SEC Petition 116 ‐ United Nucl

Uranium Refining Atomic Weapons Employers Wor

Henry A. Anderson, MD (Chair)

R. William Field, PhD

David Kotelchuck, PhD, MPH

Presented to:

The Advisory Board on Radiation and Worker He

Denver, Colorado Meeting

September 18–20, 2012
United Nuclear ‐ Summar

• The Uranium Refining AWE Work Group

recommends that Petition 116 be denied

• The Work Group review process underlyin

recommendation will be described in thefollowing slides

• The presentation examines both the Unite

Nuclear Site Profile and the SEC PetitionEvaluation Report, since they are closelyintertwined
United Nuclear – Site Descrip

• Located in Hematite, Missouri• Manufactured uranium metal and uran

compounds from natural and enriched

uranium for use as nuclear fuel for U.S. and commercial customers

• Manufactured Th‐U oxide pellets in 196

• Operations Period from 1958–1973• Residual Period from 1974–2009
United Nuclear – Chronolo

• March 2008 – NIOSH Issues Appendix 

TBD‐6001 (Battelle 2008) – Site Profile 

United Nuclear, Rev. 0

• June 2008 – NIOSH receives SEC Petitio

• November 2008 – NIOSH qualifies Peti

116 for evaluation

• August 2009 – NIOSH issues SEC Petitio

Evaluation Report (NIOSH 2009)
United Nuclear ‐ Chronology (c

• September 2009 – SC&A provides review 

United Nuclear Site Profile only (SC&A 20

Review makes 6 Findings.

• February 2010 – NIOSH issues revision to

Petition Evaluation Report (NIOSH 2010

• April 2010 – NIOSH issues Rev. 1 to Appe

(United Nuclear Site Profile) (NIOSH 201

Revised to include additional site‐specifi

• June 2010 – SC&A delivers review of Rev

Appendix D (SC&A 2010a)
United Nuclear ‐ Chronology (c

• September 2010 – SC&A delivers focuse

review NIOSH Petition Evaluation Repor

(SC&A 2010b) with

8 Findings

• March 2011 – NIOSH issues free

‐standin

Profile replacing Appendix

D of TBD

‐600

(DCAS 2011)

• November 2011 – NIOSH issues white p

responding to SC&A review of PER (Dav

2011, Clark 2011, Hughes 2011)

• September 2012 – Work Group propose

deny SEC Petition
United Nuclear – Uranium Refi

AWE Work Group Activities

• July 7, 2010 (First meeting under TBD‐600• November 4, 2010• May 16, 2011• August 16, 2011 (As Uranium Refining AW• November 21, 2011• February 14, 2012• September 7, 2012
United Nuclear ‐ Monitoring 

• Extensive bioassay data available at UNC

• Bioassay coworker model developed for operat

and supervisors/laborers for two periods: prio

June 1963 and after June 1963, when significan

process improvements made at site

• Bioassay data gap exists during 1961–1962, bu

sampling data are available to validate bioassa

model

• Coworker model intakes are more claimant

‐fav

than intakes based on air sampling for 1961–19

period (NIOSH 2011)

• NIOSH agreed to modify coworker model to us

95th percentile for gap period (1961–1962) and 

distribution for other years (9/7/2012 WG Mee
United Nuclear – Urinalysis Monitoring 

Year No. of Employees No. of Samp

1958 19 71959 41 1381960 37 1061961 0 01962 74 1961963 110 17301964 45 15371965 57 12381966 87 13511967 64 13201968 116 op. /74 non‐op 1845

1969 131 19801970 45 158

Data for 1971–1973 available but not reliable.Source: NIOSH PER for SEC‐116.
United Nuclear – Resolution of 

Profile Findings

• SC&A made 6 Findings based on its rev

Appendix D of TBD‐6001 (Battelle 2008

• Some of the Findings were inter‐relate

PER Findings

• All Site Profile Findings have been reso

in principle, but minor clean‐up remain
United Nuclear – Resolution of Site 

Finding #1

• SC&A Finding: Current guidance for ass

occupational medical dose is insufficien

prescriptive

• Resolution: On November 4, 2010, the

Uranium Refining AWE Work Group clos

Finding #1 on the basis that there were 

occupational medical exposures at the site
United Nuclear – Resolution of Site 

Finding #2

• SC&A Finding: Default doses defined in

Battelle‐TBD‐6001, Appendix D, Rev. 0 foexternal whole‐body and skin doses are exclusively on summary statements of a AEC inspection report and may beinappropriate

• Resolution: New dosimetry data coverin

years 1958–1973 were subsequentlyincorporated in Battelle‐TBD‐6001, Appe

D, Rev. 1; the Work Group closed Finding 

on 11/4/2010
United Nuclear – Resolution of Site 

Finding #3

• SC&A Finding: Potential exposures to

neutrons are not addressed in Battelle‐T

6001, Appendix D, Rev. 0

• Resolution: In Section D.4.2 and Table D

Battelle‐TBD‐6001, Appendix D, Rev. 1, Nintroduced modeled neutron doses for tjob categories that employed claimant‐favorable assumptions/model parameteaddress Finding #3
United Nuclear – Resolution of Site 

Finding #4

• SC&A Finding14: The geometric mean of cowo

inhalation intakes of uranium, as recommendeNIOSH in Table D.1 of Battelle‐TBD‐6001, Appe

Rev. 0 for all workers, may not correlate with

empirical UNC urinalysis data for select years.

• Resolution: (1) NIOSH has restricted the use o

Table D.1 to UNC workers for whom bioassay d

inadequate; and (2) in the recent Work Group

discussion (9/7/2012), NIOSH has agreed to us

95th percentile values of the coworker intakes

defined in Table D.1 for 1961–1962 when no b

data are available.
United Nuclear – Resolution of Site 

Finding #5

• SC&A Finding: NIOSH provides insufficient

information regarding the method used to der

inhalation intakes from residual contamination

• Resolution (Conditional): In a Work Group sess

dated 11/4/2010, NIOSH agreed that there wa

mathematical error in their calculation; NIOSH 

agreed that this error will be addressed when t

independent Site Profile (DCAS‐TKBS‐0008) is i

Note, however, Table 4 of DCAS‐TKBS‐0008 con

the same erroneous values identified in Findin

this error in DCAS‐TKBS‐0008 is corrected, Find

will be considered resolved.)
United Nuclear – Resolution of Site 

Finding #6

• SC&A Finding: Section D.6 of Appendix D pro

insufficient information that would allow thevalidation of default external dose estimates 

residual contamination.

• Resolution: In an attempt to validate NIOSH’

default external dose estimates from residua

contamination, SC&A failed to include the do

contributions of short‐lived daughters associa

with U‐234 and U‐235. When this error was

accounted for, SC&A validated NIOSH’s defauexternal dose estimates and withdrew Findin
United Nuclear – Resolution of 

Findings

• SC&A made 8 Findings based on its re

of Rev. 1 of the Petition Evaluation Re

• Some of the Findings were inter‐relat

with Site Profile Findings

• All PER Findings have been resolved
United Nuclear ‐ PER Findin

• Finding A: There is a need for better docume

of the beta/gamma ratios used to reconstruc

external doses

• Finding B: How were the beta/gamma ratios 

and how will they be used in a claimant‐favo

way for reconstructing external doses for 196

through 1965?

• Resolution: Additional data were included in 

Profile (DCAS 2011) (see also Site Profile Find
United Nuclear – PER Findings (c

• Finding C: Model used to reconstruct the n

doses likely overestimates the doses signifi

and needs to be based on assumptions tha

be related to the actual operations at UNC

• Resolution: Based on worker interviews, it 

determined that the assumption of 2,000 h

per year was both bounding and plausible; 

WG closed this issue at the 11/21/2011 me

(ABRWH 2011, p. 156)
United Nuclear – PER Findings (c

• Finding D: If dose estimates are to be ba

in some cases on air sample data alone, 

necessary to consider the possibility of

inhalation of Type F material to avoidunderestimates of doses to systemic tiss

• Resolution: The coworker model is base

bioassay results – air sampling is not use

the model
United Nuclear – PER Findings (c

• Finding E: For workers that might have been

exposed to Type F uranium, the frequency of sampling, bioassay sampling, and/or chest co

does not appear sufficient to provide adequa

for dose reconstruction.

• Resolution: Issue discussed in detail at 11/4/

WG meeting. NIOSH position that chronic ex

currently calculated as Type M or Type S are

bounding for reasonable scenarios was accep

Frequency of air sampling is not relevant, sinsampling not used for dose reconstruction.Sufficient bioassay sampling available to calcbounding doses.
United Nuclear – PER Findings (c

• Finding F: The use of air sampling data 

dose reconstruction is not reliable

• Resolution: The coworker model is base

on bioassay results – air sampling is not

used in the model
United Nuclear – PER Findings (c

• Finding G: A discussion is needed describing 

internal exposures can be reliably reconstruc

given the limited bioassay data available from 

through 1962 and what appears to be the

unreliability of air sampling data as a means t

reconstruct internal doses.

• Resolution: Air sampling results were used o

validate the assumption that exposures in 19

1962 were similar to the years before and aft

data gap period (Hughes 2011): NIOSH will u

95th percentile of the bioassay coworker mod

this period (09/07/2012 WG Meeting)
United Nuclear – PER Findings (c

• Finding H: Considerably more information is 

before an assessment of the feasibility of

reconstructing doses to thorium workers, ev

upper bound doses, can be made

• NIOSH white paper (Davis 2011) provided ev

to WG that upper bound doses could be plauestimated. Issue closed at 11/21/2011 WG m

(ABRWH 2011, p. 154).
United Nuclear – Naval Fue

Operations

• The WG initially had some concerns that clas

activities at UNC might not have been adequ

reflected in the NIOSH assessments

• Therefore NIOSH interviewed an Item Plant W

on February 28, 2012 (Interview 2012)

• The worker also participated in the WG

teleconference call on September 7, 2012

• Discussions with worker provided considerab

detail that confirmed NIOSH’s documented

understanding of UNC operations
United Nuclear – Uranium Refi

AWE WG Recommendation

• Petition 116 covering “All site employees that 

in any area of the United Nuclear Corporatio

Hematite, MO, site from January 1, 1958 thro

December 31, 1973 and the residual radiatio

January 1, 1974 through July 31, 2006” shouldenied

• Based on analysis of the available resources, 

no part of the class under evaluation for whic

radiation doses cannot be bounded under pla

circumstances
United Nuclear ‐ Referenc

• Battelle 2008. Battelle‐TBD‐6001, Site Profiles for At

Weapons Employers the Refine Uranium and Thorium 

Appendix D United Nuclear Corporation, March 14, 2

• SC&A 2009. Review Of The NIOSH Site Profile For Th

Nuclear Corporation, Missouri, Battelle‐TBD‐6001, A

D. September 2009.

• NIOSH 2009. SEC Petition Evaluation Report for the U

Nuclear Corporation, Petition SEC‐00116. Rev. 0. Au2009.

• SC&A 2010a. A Critical Review of Revision 1 of the N

Profile for the United Nuclear Corporation, Missouri,

Addendum to SCA‐TR‐SP2009‐0040. June 24, 2010.
United Nuclear – References (co

• SC&A 2010b. A Review of the SEC Petition Report 

United Nuclear Corporation, Petition SEC‐00116.

September 2010.

• NIOSH 2010a. Rev. 1 to Appendix D. April 30, 201

• NIOSH 2010b. SEC Petition Evaluation Report for 

United Nuclear Corporation, Petition SEC‐00116. 

January 28, 2010.

• DCAS 2011. Technical Basis Document for the Uni

Nuclear Corporation , Hematite, Missouri. DCAS‐

0008. Effective Date 03/21/2011. (Replaces Appe

• Hughes 2011. United Nuclear Corporation Air

Concentration Data for 1961 and 1962. Lara Hug

NIOSH/DCAS. November 2011.
United Nuclear – References (co

• Davis 2011. White Paper: Representativeness and

Applicability of United Nuclear Corporation Air SampReconstructing Thorium Intakes. NIOSH. November 

• Clark 2011. White Paper: SEC‐00116 United Nuclear

Corporation Petitioner Issues. Rev. 1. November 3, 2

• ABRWH 2011. Transcript of the Uranium Refining AW

Group Meeting of November 21, 2011. Advisory Boa

Radiation and Worker Health.http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2011/w1.pdf

• Interview 2012. Interview with UNC Employee (3433

February 28, 2012.