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Technical Basis Document
Basis for Development
of an Exposure Matrix for Bethlehem Steel Corporation
(Revised November 30, 2010)
 PDF 682 KB (34 pages)
Revision Includes: Incorporates SEC designation information;
additional changes include deletion of unnecessary information throughout document
affected by SEC; added information regarding recycled uranium at BSC and additional
rolling data to Table 1; corrected minor typographical errors; included NIOSH
internal comments.
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Technical Information Bulletins (TIBs)
At the current time, there are no TIBs for Bethlehem Steel Corporation.
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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 new information may result in an increase in dose for a completed dose reconstruction with a probability of causation of less than 50%, 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 Corporation:
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Advisory Board Work Group on the Use of Surrogate Data
This Work Group will consider the conditions under which "surrogate" data can be used as a valid substitute for actual data for a given site.
The Work Group will seek to establish the type and importance of various parameters (e.g., type of nuclide, amounts of material, chemical and physical
forms, processes, working conditions, and other such parameters) that impact on worker dose, and will consider the extent to which such parameters at one
site may apply to other sites. The Work Group may also consider the extent to which theoretical considerations can be properly used to bound dosed in the
absence of actual workplace measurements. The Work Group should strive to develop a policy recommendation that can be adopted by the Board regarding the
use of surrogate data. This Work Group was asked to consider the application of surrogate data criteria to the Texas City Chemicals, Inc., site in relation
to the SEC petition for that facility.
- Work Group Members
James Malcolm Melius, M.D., Dr. P.H.-Chair
Josie Beach
James E. Lockey, M.D., M.S.
Wanda I. Munn
- Meeting Information
- May 13, 2010
Teleconference Meeting of the Advisory Board's Work Group on the Use of Surrogate Data
1:00 p.m. (Eastern time)
This meeting is open to the public, but without a public comment period.
Teleconference call access is available for this meeting
and it is limited only by the number of ports available.
To access the meeting via the teleconference call access,
you must dial 1-866-659-0537. To be automatically connected
to the meeting, you will need to enter the following participant
code: 9933701.
Agenda
PDF 45 KB (1 page)
Transcript
PDF 131 KB (69 pages)
Please note that as part of the procedures and processes of the Advisory Board's Work Groups, several kinds of pre-decisional documents may be developed. These documents, which can include white papers, matrices, working drafts, etc., are distributed among the Work Group members as research and background tools to facilitate discussion and deliberation. The discussions during the above meeting may cover a pre-decisional document. Because these types of documents are pre-decisional in nature, may contain sensitive information, and may change over time, they are not posted on our Web site. These finalized, reviewed and redacted pre-decisional documents are also available to other interested parties through an appropriate Freedom of Information Act request. Requests for documents not in the public domain should be submitted to the CDC/ATSDR Freedom of Information Act Office at foiarequests@cdc.gov.
- November 16, 2007
Teleconference Meeting of the Advisory Board's Work Group on the Use of Surrogate Data
2:00 p.m. (Eastern time)
This meeting is open to the public, but without a public comment period. To access the meeting via the call-in access, you must dial 1-866-659-0537. To be automatically connected to the meeting, you will need to enter the following participant code: 9933701.
An agenda will be available at a later date.
Transcript
PDF 105 KB (69 pages)
Please note that as part of the procedures and processes of the Advisory Board's Work Groups, several kinds of pre-decisional documents may be developed. These documents, which can include white papers, matrices, working drafts, etc., are distributed among the Work Group members as research and background tools to facilitate discussion and deliberation. The discussions during the above meeting may cover a pre-decisional document. Because these types of documents are pre-decisional in nature, may contain sensitive information, and may change over time, they are not posted on our Web site. These finalized, reviewed and redacted pre-decisional documents are also available to other interested parties through an appropriate Freedom of Information Act request. Requests for documents not in the public domain should be submitted to the CDC/ATSDR Freedom of Information Act Office at foiarequests@cdc.gov.
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Comments on Bethlehem Steel Corporation Documents
How to Submit Comments
Comments on Bethlehem Steel Corporation 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/Docket Number (011) on all comments.
Comments Received
- Letter to the Advisory Board from Congressman Brian Higgins on behalf of Bethlehem
Steel workers
(May 19, 2010)
PDF 120 KB (1 page)
Advisory Board response to May 19, 2010, letter from Congressman Brian Higgins
(June 2, 2010)
PDF 41 KB (1 page)
- 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 Corporation
- SEC Petitions Not Qualifying for Evaluation
Two separate petitions were received but did not qualify for evaluation because one petition
did not meet the minimum petition requirements and the other petition was withdrawn by the
applicant.
- Class Added to the SEC
All Atomic Weapons Employer employees who worked at the Bethlehem Steel Corporation facility in Lackawanna, New York from January 1, 1949 to December 31, 1952, for a number of work days aggregating at least 250 work days, occurring either solely under this employment or in combination with work days within the parameters established for one or more other classes of employees in the Special Exposure Cohort.
- Petitions Qualified for Evaluation
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 79 KB (1 page)
- Copy of the Petition Received
Bethlehem Steel Corporation SEC Petition
(March 13, 2006)
PDF 4.1 MB (10 pages)
Attachments to the petition:
- SEC Petition Evaluation Report
Bethlehem Steel Corporation SEC Petition Evaluation Report
(February 21, 2007)
PDF 202 KB (53 pages)
- Petition to be Discussed by the Advisory Board
The petition was discussed by the Advisory Board on May 20, 2010; May 3, 2007; July 18, 2007; January 9, 2008; and
April 9, 2008, during its regular meetings.
- Advisory Board Recommendation on SEC Petition
Advisory Board recommendation regarding the Bethlehem Steel Corporation SEC Petition (January 1, 1949 to December 31, 1952)
(June 11, 2010)
PDF 48 KB (2 pages)
- HHS Letters to Congress Regarding the SEC Petition
HHS Letters to Congress regarding the Bethlehem Steel Corporation SEC petition
(July 14, 2010)
PDF 108 KB (11 pages)
- Federal Register Notice: Designation of a Class of Employees
for Addition to the Special Exposure Cohort
Designation of a Class of Employees from Bethlehem Steel Corporation to the SEC
(July 30, 2010)
PDF 69 KB (1 page)
- HHS Designation of Additional Members to the SEC
HHS Designation of additional members from Bethlehem Steel Corporation to the SEC
(July 14, 2010)
PDF 48 KB (6 pages)
- Effective Date for the SEC Class
August 13, 2010
- Federal Register Notice: Final Effect of Designation of a Class of Employees for Addition to the Special Exposure Cohort
Final Effect of Designation of a Class of Employees from Bethlehem Steel Corporation for Addition to the SEC
(August 23, 2010)
PDF 67 KB (1 page)
- Letter to DOL Regarding the Addition of a New Class of Employees to the SEC
Letter to DOL Regarding the Addition of a New Class of Employees from Bethlehem Steel Corporation to the SEC
(August 24, 2010)
PDF 29 KB (1 page)
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Previous Versions of Bethlehem Steel Corporation Documents
- Basis for Development of an Exposure Matrix for Bethlehem Steel Corporation
- Revised 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.
- Revised June 29, 2004
PDF 160 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 159 KB (14 pages)
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