Technical Basis Document
Basis for Development
of an Exposure Matrix for Bethlehem Steel Company
(Approved July 27, 2006)
PDF 395 KB (41 pages)
Revision Includes: Approved issue of Revision 0 of OCAS-TKBS-003. This supersedes rev. 1 of the previous ORAUT-TBKS-0001.
An Exposure Matrix indicates the type and quantity of
radiation exposure to individuals for a specific location
and specific time. Locations can be as broad as an entire
facility or as narrow as a single small room. Time can
be years, months, or even a single event. When personnel
monitoring data are incomplete or do not exist, an exposure
matrix is developed to estimate the dose. The matrix is
typically developed using a combination of personnel monitoring
data in conjunction with area monitoring data. Once the
exposure is estimated, data about how long the worker
was exposed (time) is used to estimate their total exposure.
There was no identified documentation that contained personal
monitoring data for employees of the Bethlehem Steel site.
Therefore, an exposure matrix that relied on air sampling
data was developed to estimate radiation dose to many
individuals. The matrix that was developed can be used
to estimate the dose for a large number of the employees
at the Bethlehem Steel site.
In many cases, the development of a facility specific
matrix is more difficult but due to the limited operations
that took place in this AWE, this matrix was able to be
developed more quickly. The following documented facts
were used in the development of this matrix:
- Uranium processing occurred
on one rolling mill.
- The amount of time involving
work with uranium was no more than 500 hours total
over a four year period.
Because of these two facts, the workplace exposure conditions
could be estimated from the available data. Once the workplace
exposures were estimated, Bethlehem Steel employees are
then assumed to be exposed to these "worst-case scenario"
conditions as a claimant favorable approach.
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Technical Information Bulletins (TIBs)
At the current time, there are no TIBs for Bethlehem Steel Company.
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Program Evaluation Reports (PERs) and Program Evaluation Plans (PEPs)
NIOSH is committed to applying the best available science in dose reconstructions. In keeping with this commitment, completed cases with probabilities of causation less than 50% are reviewed as relevant new information becomes available. The results of these reviews are described in a Program Evaluation Report (PER). The PER details the effect, if any, of the new information on the completed dose reconstruction. If it appears that the compensability of a completed dose reconstruction may be effected, NIOSH is committed to working with the Department of Labor to reopen and rework the dose reconstruction, as appropriate. A Program Evaluation Plan (PEP) describes plans for evaluating specific program details or issues.
- Evaluation of the Effect of Adding Ingestion Intakes to Bethlehem Steel Cases
PDF 31 KB (3 pages)
Document Number: OCAS-PER-0003 Rev-00
About this Document: Describes the evaluation of the programmatic
effect of the effect of adding ingestion intakes to Bethlehem Steel cases.
Approved: January 28, 2005
Summary: As a result of adding ingestion
intakes, the probability of causation of none of the
previously completed Bethlehem Steel claims would increase
to greater than 50%.
- Evaluation of the Effect of Revision 2 of the Site Profile on Previously Completed Bethlehem Steel Cases
PDF 42 KB (7 pages)
Document Number: OCAS-PER-0007 Rev-00
About this Document: New document to evaluate the effect of revision 2
of the site profile on previously completed dose reconstructions from Bethlehem Steel.
Approved: November 9, 2006
Summary: The Bethlehem Steel Technical Basis Document was revised on July 27, 2006. The revision changed the estimated quantity of uranium inhaled and ingested as well as external dose to the skin. As a result of revisions to the Bethlehem Steel Technical Basis Document, three claims that were previously determined to have a PC of less than 50% will now have a PC greater than 50%. Eight cases that previously had a PC greater than 50% now have a PC less than 50%. This report, along with detailed information on the specific cases and calculations, has been provided to DOL for determination of further action.
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Worker Outreach Activities
Based on a recommendation from the Advisory Board to provide workers and site experts with opportunities to participate in developing the technical documents used in dose reconstruction, NIOSH established a Worker Outreach Program.
At Worker Outreach Meetings, current and former DOE and AWE employees have opportunities to obtain information about Site Profiles, Technical Basis Documents, and Technical Information Bulletins, and to provide information for consideration and possible use in dose reconstruction. This process is valuable to ensure that the technical documents used in dose reconstruction contain correct and useful information.
Below are the Worker Outreach Activities for the Bethlehem Steel Company:
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Comments on Bethlehem Steel Company Documents
How to Submit Comments
Comments on Bethlehem Steel Company documents can be submitted to the NIOSH Docket Officer electronically by e-mail at NIOCINDOCKET@cdc.gov or printed comments can be mailed to NIOSH Docket Office, Robert A. Taft Laboratories, MS-C34, 4676 Columbia Parkway, Cincinnati, OH 45226. Please include the Site Profile Number (011) on all comments.
Comments Received
- Comments from DOL regarding the Bethlehem Steel SEC Petition Evaluation Report
February 21, 2007
PDF 105 KB (1 page)
- Letter to Ed Walker
September 11, 2006
PDF 18 KB (2 pages)
Note: The enclosures to the letter are available upon request.
- Letter from Ed Walker
June 2006
PDF 29 KB (8 pages)
NIOSH response to Mr. Ed Walker's June 2006 letter August 22, 2006
PDF 1.3 MB (17 pages)
- Letter from Ed Walker
January 10, 2006
PDF 193 KB (5 pages)
NIOSH response to Mr. Ed Walker's letter February 3, 2006
PDF 142 KB (4 pages)
- Comments from Edwin Walker: New Acquired Information Pertaining to the Bethlehem Steel Site Profile
June 25, 2005
PDF 1.28 MB (13 pages)
NIOSH response to Mr. Edwin Walker's comments August 16, 2005
PDF 636 KB (3 pages)
- Review of NIOSH Site Profile for Bethlehem Steel Plant, Lackawanna, NY
Contract No. 200-2004-03805
Task Order No. 1
SCA-TR-TASK1-0001
October 2004
PDF 512 KB (87 pages)
NIOSH Comments on the SC&A Review of the Bethlehem Steel Site Profile Specific Responses to Findings, Observations, and Procedural Non-conformances
PDF 65 KB (14 pages)
- NIOSH Worker Outreach Meeting with Bethlehem Steel Claimants Action Group--Retired Plan Workers Advocacy Group
July 1, 2004
PDF 81 KB (17 pages)
- Comments from M. Resnikoff on behalf of Radioactive Waste Management Associates: NIOSH Dose Reconstruction -- Manhattan Project.
PDF 57 KB (1 page)
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Special Exposure Cohort Petition Information for Bethlehem Steel Company
- Submissions Not Qualifying
for Evaluation
Two separate submission were received but did not qualify for evaluation because one submission did not meet the minimum petition requirements and the other submission was withdrawn by the applicant.
- Petition Information
-
Location: 10 inch Bar Mill and Blooming Mill
Job Titles and/or Job Duties: Millwrights, welders, electricians,
bricklayers, carpenters, all maintenance, testers, rollers, supervisors, crane operators, hookers, clean-up crews, grinders
Period of Employment: 1949 through 1952
- Federal Register Notice Announcing that the Bethlehem Steel Corporation SEC Petition has met the Minimum Qualifications for Review and Evaluation
September 7, 2006
PDF 45 KB (1 page)
- Copy of the Petition Received
Bethlehem Steel Company SEC Petition
PDF 4.1 MB (10 pages)
Attachments to the petition:
13" Bar Mill: Lackawanna Plant (brochure)
PDF 2.1 MB (5 pages)
Photo of cooling bed
PDF 493 KB (1 page)
Sketch of cooling tables
PDF 717 KB (1 page)
- SEC Petition Evaluation Report
Bethlehem Steel Company SEC Petition Evaluation Report
PDF 202 KB (53 pages)
- Petition to be Discussed by the Advisory
Board
The Advisory Board discussed the petition on May
3, 2007; July 18, 2007; January 9, 2008; and April 9, 2008, during its regular meetings.
- Advisory Board Recommendation on SEC Petition
The Advisory Board has not discussed the petition at this time.
- NIOSH Letter to HHS Regarding the SEC Petition
Not completed at this time.
- HHS Letter to Congress Regarding the SEC Petition
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
- Federal Register Notice: Designation of a Class of Employees
for Addition to the Special Exposure Cohort
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
- HHS Designation of Additional Members to the SEC
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
- Effective Date for the SEC Class
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
- Federal Register Notice: Final Effect of Designation of a Class of Employees for Addition to the Special Exposure Cohort
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
- Letter to DOL Regarding the Addition of a New Class of Employees to the SEC
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
- Letter from DOL Regarding the Return of All Cases for the New SEC Class
Not applicable at this time.
(Note: this only applies if the class is added to the SEC.)
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Previous Versions of Bethlehem Steel Company Documents
- Basis for Development of an Exposure Matrix for Bethlehem Steel Company
- Revised June 29, 2004
PDF 161 KB (13 pages)
Revision Includes: Revision to incorporate occupational X-ray doses from the OTIB-0006, estimates of ingestion intakes, and additional OCAS comments.
- Approved March 31, 2003
PDF 1.4 MB (15 pages)
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Page last updated: March 19, 2008
Page last reviewed: May 30, 2008
Content Source: National Institute for Occupational Safety and Health (NIOSH)
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