Task 3.